Tay Valley Township is a…

Tay Valley Township is a small, rural municipality that supports the position and comments that have been previously provided by ROMA and MFOA which explain the burden this proposed legislation will have on small municipalities like our own. The proposed Asset Management Planning Regulation is overly burdensome and prescriptive. More specifically, we also have the same concerns as ROMA and MFOA in the following areas and share these excerpts as our response to you as well: Capacity Many small, rural and Northern rural communities already suffer from a lack of staffing expertise and capacity. Resulting from a combination of the inability to attract professionally trained staff and reliable funding, this lack of capacity will only exacerbate an already untenable situation. While the phasing in of certain requirements of the Regulation may assist implementation in larger communities it only prolongs the difficulty in complying for the smaller communities. Financial Burden Ontario Municipal Partnership Fund is being reduced along with other supporting grants, the additional burden will be fatal to municipal budgets. This burden is ongoing and so one-time funding assistance will not be beneficial in the long run. The proposed Regulation is very prescriptive. In a best case scenario it will require most communities to engage outside professional assistance in order to complete the various requirements such as the five year renewal, progress reporting, service level definitions, risk analysis and the approval of an engineer; this will require additional funds that will need to come from the local ratepayer. In a worst case scenario, all the requirements will need to be satisfied by outside assistance placing an even higher financial burden on those who can least afford the increased costs.

The requirement to obtain sign-off by an engineer. This requirement will be a challenge to fulfill, if it is at all possible. We believe that engineers will be unlikely to risk their license on a document with detailed condition assessments that they did not themselves conduct. Additionally, for municipalities without an engineer on staff who is involved in all aspects of the AMP development, this will likely require an in-depth re-examination of methodology by an engineering firm which would result in high consultant fees. The initial investment of $12 million that coincided with the launch of the Province’s Municipal Infrastructure Strategy in 2012 had the most significant impact in getting municipal asset management in Ontario to where it is today, where approximately 98% of municipalities have asset management plans. While MFOA appreciates that the Ontario Communities Infrastructure Fund (OCIF) can be leveraged for asset management activities, we believe that an additional dedicated investment in asset management activities would go further, as municipalities would no longer need to choose between allocating funds to gather better information about their infrastructure deficit or using those funds to reduce that gap through infrastructure repair and maintenance. Climate Change The Regulation does indicate a strong focus on climate change vulnerability. Some communities may be in a position to comment on this but many have not yet begun to turn their attention to this issue. The focus on climate change will only increase the burden to the small and understaffed municipalities resulting in imperfect and unreliable reporting. Risk Analysis Risk Analysis and Management is a relatively new concept for many communities. It is an unknown commodity for far too many and suffice it to say that the introduction of such analysis places the discussion and comprehension of risk beyond many. The smaller communities in the sector are not yet ready for this concept which only adds to the impending confusion. Training Given the complexity of the Regulation, the municipal sector will require intensive training. The necessary training will be most necessary for the smaller municipalities that lack the capacity and expertise to fully comprehend the new regulatory requirements. Even in a good year, these communities financially struggle to train staff and Council in many of the current governance and administrative necessities; the new Regulation will only increase the struggle. Reporting The Ministry must take into account the findings of the AMCTO report entitled; "Bearing the Burden; A Review of Municipal Reporting to the Province as described above. While municipalities understand the importance of reporting, there is a limit to what those same municipalities can do. Certainly the requirements in the Regulation will not result in data that is either accurate or usable and will only serve to frustrate municipalities.

MFOA and AMCTO both drafted separate reports on the municipal reporting burden over the past six months identifying the need to reduce overlap in collecting information and only collecting information that is necessary. Additionally, when information is collected it should be made clear to municipalities how and when that information is being used.

[Original Comment ID: 210283]