The Calgary River Valleys Project aims to establish City of Calgary planning regulations to address flood risk. The final draft of the proposed regulations has not been released as of this publication, but previous communications with the City give rise to concerns about provisions that might be included.
High-level overview about CRVP: Calgary River Valleys Project – Flood Hazard Mapping and Development Rules
The Calgary River Communities Action Group (CRCAG) has remained steadfast in our mission to advocate against policy, legislative and regulatory changes that are prejudicial to and negatively impact property owners in flood impacted communities.
With the City’s Stage 3 engagement period set to begin on Monday, November 24, the updated draft of proposed development regulations will soon be shared for public review, along with Calgary’s regulatory flood map (which includes new groundwater mapping).
Today, we’re sharing our position on the Calgary River Valleys Project, responding to information shared in previous engagement communications. We invite our members, partners, and government stakeholders to read and reflect on this call to action as we continue to advocate for smart, long-term flood mitigation solutions.
Position Statement
Calgary River Communities Action Group (CRCAG) Position Statement on Calgary River Valleys Project
(1) The Provincial Design Flood Standard of 1:100 must be the basis for all Calgary floodplain policies and regulations. After all, the maps on which they are based were developed using this standard. Future considerations such as climate change and the City’s aspirational 1:200 protection target should be for future infrastructure, policies and regulations. Residual risks with remote probabilities should not factor into City policies and regulations.
(2) The City has a longer term aspirational objective that flood protection should be at the 1:200 level for Calgary (ref. Calgary Metropolitan Region Board, August 2022). We support the longer term goal of protecting against a 1:200 flood. Appropriate infrastructure should be built as soon as possible (eg. Sunnyside Flood Barrier and Upstream Reservoir Capacity on the Bow River). It makes no sense to restrict development based on a 1:200 risk when the plan is to provide protection to 1:200.
(3) Climate change is a concern for the future and its effect should be addressed in future provincial flood standard assessments and future infrastructure. For now, the impact of climate change can best be described as unknown. The engineering report on which the provincial flood standard was based does not suggest a specific provision for climate change. Some recent studies, specifically those referenced in the City of Calgary publication “Climate Projections for Calgary, January 2022”, show reduced future flood risk. The +20% assumption in the CRVP proposals appears to be arbitrary and yet would have real negative impact if implemented. It should be eliminated. Like the aspirational 1:200 target, any climate change risks should be offset by future infrastructure development and not incorporated into current floodplain policies and regulations.
(4) In some areas (ie. Elbow River) the 2013 flood exceeded 1:100 flows. This does not change the future flood probabilities. If 1:100 is the standard it should apply everywhere, even in areas where the 2013 flood was larger.
(5) The flood mitigation capability of any new reservoir capacity upstream on the Bow River, and of the existing GOA/TransAlta Modified Operations Agreement for the Ghost Reservoir must be recognized for the benefit provided and restrictions in the policies and regulations in Calgary lessened accordingly. Every dam used for flood mitigation depends on operating rules for its effectiveness. This includes SR1, existing Ghost and whatever might be built in the future. It will be important that all operating rules are developed using common sense and a low but non-zero tolerance for risk. For example, more complex rules would apply to the Bow River multipurpose reservoirs than to the dedicated SR1 reservoir and yet both should be recognized for the flood protection they provide.
(6) Floodway: We support the continued and proposed development restrictions for the Floodway. While severe, they are justified by the risk.
(7) High Hazard Flood Fringe: Because the criteria defining High Hazard Flood Fringe are essentially identical to the criteria for the Floodway this suggests applying the same severe restrictions in policies and regulations. However, flexibility in applying the policies and regulations is needed to reflect specific circumstances. One example is in Sunnyside where a significant area is designated High Hazard Flood Fringe now but will become Protected Flood Fringe when the Sunnyside Flood Barrier Project is complete. In applying the policies and regulations it is important that the near term Protected Flood Fringe designation can be kept in view and appropriate relaxations can be provided.
(8) Flood Fringe: We support continuation of the current bylaws and policies applicable to the Flood Fringe zone. There is no basis for change. Essentially, homeowners should manage their own risk.
(9) Protected Flood Fringe: There should be no mandatory floodplain bylaws nor policies applicable to protected areas. Considerable investment has been or will be made in flood mitigation infrastructure and it makes no sense to negate it by citing residual risks with remote probabilities. In any event, the standard 1:20 basis for restrictions makes no sense. Each protected area has different characteristics. Finally, assertion that regulations will not be onerous to comply with is no justification for unnecessary regulations.
(10) Areas Protected by Upstream Mitigation: No mandatory floodplain development restrictions are justified in these areas. The investment in upstream facilities provides the necessary protection. For example, the Elbow River Communities (post SR1) will enjoy protection that meets or exceeds 1:100 so no restrictions are needed.
(11) Where overland flooding is expected basement use restrictions are understandable. Groundwater seepage is entirely different. Groundwater seepage will not flood a basement quickly enough to be a risk to life or personal safety. Delineating areas prone to groundwater seepage is so complicated and technically challenging that there is reasonable doubt as to the City’s ability to define it adequately to support policies and regulations. Any attempt to do so under these conditions is likely to lead to unfair treatment of individual property owners.
(12) Calgary’s approved Flood Mitigation Measures Assessment Report (UCS2017-0266) explicitly commits to groundwater seepage mitigation for Sunnyside as follows: “Because of unique circumstances for the community of Sunnyside, the proposed barrier includes groundwater protection”. The Sunnyside Flood Barrier Project is now nearly complete. Consistent with Council direction one expects that the groundwater mitigation provided in the barrier project is adequate to avoid the need for any groundwater seepage policies and regulations applicable to Sunnyside.
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About the Calgary River Valleys Project
Timeline and key engagement stages:
- Stage 3 Engagement (November 24 – December 12, 2025) — The upcoming phase, where the City is presenting draft updated development regulations for Calgary’s flood hazard areas, which are planned for incorporation into the Land Use Bylaw in 2026, along with a new regulatory flood map that now includes Calgary’s river-related groundwater risk. All Calgarians are invited to participate through an online survey, in-person drop-in events, and a virtual information session.
- Stage 2 Engagement (January 29 – March 3, 2024) — Included a 40-question online survey and a virtual information session focused on the High Hazard Flood Fringe (held February 26, 2024). Read CRCAG’s responses to the online survey here.
- Stage 1 Engagement (April 27 – June 5, 2023) — The first phase of the City’s multi-stage engagement process, launched to gather input from people who live, work, travel, and play within Calgary’s river valleys.
Thank you for your attention to this matter. We will be sure to update you as we receive any new information on this file. If you’d like to get in touch with us, you can reach us at info@crcactiongroup.com.
Regards, CRCAG Board