The Council of the United…

The Council of the United Counties of Leeds and Grenville, at its recent Committee of the Whole meeting held July 4, 2017, reviewed the proposal for a regulation which would require municipalities to adopt asset management plans, as well as the content and other requirements. The Counties supports asset management planning and its benefits. However, it has some concerns about the proposal as posted. They are:

1. the time allotted for comments should be extended in order for all municipalities to fully analyze and assess the impact of such a regulation. There is insufficient time, especially with commencement of summer and vacation times, for a fully analysis and assessment, especially since many Councils only meet monthly.

2 for many municipalities, especially small municipalities, this new regulation shall require them to engage consultants to prepare the policy and plan, including the 5-year updates. Furthermore, annual report shall require staff resources. This is not revenue neutral and thus the province should provide funding for such work, and not competitive allocation, but rather an allocation method that could be reconciled based on actual costs to the municipality In essence, any regulation should not increase the costs for municipalities without offsetting provincial funds.

3. It is well documented that there is a real infrastructure deficit due to the lack of past investments, as well as an ongoing deficit between what municipality spend on infrastructure/assets and should be spending. This proposal would require municipality to develop financial plans to address this deficit or 'gap'. Municipalities cannot address this gap alone

- they require senior levels of government assistance. Asking municipalities to increase their debt loads or taxes is not fiscally sound for the future of municipal government in Ontario.

4. The new rules shall require municipalities to forecast and predict future growth, operational risks, energy costs, and the impact of climate change. The plans shall also require contingency plans to address such phenomena/impacts. Once again, this shall require additional resources for municipalities, not only to address in the plan and its updates, but also monitor.

5. The plans require approval by a 'licensed engineering practitioner' and an 'executive' lead. There is no definition for either, as well as what will they be approving and against what criteria. What would the risk be to these two individuals. Also, they must approve the plan prior to Council's consideration

- what is the purpose of Council approving it?

The concept of standardizing municipal asset management processes and plans is positive, however there are additional costs for municipalities, cost which need provincial funding. It is also commendable that the proposed regulation includes all assets/infrastructure, not only core.

[Original Comment ID: 210090]