The majority of the Port Lands north of the Ship Channel are subject to flood risk. In 1994, the City implemented the Lower Don Special Policy Area (SPA) in the former City of Toronto Official Plan. A large portion of the flood prone lands are included within the Special Policy Area boundary. However, lands in the western portion of the Port Lands, including the subject property, were not included within the SPA boundary. Prior to City Council adopting OPA 388, a one-zone concept under the PPS applied. OPA 388, which included the subject property, introduced a Two Zone Concept for floodplain management, as well as site and environmental planning policies. The Two-Zone Concept proposes a 'Floodway' and 'Flood Fringe', highlighting areas both not capable (floodway) and potentially capable (flood fringe) of accommodating development. Policy D_26 was also introduced and identifies that development will not be permitted until specific criteria, such as the completion of flood protection works, are fulfilled.