RE: EBR Registry Number: 013…

RE: EBR Registry Number: 013-0551: Proposed Municipal Asset Management Planning Regulation

The Clean Air Partnership would like to commend the province’s leadership in advancing municipal requirements and capacity related to improving asset management knowledge and decision-making. In particular, we would like to provide our strong support for green infrastructure and climate change mitigation and adaptation considerations being brought into asset management plans as well as asset decision making. Incorporating these considerations into asset decision making is a critical step to support sustainable, resilient and cost effective infrastructure spending in Ontario municipalities as well as to achieve the province’s (as well as numerous Ontario municipalities’) greenhouse gas reduction targets.

The Clean Air Partnership serves as the secretariat for the Clean Air Council, which is a network of 29 municipalities in the Greater Toronto, Hamilton and southwest Ontario region working collaboratively on clean air and climate change actions. Feedback provided here is based on feedback provided by Clean Air Council member municipalities but a formal consultation on this EBR posting was unable to be undertaken due to time constraints. Clean Air Partnership would be pleased to facilitate the bringing together of Clean Air Council members and Ministry of Economic Development, Employment and Infrastructure staff to provide clarity on any of the below recommendations and/or additional feedback on improving the ability of municipalities to incorporate green infrastructure and climate change into Asset Management Plans and asset decision making.

Green Infrastructure Asset Management Recommendations

1.Provide a definition for green infrastructure into the regulation to provide greater clarity on what should be considered a green infrastructure asset. Clean Air Partnership recommends that the Province use the definition of green infrastructure used in the Provincial Policy Statement.

•“Green infrastructure” means natural and human made elements that provide ecological and hydrological functions and processes. Green infrastructure can include components such as natural heritage features and systems, parklands, stormwater management systems, street trees, urban forests, natural channels, permeable surfaces, and green roofs.”

2.Revise the definition of infrastructure assets to ensure that there are not required to be tangible capital assets. In order to remove barriers to including green infrastructure into asset management plans it is important that infrastructure assets are not considered to be limited to only tangible capital assets. The draft definition of infrastructure assets could be interpreted to be applicable only to TCAs. Assets do not need to be limited to TCAs to benefit from the inclusion in asset management planning and as such we would like to advance the Green Infrastructure Ontario Coalition’s suggested definition for infrastructure assets:

•“Infrastructure Assets” are built and natural assets that are directly owned by a municipality or consolidated on the financial statements of a municipality, including tangible capital assets, and may include green infrastructure, but do not include assets that are managed by a joint municipal water board.

3.Set a timeframe for requiring green infrastructure’s integration into asset management plans. In order to ensure progress towards the goal of integrating green infrastructure into asset management planning it is important to set a timeline for its inclusion. Clean Air Partnership recommends setting a five-year phase in period target. This would provide the time for municipalities to gain the required competency related to asset management planning as well as increase their capacity on green infrastructure. In addition, this will also provide the timeline for the development of guidance documents, training as well as accounting and regulatory elements needed to integrate green infrastructure into assets management plans and decision making across Ontario municipalities.

4.Increase the ability and capacity of Ontario municipalities to document and valuate the value of their green infrastructure assets. In order to ensure that advancements associated with bringing green infrastructure into asset management plans are achieved it will be required that Ontario municipalities track, document and valuate their green infrastructure assets. Their ability to do this will be dependent on the guidance and support provided to them via the Province as well as from green infrastructure partner and advocate organizations. We have attached a draft Green Infrastructure Road Map (Appendix A) that provides priority steps and actions. This Green Infrastructure Road Map was developed by Green Infrastructure Ontario and Clean Air Partnership based on consultations that took place with Conservation Authorities, Ontario municipalities and asset management and green infrastructure organizations. We would be pleased to meet with Ministry of Economic Development, Employment and Infrastructure staff to provide more information on the Green Infrastructure Road Map and the consultations that led to its development.

Climate Change Asset Management Recommendations Clean Air Partnership supports the inclusion of a Lifecycle Management Strategy into the asset management regulation. The inclusion of lifecycle considerations will ensure that over the lifetime of the asset, capital costs savings will not be undermined by higher operation costs due to higher operational and energy costs. This direction however can be strengthened through the advancement of the recommendation below in order to not only factor in operating and energy costs into asset decision making but to factor in climate change mitigation and adaptation opportunities into asset management decision making. This will greatly advance the ability of Ontario municipalities to integrate sustainability considerations into asset management plans and decisions. Recommendation # 1: Support the efforts of Ontario municipalities to integrate a mitigation and adaptation lens into asset decision making and renewal considerations; including technical support and guidance for municipalities for how to incorporate climate change mitigation and adaptation considerations and opportunities into asset management plans. In order to achieve this goal, the below will likely be required:

•Data and guidance on quantification of greenhouse gas implication into considerations of asset creation and renewal decisions will need to be provided and be based on consistent quantification methodologies. The Ministry of Economic Development, Employment and Infrastructure should work with the Ministry of Environment and Climate Change, Ministry of Municipal Affairs and Ontario municipalities to develop the necessary guidance and methodology to enable municipalities to incorporate lifecycle greenhouse gas emissions into asset management decision making.

•In order to advance climate change adaptation considerations into asset management decisions and plans future climate projections and impacts will be necessary, but provision of data in itself does not ensure it gets factored into decision making therefore increased support and capacity building for data analysis and integration of data into decision making is needed; and

•An accountable and transparent structure for reporting on how climate change considerations have been integrated into asset management plans and infrastructure decision making is necessary.

Thank you for the opportunity to provide this input and please feel free to get in touch with me should you have any questions related to the above or would like to gather more input from Clean Air Council member municipalities on the above recommendations and input. Sincerely, Gabriella Kalapos, Executive Director, Clean Air Partnership and Co-Chair, Clean Air Council

[Original Comment ID: 210332]