Joshua McCann…

Joshua McCann
Senior Policy Analyst
Ministry of Infrastructure
Municipal Infrastructure Policy
Unit 900 Bay Street
Floor 5, Mowat Block
Toronto, Ontario
M7A 1C2

Dear Mr. McCann:

We are writing today to provide feedback on the proposed municipal asset management planning regulation under the Infrastructure for Jobs and Prosperity Act, 2015, to regulate the form and content of municipal asset management plans.

Please find the following comments for consideration: 1.A more thorough and better guidance to municipalities on asset management can achieve greater capacity while respecting municipal diversity. Municipalities have already achieved a significant expansion in asset management with guidance and capacity support. Asset management is more a continuous cycle of planning. Tying asset management to funding application requirements has helped move the practice forward but at the same time, unsuccessful grant applications detract from the use of asset management planning. Taking a guidance, supportive approach is a course of action that at this time will be seen to be more helpful than regulatory approach for 444 municipal governments. 2.Any direction, guidelines or a regulation, taken by the Province needs to be consistent with the federal gas tax reporting requirements. Otherwise, municipalities will be doing more work than needed if not aligned. 3.Regulating asset management for the sake of standardization could stretch municipal staff capacity further without a direct municipal benefit. 4.Increasing regulatory burden on municipal governments is a major drain on municipal staff time and council activity. By regulating municipal asset management plans and

requiring these plans to be integrated with all the other municipalities currently do, increases red tape, requires staff time and means councils will need to spend time on ensuring provincial requirements are met, rather than finding solutions to local problems.

The Township of Carlow/Mayo appreciates the opportunity to provide input on the proposed regulation. Consideration of our comments would be appreciated.

Yours truly,

Arlene Cox
Clerk-Administrator

[Original Comment ID: 210148]