The Township of Perth East…

The Township of Perth East agrees with the comments forwarded by the Association of Municipalities of Ontario (AMO) on the proposed Asset Management Planning Regulation under the Infrastructure for Jobs and Prosperity Act.

As noted by AMO and supported by Perth East;

1.Municipalities will have to re-start their Asset Management Plans (AMP’s) almost from scratch to comply

•Current AMP’s will not meet the criteria set out in the proposed regulation. The Perth East AMP will have to be adjusted to include specific service levels, operational criteria and climate mitigation information.

2.Municipal governments and staff do not have capacity to comply affordably

•Re-starting AMP’s may mean additional staff, staff training, hiring consultants and additional costs for data management/IT systems. Asset Management software that is user friendly yet meets all regulation requirements is difficult to find.

•Provincial templates and webinars are helpful but will not offset the need for additional skilled staff to manage AMP’s going forward.

•Approval by a licensed engineer before presentation to council adds unnecessary costs. Perth East does not have an engineer on staff and doubts that one external engineer will sign off on every part of the plan as it may be beyond their expertise.

•Service level analysis and lifecycle costing models for every asset owned will greatly expand the criteria & required expertise to meet them – again adding costs

•Level of Service and Level of Service Performance Indicators should be standardized by the Province by municipality size and type.

•Direct financial support is a must to re-do AMP’s.

3.Compliance and reporting will be a new burden

•Compliance to all AMP and Strategic Asset Management Plan criteria and reporting will be a struggle for small municipalities such as Perth East.

4.Regulation timelines are aggressive

•Small municipalities such as Perth East do not have the resources to meet the proposed timelines, that being; the adoption of a strategic management policy by January 1, 2019, completion of AMP Phase I to address core infrastructure by January 1, 2020, completion of AMP Phase II expanding on Phase I by including all infrastructure assets by January 1, 2021 and completion of AMP Phase II requiring further details for all infrastructure assets by January 1, 2022.

5.Regulation expands asset management planning beyond core competence.

•Expanding AMP’s to energy, non-infrastructure and climate mitigation costs takes the focused management of physical assets into an additional function that may unnecessarily duplicate Official and Strategic Plans, energy regulation requirements & other municipal government initiatives.

•The financing plan requirement will duplicate the municipal budget process and forecast needs

[Original Comment ID: 210151]