Comments

ood morning, I am the Treasurer/Deputy Clerk for a small municipality of under 2,500 people. Although we are small in population, we are large in area and have many roads, bridges, water & sewer systems, and so on.

It appears as though the new Phase 1 requirements will only require 'core infrastructure assets' to be included. If a Municipality has not yet completed their 2016 AMP that required 'all infrastructure assets', will they be able to publish their AMP with just the 'core assets'?

Require a compilation of a complete inventory of all infrastructures the community is currently obligated to maintain, their condition, an estimate of their remaining life and approximate replacement/ maintenance costs.

Municipalities are already over burden by the implementation of PSAB 3150 and the current asset managment reporting requirements.

I believe that the Strategic Asset Management Policy of a Municipality should include the occupational health & safety hazards and risks that relate to asset management.

This proposed legislation will create additional challenges to already overextended municipal capabilities. Additional staffing and financial commitments are significant.

Costs to rhe rate payer, especially in small rural municipalites will be great. Our municipality has a 1 percent rate increase with a spend of only roughly $40,000. We have 312.sq km do roads to maintain. Water and waste water, arenas and public lands.

Therefore Council directs staff to respond to the Province by way of the Environmental Registry that the proposed regulation:

The Township of Brock would like to voice their major concern in our capacity to meet the ne planning requirements without additional ongoing financial support.

Will the Ministry be standardizing useful lives of the Core Infrastructure Assets or other assets? This will allow for consistency when reporting or comparing results with other municipalities.

Also, could you elaborate on Green Infrastructure assets, it is not clearly defined.

My Initial Comments on the new Regulation:

1.If licenced engineer to sign off on – need to provide ongoing funding for municipalities too small to have in-house engineers.

Under the Asset Management Policy the regulation outlines a number of areas to be considered in the AM Policy relating to climate change and GHG Reductions. I think this should be revised or, like in other sections, give different considerations to different sized municipalities.

Asset management is a worthwhile tool but the implementation of a prescribed policy is not acceptable. A requirement for mandatory, ongoing engineering oversight is cost prohibitive and unwelcome in all small communities and even banding together for a shared service is impractical.

The following resolution was passed by Neebing Council on June 21, 2017 (resolution # 2017-06-152):

WHEREAS Posting 013-0551 on the Environmental Bill of Rights, entitled “Proposed municipal asset management planning regulation”, is posted for public comments until July 24, 2017;

As a municipal CAO/Clerk I must strongly object to the timing of the implementation of the regulation. I believe that asset management planning is an important tool and has many benefits for municipal councils, staff and residents.

Finally! it looks like we are beginning to value the economic and environmental benefits that our trees, soils, creeks, rivers and other natural components offer to sustain our basic existence. that is : our Green Infrastructure!

Municipal staff appreciate the need to provide an asset management framework that is consistent across the province, provides for best practices and links to various strategic municipal planning documents.

Regarding "Current Service Levels"

If you like breathing then we need trees! Trees are an essential part of our life, work and play. I don't need to tell you all the benefits of having trees as I'm sure you are well aware of them all.

Ministry of Economic Development, Employment & Infrastructure

July 6, 2017

Dear Sir/Madam