January 27, 2018…

January 27, 2018

Beth Elder
Senior Policy Advisor
Ministry of Economic Development, Employment and Infrastructure
Infrastructure Policy Division
Policy and Planning Branch
900 Bay Street Floor 5, Mowat Block
Toronto ON
M7A 1C2

Statement in Response to Ontario's Long-Term Infrastructure Plan 2017 (EBR 013-1907)

Greetings Ms. Elder,

The Ontario Society of Professional Engineers (OSPE) is the voice of the engineering community in Ontario. We represent the entire engineering community, including professional engineers, engineering graduates and students who work or will work in several of the most strategic sectors of Ontario’s economy.

Ontario is home to more than 85,000 Professional Engineers and 250,000 engineering graduates. That’s one of the largest concentrations of engineering expertise in the world, and the largest concentration of engineering expertise in Canada. OSPE stands as their advocacy body, as the voice of the engineering community in Ontario. OSPE is pleased to offer comments to the Ministry of Infrastructure regarding Ontario’s Long-Term Infrastructure Plan 2017 (LTIP). Ontario’s engineers believe that the LTIP sets forth a vision for Ontario infrastructure planning and investment that is a key step in meeting the objectives detailed in the Infrastructure for Jobs and Prosperity Act, 2015 (IJPA).

At a high-level, OSPE is pleased with Ontario’s 2017 LTIP and commends the Ministry of Economic Development, Employment and Infrastructure for bringing forward a thoughtful and comprehensive plan for the future of infrastructure in our province.

Sincerely,

*** Jonathan Hack, P.Eng. Sandro Perruzza President & Chair Chief Executive Officer

Recommendations & Commentary:

Procurement

Ontario’s intent to expand the Alternative Financing and Procurement (AFP) project model for procurement is encouraging. In partnership with several Ontario universities, OSPE’s Infrastructure Task Force is involved with the Design Optimization Working Group (DOWG) – a group of engineers and contractors with considerable infrastructure construction experience – to study past projects that have either A) had significant cost overruns and/or environmental assessments, or B) been successful in changing inappropriate designs to produce value-engineered solutions.

It is the view of OSPE and DOWG that billions of dollars in public money has been wasted as a result of suboptimal features within the prescriptive design procurement method. Ideally, the use of the AFP model – similar to the concept of ‘Value Engineering’ – should, if well structured, reduce such wastage.

A clear example of the use of value engineering to reduce costs and improve the performance of an inappropriate design is well illustrated in “Prescriptive Specification Design: The Impact on Cost and Constructability – Case History” by Shawna Munn, P.Eng, Allison Bennett, E.I.T. and Nadir Ansari, P.Eng, D.GE, M.ASCE

While OSPE is generally a proponent of the AFP model, it is important that Ontario understands where opportunities for improvement exist within their decided strategy.

Described below, there are major opportunities to enhance Ontario’s AFP model:

First, Ontario must improve the quality and availability of information to enhance the accuracy of bids. Putting full responsibility for performance on the contracting firm may cause bidders to increase prices to cover unexpected circumstances. This often occurs because bidders cannot accurately forecast their costs due to a lack of information or confidence in said information.

The inadequacy of prior geotechnical investigation is a common example of a construction contingency that unnecessarily contributes to bid inflation. Quality geotechnical investigation presents an opportunity where each dollar spent can save ten dollars in the construction process and this should be encouraged by government.

To address this challenge OSPE recommends that the Government of Ontario:

i.Create a framework whereby geotechnical investigation contracts are not necessarily awarded to the lowest bidder; ii.Establish an industry performance record for companies conducting geotechnical investigations iii.Establish an industry working group to determine other opportunities to improve industry access to bid-critical information

Second, it is well understood that construction in cities and large towns is often impeded by the lack of adequate information on existing underground utilities.

To address this challenge OSPE recommends that the Government of Ontario:

i.Empower municipalities to require of all utilities – gas, telephone, water, sewers, communications, etc. – to submit record drawings certified by a professional engineer detailing the actual condition of the completed installation. The important role of Ontario Land Surveyors (OLS) should also be more clearly communicated. ii.Encourage municipalities to set up and maintain digital records based upon those submissions – such as grants of money and audits of the results by the province. iii.Encourage the development of below-grade sensory equipment. Universities in the United Kingdom are undertaking significant sensory research that can likely be emulated and enhanced in Canada.

Lastly, Ontario should recognize that structuring an AFP to provide good results can be complex. There is a learning and development process that each procurement agency must prepare for. The specified outcomes have to be defined clearly and must not be unnecessarily restrictive.

To enhance Ontario’s AFP strategy, OSPE recommends that a preliminary draft of these outcomes should be distributed to interested parties for comment.

Project Prioritization & Funding

Ontario should develop a transparent framework that informs how infrastructure projects will be prioritized, sequenced, and funded, including the mechanisms and models for funding. Ideally, this framework would be jointly developed by all levels of government, industry participants, community organizations, and other interested parties.

This framework would ensure that Ontario does not over-promise and under-deliver on infrastructure projects and improve community, industry, labour market, and government planning to meet the needs of our growing provincial population and economy.

Technology & Innovation

Ontario should strive to be a cutting-edge jurisdiction for the implementation of new technology and be an active supporter of project innovation, including new models for financing. Adaptation: Climate Change and Extreme Weather On Page 25 the LTIP refers to the strain that climate change is having on Ontario’s existing infrastructure:

•“The Government of Ontario recognizes the growing strain climate change is putting on the province’s infrastructure, including on capital and operations and maintenance budgets” And Page 26 notes:

•“The social cost of carbon can help provide a comprehensive estimate of the potential damage from emissions, including changes to agricultural productivity, human health, property damage from increased flood risk, and changes in energy system costs.” While Page 28 notes:

•“Infrastructure investments require the application of a “risk lens” to protect their future. Infrastructure planning, design and construction require an understanding of future climatic conditions, vulnerabilities and potential risks to ensure that infrastructure, and infrastructure budgets, will not be compromised by climate change impacts.” And Page 29 notes:

•“Extreme weather events are becoming more frequent and more severe because of climate change. Building adaptable and resilient infrastructure can help communities weather these storms. For example, heavy rains can cause flooding if appropriate adaptation measures are not in place, such as proper drainage or green space to absorb water. If the consequences of these weather events are not understood, it can be difficult to justify these investments.” It is OSPE’s view that Ontario should be encouraged to critically apply the proposed ‘risk lens’ to infrastructure investments related to extreme weather adaptation, as publications including those by Environment and Climate Change Canada indicate ‘no detectable trend signal’ in short duration extreme rainfall affecting urban infrastructure. Researchers, including Dr. Trevor Dickinson, professor emeritus from the University of Guelph have published similar information on Ontario extreme rainfall trends.

Robert Muir, P.Eng., a member of OSPE’s Infrastructure Task Force, recently highlighted the need for a critical review of flood damage causes in the Journal of Water Management Modelling. Muir cites urbanization and intensification as key factors, as well as original design level of service limitations, as opposed to any risk trends associated with extreme rainfall. Dr. Dickinson has made similar observations on causes, lending credence to the argument that urbanization explains changes in flows, as opposed to changes in rainfall. If these findings are accurate, it means that extreme rain trends used to develop important Ontario policy documents such as the current Low Impact Development [LID] Manual v2 and others may be fundamentally flawed. The prevalence of the incorrect extreme rain trends information risks diverting attention away from true causes of infrastructure failure or flooding and can distort the ‘risk lens’ needed to guide infrastructure investment. As such, it is OSPE’s recommendation that the Government of Ontario review the accuracy of Ontario’s extreme weather trends and refrain from using this information as an infrastructure investment driver until it is fully investigated and verified.

Furthermore, the LTIP makes reference to an Insurance Bureau of Canada (IBC) report prepared by economists who did flood damage estimates with no engineering input, devoid of hydrology and hydraulics considerations. For the Ministry’s reference, the Intact Centre on Climate Adaptation no longer makes reference to this report because of the lack of engineering that undermines our confidence in its conclusions.

To address the issues detailed above, OSPE recommends that the Government of Ontario: i.Critically apply the proposed ‘risk lens’ to infrastructure investments related to extreme weather adaptation, recognizing variations in observed and predicted trends across the province.

ii.Evaluate adaptation measures such as green infrastructure for stormwater management, often cited as key mitigation measure, using the same ‘risk lens’ and consider the cost-effectiveness of those infrastructure investments.

iii.Recognize that green infrastructure must be viewed through the same lens as conventional infrastructure, adhering to established asset management principles and full cost accounting—meaning it must be addressed up-front and directly, considering system-wide costs.

Research

OSPE supports Ontario’s commitment to research that is signalled throughout the LTIP. Much of the research functions detailed in the LTIP are engineering related and it is OSPE’s view that infrastructure projects are potential laboratories that should be leveraged to deliver made-in-Ontario innovations for materials, methods, and new technologies. The Government of Ontario should advance the industry by providing funding for research that can take advantage of these projects and will help advance the industry.

Involve Engineers

Reviewing the entirety of the LTIP, the word ‘engineer’ only appears three times. OSPE recommends that professional engineers and engineering be more prominently featured in Ontario’s LTIP.

For your reference, Section 2.1 Planning Based on Evidence and Section 3.7 Modernizing Apprenticeships and Monitoring Labour Force Needs should be updated to feature engineers and engineering.

Section 2.1 makes reference to evidence-based decision making and the use of analytics, research, and information. Engineering should also be a consideration for evidence-based decision making and should therefore be mentioned in this section.

Section 3.7 could be improved by making mention to the Professional Engineers Ontario (PEO) Engineering Intern Program (EIT). The EIT is how engineering graduates acquire experience to quality for licensure. The EIT is also a pathway for foreign-trained engineering graduates to get their Canadian experience to qualify for licensure. This is an opportunity for the Government of Ontario to signal to stakeholders that they support these individuals and the welfare of the broader engineering community.

Questions & Comments:

For any questions or comments regarding this document, please contact Patrick Sackville, Lead, Policy and Government Relations at (416) 223-9961 ext. 225 or patrick@ospe.on.ca.

About OSPE:

The Ontario Society of Professional Engineers (OSPE) is the voice of the engineering community in Ontario. We represent the entire engineering community, including professional engineers, engineering graduates and students who work or will work in several of the most strategic sectors of Ontario’s economy.

Ontario is home to more than 85,000 Professional Engineers and 250,000 engineering graduates. That’s one of the largest concentrations of engineering expertise in the world, and the largest concentration of engineering expertise in Canada. OSPE stands as their advocacy body, as the Voice of the engineering community in Ontario.

OSPE elevates the profile of engineers by advocating with governments, offering career building services, and providing opportunities for ongoing learning, networking, and community building. Engineers are trained, innovative problem solvers who develop solutions by considering costs and benefits, sustainability, public safety, and the complete lifecycle and integration of projects. Engineers are on the frontlines of developing, safeguarding, and maximizing Ontario’s investments.

OSPE was formed in 2000 after members of Professional Engineers Ontario (PEO) voted to separate regulatory and advocacy functions into two distinct organizations.

[Original Comment ID: 212285]