Municipal staff appreciate…

Municipal staff appreciate the need to provide an asset management framework that is consistent across the province, provides for best practices and links to various strategic municipal planning documents. While there are many benefits that can be derived from the proposed legislation, the challenges in meeting future legislative requirements will prove to be a considerable burden on small rural municipalities without additional supports from the Province. These comments reflect feedback from both the County of Huron along with its respective lower tier municipalities. The comments are as follows: -This will add a considerable financial burden to municipalities with new or enhanced software solutions to support the broad range of requirements in the legislation. This software will increase annual operating budgets with the yearly support costs that come along with software programs.

-In addition to the additional software costs, small municipalities lack the staff resources and asset management planning expertise to be able to support all the requirements of the proposed legislation. Many small municipalities do not have an engineer on staff and having the requirement that an engineer approve the plan will prove to be a significant financial burden. Also, municipalities will be required to hire additional staff to support the legislative requirements which will drive up the tax rates, and divert funds away from the actual infrastructure needs further accelerating the infrastructure deficits. While some of the current infrastructure funding that is available for asset management capacity building, it takes away scarce funding that could be used to fund infrastructure.

-As municipalities are forced to hire additional staff, we will end up competing for a limited labour pool with the required asset management expertise, again driving up overall costs. -Small rural municipalities cannot sustain the levels of taxes required to address both the looming infrastructure deficits and the additional financial overhead that is required with the proposed legislation, without additional support from the province.

-These requirements further increase the information reporting burden that is being placed on municipalities and this reporting burden is increasing each and every year, providing resource challenges where municipal staff are focused on reporting to various provincial ministries versus actually delivering the services required by their residents.

-There should be some flexibility around the requirements of the licensed engineer, particularly when there are none on staff. There should be some consideration that it be endorsed by the various other directors who are responsible the various types of assets in the plan, such as IT systems, recreation etc. Also, with the financial requirements of the plan, there should be some consideration that the municipal Treasurer is also a signatory of the plan.

-Under the Inventory Analysis proposal, it is suggested that ‘average remaining life’ is a better measure for each asset class type as ‘average age’ does not consider the impact of betterments.

-With the lifecycle management strategy, it would be useful that the regulation defines the expected time frame to which financial planning and forecasting be done (i.e. 30 years), or at least define a minimum time frame (i.e. 10 years).

-There are many requirements of the proposed plan that are currently not being met by municipalities, and will require a significant undertaking to meet the planning, engineering and financial requirements. As such, it would be beneficial that a longer phase in period be established to better allow for municipalities to properly develop their plans.

-Under the financial strategy, the provision speaks to estimating capital expenditure forecasts, however, it expands upon that to include both significant operating and energy costs. It would be beneficial to clearly define what is an operating vs a capital expenditure for the purposes of the regulation. Is it the expectation of this provision to also align operating and energy costs with the proposed levels of service in the asset management plan?

-The regulation also requires a policy that mandates a public input mechanism process for asset management planning. Are there specific expectations that are required or are municipalities able to define what the public input will entail and build within the policy?

[Original Comment ID: 210006]