Approvals The requirement…

Approvals The requirement for a licensed engineering practitioner to approve the AMP in writing will result in external costs for many small municipalities. It is unclear whether the AMP’s that municipalities have been working on for the past several years will need to be partially or fully re-written in order to be satisfactory for an external third party to sign off. The regulation proposal does not indicate whether this engineering sign off is required on an annual basis, whether it is required with each phase of submission or whether it is only on the 2022 submission along with every 5 year renewal. Clarification is required.

Timeframes The proposed timeframes are too aggressive, specifically related to requirements around levels of service. The development and adoption of levels of service takes time to assess and then several years to measure in order to produce sufficient reporting information. The proposed levels of service are very high level and it is likely that municipalities would want to include more detailed criteria to better indicate the performance of municipal infrastructure. The public consultation process will require extensive effort and it would be an inefficient process to expedite the province’s proposed LOS through public consultation and then repeating the process shortly after to address the LOS metrics that more clearly represent the public’s expectations for meaningful metrics. St. Marys has developed a plan for establishing and presenting LOS through public consultation and the process is estimated to take until at least 2023. The proposed regulation requires lifecycle management strategies at a very detailed level. While we agree that this is important and should be an objective of every municipality’s asset management program, the timeline for having this completed for all assets is too aggressive with the current staffing levels of small municipalities. This aggressive timeline will lead to municipalities needing to make broad assumptions about asset categories rather than taking the appropriate amount of time to gather the necessary information and assess lifecycle variables of the different assets within each category. This will inevitably lead inappropriate assumptions and poor data as a result.

Climate Change Requirements The proposed regulation will require the strategic asset management policy to commit to mitigation approaches to greenhouse gas reduction goals and targets as well as actions related to climate change. This appears to unnecessarily duplicate other municipal policies and provincial regulation. It also unnecessarily expands the focus of the asset management plan beyond the core objective.

Phased Approach It is unclear whether or not municipalities will be required to make a formal submission to fulfill the phased requirements or if there will be another way the Province ensures conformity with the regulation. In order to reduce unnecessary administrative burden of multiple submissions, the Province should allow municipalities to make one submission to fulfill the requirements of multiple phases (if they are in a situation to do so).

Guidance Tools & Support The proposed guidance tools and support will be very helpful. We hope the Province will follow through with that support. With the additional requirements imposed by the proposed regulations, it is likely that consultants will need to be engaged to rewrite the existing asset management plans. The consulting market will be pressured to rewrite many of these plans to meet the proposed deadlines. It would be preferred and more efficient if municipalities could have only one deadline to meet so that consultants only needed to be engaged once to meet the deadline requirements of the regulation. The regulation should be supported by a funding program to assist municipalities to re-engage consultants to re-write their plans to meet the requirements of the legislation.

[Original Comment ID: 210231]