The City of Barrie strongly…

The City of Barrie strongly supports improved asset management planning, which is a key component of service delivery and sustainable financial plans. Many municipalities, including Barrie recognize this and have been working diligently to develop maintenance management strategies, long term asset renewal plans and financial plans as best practices. In general, municipalities that have not implemented asset management plans have not done so due to a lack of staff, systems and financial resources to develop such plans. Barrie has had AMPs in place since 2009, however our maturity is still not fully developed, largely due to these resource constraints. While regulations may result in more municipalities undertaking AMPs, the timelines noted in the legislation should recognize the constraints and competing priorities faced by municipalities. If regulations are implemented they must be achievable, supported by tools, funding, include a reasonable implementation schedule, and recognize that there are considerable differences between municipalities in terms of the types of assets, resources, and financial capacity.

The City of Barrie’s comments on the specific sections of the Proposed Municipal Asset Management Planning Regulation are noted below.

Definitions –

Please provide clarification on whether the definition of core assets is limited to strictly the assets mentioned, or includes assets required to support the entire service that is described. For example, are the fleet and facility assets that are used to support the roads and bridges intended to be part of Phase I (core infrastructure assets), or Phase II (remaining infrastructure assets)?

With respect to assets which are jointly owned, and where a separate board exists to manage those assets, it is suggested that the requirements of this regulation be pushed to the separate board. For example, a municipal corporation that operates an airport, while consolidated on the Municipalities Financial Statements. The municipal corporation’s board is responsible for operating the airport. The airport is not a department within the municipality, and therefore should be responsible for their own Asset Management Plan.

Strategic Asset Management Policy –

We note that the proposed regulation requires the implementation of a Strategic Asset Management Policy which generally allows the municipality to determine through the policy, how various concepts and information will be captured. It appears that this provides the municipality with some flexibility, yet covers the important fundamentals of AM. Municipal Asset Management Plans –

AMPs Phase I and II -

The City is supportive of the goal to establish baseline levels of service and to estimate all capital expenditures to sustain those existing services levels. This is fundamental to good AM practice. However completing this work within the timelines prescribed for Phases I and II is extremely ambitious and will require additional resources beyond what are already dedicated within the City. Replacement timing and costs is less complex than estimating maintenance, renewal, and rehabilitation and growth information. Phasing the requirements for AMPs to separate the identification of replacement from other lifecycle activities might be an option to make the workload and timelines more manageable.

The City doesn’t currently have the tools or staff resources to do this work efficiently, in the timelines provided. Even if funding is provided to out-source some of this work to consultants, additional internal resources will be required to provide and review data, and to lead consultant work.

AMPs Phase III –

As noted previously, the requirements to consider lifecycle management and financial strategies incorporating all lifecycle activities for existing as well as new assets will be a resource intensive exercise, requiring many assumptions. By adding in the requirement to consider proposed levels of service and extensive financial analysis, the resourcing challenges only increase. It will be extremely difficult for the City of Barrie, which is fairly advanced in its asset management initiatives, let alone other municipalities who are not as advanced, to meet the requirements proposed in the regulation, within the prescribed timelines. It should be noted that municipalities are currently preparing 2018 business plans and budgets and any additional resources required to assist with implementing this proposed regulation will need to be identified and requested over the next several months. With the timing and details of the proposed regulation being a relative uncertainty at this time, it may be too late, or very difficult, to estimate and then secure the resources required to achieve the proposed regulatory timelines.

Updates, Approvals and Public Availability-

Significant resources will be required starting in 2018 to achieve the policy and initial phase I, II and III milestones, and then significant sustained effort to ensure compliance going forward. The City of Barrie recognizes that asset management planning is a journey, not a singular milestone, and supports an ongoing and sustainable asset management planning approach

Regarding the approval of the AMPs by an engineer and executive lead, the City welcomes the acknowledgement that staff from across the municipality need to be involved with and accountable for the requirements. In addition to an engineer and executive lead, the Province may consider requiring the treasurer and Chief Administrative Officer (CAO) to also approve the AMPs.

Data Collection-

Many existing annual reporting requirements may overlap with the data collection requirements of this initiative. Efforts should be made to ensure consistency among reporting requirements associated with MPMP and Development Charges in particular. Sufficient time will need to be built into annual municipal work plans to comply with this requirement.

Provincial Policy Alignment –

It is appreciated that the Province will be reviewing alignment between this, and other regulation. In the case that conflicting or duplicate requirements exist, the City would urge the province to consider flexibility in the timelines or compliance with this proposed regulation.

Asset Management Planning Guidance, Tools and Support-

We note that compliance with the new regulation will add costs to municipal operating and capital budgets starting in 2018, and request that a cost analysis be completed by the province so that the impacts are known and that a mechanism be established for funding the initiatives.

Further the City requests the Province support any AM initiatives with resources in the form of funding for staff, consultant work and/or software. Previous funding initiatives were targeted to small, rural or northern municipalities and excluded larger municipalities such as Barrie.

General –

We understand the proposed regulation is designed to have municipalities use best practices in asset management. The City is supportive of implementing these practices. The City has had an Asset Management Strategy, Policy and Plans for several years and even with this foundation, will be challenged to assemble the resources to get to the best practices described in the proposed regulation over the next 5 years.

Municipalities should be encouraged to move forward with meaningful asset management initiatives that provide value, rather than simply achieving compliance with a regulated requirement. In this respect, municipalities should be free to determine the pace and initiatives which will provide the most value for their individual circumstances.

As outlined above, we are requesting that some elements of the proposed regulation be clarified before regulations are implemented, and that sufficient time be allowed for municipalities to plan and complete the required work.

[Original Comment ID: 210309]