While we strongly support…

While we strongly support the concept of asset management planning, we like the vast majority of small municipalities have struggled and continue to struggle with asset management planning. Only five years ago you released the Building Together: Guide for Municipal Asset Management Plans, for which to fulfil would require a colossal effort. It has been a little more than two years since we completed our first asset management plan following your Guide and understandably we are still working on implementing and improving it. To issue a host of new requirements through your proposed asset management planning regulation at this time is nonsensical. The proposed regulation is too prescriptive, unaffordable and too difficult for municipalities, particularly those like us with less than 10,000 residents, to comply with in the prescribed timeframe.

There are many detailed facets of the proposed regulation such as current levels of service, inventory analysis, cost estimates to sustain current levels of service, lifecycle strategy and financial strategy. The resources needed to achieve the requirements are mind boggling. Municipalities will need extra staff and additional engineering services to comply with the proposed regulation, which means a greater burden on the municipal taxpayer.

Securing staff resources to deal with the requirements will encounter two major problems. The first is making room in the budget. The second is trying to find employees with the knowledge and skills required to perform the tasks. For example, only highly qualified persons are capable of developing and/or using a cost estimation system to provide estimates for all types of capital expenditures for ten years with the flexibility to generate numbers for different scenarios. Not only finding these people is hard, but meeting their compensation expectations is difficult.

Having a few webinars and templates to help municipal staff will not address the skill and knowledge deficiency to allow municipal staff to successfully tackle the work. If you fully recognize the complicated nature of the proposed regulation’s requirements, you will understand that people working in small municipalities, unless they are professional accountants or engineers or self-taught experts, are not going to be successful.

Getting consultants to do the work will encounter the same two major problems. First, it is challenging to find the money for pricey engineering and financial consultants, and secondly it is not easy to obtain the services of good consultants. There is a shortage of consultants and a rise in demand will increase rates.

The proposed regulation will exacerbate cost and availability problems with consultants by increasing the need for them. You expect asset condition assessments using “industry-accepted engineering practices.” The proposed levels of services tables note the pavement condition index (PCI) and bridge condition index (BCI). We all know how costly the studies can be. The proposed regulation also includes other municipal assets, including buildings. Buildings are complex assets entailing many components like roofs, doors and windows, foundations, exterior walls, electrical systems, etc. Condition assessments on all of the components done in accordance with “industry-accepted engineering practices” will create a huge workload for consultants to perform and a huge bill for municipalities to absorb.

We have many concerns with the proposed regulation requirement to have a “licensed engineering practitioner” approve an asset management plan prior to ratification by council. A plan done in accordance with all of the provisions of the regulation will involve a myriad of methodologies, analyses, assumptions, uncertainties and data. What does approving the plan in writing by an engineer mean? Putting an engineer’s stamp on the document? It is conceivable engineers, unless they are engineers employed by the municipality, won’t “approve” a plan they had not done or had the authority to control it. Your wording could mean that municipalities might have to engage an outside engineer to be in charge of asset management planning rather than their own employees. Furthermore an asset management plan does not have the precision and verifiability like a set of construction documents. Engineers can sign off on construction documents; we do not understand the concept of engineers “approving in writing” municipal asset management plans. You need to revisit this issue.

Finally we want to address the financial impact the proposed regulation will have on municipalities, particularly the small ones. A few years ago you provided financial assistance to small municipalities in order to develop asset management plans. If the current regulation is going ahead, there is no doubt that you should be providing financial assistance to allow small municipalities to comply with this regulation. It is common knowledge that municipalities own 60% of the nation’s infrastructure, but receive only 8% of the tax revenue collected in the nation. Having sound asset management planning at the municipal level to get the most value out of taxpayer dollars makes perfect sense, but the municipalities, again, the small ones in particular, need your financial support to do it. A financial support component should be built into the current proposed regulation, or a financial support mechanism should be introduced concurrently with the current proposed regulation.

[Original Comment ID: 210295]