We are submitting 26…

We are submitting 26 comments for consideration:

1

- There should be a category for medium sized municipalities with populations over 25,000 but less than 100,000. Or instead of adding a medium sized category, perhaps the size of the small municipality category could be revised to a maximum population of 80,000 instead of 25,000. It doesn’t seem reasonable to put all municipalities with populations over 25,000 into the same category. For example a municipality with a population of only 40,000 will have significantly less staff and less resources to enable them to meet the requirements of this regulation as compared to a municipality with a population of 400,000 which will have significantly more resources.

2

- It would be beneficial if a template and examples of a typical asset management policy could be provided so that we have a better understanding of the level of detail that is expected for the policy. It would be good to know approximately how long the policy should be (i.e. 4 pages, or more like 40 pages). It would be helpful to provide an outline of the expected format with typical headings for the various sections that are required. This will help create uniformity between municipalities.

3

- The period for comments to be submitted on the EBR posting should be extended three months from July 24th to Oct 24th. There are fewer council meetings over the summer, many people are away on summer vacation, and staff are very busy over the summer construction season, all of which have made it difficult to get comments from all the interested parties by the July 24th deadline.

4

- The time period for meeting these requirements should be extended to seven years so that municipalities can now begin allocating budget to meet these requirements in our 10 year capital forecasts.

5

- The timing required to have a strategic asset management policies (by January 1, 2019) conflicts with the upcoming municipal elections. In a lame duck Council situation, these policies would need to be approved by summer 2018, which would be difficult to achieve under these circumstances.

6

- With respect to the deadlines within the draft regulation, please confirm that Council approval is required by the deadline in each case.

7

- Consider the need for mandatory asset management training for Council members, similar to some water legislation training requirements. Councils across the Province need to understand the importance of asset management and the need to tie to annual budgets.

8

- Additional training and funding should be provided to municipalities to help us to be able to comply with this regulation. We will likely need to either hire additional staff or hire consultants to be able to meet the requirements of this legislation. These costs have not been allowed for in our budgets.

9

- A significant concern exists in getting a licensed engineering practitioner to sign off on the asset management plan. This could prove to be a costly and difficult task.

10

- The use of mandatory levels of service measures/metrics for all municipalities, assumes that all municipalities look at and measure levels of service in a similar manner. Also, even having mandatory metrics does not guarantee that all municipalities will measure these measures consistently, which makes comparisons across municipalities very difficult.

11

- It would be helpful to provide templates, guidelines and standard example measures/metrics of how levels of service should be calculated in order to create consistency between municipalities. Especially if provincial funding allocation is partly based on municipalities achieving a required level of service, in which case it will be particularly important for the municipalities to calculate levels of service using the same approach in order to be fair.

12

- The Proposed Levels of Service Table provided needs to be more comprehensive. It only notes the levels of service for the core assets, but it would need to be expanded to cover the levels of service for all assets as required in Phases II and III.

13

- There appear to be inconsistencies in the references to the "Proposed Levels of Service" Tables. Will these tables continue to only apply to core infrastructure, or will the Province include tables for other assets in the final regulation? Also, are municipalities required to provide the same level of detail on performance measures used at the municipality's discretion?

14

- The performance measures need to be better defined with standard measures/metrics and calculations so that there will be consistency in the approach between municipalities.

15

- A detailed guideline should be provided to accompany this regulation as a more thorough and comprehensive guide to expand on the Province’s 2012 Building Together: Guide for Municipal Asset Management Plans.

16

- It would be helpful if a comprehensive list of all the items that should be considered within the “all asset” category could be provided. This would help to better define this requirement.

17

- What are the definitions of each of the specific core asset categories? For example, does "roads" mean just the road, assets within the right-of-way (including sidewalks, streetlights, etc.), or even assets that support roads such as facilities, vehicles and equipment?

18

- The strategic asset management policy is missing 2 key items that were included in the 2012 Building Together Guide. The need for a Data Verification Policy and Condition Assessment Policy. These two policies assist in maintaining the accuracy and completeness of a municipality's asset register.

19

- Requiring a commitment to have opportunities for public input can be a complicated and difficult task for some municipalities. Can this public input be indirectly, such as through the budget process or a master planning process?

20

- Please define what condition assessment practices are "industry accepted engineering practices" as there appears to be differing opinions on this.

21

- The draft regulation uses the term "significant operating costs" within the lifecycle definition. Please confirm if significant operating costs such as salaries/wages and recreation programing costs are included in this definition? Moving beyond asset specific operating costs (such as maintenance and utilities) makes this component of the asset management plan more of a fiscal impact study, which adds significant complexity.

22

- There seems to be inconsistencies with this draft regulation and the Development Charges (DC) Act with respect to growth. This draft regulation requires a growth assessment for municipalities exceeding 25,000 population where the DC Act requires this assessment for all municipalities with a DC bylaw. Please confirm if this means the Province will be removing the asset management requirements from the DC Act?

23

- There are inconsistencies in the requirements of completing risk assessments within the draft regulation. The lifecycle management strategy section asks all municipalities to set a strategy that takes into account levels of service and managing risk, however the risk assessment section is only applicable to municipalities over 25,000 population. Please clarify.

24

- Is the lifecycle management strategy to be completed in current dollars or inflated dollars?

25

- The annual update required to Council does not stipulate if a written report is required, or if it can be combined with the budget process.

26

- Table 1 of the draft regulation (Actuals Reporting) suggests that technical levels of service are to be measured and recorded each year. The mandatory technical levels of service included by the Province include pavement condition indexes (PCI) and bridge condition indexes (BCI). Does this mean that municipalities have to be able to assess PCI and BCI on all applicable assets annually? This would be extremely costly and resource intensive. Municipalities currently only have to assess BCI every 2 years, and PCI is usually calculated much less frequently (i.e. every 5 years). Would this extend out to facilities in calculating facility condition assessments?

[Original Comment ID: 210177]