Commentaire
Section 1
- Strategic Asset Management Policy
- Requirements beyond the scope of a high level policy document
- Requirements initially appear to be too prescriptive and would be best served in guideline, procedure or SAMP (as described in the iso55000 suite). Hows and Whos are not policy items but procedural items
- Requirements could be interpreted as needing direct statements of aspects of linkages between several documents rather than statements of alignments. This needs clarification and would be best if aligning to documents rather than having discussion in the policy or explicit statements in the policy. If not around aligning the policy update frequency may be too frequent to be maintained as these documents update on different schedules
- It is unclear what bullet 4 requires, alignment to section 3 or explicit statements? section 3 has a number of statements that do not align with the purpose of asset management for municipalities such as statements about health care and education
- Many cities in preparation of this update had written and had policies approved. this may lead to many cities having to update and rewrite in some cases their policy
Section 2
- Municipal Asset Management Plans
Outline and structure does not follow previous structure. This superficially looks like more of a rewrite than an update and improve your asset management plans. In reality it is just an expansion. This expansion is labour intensive on this timeline.
Part A
- Current levels of service -"municipalities would measure current levels of service according to the information defined in the following two columns found in the Proposed Levels of Service tables (see Additional Information):" I could not find what measures would be mandated under "Other information" links and could not find additional information. -Assumption is that there will be some measures that must be reported. This is fine as long as this does not be come a source of how cities are compared without context
Part B
- Inventory Analysis
- I agree with inspections and condition being collected. Does visual inspection count? What does "industry accepted engineering practices" mean?
- The cost to inspect all assets is cost prohibitive on this time line.
- Does this discussion on approach mean we describe the means of inspection or does it mean for example for assessing roads we will use the pavement condition index to show the condition? How much detail should be in this section. Level of detail may make a long document that is too technical for public consumption.
Part C
- Estimated Cost to Sustain Current LOS
- I agree with this.
- Current systems used at municipalities may lack the granularity to actually provide this information. Redoing financial systems and purchasing Computerized Maintenance Management Systems may not be feasible on the time line proposed
- For projecting costs to sustain, would inflating for growth and inflation be enough? how do you want this shown?
Part D
- Estimated Cost to Service Growth
- I agree
- order of this item seems to be in the wrong spot. growth should come before part c especially when considering the costs in the levels of service discussion. or this should happen early in the document before LOS discussed at all
Part E
- Proposed LOS
- Order weird LOS to Inventory to LOS cost to LOS Proposed? Maybe reconsider the order of discussion
Part F
- Lifecycle management strategy
- Strategies should be asset groups. Like all trunk mains follow these strategies based on age condition, risk etc etc. For individual assets this would be labour intensive and not informative. Also not really a strategy.
- I agree with asset strategy having a green option as long as it is recognized that some asset groups inherently are not green and do not have green options.
Part G
- Financial Strategy
- First requirement is duplicated from Part C
- Does the last bullet mean that the AMP will discuss the repayments the City makes on debt? Is this the best document for that?
Part H
- Addressing Shortfall
- This should be done with options. So item A does not meet the LOS targets and it would cost this much to improve. We could a) reduce the level of service so A now meets that service target b) raise the fees/taxes that support A so we can improve A to meet the LOS or C) recognize that the risk of A failing is this and it will cost us this much to live with that risk
Part I
- Financial Strategy to Service Growth -Will risks now be considered at 3 or more different stages? asset risk, service risk (in LOS, Lifecycle Strategy and shortfalls), and AMP risk? -This is a lot of risk assessment for one plan -What about opportunities. Asset Management planning is seeming very negative based on this regulation
Overall
- Removes the flexibility of the ISO5500 suite and is very prescriptive which might not serve the improvement of asset management in the long run
- Seems to align quite heavily with the IPWEA "How to write and asset management plan" course and template
- this NAMS/IPWEA template silos Asset Management since having one plan for all city services will create an extremely large document that is difficult to read and would lack messaging.
- Silo'ed asset management would also require that someone in every department that manages assets have responsibilities to write asset management reports. Fine for large municipalities maybe but not manageable for small to medium sized municipalities.
- Silo'ed municipalities often suffer from departments that work in bubbles this could make that problem worse
Section 3
- Updates, Approvals and Public Availability
Updating
- 5 years is reasonable
Approvals
- Not all cities have an engineer, not all assets are engineered assets or have strategies that involve engineering principals. may create limits and confusion. this may also lead to consultant driving plans where municipalities do not take ownership of their plans and their recommendations. Appropriate person with appropriate knowledge should approve. this could be an engineer, could be a senior manager or operator or could be a certified technologist such as a C.Tech or C.E.T
Annual Progress update
- Agree
Public Posting and provision of plans
- I agree however the content requested in the plan may not be designed for public consumption so this may just make this a posting exercise with limited value to those that are not well versed in assets
Section 4
- Data collection
- I do not know what the additional information is that is referred to here I cannot comment. However yearly reporting sounds like it would be labour intensive.
Overall the timelines are too aggressive. all of this can be done and should be done but most municipalities cannot afford to hire more staff. making this process a process of giving consultants work and making a shelf document that no one takes ownership of. Consultants may even be cost prohibitive for some smaller municipalities.
[Original Comment ID: 210172]
Soumis le 13 février 2018 12:03 PM
Commentaire sur
Projet de règlement sur la planification de la gestion des actifs municipaux
Numéro du REO
013-0551
Identifiant (ID) du commentaire
2187
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