Oshawa Comments from the…

Oshawa Comments from the AMSC regarding proposed regulations

1. Green Infrastructure

The proposed regulation provides a definition of Infrastructure Assets and indicates that the municipality may include “green infrastructure”. The regulation does not further define 'green infrastructure'. Green infrastructure could be interpreted very differently depending on the reader. It could mean man-made infrastructure that has been designed, or made, to be "green", such as green roofs, bio swales or permeable paving in parking lots, or it could also be interpreted by some to mean natural assets, such as urban forests, natural heritage systems, valleylands/wetlands, landforms etc. Is it possible to determine a replacement value or put a price tag on a city-owned mature woodlot, for instance, beyond just land value? Perhaps further clarification from the Province is necessary to better inform our scope of work.

2. Municipal Approval

The proposed regulation states “The asset management plan would be required to be approved in writing by a licensed engineer practitioner representing the municipality, and the executive lead of the municipality prior to being presented to the municipal Council for approval.” Suggest changing the wording to “…required to be approved by a professional or professionals sufficiently qualified to approve all or some of the assets listed within the AMP, and the executive lead...”

3. Evaluation of the Plan by Province

The proposed regulations purpose is for consistency and standardization but does not provide metrics, data structures, etc. Without a prescribed performance metric for LOS could/would create a situation where municipalities invest in one developing metric and potentially province could dictate metrics in the future causing municipalities to start over again in data and analysis.

Also, there is no indication of the criteria for the evaluation of Asset Management Plans. Is there a pass or fail rating applied to plans, what are the implications? What is the implementation timeframe?

4. Timing

It would be beneficial to stagger the requirements of Phase III. Phase I requires reporting on “core assets” and then Phase II expands by including all remaining assets, this staggers the addition to the workloads of municipalities. Phase III’s “further details on assets” requirements should be phased-in in the same fashion, core assets one year and all remaining the following year.

Additionally, the timeline of 2019 may not be reasonable to actually develop actions associated with addressing risks and vulnerabilities caused by climate change and determining anticipated costs/adaptation opportunities specific to Oshawa's infrastructure and operations. An understanding of what "commitment to consider" means is required. We recommend that where a municipality has an Adaptation Plan that that be considered as meeting the requirements of "considering" risks and vulnerabilities.

[Original Comment ID: 210278]