The Corporation of the City…

The Corporation of the City of Woodstock

Proposed Municipal Asset Management Planning Regulation Comments

[EBR Registry Number 013-0661]

July 24, 2017

The City of Woodstock has been managing infrastructure assets for many years, using multi-year financial plans, strategic and master plans, continuous improvement and best practices. Since the release of the 2012 Building Together Guide, the City has published two asset management plans. During this time, staff has worked to improve the data available and evolve our asset management reporting, as resources have allowed. While we support the principle that municipalities need effective plans to manage their infrastructure, and recognize that the province needs to understand the infrastructure needs of municipalities, the proposed regulation will add a significant financial burden to our municipality and imposes unrealistic timelines.

The City of Woodstock’s key areas of concern are:

Resources which could be used to maintain/improve infrastructure are being diverted to meet reporting requirements.

•Additional staff will be required to meet the requirements being imposed. This means additional costs for adding staff, staff training, and data management systems. As well, consultants will be required to provide the level of expertise contemplated in the regulation, particularly in the areas of climate mitigation and energy. Even when consultants are used, significant staff time will be required.

Additional reporting burden is being added. Not only is an asset management plan required at least every five years, but annual reporting is being proposed. A full review of current municipal reporting requirements should be undertaken to ensure no duplication of efforts – e.g. Federal Gas Tax, Energy Reporting and the FIR.

•The timelines for Phases 1, II and III are too aggressive. The following would be more reasonable: Phase 1: January 1, 2020 [January 1, 2019 proposed] Phase II:January 1, 2022[January 1, 2021 proposed] Phase III:January 1, 2024[January 1, 2022 proposed] Significant development work will be required to meet the requirements, particularly for the Phase III lifecycle strategy and 10 year financial strategy.

•Strategic Asset Management Policy The policy is supposed to a high level statement of purpose. The regulation requires a significant detail many of which should be changed to procedures that support the policy – such as actions required to address risk, mitigation approaches to climate change and processes to ensure alignment with relevant policies.

•Levels of Service should not be dictated by the Regulation: While we appreciate the province’s desire for comparability, the types of assets owned, the urban/rural mix and the upper/lower tier designation will affect what is meaningful to a municipality. For example, using land-km of road class per household as a measure of scope does not have meaning for the City of Woodstock, as it is not something the City directly influences.

•Municipalities with populations over 25,000: requirement to report on Estimated Costs to Service Growth, Financial Strategy to Service Growth & Risk Analysis The population cutoff should be 100,000, consistent with the OCIF definition of a small municipality.

•Approval by a licensed engineer seems unnecessary and likely difficult to obtain. Council approval should be sufficient.

•Guidance, Tools and Support: While the support being offered such as sample documents, training through webinars and a provincial support team able to field questions would all be helpful, it will still take considerable time for staff to become familiar with the requirements, develop a plan to meet the requirements, gather/manage the required data and document all that is required for the plan.

•Given the nature of the work required and the emphasis on long term planning, a commitment to provide formula-based, multi-year funding would help provide financial certainty to municipalities when developing their plans.

•The expansion of asset management plans to include energy, non-infrastructure and climate mitigation activities adds a new level of complexity and cost for municipalities. These issues are already addressed in many Official and Strategic Plans and other municipal government initiatives.

[Original Comment ID: 210300]