Municipality of North Perth…

Municipality of North Perth 330 Wallace Ave N. Listowel ON N4W 1 L3

July 19, 2017

Joshua McCann, Senior Policy Analyst
Ministry of Economic Development, Employment and Infrastructure
Infrastructure Policy Division
Inter-Governmental Policy Branch
Municipal Infrastructure Policy
Unit 900 Bay Street Floor 5, Mowat Block
Toronto, Ontario
M7A 1C2

Dear Mr. McCann:

RE: Comments on Asset Management Planning Regulation Under the Infrastructure for Jobs and Prosperity Act

The Municipality of North Perth agrees with the comments forwarded by the Association of Municipalities of Ontario (AMO) on the proposed Asset Management Planning Regulation under Bill 6, the Infrastructure for Jobs and Prosperity Act.

Similar to the AMO, North Perth’s comments are as follows:

1.The Province needs to create reliable funding for future asset management planning for municipalities. Funding that would allow municipalities to use the money based on our AMP critical needs. This would shift human resources from applying for funding to actual AMP implementation. This would result in more co-operative efforts between municipalities as it take out the competitive aspect. Funding requirements could be similar to gas tax, with the auditor being responsible for ensuring the agreement is signed and completed.

2.“Level of Service” definitions need to be clarified before moving forward. These levels need to be established to ensure standardization, continuity, and comparability. However, if “Levels of Service” are too detailed, it is our concern that municipalities will become more vulnerable for liability issues. How will municipalities be protected?

3.Asset Management Plans should be completed in one phase in 2022, rather than three separate phases. The Province should require reporting at various milestones to ensure that municipalities are moving forward during the implementation process. This would allow time for municipalities to implement all asset categories concurrently, reviewing service levels and engaging the public for the whole AMP rather than in phases.

4.Clarification is required in regards to engineering signoff. For small municipalities, engineers are not on staff; therefore, there would be a cost to have a third party engineer signoff on the Asset Management Plan. Municipalities are investing their time and efforts to make their AMP as accurate as possible; a third party does not need to be involved to prove that. We suggest that the signoff is with the Department Heads responsible for the assets within the plan, as well as the Finance Office.

5.A comprehensive software application is required. To date, we have not seen a complete, integrated software application that works with or into an asset management plan. Perhaps this should be commissioned by the Province to be developed so that municipalities are not struggling with various applications and municipalities have a similar final result.

6.This is a huge financial obligation for small municipalities. Since other funding sources have been reduced, it will be a struggle to fund requirements of Bill 6. Will there be additional funding sources for this other than the FCM Grant?

Thank you for the opportunity to comment on the proposed Bill 6 with regard to the Asset Management Planning Regulation.

Yours truly,

Becky Belfour, C.M.O.
Tax Collector/Deputy Treasurer
Municipality of North Perth

[Original Comment ID: 210248]