An online article in Canadian Underwriters describes the new flood risk models developed to assess hazards, price flood endorsements and assess portfolio risk in canadianunderwriters.ca. In the comment below, we look beyond the short term insurance risk data needs and toward to holistic approach risk management.
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The journey toward a Canada-wide flood risk model shows one thing - a paradigm shift is needed in how the insurance industry, regulatory agencies and municipalities share data on flood risks. Only then will there be data to support fair and accurate insurance products based on risk, data that society can access and use to make important risk management decisions, and data that municipalities/regulatory agencies/ministries can use to set risk avoidance, reduction and remediation policies. The discussion today is just the first step toward that. While a robust 10 m fine grid flood risk screening tool could satisfy the immediate need for price local insurance products and assess portfolio risk, the long term goal has to be a comprehensive risk management strategy built on this type of data. How? Well if "flood is the new fire", consider the fire model where fire underwriters, municipal fire services their consultants, and property owners participate in a system that quantifies and shares risk data and where risk management decisions are made in a coordinated manner.
With immediate product needs, the insurance industry requires a consistent risk model across the country and so has to resort to coarse 30 m topography cell screening to at best identify riverine risks - but can not account for the local factors such as hydraulic relief structures that are important for the higher frequency events (i.e., bridges, culverts and embankment underpasses that are 'under' the 30 m topography model), or the underworkings of sewer infrastructure or surface constraints (building flow obstructions) critical in urban flash flooding beyond river valley systems. Meanwhile, some municipalities are sitting on InfoWorks and EPA SWMM dual-drainage models that predict hydraulic flood levels pipe-by-pipe that characterizes basement flood risk, and predict block by block overland ponding for all storm return periods. Similarly, conservation authorities in Ontario have return period riverine flood levels derived from survey-grade topography and hydraulic structure surveys, considering calibrated flow hydrology. Flood risk data is not new - Toronto East York SWMM models were first developed in the 1970's on punch cards, Toronto North York models in the 1980's on 20MHz 386's - no need for GPU processing really. Today Toronto is covered in InfoWorks models, Hamilton has Mike Urban, Calgary XPSWMM ... and on.
But all this existing data is in silos, each with a single regulatory or management purpose, and never rolled-up, parsed, or aggregated to provide a baseline for insurance risk purposes. You can understand why Carpenter pursues a Canada-wide 30 m grid model for surface flooding or IBC develops MRAT for sanitary back-up risk characterization - its because it is easier to start from scratch with coarse risk assessment than to get down in the weeds of pipe-by-pipe municipal infrastructure flood models (that do vary by neighbourhood to neighbourhood, consultant by consultant, model platform by model platform), or creek-by-creek conservation authority (or other provincial agency) floodplain models (that do vary as well in terms of vintage, accuracy, consistency in hyetographs/design storm drivers). So there has been a deluge of data building for a half century on riverine flood risk, and over decades on urban flood risks - but it has never been approached in a way that it can be leveraged for holistic flood risk management.
Under a new paradigm, with a more holistic risk management end goal in mind, flood risk data can be collected, developed and applied through a partnership approach, without the need to reinvent or duplicate riverine flood risk mapping. Consistent, shared risk data would support alignment between the regulatory aspects of flood risk management, the business decisions related to development, and municipal and government decisions on infrastructure investment and risk reduction programs (flood proofing, emergency preparedness, education). The constraints to getting to there is not GPU computing power for 1 metre-cell 2D urban dual drainage models, but rather it is more fundamental and more challenging, relating to how various private and public organizations cooperatively manage issues of common interest.
In-depth data and analysis on extreme weather and flood risks on www.cityfloodmap.com share engineering insight on complex topics of infrastructure design and performance, urban hydrology, flood risk assessment, and cost-effective risk management. Our goal is to promote critical, evidence-based "Thinking Slow on Floods and Flow" to improve flood and stormwater management policies and achieve effective environmental outcomes. R.J. Muir, Toronto, ON.
Overland Flood Risk - From Flood Plains to Foundation Drains
From foundation drain to floodplain there is a continuum of drainage features that affect flood risks and damages in urban areas - these are micro lot level factors and macro neighbourhood factors.
Yes, some property reference points could identify a few flood risk factors to address, but overland flooding risk is not apparent at the property scale - that is if we agree overland flooding is not a result of poor lot grading or obvious rain entry points. Unlike other risks like fire hazards, the structure or property does not define most of the risk when if comes to flooding. It will be interesting to see what methods Aviva has adopted for defining risk levels and overland flood endorsement premiums.
Aviva is excluding high risk properties (about 5% of properties) considering flood plain maps that identify river (and sometimes lake) flooding hazards. Micro-scale factors like the property's foundation drain and service lateral condition can affect almost any property, but issues with those do not cause overland / surface water flooding.
I'd suggest the most sensitive overland flooding occurs upstream of large floodplain-mapped valleys and up onto urbanized 'table land' where the sewer drainage system and overland drainage system are not designed to accommodate runoff from major rainfall events. Usually this would be in catchments draining a 125 hectare or smaller area in Ontario, lying beyond the regulated flood zones above where Aviva insurance would not be available. In these areas, neither the capacity of the storm sewer system, nor the adequacy of the overland drainage system (ideally on roadways and drainage easements) is apparent at the individual property scale.
The macro-scale, overland system is only apparent from runoff accumulation and concentration from 10's of hectares to even a couple hundred hectares of table land runoff that accumulates downstream. That is, a broad neighbourhood-scale macro factor representing many hundreds upstream of properties. The map of overland flow drainage areas (red text in yellow highlight) shows the continuum of drainage areas extending beyond regulated floodplains that flow into to smaller surface features that run through the urban lot fabric.
Neighbourhood scale risks factors for overland flooding can be assessed with some minor effort (relative to detailed pipe-by-pipe sewer and street-by-street hydraulic simulation models that is) by just considering topography from readily available elevations models and by applying core GIS hydrology tools.
The image to the left on 'major sags' is an example showing overland flooding risks including dwellings within poorly-drained sags. In this case it includes dwellings upstream of a railway embankment that can impede and 'back up' flows during large events.
The risk to dwellings and property within close proximity to overland flow paths can be ranked. For example a building within 3 m of a 10 hectare area runoff flow path, or 15 m from 100 hectare area flow path, would be at relatively low risk. Alternatively a dwellings within 3 m of a 100 ha flow path would be at a high risk. A building within both a flow path and in a sag would be at the highest risk. Remember, these are estimates and are qualitative. Nonetheless, experience shows that areas identified through these heuristic methods have be subject to overland flooding during extreme rainfall events.
The issue with overland flood insurance (urban, table-land type flooding) is that risks are concentrated with a small portion of downstream properties for whom risk-based premiums could be unaffordable, or for whom coverage would not be available. The majority of upstream properties would not likely ever experience overland flooding nor add coverage for it. So overland flood damages are not like wind damage (path of wind can be anywhere whereas path of water is always the lowest elevations).
At a property scale, a property with poor lot grading and a reverse slope driveway may be at high risk regardless of proximity to overland flow paths or major sags in topography. Such a property would benefit from having an overland flood endorsement in its water protection insurance. Ideally homeowners in this situation can take action to mitigate risks by improving grading, installing barriers to flow from the reverse drive, keeping grates clear of debris and perhaps installing a backflow valve on the driveway drain. Beyond these exceptions, anyone with foundation drains that could clog or a service lateral that could become root infested is at risk of flooding - but that would not be overland flooding, but rather back-up from the floor drain or seepage from the foundation wall and cracks (a different endorsement all together).
Check out new analysis of table land flood risks and insight into correlations with basement flooding / sewer back-up incidents : overland flow flood risk factors
Yes, some property reference points could identify a few flood risk factors to address, but overland flooding risk is not apparent at the property scale - that is if we agree overland flooding is not a result of poor lot grading or obvious rain entry points. Unlike other risks like fire hazards, the structure or property does not define most of the risk when if comes to flooding. It will be interesting to see what methods Aviva has adopted for defining risk levels and overland flood endorsement premiums.
Aviva is excluding high risk properties (about 5% of properties) considering flood plain maps that identify river (and sometimes lake) flooding hazards. Micro-scale factors like the property's foundation drain and service lateral condition can affect almost any property, but issues with those do not cause overland / surface water flooding.
| Overland flow areas in an urban setting. Areas beyond blue regulated floodplains may be several hundred hectares in size. |
The macro-scale, overland system is only apparent from runoff accumulation and concentration from 10's of hectares to even a couple hundred hectares of table land runoff that accumulates downstream. That is, a broad neighbourhood-scale macro factor representing many hundreds upstream of properties. The map of overland flow drainage areas (red text in yellow highlight) shows the continuum of drainage areas extending beyond regulated floodplains that flow into to smaller surface features that run through the urban lot fabric.
| GIS Tools can identify major sags, or depressions, (called sinks) in the landscape that can indicate or amplify overland flood risk. |
Neighbourhood scale risks factors for overland flooding can be assessed with some minor effort (relative to detailed pipe-by-pipe sewer and street-by-street hydraulic simulation models that is) by just considering topography from readily available elevations models and by applying core GIS hydrology tools.
The image to the left on 'major sags' is an example showing overland flooding risks including dwellings within poorly-drained sags. In this case it includes dwellings upstream of a railway embankment that can impede and 'back up' flows during large events.
| Ranked property risk considering proximity to overland flow path, drainage area, and major sags in topography (i.e., drainage-challenged during extreme runoff events). |
The issue with overland flood insurance (urban, table-land type flooding) is that risks are concentrated with a small portion of downstream properties for whom risk-based premiums could be unaffordable, or for whom coverage would not be available. The majority of upstream properties would not likely ever experience overland flooding nor add coverage for it. So overland flood damages are not like wind damage (path of wind can be anywhere whereas path of water is always the lowest elevations).
At a property scale, a property with poor lot grading and a reverse slope driveway may be at high risk regardless of proximity to overland flow paths or major sags in topography. Such a property would benefit from having an overland flood endorsement in its water protection insurance. Ideally homeowners in this situation can take action to mitigate risks by improving grading, installing barriers to flow from the reverse drive, keeping grates clear of debris and perhaps installing a backflow valve on the driveway drain. Beyond these exceptions, anyone with foundation drains that could clog or a service lateral that could become root infested is at risk of flooding - but that would not be overland flooding, but rather back-up from the floor drain or seepage from the foundation wall and cracks (a different endorsement all together).
Check out new analysis of table land flood risks and insight into correlations with basement flooding / sewer back-up incidents : overland flow flood risk factors
Be Logical About Rainfall Extremes And Flooding - Its What Mr. Spock (Leonard Nimoy) Would Have Wanted !
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| Mr. Spock favours facts |
--SPOCK, Star Trek: The Original Series, "Space Seed"
Flooding from extreme rainfall is dangerous. But if facts related to the cause of flooding are insufficient, the solutions to flooding will be misguided ... illogical.
As noted in an earlier post, when Environment Canada recently reviewed Southern Ontario rainfall statistics to see if there have been any measurable trends in rainfall patterns and intensities they found the following:
- Significant increases, as well as decreases, were detected at some stations in a number of the extreme precipitation indicators. However, the majority of station trends were determined to be non-significant and no consistent geographical patterns for increases or decreases were observed across Canada. In most cases, the magnitude of the observed changes was also very small.
- On sub-daily or short duration rainfall intensities of less than 24 hours (this is the data / or trends municipalities would use for planning, design and management of most drainage and stormwater systems that respond to flashy storms): The majority of the trends were determined to be non-significant with no simple patterns or uniform rates of change evident in the short duration rainfall. Trends were determined to vary with duration and regional location.
Those are the facts. The report is entitled "Methodologies to Improve Rainfall Intensity-Duration-Frequency (IDF) Estimates: A Southern Ontario Pilot Study", by Environment Canada, Adaptation and Impacts Research Climate Research Division, dated December 2011. The study was supported through the Natural Sciences and Engineering Research Council of Canada (NSERC). It's 176 pages long. Click for report. Mr. Spock, Leonard Nimoy (RIP), would be proud. More recently, Environment Canada had an article on extreme rain trends published in Atmosphere-Ocean that reiterated there are no overall trends in rain intensity - click for abstract.
Here are some insufficient non-facts:
"The August 19th downpour was just one of 8 extreme rainfall events in the past 20 years that resulted in basement flooding and other damages. The August 19th storm exceeded the rainfall expected in a 1-in-100 year storm. Most of the other storms were estimated previously as having a 1-in-25 year to 1-in-50 year chance of occurring. Taken together, these events indicate that intense rainfalls are already on the rise in the Toronto area and that design standards for stormwater management need to be revised."
This is from a report is entitled "Climate Change Adaptation in the City of Toronto: Lessons for Great Lakes Communities" by Clean Air Partnership, dated 2008. See Report Pages 19-20. The phrase "Taken together" takes the place of statistics, analysis and scientific conclusions. The plural of anecdote is not data. Environment Canada's analysis and conclusions indicated "... trends were determined to be non-significant with no simple patterns or uniform rates of change evident ...", while Clean Air Partnership's conjecture is that intense rainfalls are "already on the rise".
Once you have eliminated the impossible, whatever remains, however improbable, must be the truth.
--SPOCK, Star Trek (2009)
It is possible that the proliferation of low cost, closely spaced rainfall gauges has increased the observation of intense rainfall events and improved technology has resulted in near-real time reporting of extremes in the 24-hour media. But this does not mean that the intensities at any static location have increased - Environment Canada's analysis of individual rain gauge locations shows only very small, non-significant changes. Factually, in the municipality where I work we used to rely on Toronto's Bloor Street rain gauge statistics many decades ago when there were no reliable local records in the then township. A decade ago we used a single rain gauge at the local airport to characterize rainfall - that's one gauge per 200 square kilometers. Today we have a dense rain gauge network with over 10 gauges covering 15 square kilometers each - this dense network observes more intense rainfall events because previously storm cells could readily pass around the single airport gauge available.
Factually, extreme rainfall data were not reported in real time decades ago, and data used to be recorded with analog systems (rotating drum charts) that needed to be reviewed by hand, transcribed and digitized before being reported or compared to statistical data to report on frequencies. Today, rainfall intensity and volume data are recorded and analyzed and compared to statistical data in real time. Results over thresholds associated with local or widespread flooding are texted in real time and also emailed. This and 24-hour media contribute to a focus on extreme weather, observed more often due to the denser monitoring networks available today.
It is possible that infill and intensification in Toronto has increased runoff rates and volumes. Anecdotally, I need only to look around my house to see the residential intensification in the last 45 years: on my block the rear laneway has been urbanized (used to be gravel, now it is concrete with storm sewer), the two smallest homes across the street are now monster sized, the third smallest is now the vestibule for the massive new home in the old back yard, the semi I'm attached to has an extension on the back as do several others, smaller homes on large lots that had some greenspace have been replaced with multiple homes (includes the neighbours to the north of me, and the neighbours north of them, and the neighbours north of them). The latter two homes now have 90% paved front yards for parking and many other homes have added or expanded front yard parking (more impermeable surfaces = more runoff). Factually, as part of flood remediation hydrologic model refinements, I have quantified increases in rooftop area of several percentages over 10 years in a GTA municipality using GIS data. Additional driveway increases, not measured, would add more pavement. Over multiple decades infill and intensification increases runoff.
It is possible that infill an intensification in Toronto has obstructed major overland flow paths, aggravating flood damages during extreme rainfall events. Factually, I have observed drainage easements encumbered by sunroom additions and landscaping such that drainage of low points in residential roads is compromised, and have observed overland flow paths encumbered by monster home rebuilds. This occurs because overland flow paths (unless there is an old easement) are not regularly mapped or managed by municipalities, yet are prevalent in areas built pre-1980's when overland drainage was not engineered/designed to stay on right-of-ways and away from homes.
It is possible that removal of sanitary overflows for environmental protection has increase basement flooding risks by removing the "relief valves" from the system during extreme events. See Ministry of the Environment's Procedure F-5-5. Factually, the basement flood remediation Class Environmental Assessment (EA) Study for my neighbourhood (Toronto Remediation Area 32) identified the adverse impact of sewage overflow measures on basement flooding. These measures built in the early 1990's were effective at achieving water quality improvement for small storms (see Council report - Eastern Beaches Water Quality - Effectiveness of the Kenilworth Avenue and Maclean Avenue Detention Tanks (Ward 26)). But the Kenilworth tank and related flap gates were cited in the Class EA as the cause of flooding (excerpt from the Class EA study):
The solution to flooding includes reestablishing sewerage overflows as highlighted in the causes and remedial measures summary for Area 32 flood cluster area 1:
The Toronto Area 32, flood cluster 1 shows environmental improvements implemented in the 1990's to reduce sewage overflows aggravated basement flooding during the extreme August 19, 2005 storm. This is often referred to as the "law of conservation of poop" - poop either it spills to the river / or lake or backs up in the system and potentially into basements - it is an incompressible liquid and it has to go somewhere. Area 32 is one specific example in my neighbourhood, but you can find many others.
Another example is in Hamilton, Ontario, in relation to their Ward One Combined Sewer Overflow Master Plan Class Environmental Assessment. The 2003 report to the Committee of the Whole recommends implementation of overflow reduction measures to prevent pollution in Cootes Paradise Hamilton Harbour - it is also to address MOE Procedure F-5-5 control requirements. The report notes the risk of interfering with the law of conservation of poop as follows in the analysis of Class EA alternatives on page 4:

"• Combined Sewer Overflow Regulator Adjustments
Adjustments to combined sewer overflow regulators to send more flow to the treatment plant can reduce combined sewer overflows, but must be carefully investigated to prevent basement flooding and overloading of the wastewater treatment plant."
The recommended solution for the Sterling outfall :
"For the Sterling outfall the recommended solution is a regulator adjustment, which would involve the raising of the existing weir within the combined sewer system to increase the amount of wet weather flow going to the wastewater treatment plant and reduce CSOs. This is a Schedule A project and may proceed to implementation."
Translation: Schedule A = no further study required as impacts are assumed to be small per the Municipal Class EA Process. The law of conservation of poop would tell us that reducing the overflow of sewage at the Sterling outfall by raising the height of the overflow weir will increase the volume of poop in the sewer system, will raise the level of poop in the system and can put basements at higher risk of flooding. It is not clear if those flooding impacts have been quantified - they may be low or they may be high, just like the Toronto Area 32 impacts. Google F-5-5 and see what other municipalities have tightened up their sewer systems to achieve pollution reduction but may also have unintended impacts.
The challenge in large municipalities is that there can be competing interests and programs. And it is possible that right hands are not fully informed of what left hands are doing or of impacts of actions or inaction. A good example of that is in Ottawa where Petrie Island beach closure in August 2006 were likely caused by a major unreported sewage spill at the Keefer regulator site adjacent to the John Street-Sussex Drive intersection. The 2008 audit report is available online. Like in Toronto Area 32 or Hamilton Ward 1, the management of sewage spills will affect the system - too much regulation in Toronto and perhaps Hamilton can adversely affect basement flooding, while too little regulation as in Ottawa will cause sewage spills/pollution. Municipalities are caught between a rock and poop.
To sum it up:
Here are some insufficient non-facts:
"The August 19th downpour was just one of 8 extreme rainfall events in the past 20 years that resulted in basement flooding and other damages. The August 19th storm exceeded the rainfall expected in a 1-in-100 year storm. Most of the other storms were estimated previously as having a 1-in-25 year to 1-in-50 year chance of occurring. Taken together, these events indicate that intense rainfalls are already on the rise in the Toronto area and that design standards for stormwater management need to be revised."
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| Mr Data favours data |
Once you have eliminated the impossible, whatever remains, however improbable, must be the truth.
--SPOCK, Star Trek (2009)
| Dusty old data |
| Decades old analog chart for tipping bucket rain gauge |
It is possible that infill and intensification in Toronto has increased runoff rates and volumes. Anecdotally, I need only to look around my house to see the residential intensification in the last 45 years: on my block the rear laneway has been urbanized (used to be gravel, now it is concrete with storm sewer), the two smallest homes across the street are now monster sized, the third smallest is now the vestibule for the massive new home in the old back yard, the semi I'm attached to has an extension on the back as do several others, smaller homes on large lots that had some greenspace have been replaced with multiple homes (includes the neighbours to the north of me, and the neighbours north of them, and the neighbours north of them). The latter two homes now have 90% paved front yards for parking and many other homes have added or expanded front yard parking (more impermeable surfaces = more runoff). Factually, as part of flood remediation hydrologic model refinements, I have quantified increases in rooftop area of several percentages over 10 years in a GTA municipality using GIS data. Additional driveway increases, not measured, would add more pavement. Over multiple decades infill and intensification increases runoff.
![]() |
| Example intensification, just the 8 addresses north of me since the late 1970's ... add it up. |
It is possible that infill an intensification in Toronto has obstructed major overland flow paths, aggravating flood damages during extreme rainfall events. Factually, I have observed drainage easements encumbered by sunroom additions and landscaping such that drainage of low points in residential roads is compromised, and have observed overland flow paths encumbered by monster home rebuilds. This occurs because overland flow paths (unless there is an old easement) are not regularly mapped or managed by municipalities, yet are prevalent in areas built pre-1980's when overland drainage was not engineered/designed to stay on right-of-ways and away from homes.
It is possible that removal of sanitary overflows for environmental protection has increase basement flooding risks by removing the "relief valves" from the system during extreme events. See Ministry of the Environment's Procedure F-5-5. Factually, the basement flood remediation Class Environmental Assessment (EA) Study for my neighbourhood (Toronto Remediation Area 32) identified the adverse impact of sewage overflow measures on basement flooding. These measures built in the early 1990's were effective at achieving water quality improvement for small storms (see Council report - Eastern Beaches Water Quality - Effectiveness of the Kenilworth Avenue and Maclean Avenue Detention Tanks (Ward 26)). But the Kenilworth tank and related flap gates were cited in the Class EA as the cause of flooding (excerpt from the Class EA study):
The solution to flooding includes reestablishing sewerage overflows as highlighted in the causes and remedial measures summary for Area 32 flood cluster area 1:
The Toronto Area 32, flood cluster 1 shows environmental improvements implemented in the 1990's to reduce sewage overflows aggravated basement flooding during the extreme August 19, 2005 storm. This is often referred to as the "law of conservation of poop" - poop either it spills to the river / or lake or backs up in the system and potentially into basements - it is an incompressible liquid and it has to go somewhere. Area 32 is one specific example in my neighbourhood, but you can find many others.
Another example is in Hamilton, Ontario, in relation to their Ward One Combined Sewer Overflow Master Plan Class Environmental Assessment. The 2003 report to the Committee of the Whole recommends implementation of overflow reduction measures to prevent pollution in Cootes Paradise Hamilton Harbour - it is also to address MOE Procedure F-5-5 control requirements. The report notes the risk of interfering with the law of conservation of poop as follows in the analysis of Class EA alternatives on page 4:
"• Combined Sewer Overflow Regulator Adjustments
Adjustments to combined sewer overflow regulators to send more flow to the treatment plant can reduce combined sewer overflows, but must be carefully investigated to prevent basement flooding and overloading of the wastewater treatment plant."
The recommended solution for the Sterling outfall :
"For the Sterling outfall the recommended solution is a regulator adjustment, which would involve the raising of the existing weir within the combined sewer system to increase the amount of wet weather flow going to the wastewater treatment plant and reduce CSOs. This is a Schedule A project and may proceed to implementation."
Translation: Schedule A = no further study required as impacts are assumed to be small per the Municipal Class EA Process. The law of conservation of poop would tell us that reducing the overflow of sewage at the Sterling outfall by raising the height of the overflow weir will increase the volume of poop in the sewer system, will raise the level of poop in the system and can put basements at higher risk of flooding. It is not clear if those flooding impacts have been quantified - they may be low or they may be high, just like the Toronto Area 32 impacts. Google F-5-5 and see what other municipalities have tightened up their sewer systems to achieve pollution reduction but may also have unintended impacts.
The challenge in large municipalities is that there can be competing interests and programs. And it is possible that right hands are not fully informed of what left hands are doing or of impacts of actions or inaction. A good example of that is in Ottawa where Petrie Island beach closure in August 2006 were likely caused by a major unreported sewage spill at the Keefer regulator site adjacent to the John Street-Sussex Drive intersection. The 2008 audit report is available online. Like in Toronto Area 32 or Hamilton Ward 1, the management of sewage spills will affect the system - too much regulation in Toronto and perhaps Hamilton can adversely affect basement flooding, while too little regulation as in Ottawa will cause sewage spills/pollution. Municipalities are caught between a rock and poop.
To sum it up:
- There is factual, scientific analysis of rainfall extremes that shows no increasing trends. There are also anecdotes (MR Spock's dangerous insufficient facts) about a lot of big storms that are turned into misguided conclusions - this is really like "Jenny McCarthy vaccine science".
- Without more intense rainfall, there are also many factual explanations for increased flooding in urban areas based on i) tangible, even measurable, runoff factors (infill and intensification), and ii) the regulation/modification of the underlying sewer systems to meet other often competing objectives like pollution prevention (F-5-5).
- Insufficient facts could cause us to connect flooding solely with climate change, and cause us to more fully invest in green energy and carbon pricing to reduce greenhouse gases as a mitigation measure - or as Mr. Spock says 'invite danger' by trying to solve the wrong problem, and misdirecting focus and resources.
- Scientific facts should cause us to promote greater runoff source controls for infill development, and to preserve overland flow paths in old neighbourhoods with easements, grading or infrastructure improvements.
- Scientific facts should cause us to carefully trade off pollution control objectives and natural environment impacts with social and human impacts due to flooding, and to restore overflows where pollution controls have caused flooding (see Area 32 structural recommendations above).
The world is also complex and requires sufficient facts to make informed decisions on important topics. This is especially so when the facts about problems influence the billion dollar decisions on solutions.
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