The Township of Perth South…

The Township of Perth South has the following comments in regards to the proposed municipal asset management planning regulation as posted on the Environmental Registry EBR 013-0551: 1.The redesign of the Ontario Municipal Partnership Fund (OMPF) in 2012 has had a significant financial impact on the Township of Perth South. The redesigned OMPF formula results in a $2,000,000 reduction in grant funding. With a population of less than 4,000 people and land that is primarily agricultural with no urban centres or growth, there is little opportunity to replace this funding. The impact of the funding reduction is equal to a tax increase of 66% for the Township’s (Lower Tier municipality) portion. In addition, the County of Perth (Upper Tier municipality) will see their grant funding eliminated completely. In 2017 the County of Perth received $1,954,300, and Perth South’s portion of this loss is estimated to be $254,059 which is equal to an additional 8.5% tax increase. Together this represents a tax increase of 74.5%. In response to the reductions that have been realized and that will continue in the future, the Council for the Township has had to make difficult decisions to offset the loss of funding. The cost-cutting measures include eliminating the CAO position and the closing and removal of two municipal bridges that, given our new financial reality, were too expensive to repair. Given our financial position we are concerned about the financial implications that are associated with the proposed legislation. a)Like many small municipalities, staff currently has difficulty completing their existing workload and adding more to the workload is not an option. Perth South would incur the additional cost of hiring staff or contracting out the work to a consultant to complete required update and maintain annual reporting requirements. A further tax increase would be required to cover this cost. In addition, staff training costs and software costs are also another burden likely to be added to the total cost.

b)Funding has been received in the past for the development of the existing Asset Management Plan. These changes will mean that the existing plan will no longer comply and will have to be re-written. Again, this will be an added cost to the Township.

c)Perth South does not have a licensed engineer and the requirement that a licensed engineer sign off on the asset management plan, or components of it, will be an additional cost to the Township.

d)Levels of service and Level of Service Performance Indicators should be standardized based on the size and type of the municipality. This needs to be sorted out to establish some standardization for continuity and comparability.

e)Total costs could be reduced by requiring the Asset Management Plans be completed in one phase by 2020, instead of three.

2.Regulation timelines are aggressive

- Small municipalities such as Perth South do not have the resources to meet the proposed timelines, that being; the adoption of a strategic management policy by January 1, 2019, completion of AMP Phase I to address core infrastructure by January 1, 2020, completion of AMP Phase II expanding on Phase I by including all infrastructure assets by January 1, 2021 and completion of AMP Phase II requiring further details for all infrastructure assets by January 1, 2022.

3.Regulation expands asset management planning beyond core competence.

•Expanding AMP’s to energy, non-infrastructure and climate mitigation costs takes the focused management of physical assets into an additional function that may unnecessarily duplicate Official and Strategic Plans, energy regulation requirements & other municipal government initiatives.

4.A comprehensive software application is required. To date, we have not seen a complete, integrated software application that works with or into an asset management plan. Maybe this should be commissioned by the Province to be completed so that we are not struggling with various applications and trying to sort through them effectiveness and integration.

5.Part of the solution is to create reliable funding for future planning that municipalities can count on in their AMP. This would shift human resources from applying for funding to actually implementing the AMP. This would result in more cooperative efforts between municipalities as it takes out the completive aspect.

Is the provincial government prepared to pay municipalities to complete the documents that are required in this proposed regulation? We would also like to bring to your attention the fact that the consultation period that runs into the summer months, a period when Perth South Council reduces their meetings from two to one per month due to summer vacations, makes providing comments more difficult. Additional time should be given to comment periods that extend into and/or through the summer months.

[Original Comment ID: 210308]