Comment
Timeline
The timeline to incorporate additional assets into the current asset management plan layout was determined to be achievable by most departments surveyed. Concern was expressed by two departments that the time commitments required for the entry into the tangible capital asset registry were either unclear or not achievable with current staffing levels resources and funding.
The requirement to report on and estimate operating costs will be difficult in the short term timeline proposed by the regulation. The City is currently in the process of acquiring and implementing a work order management system but is not expected to have a full year’s worth of data to draw on for all core assets until 2021.
City staff would prefer an increase to the number of phases, with fewer requirements for each phase. In particular breaking out the inventory, level of service and operating cost sections to separate years for both the core assets and the additional assets, as well as dividing the input of the additional assets over multiple years. While the core asset deadlines are felt to be achievable for inventories and level of service; the number of new departments which would need to be included by Jan 1, 2021 is unlikely to be achieved at current staffing levels. The City is in the process of finalizing the 2017 AMP which brought in the assets of one additional department and the process took over 12 months at current staffing levels.
Implementation
City Staff expressed uncertainty about the requirements for their individual departments assets in particular with regards to levels of service and operating expenses. Templates and examples were requested for estimating the operating expenses and determining the levels of service.
The P.Eng. sign off requirement is a concern as departments have diverse operational models, and many different asset classes. It is unclear what the engineer is actually approving (e.g. are they taking responsibility for all condition assessments and recommendations included in the AMP). A single engineer is unlikely to have the expertise to certify that all estimated service lives, conditions and levels of service meet or exceed industry standard. The regulation needs to further clarify the role of the engineer in this process, what they are actually certifying (e.g. all estimates carried out in a manner consistent with some stated parameters) and what the extents are of their liability will be. Potentially the province will also need to provide a list of standard estimated service lives (or a list of standard sources) and levels of service, which can be used for each asset type in the absence of the City having historical data to support their estimates.
Financial Impact
Many departments indicated that they expect to require additional staff and additional funding in order to meet the proposed regulation requirements. As well some departments identified the need for software applications in order to track and report on the data requested by the regulation.
Staff Impact
City has identified that there will be an increased administrative burden and related costs to the initial addition of assets belonging to non-core departments into the AMP and the long term maintenance of those inventories.
City has identified that corporate training will be required for City staff focused on asset management, operational costing, analysis and projections.
Other potential cost impacts include the potential hiring and training of new hires to meet the current deadlines and the ongoing reporting and maintenance requirements of the regulation. New hires are expected to be required by some departments due to current demands on existing staff exhausting capacity to take on new commitments
Recommendations
The City recommends the development of templates and other decision making support documents which municipalities can reference to complete their AMPs. In particular these tools should support LOS and KPI setting. Implementation phases should be increased to prolong the implementation period for assets beyond the core assets and allow the gathering of operating data.
Conclusion
The City of Brantford is supportive of the proposed municipal asset management planning regulation however the City is concerned that the implementation timeline is not realistic considering the amount of additional new data and assets which will need to be brought into existing AMPs. Further direction and details are required from the province in order for municipalities to estimate the amount of staff and financial resources required to meet the requirements of this regulation. These comments will be presented to Brantford City Council at their meeting on September 12, 2017. Any amendments to these comments directed to staff by City Council will be sent to the MOI as soon as possible.
[Original Comment ID: 210235]
Submitted February 13, 2018 12:10 PM
Comment on
Proposed municipal asset management planning regulation
ERO number
013-0551
Comment ID
2197
Commenting on behalf of
Comment status