Use of the local improvement processes was suggested on by Ontario's Special Advisor on Flooding, Douglas McNeil, when he published his report An Independent Review of the 2019 Flood Events in Ontario for the Hon. John Yakabuski, Minister of Natural Resources and Forestry in November 2019.
McNeil's report contains sixty-six recommendations. Recommendation #16 states:
That municipalities consider utilizing local improvement charges to help finance and install (or upgrade) shoreline protection works, and if necessary, that the Province provide municipalities with enhanced authority to do so. (p. 7)
Regarding shoreline protection works, Mr. McNeil notes that:
These mitigative measures are extremely expensive and sometimes can't protect to the water levels seen recently. Property owners are responsible for covering the cost of these works on private property, which is the same in many jurisdictions across Canada. In Ontario (and similarly in other jurisdictions), municipalities may consider using local improvement charges (see Ontario Regulation 586/06 under the Municipal Act, 2001) to: first, assist with the construction and financing of a shoreline protection project for a group of private property owners (that may provide economy of scale for the design and construction of the works); and second, imposing a local improvement charge which may help make the financial commitment of the overall cost of the shoreline protection works on their property easier for the private property owner by spreading it out over 20 years or more.
In addition to the use of the local improvement charges, Mr. McNeil provided this additional commentary under Recommendation # 16:
In my review of Ontario statutes, I discovered a piece of older legislation that is not currently used titled: The Shoreline Property Assistance Act. Under this legislation, the province may offer a Shoreline Property Assistance Program under which municipalities may issue debentures (subsequently purchased by the Treasurer of Ontario) to fund loans to private property owners to construct works such as retaining walls, dikes, breakwaters, groynes, cribs and other structures for the rehabilitation or protection of shorelines, including repairs and improvements to existing works. The funds may also be used by private property owners for raising, relocation or repairs to buildings. The Shoreline Property Assistance Program was cancelled by the Province in 2010 and not currently available to municipalities. Municipalities may still consider offering loans to private property owners. One municipality in southwestern Ontario, the Town of Essex, has recently approved a new loan program for shoreline residents.(p. 110)
As noted in the commentary, the provisions of the Shoreline Property Assistance Act are a provincial program and not currently available. The Regulation under the Shoreline Property Assistance Act contains limitations such as only 75% of the shoreline works qualify for the loans and a maximum of $20,000 loan is available for home repairs or home relocations. The interest rates on the loans are set in the