Ontario urban flood damages are real. Green Infrastructure (GI), or Low Impact Development (LID) stormwater management measures have been proposed as the solution to urban flooding as well as water quality impairment, stream erosion, and potable water supply security (aka Source Water Protection in Ontario). And proponents have cited that it is CHEAPER to rebuild roads with GI or LID, so why not go "all in". It sounds too good to be true, right? The truth is the incremental costs are higher than conventional , so are operational costs. But the absolute costs for achieving targets proposed the Ontario Ministry of Environment and Climate Change (MOECC) are actually PROHIBITIVE, potentially consuming entire municipal capital budgets for decades. |
Ontario has 852,000 untreated urban hectares ans a unit LID / GI
cost of almost $400,000 per hectare treated. That results in a very
high province-wide costs over 300 billion. Some recent tender costs
show even HIGHER unit costs for small scale installations.
|
Here's why GI or LID will not be part of Ontario flood risk reduction for our cities 'existing urban development areas. This is discussed under the topics of i) cost, and ii) existing infrastructure and property impacts that can increase flooding. We have included GI / LID retrofit implementation costs for all Ontario municipalities to show the big green pill we would have to swallow.
Background
These GI or LID stormwater Best Management Practices (BMPs) have been used for years to address stream erosion impacts due to change in water balance following development, and have been used to manage water quality impacts through vegetative source and conveyance controls, promoted in Ontario's 1994 Stormwater Management Practices Planning and Design Manual.
On November 15, 2016, the Environmental Commissioner of Ontario released a report, Urban Stormwater Fees: How to Pay for What We Need. The report cites the issues as follows “Stormwater runoff – from heavy rain or snowmelt – can cause flooding, stream or river-bank erosion, and water pollution" and then "calls on the province to require municipalities to recover the full costs of managing stormwater runoff; for example, by charging landowners a separate stormwater fee based on runoff volumes". It also says the "Ontario government should also require all municipalities to prepare asset management plans for both their grey (pipes, drains, etc.) and green (wetlands, green roofs, permeable pavement, rain gardens, etc.) stormwater infrastructure."
The Environmental Commissioner of Ontario is on the right track to promote asset management plans with full lifecycle accounting of infrastructure capital, operating and renewal costs. This is already a requirement for all municipalities by the end of 2016 as a condition of receiving federal Gas Tax funding. But no municipalities have done the deep dive into GI and LID impacts, because to date only demonstration, or pilot, projects have taken place. The demonstration projects often have heavy subsidies (donated profession design time, donated materials) that it is difficult to know the true implementation cost for a project, or the cost for municipal-wide implementation. Until now, so read on.
Proponents of GI and LID such as Credit Valley Conservation have reported that there are on average savings of 25% on road retrofits by applying LIDs:
"LID road retrofits save 25 per cent on average compared to traditional stormwater management practices."(1)
(1) http://www.creditvalleyca.ca/wp-content/uploads/2015/07/Advancing-Low-Impact-Development-as-a-Smart-Solution-for-Stormwater-Management-v1.pdf
And other proponents have reinforced this cost efficiency message, such as Green Communities Canada indicating "The Credit Valley Conservation has produced a number of case studies detailing road right-of-way low impact development projects, and has found that costs are consistently lower than expected and performance has exceeded expectations".
A thorough examination of cost claims reveals there are no such savings or efficiencies - GI or LID projects cost more, and the literature case studies for cost savings (typical rural estate residential developments in the southern US) are not applicable to the sustainable built form communities in most Ontario municipalities where urban flooding issues exist.
Reality Check - Prohibitive Cost of Green Infrastructure, Low Impact Development Retrofits in Ontario
GI / LID demonstration
project, literature, and local project costs indicate excessive, prohibitively
high costs for implementation when applied to target management areas
Incremental GI / LID implementation costs for additional elements
beyond standard design features has been estimated based on completed projects
and unit costs for various measures. The incremental, additional cost is
$390,000 per hectare of service area (untreated catchment)(1).
The untreated urban area in Ontario is estimated by urban
land use area in place in the late 1990’s – early 2000’s and equates to 852,045
hectares(2).
The incremental GI / LID implementation cost is therefore $390,000
x 852,045 = $332,000,000,000, i.e., over $330 billion. As an example, the City of Markham's portion of this cost is $4.18 billion which is considered prohibitive as it is
equivalent to 34 times the city’s 2016 capital budget of $122.9 million(3).
Organizations such as Credit Valley Conservation has identified
over 140,000 kilometers of municipal roadway in Ontario(4),
equating to 281,621 hectares of right of way(5).
(1) CVC, University of Toronto and TRCA demonstration projects per City of Markham
analysis.
(2) SOLRIS
Version 1.2 land cover GIS mapping, as compiled in the Ontario Land Cover
Compilation Version 2.0
(3) City of Markham 2016 Budget, https://www.markham.ca/wps/wcm/connect/markhampublic/129bc6d6-2289-49a2-b199-8893c02af011/2016-Budget-Signed-v2.pdf?MOD=AJPERES&CACHEID=129bc6d6-2289-49a2-b199-8893c02af011
(5) Assuming 20.1 metre, 66 foot right of way width
GI / LID demonstration
project, literature, and local project costs indicate only severely limited,
technically ineffective implementation of GIs / LIDs can be achieved considering even
Ontario’s entire stormwater infrastructure deficit
The entire national infrastructure deficit for water supply,
wastewater, stormwater and roads is $170 billion, of which stormwater comprises
23% or $39.1 billion(1).
The Ontario stormwater infrastructure deficit has been stated as $6.8 billion (2).
(1) Canadian Construction Association, Canadian Public Works Association, Canadian
Society for Civil Engineers and Federation of Canadian Municipalities. 2012.
Municipal Roads and Water System. Volume 1
(2) Urban
Stormwater Fees: How to Pay for What We Need, Environmental Commissioner of
Ontario, November, 2016, https://media.assets.eco.on.ca/web/2016/11/Urban-Stormwater-Fees.pdf
GI / LID project implementation
costs are more expensive than traditional servicing projects, contrary to
promotional documents that indicate 25% savings
The CVC has reported that there are on average savings of
25% on road retrofits by applying LIDs:
"LID road retrofits save 25 per cent on average
compared to traditional stormwater management practices."(1)
The reference for the average costs savings is from USEPA (2),
but it does not in fact demonstrate such average savings for the two roadway
project included in the reference.
The first road project is the 2nd Avenue SEA
Street in Seattle Washington. The USEPA gives the convention project cost of
$868,803, and LID cost of $651,548, suggesting 25% savings. However the Seattle
Public Utilities actual project costs of $850,000 (3) for the LID design suggesting very little savings (only 2.2%). Seattle Public Utilities notes the high soft
cost of associated with LID design as follows "This included an extensive
design and communications budget due to the need to work closely with residents
on the design."
The second project is Crown Street, Vancouver British
Columbia, a street redevelopment project. The project added 79% of the capital cost in consultant design fees and aesthetic design features (capital cost $396k, consultant and aesthetic design features cost $311k), which is line with Markham’s experience on Glencrest Park Raingarden implementation. The USEAP report notes that “Discounting the extra costs, the $396,000 construction cost is 9 percent higher than the estimated $364,000 conventional curb-and-gutter design cost.” The average cost of roadway LID retrofits is therefore 5-6% more than conventional design, or 38% more than conventional design if additional consultant fees and aesthetic design features are considered – this is 63% higher than the average reduced costs cited by CVC.
Other USEPA case studies are for rural, large lot
subdivisions (e.g., Auburn Hills Subdivision, Southwestern Wisconsin, Gap Creek Subdivision, Sherwood Arkansas, Laurel Springs Subdivision, Jackson, Wisconsin, Mill Creek Subdivision, Kane County, Illinois, Prairie Crossing Subdivision, Grayslake, Illinois, Prairie Glen Subdivision, Germantown, Wisconsin) that are not relevant to Ontario urban areas and not relevant to
urban roadway retrofits.
Detailed economic studies on source control implementation
have acknowledged that implementation of source control (SC) GI / LIDs would be more costly in retrofit
settings than in greenfield settings. For example, a study of the Rouge River watershed (4)
identified:
“The average per-house costs of the intervention strategies
for medium density residential development in urban greenfield areas is $2,785
while the average cost is $4,607 in urban retrofit areas. These values suggest
that retrofitting old developments is more costly than integrating best
practices into the new development. In addition, the Rouge River Study modeling
results suggest that the surface water quality improvements from the urban
retrofit areas are less than the surface water quality improvements from urban
green field development under the SC (source control) scenario, relative to FBO
(uncontrolled full build out).”
(1) http://www.creditvalleyca.ca/wp-content/uploads/2015/07/Advancing-Low-Impact-Development-as-a-Smart-Solution-for-Stormwater-Management-v1.pdf
(2) https://www.h-gac.com/community/low-impact-development/documents/Reducing-Stormwater-Costs-through-LID.pdf
(4) http://www.greeninfrastructureontario.org/sites/greeninfrastructureontario.org/files/Final%20Rouge%20Report%20Nov%2030.pdf
Reality Check - Existing infrastructure
and property impacts of GI / LID infiltration measures have been overlooked
Flooding and
operational cost impacts of GI / LID to partially separated wastewater systems have been
overlooked
It is commonplace that urban areas built between 1960 and
1980 are serviced by partially separated sewer systems that exhibit high
extraneous flow rates during wet weather events. Analysis of historical
flooding events in the City of Toronto (May 2000, August 2005, July 2013)
demonstrates that the 1961-1980 era developments have the highest relative
proportion of reported flooding (1).
In the City of Markham, the proportion of properties flooded during the August
19, 2005 extreme rainfall was highest for partially separated properties
serviced before 1980, with over 2.5% of properties flooded. In contrast, only
0.3% of fully separated properties were flooded. These data indicate that
partially separated sewer systems are at significantly higher risk of flooding
than new fully separated areas. Statistical analysis of wet weather flows by
the City of Ottawa support the variability in risk for different systems,
identifying average 100 year extraneous flow rates of 4.87 L/s/ha in partially
separated systems and only 0.57 L/s/ha in newer separated systems (2).
Wastewater systems are sensitive to groundwater conditions
that contribute to extraneous flow rates that cause property flooding / sewer
back-ups. As indicated in the document Infiltration/Inflow
Control/Reduction for Wastewater Collection Systems. A Best Practice by the
National Guide to Sustainable Municipal Infrastructure, by the Federation
of Canadian Municipalities and National Research Council:
"Uncontrolled infiltration/inflow in sanitary sewers
can have very detrimental effects on social, economic and environmental aspects
of urban areas. Excessive flows can severely limit the capacity of existing
sewer systems to serve expanded populations. They also generate sewer backups,
basement flooding and health risks, increase the operation and maintenance
costs of the treatment and pumping facilities, and give rise to overflow of
wastewater to streets or to watercourses."(3)
And further that inflow and infiltration (I/I) is affected by
groundwater levels:
"Groundwater infiltration (GWI) — Flow deriving from
groundwater flowing into the sewer cracks in the pipe, manholes, etc. This I/I
component tends to be continuous and dependent on groundwater levels. "
City of Ottawa analysis of monitored extraneous flows also identified
factors affecting these flows including age of pipe, and noted the importance
of groundwater conditions:
“Other factors are more prevalent with respect to extraneous
flows such as construction practices, type of material, groundwater levels,
etc.” (4)
Given observed flood history data for wastewater systems and
infrastructure management best practices, infiltration LID implementation in existing
urban areas that is intended to replenish groundwater systems and raising
groundwater levels (or have recharge intercepted in trenches or foundation
drains in partially separated sewer systems), would put additional stress on wastewater.
This would contributing to increased operating costs where infiltrated water
enters the wastewater sewer system during moderate conditions, and increased
sewer backups and overflows during extreme conditions. Where LID implementation
has a tangible benefit on groundwater levels, it will have a tangible
dis-benefit on I/I stresses.
The effect of infiltration LIDs on groundwater levels has
been identified through numerous monitoring and analysis studies that have
demonstrated:
i) local groundwater mounding potential in the vicinity of
an infiltration LID, with increases of groundwater level of over 1 m for
extreme events (5),
and
ii) statistically significant regional scale increases in
groundwater level following infiltration LID implementation (6),
and
iii) recharge targets of 10 mm will result in extensive
groundwater level increases, even up to surface(7).
The US Transportation Research Board in its Evaluation of Best Management Practices for
Highway Runoff Control, Issue 565 has identified I/I risks with
infiltration BMPs in urban areas:
“In urban areas, unrestricted infiltration may exacerbate
infiltration and inflow (I/I) problems in both separate and combined systems;
the likelihood of this scenario must be evaluated before constructing unlined
infiltration systems.”(8)
Flooding impacts of GI / LID to adjacent properties have been overlooked
Comprehensive analysis of groundwater effects due to LID
implementation has been completed for the North Markham Urban Area (Future
Urban Area (FUA)), where coupled surface and groundwater modelling at a
subwatershed scale allowed effects of groundwater recharge to be assessed in
terms of groundwater levels. This comprehensive assessment leverages
considerable long-term, investment in the development of the regional
groundwater models, refinements to water quantity stress models in three tiers
of Clean Water Act refinements, and further analysis refinement at a
subwatershed level to refine and calibrate the modelling tools to assess local
impacts.
In North Markham, the comprehensive modelling results
indicate that groundwater levels will increase above existing levels in some
areas even if low LID implementation targets for recharge (i.e., 4 mm event)
are implemented. If more moderate targets (10 mm event) are implemented, “Most
parts of the FUA show a rise in water table above existing conditions and the potential
for ponded water in areas where it rises to ground surface”, according to the
Phase 2 analysis report (page 79-80). Based on this detailed modelling, infiltration
LIDs implemented in existing urban areas are predicted to impact groundwater
levels, which in turn adversely affect I&I stresses as noted above, and
also adversely affect adjacent properties.
The MOECC LID design guidance of 25- 33 mm, 625-825% greater
than a target that can increase groundwater levels in some areas, and 250-330%
greater than a target that can increase groundwater levels in most areas, would
clearly increase groundwater levels significantly in most areas, resulting in
significantly higher I&I impacts, and adjacent property impacts.
Other jurisdictions have opted to prevent infiltration from
LIDs due to adjacent property impacts. This includes the Seattle 2nd
Avenue SEA Street swales where groundwater impacts to adjacent properties were
identified through engineering analysis:
"Our original hope for retaining flows and allowing
infiltration into the native soils throughout the length of the block was not
possible because some homes had an existing groundwater intrusion problem. To
limit the potential for stormwater to adversely impact the residences of
concern, our geotechnical engineers identified some swales that needed an
impermeable liner – for example, a six inch depth of natural clay material was
used as the preferred material.”(9)
Similarly the Seattle Swale on Yale is lined to prevent
water from infiltrating into the ground adjacent to the proposed developments (10).
****
More - check out this high level assessment of GHG /CO2 emission impacts of green infrastructure construction.
****
More - check out this high level assessment of GHG /CO2 emission impacts of green infrastructure construction.
(1)
Analysis by R. Muir: http://www.cityfloodmap.com/2016/04/design-standard-adaptation-vs-climate.html
(2)
City of Ottawa, Sanitary Sewer Extraneous Flow Analysis, E. Tousignant, P.Eng.,
October 1, 2008.
(3)
Infiltration/Inflow Control/Reduction for Wastewater Collection Systems, A Best
Practice by the National Guide to Sustainable Municipal Infrastructure,
Federation of Canadian Municipalities and National Research Council, March 2003
https://www.fcm.ca/Documents/reports/Infraguide/Inflow_Infiltration_Control_Reduction_for_Wastewater_Collection_Systems_EN.pdf
(4)
City of Ottawa, Sanitary Sewer Extraneous Flow Analysis, E. Tousignant, P.Eng.,
October 1, 2008.
(5)
Villanova University, The Graduate School, Department of Civil and
Environmental Engineering, The Observed Effects of Stormwater Infiltration on
Groundwater, Matthew Damien Machusick, 2009
https://www.google.ca/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0ahUKEwjso-_107XQAhWs6YMKHdtPA8gQFggjMAA&url=https%3A%2F%2Fwww1.villanova.edu%2Fcontent%2Fdam%2Fvillanova%2Fengineering%2Fvcase%2Fvusp%2FMachusick%252009Thesis%252004_28_09.pdf&usg=AFQjCNHoQDNxwHISnqTYOPM9le8jHbYYBA&sig2=8VmthXVnITZqjc5Qv8rRJQ
(6) Impact
of Storm Water Recharge Practices on Boston Groundwater Elevations, Journal of
Hydrologic Engineering 17(8):923-932 · August 2012
https://www.researchgate.net/publication/236325104_Impact_of_Storm_Water_Recharge_Practices_on_Boston_Groundwater_Elevations
(7) North
Markham Subwatershed Study, Phase 2 Assessment.
(8) Section 2.2.3.2, https://books.google.ca/books?id=jKR-CF7PG6AC&printsec=frontcover&source=gbs_ge_summary_r&cad=0#v=onepage&q&f=false
Ontario urban flood damages are real. Readers of this blog know we do our best to explain the causes. In general it is decades-old low design standards, constrained overland flow paths, and increasing imperviousness:
It is not aging infrastructure or extreme weather changes as the Environmental Commissioner of Ontario states - that narrative from the insurance industry has been shown to be incorrect and Engineering Climate Datasets for southern Ontario show mostly statistically significant decreasing trends in extreme rainfall.
The cost to mitigate flooding are also real. If GI / LID is the solution, then the cost is prohibitive - and it would be at best a partial solution because the target storms are smaller than the events that cause flooding in Ontario cities, they may be ineffective for concurrent events (i.e., they are slow draining and may be full with a preceding 'small' storm when the 'big' flood-inducing storm arrives), and can in fact aggravate extraneous flow stresses causing flooding and increased pumping and treatment costs in existing urban areas where flooding is most acute. Here are implementation costs for Ontario municipalities, assuming $390,000 per hectare of untreated runoff and urban areas from the Ontario land use GIS layer:
Table
1 - LID Retrofit Cost per Ontario Municipality
|
||
Urban Area Built by 2000 Where LID
Retrofit Can Apply per Ontario Land Classification v2 (Hectares)
|
Retrofit LID Cost at $390k Per
Hectare (average unit cost)
|
|
City
of Barrie
|
5836
|
$ 2,275,397,213
|
City
of Belleville
|
3418
|
$ 1,332,359,598
|
City
of Brampton
|
15925
|
$ 6,208,581,693
|
City
of Brantford
|
4955
|
$ 1,931,925,803
|
City
of Brockville
|
1287
|
$ 501,584,398
|
City
of Burlington
|
8009
|
$ 3,122,356,516
|
City
of Cambridge
|
5921
|
$ 2,308,519,800
|
City
of Clarence-Rockland
|
2144
|
$ 835,827,798
|
City
of Cornwall
|
2542
|
$ 991,133,787
|
City
of Dryden
|
1861
|
$ 725,696,949
|
City
of Elliot Lake
|
2730
|
$ 1,064,168,391
|
City
of Greater Sudbury
|
19652
|
$ 7,661,598,386
|
City
of Guelph
|
5678
|
$ 2,213,801,129
|
City
of Hamilton
|
24115
|
$ 9,401,464,058
|
City
of Kawartha Lakes
|
12128
|
$ 4,728,354,653
|
City
of Kenora
|
3367
|
$ 1,312,596,571
|
City
of Kingston
|
7458
|
$ 2,907,682,499
|
City
of Kitchener
|
8427
|
$ 3,285,434,384
|
City
of London
|
17389
|
$ 6,779,305,984
|
City
of Mississauga
|
24509
|
$ 9,555,173,566
|
City
of Niagara Falls
|
5748
|
$ 2,240,932,529
|
City
of North Bay
|
5179
|
$ 2,019,170,839
|
City
of Orillia
|
1816
|
$ 707,837,418
|
City
of Oshawa
|
5985
|
$ 2,333,212,619
|
City
of Ottawa
|
41720
|
$
16,265,094,044
|
City
of Owen Sound
|
1305
|
$ 508,882,595
|
City
of Pembroke
|
958
|
$ 373,558,930
|
City
of Peterborough
|
3793
|
$ 1,478,849,856
|
City
of Pickering
|
4208
|
$ 1,640,664,574
|
City
of Port Colborne
|
1914
|
$ 746,249,444
|
City
of Prince Edward County
|
4163
|
$ 1,623,173,462
|
City
of Quinte West
|
4647
|
$
1,811,707,301
|
City
of Sarnia
|
5551
|
$ 2,164,011,985
|
City
of Sault Ste. Marie
|
7892
|
$ 3,076,804,186
|
City
of St. Catharines
|
6170
|
$ 2,405,396,352
|
City
of St. Thomas
|
1925
|
$
750,652,924
|
City
of Stratford
|
1852
|
$ 722,205,744
|
City
of Temiskaming Shores
|
1743
|
$ 679,548,131
|
City
of Thorold
|
1701
|
$ 663,320,169
|
City
of Thunder Bay
|
10507
|
$ 4,096,288,663
|
City
of Timmins
|
8338
|
$ 3,250,583,737
|
City
of Toronto
|
53697
|
$
20,934,317,510
|
City
of Vaughan
|
12834
|
$ 5,003,659,847
|
City
of Waterloo
|
4475
|
$ 1,744,655,113
|
City
of Welland
|
3345
|
$ 1,303,912,418
|
City
of Windsor
|
10673
|
$ 4,160,875,955
|
City
of Woodstock
|
2224
|
$ 867,169,696
|
County
of Brant
|
5686
|
$ 2,216,581,813
|
Haldimand
County
|
7119
|
$ 2,775,288,639
|
Municipality
of Arran-Elderslie
|
1414
|
$ 551,084,070
|
Municipality
of Bayham
|
1014
|
$ 395,155,278
|
Municipality
of Bluewater
|
1735
|
$
676,521,836
|
Municipality
of Brighton
|
1321
|
$ 514,996,590
|
Municipality
of Brockton
|
1927
|
$ 751,144,149
|
Municipality
of Brooke-Alvinston
|
850
|
$ 331,383,770
|
Municipality
of Callander
|
128
|
$ 49,868,091
|
Municipality
of Central Elgin
|
2077
|
$ 809,731,480
|
Municipality
of Central Huron
|
1661
|
$ 647,390,450
|
Municipality
of Centre Hastings
|
463
|
$
180,647,927
|
Municipality
of Charlton and Dack
|
376
|
$ 146,604,292
|
Municipality
of Chatham-Kent
|
13837
|
$ 5,394,323,927
|
Municipality
of Clarington
|
5832
|
$ 2,273,774,416
|
Municipality
of Dutton/Dunwich
|
1008
|
$ 393,111,432
|
Municipality
of French River
|
807
|
$ 314,690,899
|
Municipality
of Gordon / Barrie Island
|
0
|
$ -
|
Municipality
of Greenstone
|
5313
|
$ 2,071,521,370
|
Municipality
of Grey Highlands
|
2502
|
$ 975,432,137
|
Municipality
of Hastings Highlands
|
733
|
$ 285,805,125
|
Municipality
of Highlands East
|
90
|
$
34,973,453
|
Municipality
of Huron East
|
2131
|
$ 830,836,603
|
Municipality
of Huron Shores
|
1093
|
$ 426,172,616
|
Municipality
of Killarney
|
61
|
$ 23,736,685
|
Municipality
of Kincardine
|
2539
|
$ 989,975,900
|
Municipality
of Lambton Shores
|
2183
|
$ 851,038,224
|
Municipality
of Leamington
|
2894
|
$ 1,128,141,652
|
Municipality
of Magnetawan
|
0
|
$ -
|
Municipality
of Markstay-Warren
|
880
|
$ 342,927,554
|
Municipality
of Marmora and Lake
|
580
|
$ 226,112,538
|
Municipality
of McDougall
|
594
|
$ 231,498,467
|
Municipality
of Meaford
|
1860
|
$ 725,003,971
|
Municipality
of Middlesex Centre
|
3003
|
$ 1,170,606,283
|
Municipality
of Morris-Turnberry
|
963
|
$ 375,392,251
|
Municipality
of Neebing
|
93
|
$ 36,298,005
|
Municipality
of North Grenville
|
2151
|
$ 838,722,516
|
Municipality
of North Middlesex
|
1751
|
$ 682,609,515
|
Municipality
of North Perth
|
1881
|
$
733,267,074
|
Municipality
of Northern Bruce Peninsula
|
1822
|
$ 710,416,348
|
Municipality
of Oliver Paipoonge
|
1245
|
$ 485,233,629
|
Municipality
of Port Hope
|
1947
|
$ 758,959,886
|
Municipality
of Powassan
|
520
|
$ 202,674,096
|
Municipality
of Red Lake
|
872
|
$ 339,910,030
|
Municipality
of Shuniah
|
1734
|
$ 675,872,717
|
Municipality
of Sioux Lookout
|
2161
|
$ 842,301,440
|
Municipality
of South Bruce
|
1325
|
$ 516,408,861
|
Municipality
of South Huron
|
1863
|
$ 726,258,348
|
Municipality
of Southwest Middlesex
|
1466
|
$ 571,575,162
|
Municipality
of St.-Charles
|
16
|
$ 6,149,082
|
Municipality
of Temagami
|
1303
|
$ 508,101,898
|
Municipality
of Thames Centre
|
2424
|
$ 944,949,883
|
Municipality
of the Nation
|
2410
|
$ 939,485,007
|
Municipality
of Trent Hills
|
2174
|
$ 847,415,441
|
Municipality
of Tweed
|
1185
|
$ 462,172,378
|
Municipality
of Wawa
|
1540
|
$ 600,408,305
|
Municipality
of West Elgin
|
1243
|
$ 484,716,088
|
Municipality
of West Grey
|
2492
|
$ 971,344,445
|
Municipality
of West Nipissing
|
1339
|
$ 522,031,631
|
Municipality
of West Perth
|
1853
|
$ 722,240,831
|
Municipality
of Whitestone
|
353
|
$ 137,630,668
|
Norfolk
County
|
8760
|
$ 3,415,266,857
|
Town
of Ajax
|
3718
|
$ 1,449,481,629
|
Town
of Amherstburg
|
2071
|
$ 807,371,846
|
Town
of Arnprior
|
581
|
$ 226,314,291
|
Town
of Aurora
|
2608
|
$ 1,016,659,934
|
Town
of Aylmer
|
432
|
$ 168,376,078
|
Town
of Bancroft
|
289
|
$ 112,551,886
|
Town
of Blind River
|
1514
|
$ 590,232,933
|
Town
of Bracebridge
|
2509
|
$ 978,204,048
|
Town
of Bradford West Gwillimbury
|
2047
|
$ 797,863,137
|
Town
of Bruce Mines
|
193
|
$ 75,131,081
|
Town
of Caledon
|
6008
|
$ 2,342,124,841
|
Town
of Carleton Place
|
451
|
$ 175,867,256
|
Town
of Cobalt
|
144
|
$ 56,315,417
|
Town
of Cobourg
|
1293
|
$ 504,128,241
|
Town
of Cochrane
|
1164
|
$ 453,760,153
|
Town
of Collingwood
|
1616
|
$ 629,890,566
|
Town
of Deep River
|
537
|
$ 209,481,069
|
Town
of Deseronto
|
103
|
$ 40,148,857
|
Town
of East Gwillimbury
|
2364
|
$ 921,792,141
|
Town
of Englehart
|
199
|
$ 77,543,346
|
Town
of Erin
|
1415
|
$ 551,627,926
|
Town
of Espanola
|
926
|
$ 361,094,100
|
Town
of Essex
|
2053
|
$ 800,459,612
|
Town
of Fort Erie
|
3964
|
$ 1,545,507,309
|
Town
of Fort Frances
|
1080
|
$ 420,944,581
|
Town
of Gananoque
|
326
|
$ 127,139,509
|
Town
of Georgina
|
3197
|
$ 1,246,579,464
|
Town
of Goderich
|
580
|
$ 226,024,819
|
Town
of Gore Bay
|
0
|
$ -
|
Town
of Gravenhurst
|
1544
|
$ 602,074,960
|
Town
of Greater Napanee
|
2169
|
$ 845,687,382
|
Town
of Grimsby
|
1478
|
$ 576,075,133
|
Town
of Halton Hills
|
3974
|
$ 1,549,191,495
|
Town
of Hanover
|
471
|
$ 183,437,382
|
Town
of Hawkesbury
|
557
|
$ 217,068,738
|
Town
of Hearst
|
985
|
$ 384,067,632
|
Town
of Huntsville
|
2378
|
$ 927,265,789
|
Town
of Ingersoll
|
843
|
$ 328,655,718
|
Town
of Innisfil
|
3405
|
$ 1,327,561,384
|
Town
of Iroquois Falls
|
2241
|
$ 873,695,969
|
Town
of Kapuskasing
|
1738
|
$ 677,425,339
|
Town
of Kearney
|
0
|
$ -
|
Town
of Kingsville
|
2644
|
$ 1,030,852,823
|
Town
of Kirkland Lake
|
1167
|
$ 454,918,040
|
Town
of Lakeshore
|
4206
|
$ 1,639,673,352
|
Town
of Lasalle
|
2024
|
$ 789,108,809
|
Town
of Latchford
|
395
|
$ 154,077,927
|
Town
of Laurentian Hills
|
851
|
$ 331,629,383
|
Town
of Lincoln
|
2321
|
$ 904,765,938
|
Town
of Marathon
|
974
|
$ 379,664,152
|
Town
of Markham
|
10732
|
$ 4,184,077,556
|
Town
of Mattawa
|
193
|
$ 75,367,922
|
Town
of Midland
|
1307
|
$ 509,654,520
|
Town
of Milton
|
5163
|
$ 2,012,855,092
|
Town
of Minto
|
1137
|
$ 443,277,766
|
Town
of Mississippi Mills
|
1400
|
$ 545,724,456
|
Town
of Mono
|
1175
|
$ 457,944,336
|
Town
of Moosonee
|
277
|
$ 108,095,775
|
Town
of New Tecumseth
|
2371
|
$ 924,379,844
|
Town
of Newmarket
|
2963
|
$ 1,155,229,192
|
Town
of Niagara-on-the-Lake
|
2538
|
$ 989,510,991
|
Town
of Northeastern Manitoulin and the Islands
|
253
|
$ 98,473,032
|
Town
of Oakville
|
7890
|
$ 3,076,128,752
|
Town
of Orangeville
|
1174
|
$ 457,593,461
|
Town
of Parry Sound
|
640
|
$ 249,515,892
|
Town
of Pelham
|
1679
|
$ 654,750,050
|
Town
of Penetanguishene
|
731
|
$ 284,989,341
|
Town
of Perth
|
470
|
$ 183,323,347
|
Town
of Petawawa
|
1503
|
$ 586,136,469
|
Town
of Petrolia
|
419
|
$
163,191,902
|
Town
of Plympton-Wyoming
|
1450
|
$ 565,312,046
|
Town
of Prescott
|
331
|
$ 129,157,039
|
Town
of Rainy River
|
0
|
$ -
|
Town
of Renfrew
|
520
|
$ 202,858,306
|
Town
of Richmond Hill
|
6032
|
$ 2,351,554,603
|
Town
of Saugeen Shores
|
1504
|
$ 586,443,485
|
Town
of Shelburne
|
363
|
$ 141,525,379
|
Town
of Smiths Falls
|
528
|
$ 205,665,305
|
Town
of Smooth Rock Falls
|
776
|
$ 302,682,206
|
Town
of South Bruce Peninsula
|
1837
|
$ 716,258,415
|
Town
of Spanish
|
596
|
$ 232,296,707
|
Town
of St. Marys
|
608
|
$ 236,893,168
|
Town
of Tecumseh
|
2187
|
$ 852,634,705
|
Town
of the Blue Mountains
|
2173
|
$ 847,196,144
|
Town
of Thessalon
|
220
|
$ 85,955,571
|
Town
of Tillsonburg
|
1006
|
$ 392,085,123
|
Town
of Wasaga Beach
|
2033
|
$ 792,687,733
|
Town
of Whitby
|
5046
|
$ 1,967,074,693
|
Town
of Whitchurch-Stouffville
|
3244
|
$ 1,264,781,098
|
Township
of Addington Highlands
|
261
|
$ 101,920,378
|
Township
of Adelaide-Metcalfe
|
967
|
$ 377,058,907
|
Township
of Adjala-Tosorontio
|
1340
|
$ 522,549,171
|
Township
of Admaston/Bromley
|
660
|
$ 257,322,857
|
Township
of Alberton
|
82
|
$ 31,798,035
|
Township
of Alfred and Plantagenet
|
1731
|
$ 674,863,952
|
Township
of Algonquin Highlands
|
744
|
$ 290,208,605
|
Township
of Alnwick/Haldimand
|
1707
|
$ 665,328,927
|
Township
of Amaranth
|
835
|
$ 325,594,335
|
Township
of Armour
|
407
|
$ 158,735,791
|
Township
of Armstrong
|
151
|
$ 58,964,522
|
Township
of Ashfield-Colborne-Wawanosh
|
1712
|
$ 667,285,055
|
Township
of Asphodel-Norwood
|
759
|
$ 295,901,549
|
Township
of Assiginack
|
0
|
$ -
|
Township
of Athens
|
472
|
$ 183,858,432
|
Township
of Atikokan
|
546
|
$ 212,910,871
|
Township
of Augusta
|
1479
|
$ 576,461,095
|
Township
of Baldwin
|
436
|
$ 170,165,540
|
Township
of Beckwith
|
854
|
$ 332,769,726
|
Township
of Billings
|
0
|
$ -
|
Township
of Black River-Matheson
|
4110
|
$ 1,602,287,635
|
Township
of Blandford-Blenheim
|
1357
|
$ 529,110,531
|
Township
of Bonfield
|
231
|
$ 90,034,491
|
Township
of Bonnechere Valley
|
0
|
$ -
|
Township
of Brethour
|
2
|
$ 807,012
|
Township
of Brock
|
1704
|
$ 664,434,196
|
Township
of Brudenell, Lyndoch and Raglan
|
0
|
$ -
|
Township
of Burpee and Mills
|
0
|
$ -
|
Township
of Calvin
|
291
|
$ 113,551,880
|
Township
of Carling
|
95
|
$ 36,938,352
|
Township
of Carlow/Mayo
|
0
|
$ -
|
Township
of Casey
|
23
|
$ 8,842,047
|
Township
of Cavan-Monaghan
|
1674
|
$ 652,469,363
|
Township
of Central Frontenac
|
0
|
$ -
|
Township
of Central Manitoulin
|
0
|
$ -
|
Township
of Centre Wellington
|
2596
|
$ 1,012,045,930
|
Township
of Chamberlain
|
252
|
$ 98,385,313
|
Township
of Champlain
|
1361
|
$ 530,575,434
|
Township
of Chapleau
|
412
|
$ 160,437,534
|
Township
of Chapple
|
0
|
$ -
|
Township
of Chatsworth
|
1562
|
$ 608,934,564
|
Township
of Chisholm
|
0
|
$ -
|
Township
of Clearview
|
2436
|
$ 949,739,325
|
Township
of Cockburn Island
|
0
|
$ -
|
Township
of Coleman
|
762
|
$ 296,998,033
|
Township
of Conmee
|
165
|
$ 64,455,714
|
Township
of Cramahe
|
1071
|
$ 417,611,270
|
Township
of Dawn-Euphemia
|
1299
|
$ 506,610,680
|
Township
of Dawson
|
0
|
$ -
|
Township
of Dorion
|
573
|
$ 223,568,695
|
Township
of Douro-Dummer
|
1180
|
$ 460,023,269
|
Township
of Drummond/North Elmsley
|
1091
|
$ 425,295,429
|
Township
of Dubreuilville
|
465
|
$ 181,297,045
|
Township
of Ear Falls
|
545
|
$ 212,586,312
|
Township
of East Ferris
|
227
|
$ 88,578,361
|
Township
of East Garafraxa
|
570
|
$ 222,305,545
|
Township
of East Hawkesbury
|
765
|
$ 298,050,658
|
Township
of East Luther Grand Valley
|
450
|
$ 175,516,382
|
Township
of East Zorra-Tavistock
|
1080
|
$ 420,979,668
|
Township
of Edwardsburgh/Cardinal
|
1394
|
$ 543,557,804
|
Township
of Elizabethtown-Kitley
|
2054
|
$ 800,889,433
|
Township
of Emo
|
0
|
$ -
|
Township
of Enniskillen
|
888
|
$ 346,059,112
|
Township
of Essa
|
1631
|
$ 635,837,895
|
Township
of Evanturel
|
160
|
$ 62,227,658
|
Township
of Faraday
|
15
|
$ 5,745,576
|
Township
of Fauquier-Strickland
|
853
|
$ 332,743,411
|
Township
of Front of Yonge
|
546
|
$ 212,945,958
|
Township
of Frontenac Islands
|
556
|
$ 216,656,460
|
Township
of Galway-Cavendish and Harvey
|
1481
|
$ 577,320,738
|
Township
of Gauthier
|
0
|
$ -
|
Township
of Georgian Bay
|
1426
|
$ 556,031,406
|
Township
of Georgian Bluffs
|
2060
|
$ 803,187,664
|
Township
of Gillies
|
0
|
$ -
|
Township
of Greater Madawaska
|
0
|
$ -
|
Township
of Guelph/Eramosa
|
1496
|
$ 583,118,946
|
Township
of Hamilton
|
1958
|
$ 763,494,944
|
Township
of Harley
|
214
|
$ 83,508,219
|
Township
of Harris
|
78
|
$ 30,455,939
|
Township
of Havelock-Belmont-Methuen
|
760
|
$ 296,103,302
|
Township
of Head, Clara and Maria
|
617
|
$ 240,559,810
|
Township
of Hilliard
|
46
|
$ 17,903,390
|
Township
of Hilton
|
56
|
$ 21,815,645
|
Township
of Hornepayne
|
732
|
$ 285,199,866
|
Township
of Horton
|
498
|
$ 194,279,415
|
Township
of Howick
|
861
|
$ 335,506,550
|
Township
of Hudson
|
0
|
$ -
|
Township
of Huron-Kinloss
|
1621
|
$ 632,048,446
|
Township
of Ignace
|
778
|
$ 303,261,150
|
Township
of James
|
0
|
$ -
|
Township
of Jocelyn
|
0
|
$ -
|
Township
of Johnson
|
0
|
$ -
|
Township
of Joly
|
13
|
$ 5,035,054
|
Township
of Kerns
|
0
|
$ -
|
Township
of Killaloe, Hagarty and Richards
|
0
|
$ -
|
Township
of King
|
3119
|
$ 1,215,930,544
|
Township
of La Vallee
|
0
|
$ -
|
Township
of Laird
|
0
|
$ -
|
Township
of Lake of Bays
|
978
|
$ 381,137,827
|
Township
of Lake of the Woods
|
113
|
$ 43,859,359
|
Township
of Lanark Highlands
|
420
|
$ 163,928,739
|
Township
of Larder Lake
|
0
|
$ -
|
Township
of Laurentian Valley
|
1053
|
$ 410,383,247
|
Township
of Leeds and the Thousand Islands
|
2142
|
$ 835,257,627
|
Township
of Limerick
|
148
|
$ 57,631,197
|
Township
of Loyalist
|
1653
|
$ 644,539,591
|
Township
of Lucan Biddulph
|
682
|
$ 265,726,310
|
Township
of Macdonald, Meredith and Aberdeen Additional
|
54
|
$ 20,973,545
|
Township
of Machar
|
96
|
$ 37,438,349
|
Township
of Machin
|
1104
|
$ 430,330,484
|
Township
of Madawaska Valley
|
0
|
$ -
|
Township
of Madoc
|
382
|
$ 148,806,032
|
Township
of Malahide
|
1462
|
$ 569,838,332
|
Township
of Manitouwadge
|
1150
|
$ 448,532,117
|
Township
of Mapleton
|
1607
|
$ 626,688,832
|
Township
of Matachewan
|
0
|
$ -
|
Township
of Mattawan
|
108
|
$ 42,280,422
|
Township
of Mattice-Val Cote
|
380
|
$ 148,200,773
|
Township
of McGarry
|
0
|
$ -
|
Township
of McKellar
|
0
|
$ -
|
Township
of McMurrich-Monteith
|
0
|
$ -
|
Township
of McNab/Braeside
|
911
|
$ 355,015,193
|
Township
of Melancthon
|
849
|
$ 331,173,246
|
Township
of Minden Hills
|
1215
|
$
473,874,055
|
Township
of Montague
|
664
|
$ 259,050,916
|
Township
of Moonbeam
|
459
|
$ 178,832,149
|
Township
of Morley
|
0
|
$ -
|
Township
of Mulmur
|
850
|
$ 331,445,174
|
Township
of Muskoka Lakes
|
293
|
$ 114,209,770
|
Township
of Nairn and Hyman
|
726
|
$ 283,059,529
|
Township
of Nipigon
|
788
|
$ 307,296,211
|
Township
of Nipissing
|
130
|
$ 50,640,016
|
Township
of North Algona Wilberforce
|
68
|
$ 26,377,018
|
Township
of North Dumfries
|
1298
|
$ 506,084,368
|
Township
of North Dundas
|
1796
|
$ 700,030,452
|
Township
of North Frontenac
|
804
|
$ 313,278,627
|
Township
of North Glengarry
|
1948
|
$ 759,503,742
|
Township
of North Huron
|
711
|
$ 277,103,428
|
Township
of North Kawartha
|
265
|
$ 103,192,299
|
Township
of North Stormont
|
1340
|
$ 522,487,768
|
Township
of Norwich
|
1629
|
$ 635,171,232
|
Township
of O'Connor
|
4
|
$ 1,614,024
|
Township
of Opasatika
|
264
|
$ 102,867,740
|
Township
of Oro-Medonte
|
3791
|
$ 1,478,139,334
|
Township
of Otonabee-South Monaghan
|
1442
|
$ 562,329,609
|
Township
of Papineau-Cameron
|
665
|
$ 259,173,722
|
Township
of Pelee
|
190
|
$ 74,210,035
|
Township
of Perry
|
616
|
$ 240,094,901
|
Township
of Perth East
|
2200
|
$ 857,739,934
|
Township
of Perth South
|
1090
|
$ 424,769,117
|
Township
of Pickle Lake
|
857
|
$ 333,936,385
|
Township
of Plummer Additional
|
53
|
$ 20,657,758
|
Township
of Prince
|
556
|
$ 216,577,513
|
Township
of Puslinch
|
1231
|
$ 480,093,312
|
Township
of Ramara
|
2010
|
$ 783,740,424
|
Township
of Red Rock
|
537
|
$ 209,516,156
|
Township
of Rideau Lakes
|
2222
|
$ 866,257,421
|
Township
of Russell
|
1399
|
$ 545,496,388
|
Township
of Ryerson
|
0
|
$ -
|
Township
of Sables-Spanish Rivers
|
2525
|
$ 984,589,971
|
Township
of Schreiber
|
192
|
$ 74,964,416
|
Township
of Scugog
|
2526
|
$ 984,625,059
|
Township
of Seguin
|
626
|
$ 243,963,297
|
Township
of Severn
|
2678
|
$ 1,044,150,980
|
Township
of Sioux Narrows-Nestor Falls
|
0
|
$ -
|
Township
of Smith-Ennismore-Lakefield
|
2575
|
$ 1,003,949,492
|
Township
of South Algonquin
|
835
|
$ 325,629,423
|
Township
of South Dundas
|
2419
|
$ 942,897,265
|
Township
of South Frontenac
|
2213
|
$ 862,617,095
|
Township
of South Glengarry
|
2597
|
$ 1,012,510,839
|
Township
of South Stormont
|
2190
|
$ 853,731,189
|
Township
of Southgate
|
1530
|
$ 596,513,594
|
Township
of South-West Oxford
|
1464
|
$ 570,890,956
|
Township
of Southwold
|
1255
|
$ 489,330,093
|
Township
of Springwater
|
2971
|
$ 1,158,316,891
|
Township
of St. Clair
|
3090
|
$ 1,204,570,971
|
Township
of St. Joseph
|
0
|
$ -
|
Township
of Stirling-Rawdon
|
803
|
$ 313,059,330
|
Township
of Stone Mills
|
1276
|
$ 497,400,215
|
Township
of Strathroy-Caradoc
|
1955
|
$ 762,065,129
|
Township
of Strong
|
420
|
$ 163,849,792
|
Township
of Tarbutt and Tarbutt Additional
|
0
|
$ -
|
Township
of Tay
|
1054
|
$ 411,093,769
|
Township
of Tay Valley
|
548
|
$ 213,805,602
|
Township
of Tehkummah
|
0
|
$ -
|
Township
of Terrace Bay
|
747
|
$ 291,348,948
|
Township
of the Archipelago
|
420
|
$ 163,867,336
|
Township
of the North Shore
|
1170
|
$ 456,268,908
|
Township
of Tiny
|
2636
|
$ 1,027,633,546
|
Township
of Tudor and Cashel
|
113
|
$ 44,201,462
|
Township
of Tyendinaga
|
916
|
$ 357,111,670
|
Township
of Uxbridge
|
2328
|
$ 907,493,990
|
Township
of Val Rita-Harty
|
1082
|
$ 421,795,452
|
Township
of Wainfleet
|
1088
|
$ 424,312,980
|
Township
of Warwick
|
897
|
$ 349,550,317
|
Township
of Wellesley
|
1148
|
$ 447,426,862
|
Township
of Wellington North
|
1766
|
$ 688,688,422
|
Township
of West Lincoln
|
1809
|
$ 705,065,506
|
Township
of White River
|
556
|
$ 216,788,038
|
Township
of Whitewater Region
|
1730
|
$ 674,285,008
|
Township
of Wilmot
|
1896
|
$ 739,319,666
|
Township
of Wollaston
|
0
|
$ -
|
Township
of Woolwich
|
2576
|
$ 1,004,098,614
|
Township
of Zorra
|
1813
|
$
706,740,934
|
United
Townships of Dysart, Dudley, Harcourt, Guilford, Harburn, Bruton, Havelock,
Eyre and Clyde
|
563
|
$ 219,647,668
|
Village
of Burk's Falls
|
154
|
$ 59,920,656
|
Village
of Casselman
|
239
|
$ 93,201,137
|
Village
of Hilton Beach
|
0
|
$ -
|
Village
of Merrickville-Wolford
|
508
|
$ 198,156,583
|
Village
of Newbury
|
59
|
$ 22,903,357
|
Village
of Oil Springs
|
92
|
$ 35,798,009
|
Village
of Point Edward
|
305
|
$ 119,007,984
|
Village
of South River
|
170
|
$ 66,438,157
|
Village
of Sundridge
|
180
|
$
69,990,765
|
Village
of Thornloe
|
5
|
$ 2,096,477
|
Village
of Westport
|
2
|
$ 666,662
|
TOTAL
|
852,045
|
$ 332,178,923,064
|
total
hectares
|
total
cost
|
The Environmental Commissioner of Ontario is right that we have to look at costs to address water resource management challenges in the province, including flooding. We have good models for this in the realm of Source Protection under the Clean Water Act has developed locally-driven, evidence based, semi-quantitative risk management policies for the significant risk. That process has also adopted cost-effective risk prevention policies to prevent future risks from occurring.
We can learn from the 15 year post-Walkerton Source Protection process that risks are not universal, nor are the appropriate solutions. For example, potable water quantity risks are not universal across the province: there are “more than 970 wellhead protection areas and 150
intake protection zones within the source protection areas in Ontario”[1] But only 22 municipal systems have required Tier 3 water
quantity stress assessments[2],
indicating that water quantity stresses were confirmed at the earlier
Conceptual, Tier 1 or Tier 2 evaluations. Of these systems with Tier 3
assessments, only 18 are groundwater systems that would require recharge
management policies – this represents a very small fraction of potable water
supplies. Applying this to urban flood risk areas would also show a high variability in risk and required solutions (Toronto basement flooding densities vary from > 4 properties per hectare to less than 0.5 per hectare depending on the topography / slopes).
Unfortunately, Green Infrastructure and Low Impact Development stormwater management measures have been proposed as a universal solution, regardless of local issues to address. regardless of more cost effective pollution prevention measures (ban fertilizers like we did with pesticides), regardless of clearly prohibitive implementation costs, and regardless of impacts to existing wastewater systems in existing urban areas.
Unfortunately, Green Infrastructure and Low Impact Development stormwater management measures have been proposed as a universal solution, regardless of local issues to address. regardless of more cost effective pollution prevention measures (ban fertilizers like we did with pesticides), regardless of clearly prohibitive implementation costs, and regardless of impacts to existing wastewater systems in existing urban areas.
When something is promised to solve all our problems and cost less, it is a "Trumpesque" proposition at best. Fulsome economic analysis shows that Green Infrastructure and Low Impact Development stormwater management measures are unaffordable for Ontario urban retrofits, and fulsome technical analyses shows that implementation would be counter productive for flood risk reduction where infiltration is already a chronic challenge in many Ontario cities, and should not be aggravated by additional recharge from well-meaning GI and LID measures.
[1] http://conservationontario.ca/what-we-do/source-water-protection
[2] Personal communication with Program
Services Section, Ministry of Natural Resources & Forestry
****
Recent reporting from Philadelphia in the US suggests private sector implementation costs of $625,000 to $750,000 per hectare for green infrastructure installations to address small storms resulting in CSO's:
https://www.environmentalleader.com/2018/03/philadelphia-stormwater-runoff/
****
Recent reporting from Philadelphia in the US suggests private sector implementation costs of $625,000 to $750,000 per hectare for green infrastructure installations to address small storms resulting in CSO's:
https://www.environmentalleader.com/2018/03/philadelphia-stormwater-runoff/
