of standards and has committed to developing guidance materials, but has not provided a timeline for when these will be made available. Even with guidelines, however, best practices are usually site- or area-specific engineering solutions to specific problems.

In absence of such standards, developing a by-law to address flood abatement on private property will be very challenging. Establishing that a violation has occurred would require the consultation of professional staff, particularly a hydraulic engineer, if City staff do not have established standards to evaluate the property's condition against. This lack of standards would also make any order issued very likely to be contested at the Property Standards Committee and in the courts.

Without established standards, any Orders to Repair issued under a by-law intended to address flood abatement would require the consultation of an engineer with appropriate expertise. The Building Division does not have a hydraulic engineer on staff, so a consultant would likely need to be contracted with before an Order to Repair could be issued. Should the Order be successfully contested, the cost of hiring a consulting hydraulic engineer would likely fall to the City with little opportunity for full cost recovery.

Financial Matters:

There are a number of financial impacts that would need to be more fully analyzed and considered if such a change in policy were to be put forward. This would include such items as assessing the impact to city funding, the impact on available cash flows, and costs associated with the administration of the program, etc. Currently the cost for local improvement work is either funded as part of a municipal capital project or cost shared between the City and the property owner. The portion which remains to be funded over time to the taxpayer is in essence a loan with the City becoming the financing authority on a long-term basis. In terms of cash flow, in today's economic environment wherein interest rates are very low and affordable, it would be advantageous for a property owner to accept and maintain a 20-year repayable loan from the City. In contrast, where interest rates are initially higher and then fall over the repayment period, a property owner can choose a payout based upon the remaining balance outstanding. The same does not hold true for the city, as interest rates rise over the 20-year period, the City would be essentially forgoing interest revenue until the full balance owing is collected. There is no ability for the City to renegotiate the terms of the loan.

Under the current local improvement policy, property owners are provided with the choice to pay their share of the cost in full. Those property owners who require financial assistance with the full payment can choose to access alternative financing through various lending institutions which would likely have provisions for longer-term repayment periods and attractive interest rates.

Consultations: