Re: Proposed Municipal Asset…

Re: Proposed Municipal Asset Management Planning Regulation

The Ontario Association of Landscape Architects (OALA) is a not-for-profit professional association established in 1968 to regulate its membership of landscape architects in Ontario. Our scope of work includes landscape based public and private spaces that include designing public living and non-living green infrastructure.

The OALA strongly supports the province’s leadership in integrating living and non-living green infrastructure into its new regulation for municipal asset management planning. Including living and non-living green infrastructure and landscape based components in the definition of “infrastructure assets” is a critical strategy for lifecycle cost management. Further, these are important steps to supporting sustainable and cost effective future infrastructure spending in Ontario.

Green infrastructure also helps align the new regulation with the growing number of provincial plans and policies that recognize landscape based components as an important tool for communities in Ontario. In particular, alignment with the direction in the new regulation for municipalities to develop strategic asset management policies that include: “a process to ensure that asset management planning is aligned with Ontario’s lands-use planning framework, including any relevant policy statements issued under section 3(1) of the Planning Act; provincial plans as defined in the Planning Act; and, municipal official plans.” This connects directly to living and non-living green infrastructure in two ways:

1)The Provincial Policy statement (2014) under the Planning Act includes direct reference to the promotion of green infrastructure as a complement to infrastructure (Section 1.6.2). 2)The Growth Plan for the Greater Golden Horseshoe (2017) includes support for green infrastructure in several sections related to complete communities, storm water management, and climate change.

Additionally Ontario’s 10-year Infrastructure Plan, includes green infrastructure and landscape based components as a practice that can reduce the need for costly, large-scale infrastructure, is specifically cited as a way to reduce the burden on built systems, and integrating it into the regulation directly supports the direction outlined in the 10-year Plan. Landscape architects can play an important role to help address a wide range of Green solutions.

Municipalities need to plan and manage new and existing living and non-living green infrastructure and they should be encouraged to use the same framework as they use for grey infrastructure assets. In addition to offering our high level support of the province’s efforts to integrate living and non-living green infrastructure and landscape based low impact designs (LID) we offer the following suggestions which we hope the Ministry will consider.

1) Define “green infrastructure”: To ensure clarity around the definition of green infrastructure and alignment to policy statements under section 3(1) of the Planning Act, we recommend including a direct reference to or inclusion of the Provincial Policy Statement (2014) definition of green infrastructure:

“Green infrastructure: means natural and human made elements that provide ecological and hydrological functions and processes. Green infrastructure can include components such as natural heritage features and systems, parklands, stormwater management systems, street trees, urban forests, natural channels, permeable surfaces, and green roofs.”

2) Revise the definition of “infrastructure assets” to ensure green infrastructure assets are not required to be tangible capital assets: We suggest broadening the definition of “infrastructure assets” beyond tangible capital assets (TCAs) to avoid a potential contradiction between the regulation and Public Sector Accounting Board guidance. The draft definition of “infrastructure assets” in the proposed regulation could be interpreted to only include TCAs. The term TCA does not include green infrastructure assets, according to the current guidance from the Public Sector Accounting Board. Not all infrastructure assets owned by a municipality are TCAs, and assets do not need to be TCAs to benefit from inclusion in asset management planning. We propose an alternate definition below for your consideration:

“Infrastructure Assets” are built and natural assets that are directly owned by a municipality or consolidated on the financial statements of a municipality, including tangible capital assets and may include living green infrastructure, but do not include assets that are managed by a joint municipal water board.

3) Set a time frame to require green infrastructure’s integration to asset management plans: Require green infrastructure be integrated into asset management plans following a five year phase in period. This would provide time to develop guidance documents and establish the various training, accounting and regulatory elements needed to implement green infrastructure asset management across the province.

4) Further, we suggest that the definition of green infrastructure include living and non-living landscape components as listed in the Provincial Policy Statement, and that LID be recognized as a way to achieving built green infrastructure. Living landscape components will naturally evolve over time with little management intervention.

The OALA welcomes any dialogue or discussion with the Ministry on this important addition to the new Municipal Asset Management Planning Regulation. Landscape architects are well positioned to address the wide range of issues and challenges facing society. Our knowledge in science and technologies that utilize natural living systems to mitigate climate change and support sustainability are highly valued. The OALA is also a member of the Steering Committee for the Green Infrastructure Ontario Coalition.

Thank you for your consideration of our support for the above addition to the Municipal Asset Management Planning Regulation.

Sincerely, ONTARIO ASSOCIATION OF LANDSCAPE ARCHITECTS

Doris Chee OALA, CSLA OALA President

[Original Comment ID: 210289]