After thorough review of the…

After thorough review of the proposed regulation, it is my belief that the proposed municipal asset management planning regulation:

1. Is overly prescriptive;

2. Does not reflect the principle that municipalities are responsible, mature governments;

3. Incrementally increases engineering costs for municipalities at a time when the demand for engineering firms and expertise may exceed the availability;

4. Will create a resource and fiscal strain on our municipality and others that have limited staffing capacity, being the most vulnerable and sensitive to an increasingly burdensome regulatory environment.

5. There has not been adequate support or funding to accomplish what would be required to be compliant with the regulation;

6. The Town of Grimsby is under additional strain, as the Town falls in the ‘over 25,000’ population category, and must fulfill further requirements, without the funding or staff resources of a larger municipality.

7. Under the regulation, Council should be held accountable. Ideally, Council should be required to develop and adopt a long-term council community plan that comprises integrated short, medium, and long range plans to achieve the municipality’s vision for the future, and should include a financial and infrastructure strategy for a period of at least 30 consecutive financial years.

8. The requirements, as described, are too prescriptive and go beyond the scope of a policy document. They would be better served in an Asset Management Guideline, Asset Management Procedure or Strategic Asset Management Plan as defined by the ISO 55000 Suite. The regulation is intended for municipalities to follow best practices, but the Regulation is not aligned with ISO 55000. The Town has already created a policy for Asset Management and intended to do a strategic plan separately. It is unclear if this will be acceptable under the regulation, and would be time consuming and costly to reproduce.

9. It in unclear what energy usage and costs refer to and how this is to be measured.

10. Condition assessments using engineering principals, while should be the goal, could be very costly and still allows for a wide variance of opinion on how best to determine condition.

[Original Comment ID: 210292]