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HomeMy WebLinkAbout2013-04-22 Workshop Meeting Agenda and Reports.pdfDistrict of Maple Ridge 1.ADOPTION OF THE AGENDA 2.MINUTES –April 8, 2013 3.PRESENTATIONS AT THE REQUEST OF COUNCIL 3.1 4.UNFINISHED AND NEW BUSINESS 4.1 Remedial Action, Complete Abatement of the Noxious Odor Emanating from the Structure Containing the Medical Grow-op at Units 103, 104 and 105 at 11410 Kingston Street, Maple Ridge, BC Staff report dated April 22, 2013 recommending that the owner of the property at 11410 Kingston Street be required for perform remedial action requirements within 30 days of the receipt of a resolution of Council. COUNCIL WORKSHOP AGENDA April 22, 2013 9:00 a.m. Blaney Room, 1st Floor, Municipal Hall The purpose of the Council Workshop is to review and discuss policies and other items of interest to Council. Although resolutions may be passed at this meeting, the intent is to make a consensus decision to send an item to Council for debate and vote or refer the item back to staff for more information or clarification. REMINDERS April 22, 2013 Audit and Finance Committee Meeting 8:00 a.m. Closed Council following Workshop Committee of the Whole Meeting 1:00 p.m. April 23, 2013 Council Meeting 7:00 p.m. Council Workshop April 22, 2013 Page 2 of 4 4.2 Update on LED Street Light Pilot Project Staff report dated April 22, 2013 providing an update on the District of Maple Ridge’s LED Street Light Pilot Project. 4.3 Council & Staff Liaison Roles Policy 3.10 Staff report dated April 22, 2013 providing information on the results of the review of Council and Staff Liaison Roles Policy 3.10. 4.4 Public Art Verbal update by the Director of Community Services 5. CORRESPONDENCE The following correspondence has been received and requires a response. Staff is seeking direction from Council on each item. Options that Council may consider include: a) Acknowledge receipt of correspondence and advise that no further action will be taken. b) Direct staff to prepare a report and recommendation regarding the subject matter. c) Forward the correspondence to a regular Council meeting for further discussion. d) Other. Once direction is given the appropriate response will be sent. 5.1 E-Comm 911 Board of Directors Designate – 2013/2014 Year Letter dated March 28, 2013 from E-Comm 911 requesting written confirmation of the designation of one individual for election to the Board of Directors of E- Comm. Recommendation: d) Appoint Mayor Ernie Daykin to the Board of Directors for the 2013/2014 term. Council Workshop April 22, 2013 Page 3 of 4 6. BRIEFING ON OTHER ITEMS OF INTEREST/QUESTIONS FROM COUNCIL 7. MATTERS DEEMED EXPEDIENT 8. ADJOURNMENT Checked by: ___________ Date: _________________ Council Workshop April 22, 2013 Page 4 of 4 Rules for Holding a Closed Meeting A part of a council meeting may be closed to the public if the subject matter being considered relates to one or more of the following: (a) personal information about an identifiable individual who holds or is being considered for a position as an officer, employee or agent of the municipality or another position appointed by the municipality; (b) personal information about an identifiable individual who is being considered for a municipal award or honour, or who has offered to provide a gift to the municipality on condition of anonymity; (c) labour relations or employee negotiations; (d) the security of property of the municipality; (e) the acquisition, disposition or expropriation of land or improvements, if the council considers that disclosure might reasonably be expected to harm the interests of the municipality; (f) law enforcement, if the council considers that disclosure might reasonably be expected to harm the conduct of an investigation under or enforcement of an enactment; (g) litigation or potential litigation affecting the municipality; (h) an administrative tribunal hearing or potential administrative tribunal hearing affecting the municipality, other than a hearing to be conducted by the council or a delegate of council (i) the receiving of advice that is subject to solicitor-client privilege, including communications necessary for that purpose; (j) information that is prohibited or information that if it were presented in a document would be prohibited from disclosure under section 21 of the Freedom of Information and Protection of Privacy Act; (k) negotiations and related discussions respecting the proposed provision of a municipal service that are at their preliminary stages and that, in the view of the council, could reasonably be expected to harm the interests of the municipality if they were held in public; (l) discussions with municipal officers and employees respecting municipal objectives, measures and progress reports for the purposes of preparing an annual report under section 98 [annual municipal report] (m) a matter that, under another enactment, is such that the public may be excluded from the meeting; (n) the consideration of whether a council meeting should be closed under a provision of this subsection of subsection (2) (o) the consideration of whether the authority under section 91 (other persons attending closed meetings) should be exercised in relation to a council meeting. (p) information relating to local government participation in provincial negotiations with First Nations, where an agreement provides that the information is to be kept confidential. District of Maple Ridge COUNCIL WORKSHOP April 8, 2013 The Minutes of the Municipal Council Workshop held on April 8, 2013 at 9:00 a.m. in the Blaney Room of the Municipal Hall, 11995 Haney Place, Maple Ridge, British Columbia for the purpose of transacting regular Municipal business. PRESENT Elected Officials Appointed Staff Mayor E. Daykin J. Rule, Chief Administrative Officer Councillor C. Ashlie K. Swift, General Manager of Community Development, Councillor C. Bell Parks and Recreation Services Councillor J. Dueck P. Gill, General Manager Corporate and Financial Services Councillor A. Hogarth F. Quinn, General Manager Public Works and Development Councillor B. Masse Services Councillor M. Morden C. Marlo, Manager of Legislative Services A. Gaunt, Confidential Secretary Other Staff as Required L. Holitzki, Director of Licences, Permits and Bylaws F. Armstrong, Manager of Corporate Communications Note: These Minutes are posted on the Municipal Web Site at www.mapleridge.ca 1.ADOPTION OF THE AGENDA The agenda was adopted with the addition of the following items: 4.4 Grow Ops 4.5 Cell Towers 4.6 Municipal Auditor General 2.MINUTES R/2013-138 Minutes It was moved and seconded March 18, 2013 That the minutes of the Council Workshop Meeting of March 18, 2013 be adopted as circulated. CARRIED 2.0 Council Workshop Minutes April 8, 2013 Page 2 of 5 3.PRESENTATIONS AT THE REQUEST OF COUNCIL – Nil 4.UNFINISHED AND NEW BUSINESS 4.1 Transportation Plan – John Steiner, Urban Systems The Municipal Engineer introduced the process for the development of the transportation plan. He advised that a discussion involving the Abernethy Corridor has been incorporated into the transportation plan presentation and introduced John Steiner from Urban Systems. 4.1.1 Transportation Plan Update Mr. Steiner gave a PowerPoint presentation providing a progress update on the development of the master transportation plan prior to public consultation. He outlined the key issues and the strategic directions for the road network, pedestrian, bicycle and transit strategy plan and outlined the next steps in the process. 4.1.2 Abernethy Way Update (Abernethy/128 Corridor) Mr. Steiner outlined future plans for the Abernethy Way corridor. Note: The meeting was recessed at 10:31 a.m. and reconvened at 10:42 a.m. 4.2 Customer Experience The General Manager of Community Development, Parks and Recreation Services gave a PowerPoint presentation providing an update on the customer experience initiative project. She highlighted initiatives which have been put in place since the start of the project and outlined the steps and tools staff are currently using. 4.3 Field Maintenance Program The Manager of Parks and Open Space gave a PowerPoint presentation on the sports field maintenance plan for the District and the process involved in the sports field management strategy. He advised on the types of fields in Maple Ridge and Pitt Meadows and the science involved in maintaining the fields. He outlined challenges of meeting the expectations of various user groups. Council Workshop Minutes April 8, 2013 Page 3 of 5 4.4 Grow Ops The Chief Administrative Officer provided an update on progress in the development of a grow op bylaw for Maple Ridge. He advised that a bylaw will come before Council in a few weeks. 4.5 Cell Towers The General Manager of Public Works and Development reviewed the resolutions passed by Council relating to the construction of cell towers in Maple Ridge and outlined work done by staff as follow up to Council direction. He advised on the outcome of staff requests to various cell phone tower companies in terms of holding construction of towers in abeyance. Staff was requested to have further discussion on the issue with Industry Canada. 4.6 Municipal Auditor General It was the consensus of Council that a letter be forwarded to the Municipal Auditor General requesting that an analysis be carried out comparing contractor pricing for work done for private companies to work carried out for government agencies. 5.CORRESPONDENCE 5.1 District of Invermere - Action on Concept of Towns with no People and Appointed Councils Letter dated March 15, 2013 from Gerry Taft, Mayor, District of Invermere seeking support on a request to the Union of British Columbia Municipalities (“UBCM”) Executive to take action on the concept of towns with no people and appointed councils as per Resolution B55 endorsed at the 2012 UBCM convention. R/2013-139 District of Invermere It was moved and seconded Support That a letter be sent to the Union of British Columbia Municipalities (“UBCM”) in support of the request by the District of Invermere that the UBCM Executive take action on the concept of towns with no people and appointed Councils. CARRIED Council Workshop Minutes April 8, 2013 Page 4 of 5 5.2 Metro Vancouver – Waste Flow Management Letter dated March 18, 2012 from Greg Moore, Chair, Metro Vancouver Board providing information on an emerging trend of hauling garbage to private sector disposal facilities and offering the availability of Metro Vancouver staff to present on waste flow management at an upcoming Council meeting. Mayor Daykin reviewed the letter. R/2013-140 Metro Vancouver Waste Flow It was moved and seconded Management Invitation to attend That Metro Vancouver staff be invited to attend a future Council meeting to present on waste flow management. CARRIED 5.3 Fresh Outlook Foundation E-mail from Joanne de Vries, Founder and CEO, Fresh Outlook Foundation providing information on the Fresh Outlook Foundation’s Building Sustainable Communities 2013 Conference. Mayor Daykin reviewed the letter. Councillor Hogarth provided information on previous conferences and suggested the municipality present at the upcoming conference. It was agreed that the municipality would not present at this conference. 6.BRIEFING ON OTHER ITEMS OF INTEREST/QUESTIONS FROM COUNCIL Councillor Hogarth advised on work being done on provincial legislation with regard to illegal activity on rental property. He expressed concern with the legislation. Mayor Daykin requested that Councillor Hogarth provide background material on the subject to allow for discussion at a future Council meeting. Council Workshop Minutes April 8, 2013 Page 5 of 5 7.MATTERS DEEMED EXPEDIENT - Nil 8.ADJOURNMENT – 12:23 p.m. _______________________________ E. Daykin, Mayor Certified Correct ___________________________________ C. Marlo, Corporate Officer Page 1 of 3 District of Maple Ridge TO: His Worship Mayor Ernie Daykin DATE: April 22, 2013 and Members of Council FROM: Chief Administrative Officer Meeting: Council Workshop SUBJECT: Remedial Action for the Complete Abatement of the Noxious Odor Emanating from the Structure Containing the Medical Grow-op at Units 103-104 and 105 11410 Kingston Street, Maple Ridge BC EXECUTIVE SUMMARY: Units 103-104 and 105 11410 Kingston Street (the “Property”) are owned by Arms Holdings Ltd. (the “Owner”) and are located in an Industrial zoned building. The three units have been combined into one unit to accommodate a medical grow operation. The tenants of the Property have applied for a building permit and the other necessary accessory permits however they have not submitted all the documentation required for the District to issue these permits. Significant renovations have been made to the Property in order to accommodate the grow operation and a large grow operation is already in operation without having the necessary municipal permits in place. The grow operation generates an extremely noxious odour that is disrupting other businesses adjacent to the Property. The odour is passing through interior ducting and fixtures. The problem is so significant that two businesses are forced to consider relocating their offices. One of the neighbouring businesses has had to discontinue marketing sports related clothing because the odour has made the clothing unmarketable. Staff has attended the site and can attest to the strength of the odour, both outside of the buildings and inside the adjacent units as well. Staff have attended this site on numerous occasions and requested that the Owner or the tenants take steps to mitigate the odour emanating from the Property. Steps taken by the Owner or the tenants, if any, have not made any significant difference. On December 7, 2012 our Solicitor sent a letter (attached as Appendix I) to the Owner directing that the necessary steps be taken to mitigate the odour. During an inspection of the site on December 13, 2012 attended by the Senior Bylaw Enforcement Officer, the Director of Licences, Permits and Bylaws and our solicitor, the Senior Bylaw Enforcement Officer again instructed the property owner and the tenant to take the necessary steps to abate the noxious odour and gave them until December 19, 2012 to retain a consultant to find a solution to the odour nuisance problems coming from the grow operation. On December 20, 2012 our Solicitor wrote to the Owner again to inform the Owner that, having failed to retain a qualified consultant by December 20, 2012 he anticipated that the matter would be referred Maple Ridge District Council to adopt a resolution under Section 74 of the Community Charter to declare the noxious odour a nuisance and order that the owner take immediate steps to abate the odour problem or the District would conduct the necessary work and bill the costs back to the Owner. As Council is aware, Section 74 of the Community Charter provides authority to Council to pass a remedial action requirement requiring an owner or occupier of real property to take measures to deal with a declared nuisance. 4.1 Page 2 of 3 If a person with notice of this resolution wishes to request reconsideration of these requirements by Council, written notice of this request must be provided to the Manager of Legislative Services within 14 business days of that person receiving notice of this resolution. In the event the owner or occupier has not performed all of the remedial action requirements within the time provided for compliance after the resolution is delivered to them, the District may, by its own forces or those of a contractor engaged by the District, enter the Property and perform the remedial action requirements. In the event the District takes the above referenced action, the District may recover the expense from the owner or occupier, together with costs and interest, in the same manner as municipal taxes in accordance with sections 17, 258, and 259 of the Community Charter. Based upon the above referenced information on this matter staff recommends Council pass the following resolutions. RECOMMENDATIONS: NOW THEREFORE, be it resolved: THAT Council declare the medical marijuana grow operation at Units 103-104 and 105 11410 Kingston Street, legally described as: (a) PID 023 969 440, Strata Lot 3 District Lot 280, Group 1 New Westminster District Strata Plan LMS3029,; (b) PID 023 696 458 Strata Lot 4 Group 1 New Westminster Strata Plan LMS 3029,; and (c) PID 023 969 466 Strata Lot 5 District Lot 280 Group 1 New Westminster District Strata Plan LMS3029 (the “Property”) a nuisance within the meaning of paragraph 74 (1)(d) of the Community Charter; THAT THE Owner must, not later than thirty (30) days after receiving a copy of this resolution, shall: 1.Retain a qualified consultant to find a solution to the odour emanating from the grow operation; 2.Complete the work recommended by the consultant and 3.Maintain the system as recommended by the manufacturer and/or the consultant; or 4.Remove the grow operation from the Structure. DISCUSSION: a)Background Context: The odour emanating from the grow operation located at the “Property presents a significant concern in the community. The purpose of this report is to recommend Council use the authority provided under Part 3 Division 12 under Section 74 of the Community Charter to impose a remedial action requirement on the Owner as recommended in this report. The Owner leased the Property to the current tenants sometime prior to June 2012. Renovations on the Property were started without the required District permits. Two joint inspections were conducted by the Fire, Building, Electrical and Bylaw Departments on June 21, 2012 and July 19, 2012 as with the results set out in Appendix II. Photos were taken of Page 3 of 3 the site as set out in Appendix IV. Despite numerous requests from staff and the issuance of Stop Work Orders placed on the Property, work continued. A building permit application was made by a tenant of the Property on September 17, 2012 but no permit has been issued due to incomplete submissions by the applicant. District staff has inspected the Property on numerous occasions since the time the tenants moved in and have continually reminded the workers on site that no permits have been issued for the work being conducted. b) Citizen/Customer Implications: Complaints have been received on a regular basis from tenants of the other units in the complex, including insurance being cancelled due to the grow operation. The District has received written submissions from the other tenants in the complex regarding the problems they have been having with respect to the odour (attached as Appendix III). b) Alternatives: For Council to not pass the Remedial Action order and provide staff with alternative direction in dealing with this nuisance/hazardous Structure. CONCLUSIONS: The grow operation creates a significant nuisance for the other tenants in the industrial complex where it is located. District staff has given the Owner and the tenants ample opportunity to resolve the situation but it appears that they do not intend to take any action in response to the problem. District staff recommends that Remedial Action requirements as described in the Recommendation in this report be adopted. The recommendations contained in this report have been reviewed by our municipal solicitors. “Original signed by E.S. (Liz) Holitzki” ______________________________________________ Prepared by: E.S. (Liz) Holitzki Director: Licences, Permits and Bylaws “Original signed by Frank Quinn” _______________________________________________ Approved by: Frank Quinn General Manager: Public Works and Development Services “Original signed by J.L. (Jim) Rule” _______________________________________________ Concurrence: J.L. (Jim) Rule Chief Administrative Office Appendices: I. Letters from Municipal Solicitor II. Letter from Senior Licence & Bylaw Enforcement Officer III. List of Property Complaints IV. Site Photos "Original signed by Barb Melnick" 1 District of Maple Ridge TO: His Worship Mayor Ernie Daykin DATE: April 22, 2013 and Members of Council FROM: Chief Administrative Officer ATTN: Council Workshop SUBJECT: Update on LED Street Light Pilot Project EXECUTIVE SUMMARY: The District of Maple Ridge embraces the pursuit of efficiencies wherever possible. Part of that pursuit is to reduce energy costs. To that end the District has been employing LED technology in various areas for a number of years. For example, the conversion of traffic signals to LED began almost ten years ago and is now 90% complete. One area where LED technology is undergoing considerable review and analysis is street lighting. Across North America, there is a full range of LED conversion progress, from those waiting for the industry to settle, to those like the Province of Nova Scotia, where there is a full-scale requirement to convert all municipally-owned street lights by 2019. Equally broad in range are the business cases for those conversion analyses. One key driver in the business case for conversion is the cost of electricity. In Nova Scotia for example, where the cost of electricity is over three times the rate in British Columbia, the payback period is much shorter. As such, the Province is willing to upfront the significant capital cost to convert street lights to LED. Here in British Columbia, where the cost of electricity is much less, the primary driver behind the business case is the capital cost of street lights. This report illustrates how significant the capital cost was to making a positive business case for the District’s LED street light pilot project. The realignment of Abernethy Way at 224 Street was completed in 2011 with funding received from the Canada-British Columbia Municipal Rural Infrastructure Fund (CBCMRIF). A component of this funding was innovative street lighting and the District, with direction from Mayor and Council, chose to test Light Emitting Diode (LED) street light technology instead of installing the standard High Pressure Sodium (HPS) street lights. After almost two years since completion of the realignment work, the LED street lights component of the project is generating savings for the District in both maintenance and energy costs. The project has also proven to be meeting industry standards for illumination. The project is estimated to deliver a positive financial bottom line, due to a significant capital cost discount and grant funding. LED technology in a street light application is relatively new, and quickly evolving. Capital costs are dropping, and in fact are half of what they were when the pilot project began. It is anticipated that this trend will continue as the use of LED street lights becomes more widespread. It is expected that the range of quality and the number of vendors will also settle once the technology is more widely adopted. The District will continue to monitor technology, industry trends and the experiences of other local governments, continue to collaborate with BC Hydro and government on a collective solution, and continue to watch BC Hydro for action that signals their confidence in the industry. 4.2 2 Given the District’s commitment to energy efficiency and innovative technologies, l ogical next steps also include a test retrofit on existing District-owned street lights, and a pilot project to test LED street lights in a neighbourhood setting with participation from the private sector. A follow-up report to cover these two topics will be brought forward to Council before the end of the second quarter. RECOMMENDATION: That this report dated April 22, 2013 entitled Update on LED Street Light Pilot Project be received for information; and further, That staff be directed to bring forward a report outlining a test retrofit on existing District-owned street lights, and a pilot project to test LED street lights in a neighbourhood setting with participation from the private sector. DISCUSSION: Roadway lighting is part of a safe and efficient road network. A well designed lighting system provides night time visibility of potential hazards for pedestrians and motorists. The District follows lighting level guidelines developed by the Transportation Association of Canada (TAC) and illumination values from the Illuminating Engineers Society of North America (IESNA) for specific road classifications. During the completion of the realignment of Abernethy Way at 224 Street, District staff, with direction from Mayor and Council, used the project as an opportunity to test LED street light technology. Following the completion of the project in 2011, Mayor and Council requested staff to report back on the status of the LED street light pilot project. LED Street Light Technology Overview LED street lights offer a way to produce a higher light output with a lower wattage that has the potential to reduce electrical energy use and maintenance costs. The District tested twenty-four 129 Watt LED street lights to put the theory into practice and see whether the savings materialized. LED technology in a street light application is relatively new and quickly evolving. There are a few factors that must be weighed off against the potential for cost savings, including product quality variations and the difficulty for end users to keep pace with product and vendor changes, high initial capital costs and technology uncertainties. Although the technology offers benefits under the right conditions, and interest in them is increasing, the use of LED street lights has not yet become common practice. A listing of the advantages and disadvantages of LED street lights is attached in Appendix “B”. Several Lower Mainland communities are conducting LED street light pilot tests. Appendix “D” provides information that shows the complexity and variety of results and measures taken by other North American communities when utilizing LED street light technology. District staff will continue to monitor the industry trends and collaborate with these and other communities. BC Hydro’s Role BC municipalities are encouraging BC Hydro to retrofit their own street lights. BC Hydro owns approximately one-third of the street lights in Maple Ridge. Those lights account for over 60% of the total District yearly street light cost, because the flat rate charged by BC Hydro includes a maintenance cost. For a breakdown of the Maple Ridge street light inventory and associated monthly electricity costs, see Appendix “A”. The District’s approach thus far has been to look to BC Hydro, with their vast street light inventory across the Province and associated significant potential for 3 energy savings, for action that signals their confidence in the industry. Furthermore, BC Hydro is working on an initiative that assesses the potential for bulk purchasing discounts and setting LED street light industry standards among BC municipalities. There is also the opportunity to take advantage of BC Hydro incentive dollars for retrofit installations. Abernethy Way at 224 Street Pilot Project Update After almost two years since completion of the project, the LED street lights are generating savings for the District in both maintenance and energy costs. The project has also proven to be meeting industry standards for illumination, meaning that an adequate amount of light is being provided to the roadway. Energy Savings The original lighting consultant, Acuity Brands Lighting Canada, provided a follow-up assessment to determine, for both the District and future clients, whether the street lights were performing as intended. The standard practice for an arterial road like Abernethy Way is to install High Pressure Sodium (HPS) street lights. The HPS street light that would meet the criteria for this road is a 150 Watt fixture. HPS street lights draw a higher wattage due to a loss of energy in the ballast, and therefore, a 150 Watt HPS street light draws 188 Watts of electricity. BC Hydro charges a flat rate of $0.0271 per Watt per month for District owned street lights. A 150 Watt street light therefore, costs the District $5.151 per month. The chosen 129 Watt LED street lights along Abernethy Way and 224 Street draw 129 Watts of electricity. LED street lights do not incur an energy loss in the ballast. The District pays $3.521 per month for each light. In summary, the LED street lights are generating energy saving of 591 Watts per street light. These findings are consistent with BC Hydro’s own assessment and correlate with billing rates 1. For a breakdown of the Maple Ridge street light inventory and associated monthly electricity costs, see Appendix “A”. Illumination A consultant with Great Northern Engineering Consultants Inc. (GNEC) was retained to assess the illumination and spacing of the LED street lights along Abernethy Way to ensure that adequate levels of lighting are provided along the roadway and at the intersection. Because LED technology is rapidly evolving, there is limited information available on industry standards pertaining specifically to LED lighting. In North America, the criteria and associated lighting levels are established by IESNA. For more information on street lighting standards, see Appendix “C”. GNEC was able to confirm that the street light design spacing, number of poles and illumination levels for the test pilot project meet industry standards. Economic Performance The following scenarios show the results of a simple cost analysis over a 20 year time period (the life expectancy of the LED street lights). In examining the three scenarios it is important to understand the impact of grant funding on the bottom line. In addition the LED lights for the pilot area were supplied at a 50% discount. Scenario 1: Includes 50% discount and grant For 24 street lights: HPS LED Savings/<Cost> 1 BC Hydro groups a range of fixtures together based on wattages, and therefore a fixture drawing 188 watts is charged under the 190 watt category. Likewise, the LED fixture drawing 129 watts is grouped in the 130 watt category. Applying the flat rate of $0.0271 to 190 watts and to 130 watts respectively delivers the cost per month noted above. 4 Capital Cost $4,800 $8,000 <$3,200> Energy $29,658 $20,292 $ 9,366 Maintenance $10,500 $ 560 $ 9,940 Total SAVINGS over 20 years $ 16,106 Scenario 2: Excludes discounts and grant For 24 street lights: HPS LED Savings/<Cost> Capital Cost $4,800 $48,000 <$43,200> Energy $29,658 $20,292 $ 9,366 Maintenance $10,500 $ 560 $ 9,940 Total SAVINGS over 20 years <$ 23,894> Scenario 3: Includes 50% discount but no grant For 24 street lights: HPS LED Savings/<Cost> Capital Cost $4,800 $24,000 <$19,200> Energy $29,658 $20,292 $ 9,366 Maintenance $10,500 $ 560 $ 9,940 Total SAVINGS over 20 years $ 106 The District’s pilot project is represented by Scenario 1, where we expect to achieve a positive bottom line of just over $16,000 over a 20 year time period. Had we not received the grant funding or manufacturer discount (Scenario 2), the project would be expected to have a negative financial return of almost $24,000. Scenario 3 is a break-even situation with manufacturer discount and no grant. With British Columbia electricity rates being relatively low, the above scenarios illustrate how the capital cost is the key driver of the bottom line, whereas for other Provinces2, higher electricity rates may reduce the impact of capital cost on the business case. Pricing for LED street lights has dropped by half in the past two years, and this trend is expected to continue. It would be prudent to wait until product pricing delivers a positive bottom line before wholesale adoption of the technology is undertaken, and until the industry settles and issues such as product quality and vendor selection are more stable. Next steps Research shows that municipalities across Canada are at different stages with regard to the adaptation of LED street lights. Nova Scotia has made them mandatory. In the Lower Mainland most municipalities are still in the testing/pilot stage. Three of the major outstanding concerns are the lack of standardization, initial capital costs and the long term performance. A new guide focused on emerging lighting technologies such as LED lights is currently being developed by the TAC, and is scheduled for completion in 2013. This guide, which is focused on the application of energy efficient roadway lighting and furthering understanding of the resulting reductions in power consumption and cost, is being developed by transportation professionals from the public and private sectors. It will be used to direct lighting technology decisions made by designers, administrators and policy makers in Canada. It is also understood that BC Hydro is working with municipalities towards standardization. While the District of Maple Ridge prides itself on being on the leading edge of technology a phased approach to the implementation of LED streetlights is prudent. 2 Appendix D shows the business case sensitivity to electricity pricing using Nova Scotia as an example. 5 The pilot project builds upon the District’s steady adoption of LED technology, and was an important step in the progression toward more energy efficient street lighting. There are several next steps to be considered: Continue to monitor technology and industry trends, and the experiences of other local governments; Continue to collaborate with BC Hydro and government on a collective solution; Encourage BC Hydro to retrofit the street lights they own in the community; Undertake a test retrofit of District-owned street lights; Undertake a pilot project to test LED street lights in a neighbourhood setting with participation from the private sector. CONCLUSIONS: LED technology in a street light context is relatively new and is continuing to evolve. Preliminary research shows that it has the potential to save money and reduce energy consumption, although many municipalities are taking a cautious approach, waiting for the industry to settle, preferring to do pilot projects to develop their own experience in the meantime and test business case assumptions. Areas with higher electricity rates find a stronger business case, whereas in British Columbia, product cost is the key driver of the bottom line. After almost two years since completion of the Abernethy Way pilot project, the project is generating savings for the District in energy costs and is anticipated to deliver maintenance cost savings. However, the positive financial case was dependent upon a significant product cost discount and grant funding. The District will continue to monitor the industry as costs come down and the industry matures. A follow-up report will suggest consideration of a test retrofit on existing District-owned street lights, and a pilot project to test LED street lights in a neighbourhood setting with participation from the private sector. “Original signed by Alexandra Tudose” _______________________________________________ Prepared by: Alexandra Tudose Research Technician “Original signed by Laura Benson” _______________________________________________ Prepared by: Laura Benson, CMA Manager of Sustainability & Corporate Planning “Original signed by Frank Quinn” _______________________________________________ Approved by: Frank Quinn, MBA, P.Eng GM: Public Works and Development Services “Original signed by J.L. (Jim) Rule” _______________________________________________ Concurrence: J.L. (Jim) Rule Chief Administrative Officer Attachment: Appendix A – Street Lighting Overview Attachment: Appendix B – Advantages and Disadvantages of LED Street Lights Attachment: Appendix C – Street Lighting Standards Attachment: Appendix D – Current Research and Testing 6 Appendix A - Street Light Overview Below is a diagram depicting the components of an existing HPS (High Pressure Sodium) decorative street light that can be seen along 224 Street in downtown Maple Ridge. This diagram is used in the introduction of this report to ensure consistency in the terminology used throughout it and during discussions. Current Street Light Situation There are approximately 4,800 street lights in Maple Ridge. The District owns approximately 68% (two thirds) of this inventory and BC Hydro owns the balance (32% or one third). From an electrical energy consumption point of view, in 2012, street lights consumed a total of 2.9 million KWh for a total yearly cost of approximately $450,400. Of the total cost, District owned street lights cost approximately 39% of the total and BC Hydro owned street lights cost approximately 61%. Street lights are the second most electricity consuming asset to the Leisure Centre and the most expensive for the District. The chart below looks at the current District street light inventory, associated electricity usage and costs: Current inventory Quantity 2012 total cost 2012 total kW/h Description District Owned Street Lights 3250 $175,846 2,174,535 Ornamental street lights that are installed on metal poles, either davit arm or on top of straight poles; use mainly HPS or Metal Halide technology, range from 95 to 480 watts. BC Hydro Owned Street Lights 1542 $274,551 725,509 Overhead street lights that are installed on wood poles with mast arms and have a cobra head. Luminaire (or head) Arm Pole 7 District Owned Street Lights BC Hydro Owned Street Lights Decorative street light Street light found in new developments Street light found in most new residential developments 8 Below is a breakdown of the inventory and associated monthly electricity costs: District-owned street lights BC Hydro-owned street lights Quantity Watts Rate Cost Quantity Watts Rate Cost 10 95 0.0271 25.75 1 175 0.0886 15.51 1735 130 0.0271 6112.41 26 250 0.0715 464.62 1218 190 0.0271 6271.48 1151 100 0.1412 16252.12 138 250 0.0271 934.95 273 150 0.1122 4594.59 27 305 0.0271 223.17 91 200 0.0972 1769.04 21 310 0.0271 176.42 70 480 0.0271 910.56 7 140 0.0271 26.56 24 130 0.0271 84.55 Total, including taxes/fees 17,707$ Total, including taxes/fees 24,503$ The charge for District-owned street lights is a flat rate per watt per month. This rate helped us determine the electricity savings of the different street light technologies. The charge for BC Hydro owned street lights is higher, as it represents wattage plus maintenance costs. The majority of the street lights in Maple Ridge are HPS (High Pressure Sodium). This luminaire is relatively inexpensive and has been in use for over 40 years. 9 Appendix B - Advantages and Disadvantages of LED Street Lights The advantages of LED street lights include3: Long-term energy and greenhouse gas emissions reductions Reduced electricity costs Reduced maintenance costs Longer product lifetimes, resulting in reduced replacement costs A quality of light that better approximates sunlight and can contribute to better colour and contrast perception and enhanced crime prevention Reduced light pollution because light can be directed where it is needed Reduced use of environmentally hazardous chemicals, such as mercury, which requires special handling and disposal Disadvantages of LED street lighting: Cost – the unit cost can be quite high compared to standard cobra head luminaires. Better quality LED street lights can be over $1,000 whereas a typical cobra head luminaire is typically around $200 Lacking in proven long term performance – as LED roadway luminaires are new to the industry, long term performance has not been confirmed. This leads to some level of risk to the owner Heat – LED luminaires have varying heat management systems, with the higher the junction temperature, the shorter the life expectancy of the LEDs Standardization – LED street lights are relatively new to the market and as such there is a lack of proven luminaire specifications Difficulty for end users in keeping pace with product changes or sourcing replacement parts, given the rapid development of LED technology Potentially higher replacement cost because entire head needs to be replaced rather than the luminaire, as hardware is not standardized Wide variation in product availability, options and quality, because the LED manufacturing industry is still developing Need to customize design/placement/spacing for each specific location An example that illustrates the rapid changes in the industry is that the manufacturer of the 224 Street and Abernethy Way LED street lights has already developed an upgrade to the street lights the District installed in 2011. 3 Municipal Policy Options Guide for Advanced Outdoor Lighting, LightSavers Canada, March 2011 10 Appendix C - Street Lighting Standards Current industry design standards must be followed when using HPS or LED luminaires for street lighting. The amount of light provided by a street lighting installation is typically based on two significant engineering criteria; the classification of the roadway itself (include major/arterial, collector and local) and the level of pedestrian conflict. In North America, the criteria and associated lighting levels are established by the Illuminating Engineering Society of North America (IESNA) publication RP-8. Transportation Association of Canada (TAC) has published the Guide for the Design of Roadway Lighting that takes the recommended North American Practice criteria with adaptation to Canadian conditions. However, there is currently a lack of industry product standards when it comes to roadway lighting with LEDs. A new guide focused on emerging lighting technologies such as LED lights is currently being developed by the TAC, and is scheduled for completion in 2013. This guide, which is focused on the application of energy efficient roadway lighting and furthering understanding of the resulting reductions in power consumption and cost, is being developed by transportation professionals from the public and private sectors. It will be used to direct lighting technology decisions made by designers, administrators and policy makers in Canada. 11 Appendix D - Current Research and Testing There has been research done by various municipalities, consultants and consortiums on the potential to use LED technology in street lights. Below is a summary of the work done by the City of Vancouver, the City of Richmond, and the City of Port Coquitlam; followed by a summary of the work done in Nova Scotia and City of Los Angeles. The information below is provided to show the complexity and variety of results and measures taken by other municipalities when dealing with LED technology in street lights. Lower Mainland consultants such as DMD and Associates Electrical Consultants have produced the Roadway and Outdoor Lighting Design Guide for the Transportation Association of Canada and were commissioned to study adaptive street lighting for the District of Maple Ridge in 2010, funded by BC Hydro. LightSavers Canada is a national consortium that aims to step up the adoption of LED lighting across the country. Furthermore, there is currently a group of municipalities including Maple Ridge and led by the City of Vancouver that is compiling results of test installations around the region. At the City of Vancouver (COV), the LED initiative was launched by the Greenest City Action Team (GCAT), a group of experts brought together by the COV. The GCAT recommended showcasing a demonstration street lighting program as part of the 2010 Olympics. The program was implemented in Yaletown through collaboration between the Yaletown BIA, COV and BC Hydro. The program was a success; however, a few lessons were learned. Firstly, a competitive business case for LEDs could not be made due to prohibitive costs; however because of the special nature of the demonstration project, COV was able to obtain funding through BC Hydro. Secondly, the pilot project showed the importance of alternative rates for LEDs, and lastly, on-the-ground measurement needs to be considered to ensure light levels are actually performing to IESNA standards. City of Richmond (COR) has a dedicated street light engineer who is testing 11 different LED manufacturers in an industrial zoned area, namely Fraserwood Way. Manufacturers were asked to forward to the COR their LED street lights with matching IESNA files that were suitable for testing at the above test location. Eleven matched IESNA standards and COR staff are assessing the results of these tests for the purpose of narrowing down the list to three manufactures that COR can recommend for new development applications in Richmond. For retrofits, COR does stretches of retrofits based on a budget set aside each year for maintenance. The City of Port Coquitlam (CPC) has identified street lighting as a priority emission reduction measure, due to the high energy consumption costs and corresponding greenhouse gas emissions. In partnership with BC Hydro and LightSavers Canada, the CPC retrofitted its downtown street lights with LED lights. The downtown street lights were previously 200W HPS and retrofitted to 110W LED, reducing the annual energy consumption by 45%. LED Roadway Lighting Limited (LRL), ecoNova Scotia, Conserve Nova Scotia, and Natural Resources Canada have partnered in a pilot project to retrofit existing street lights with new LED street lights in 19 communities throughout Nova Scotia. Eleven hundred (1,100) existing HPS street lights have been converted to LED street lights, making this to date, one of the largest LED street light demonstration projects undertaken in Canada. DMD and Associates were retained to review the design and lighting factors brought forward by the supplier, review testing procedures and calculate the energy savings for this pilot. The higher electricity costs in Nova Scotia had generated a reasonable business case for this pilot project. 12 Scenario 1: Abernethy Way pilot project as experienced, with discount pricing and grant, and British Columbia electricity rates For 24 street lights: HPS LED Savings/<Cost> Capital Cost $4,800 $8,000 <$3,200> Energy $29,658 $20,292 $ 9,366 Maintenance $10,500 $ 560 $ 9,940 Total SAVINGS over 20 years $ 16,106 Scenario 2: Abernethy Way pilot project case, using Nova Scotia electricity pricing For 24 street lights: HPS LED Savings/<Cost> Capital Cost $4,800 $8,000 <$3,200> Energy $118,961 $95,247 $ 23,714 Maintenance $10,500 $ 560 $ 9,940 Total SAVINGS over 20 years $ 30,454 In Los Angeles, the LED Street Lighting Energy Efficiency Program, managed by the Bureau of Street Lighting, involved the replacement of 140,000 of the 209,000 existing street lights in the City with LEDs. This is the largest LED street light replacement program in North America. Two issues helped in the development of the program: the first was the passing of Proposition 218 in California in 1996, which limited municipalities’ ability to adjust assessments for municipal services; the second issue was the inclusion of Los Angeles among the American cities identified as having high levels of pollution. Most of the funding for the program came from a loan from the city-owned utility company, the Los Angeles Department of Water and Power. The remaining funding was provided through an energy rebate program run by the utility company and the Bureau’s own funds. District of Maple Ridge TO: His Worship Mayor Ernie Daykin MEETING DATE: April 22, 2013 and Members of Council FILE NO: FROM: Chief Administrative Officer MEETING: Workshop SUBJECT: POLICY REVIEW -COUNCIL AND STAFF LIAISON ROLES EXECUTIVE SUMMARY: Staff was directed to conduct an annual review of policies. The Council and Staff Liaison Roles Policy 3.10 has been reviewed and no changes are recommended. RECOMMENDATION: No recommendation required. “Original signed by Ceri Marlo” _______________________________________________ Approved by: Ceri Marlo, Manager Legislative Services “Original signed by Kelly Swift” _______________________________________________ Approved by: Kelly Swift, General Manager Community Development, Parks & Recreation Services “Original signed by J.L. (Jim) Rule” _______________________________________________ Concurrence: J.L. (Jim) Rule Chief Administrative Officer Attachment: District of Maple Ridge Policy 3.10 4.3 POLICY MANUAL Title: Council and Staff Liaison Roles Policy No: 3.10 Supersedes: New Authority: Legislative Operational Approval: Council CMT General Manager Effective Date: April 14, 2010 Review Date: 2013-04-22 Policy Statement: Liaison Role Municipal Council will assign members of Council and/or Municipal Management will assign staff members to the role of municipal liaison to various community organizations where the relationship between the Municipality and the organization is deemed critical to achieving the Municipality’s mandate and goals. The role of liaison is intended to facilitate excellent and ongoing communication on matters of mutual interest. The intent of doing so is to ensure a continuing dialogue on how the Municipality and organization can work together to better meet the community needs they each hope to address. Council Liaisons Council members will only be assigned a liaison role where the liaison function is felt to be critical to achieving the Municipality’s mandate and where ongoing communication and knowledge gained from that communication and shared with the rest of Council by the liaison would assist Council as a whole in considering matters of common interest with the organization with whom they have a liaison function. Staff Liaisons A staff liaison may be more appropriately assigned where the organization to which they are assigned holds a fee for service contract with the municipality for the delivery of a Municipal service to citizens. While facilitating excellent on going communication is certainly part of a staff liaison role, monitoring performance to ensure delivery of agreed upon services is also part of the staff liaison function. Providing expert advice on effective organizational operations can also be part of the staff liaison function where that expertise may not exist within the organization itself. Page 1 of 6 Policy 3.10 Prioritizing requests for a Municipal liaison There may be requests for a Council or staff liaison from community organizations which cannot be accepted in part because the time available simply does not permit such assignments to every group wishing a liaison. Where priorities need to be set for assigning liaisons a higher priority will be given to those organizations delivering services on behalf of the Municipality and, secondly, to those organizations or networks which are not represented already through a Municipal committee or Commission and which represent a network of groups and agencies which are critical to achieving community needs for which the Municipality also has some responsibility. For example the Municipality would assign a liaison to the Arts Council as well as a staff liaison because it holds a significant contract with the Municipality but may not assign a liaison to a minor sport organization because the Parks and Leisure Services Commission has been formed to consider all of the needs of the sports community. Assigning Council Liaisons There is some rationale for considering the availability of various Council members when choosing which member should be assigned to which group. Those with more flexible schedules may be more available for liaison responsibilities than others. A Council member’s personal interests and expertise should also be considered in terms of making assignments along with their involvement in a particular subject (i.e. they may be involved with a group which is in the middle of an important initiative and, therefore, under these circumstances, a change in liaison may not be advisable). Another consideration may be the notion of broadening every Council member’s knowledge by rotating their responsibilities where that is felt to be beneficial. The benefit of such rotations to the groups with whom Council members liaise is that more members of Council become familiar with the organization and the issues it is an advocate for. Since there are many factors involved in determining such assignments it is not felt appropriate to prescribe a process or a maximum term for service as a Council liaison. The only guidance to be offered by this policy statement would be to suggest all of the above be considered along with the basic principle that Council members should share liaison responsibilities as equitably as possible. Purpose: The purpose of this policy is to clarify the roles and responsibilities of Council and Staff liaisons to independent organizations. It is also intended to provide guidance to those organizations to whom liaisons have been assigned in terms of their responsibilities and the reasonable expectations they should have of assigned liaisons. Definitions: “Liaison” refers to a position assigned to a Council or Staff member where the primary objective is to maintain good communication and relationships between an outside, independently constituted organization and the District of Maple Ridge. Page 2 of 6 Policy 3.10 Key Areas of Responsibility Action to Take Responsibilities of Organizations to whom Council and staff liaisons are assigned Such groups should: a.Ensure assigned Council members and staff members are provided with sufficient advance notice of meetings and agendas, given their busy schedules. Establishing a regular meeting schedule is helpful, however, sending agendas out in advance is equally important since it will assist the Council or staff member in determining if their attendance and input would be helpful to the group and to Council. Sending agendas out at least four days in advance for regularly scheduled meetings is a minimum standard. Significantly greater advance notice and agenda distribution is required for special meetings outside the regular meeting schedule. Occasionally, despite regularly scheduled meetings, Council members in particular must choose between meetings which have been scheduled and other important community events and meetings which come up from time to time. Having an agenda in advance is an important tool in helping a Council liaison to make that determination and to be effective in their role. b.Provide advance notice for the Council or staff member to address a particular topic of interest to the group at an upcoming meeting. While not always possible advance notice of a particular question can be very helpful in ensuring the liaison has time to complete an appropriate level of investigation or research if the question happens to be on a subject with which they are not familiar. c.Be appropriately constituted, be in good standing with the Registrar of Societies and function in accordance with the guidelines which typically govern well functioning Societies. Such guidelines include sending agendas out in advance, maintaining minutes, managing meetings in accordance with appropriate rules of order, holding regular elections, maintaining proper financial records, etc. d.Welcome Council and staff liaisons to attend every meeting they choose to attend (save and except for meetings which are exclusive to the Board members only which deal with personnel or legal matters and other confidential matters such as negotiations with the municipality). Responsibility Community Organization Chair or Representative Community Organization Chair or Representative Community Organization Chair or Representative Community Organization Chair or Representative Page 3 of 6 Policy 3.10 e.Respect a Council liaison’s time by moving those items which the liaison may need to address to as early a place in the agenda as possible and not expect the liaison to stay beyond dealing with that subject, unless the liaison chooses to stay (not to participate in the Board’s further discussions but to learn more about the organization and what is important to the Board to further the relationship). The staff liaison in particular may wish to stay in order to fulfill their responsibility of monitoring the group’s performance of contracted services. f.Appreciate a Council liaison should not be expected to attend every meeting of the organization. Of course a liaison should attend on a reasonably regular basis in order to fulfill the function as best as he or she can. However, attending every meeting is, in all probability, unrealistic given the number of liaison and committee responsibilities each Council member is assigned on top of their formal Council responsibilities. In addition, some Council members have career and professional responsibilities beyond their Council role. In some cases where it is felt that very regular representation from Council is required then an alternate may also be appointed. A staff liaison’s attendance will likely be more consistent given the limitation on the number of groups for whom they have a liaison responsibility. g.Not expect a liaison to participate in group discussions as if they are just another member of the Board of Directors. The organization should definitely not give the staff or Council liaison a vote. Doing so may put the Council liaison in a conflict position with respect to matters which come before Council having to do with the group. A Council member cannot vote at Council on matters related to another organization with whom they have a fiduciary responsibility (voting at a Board meeting constitutes acceptance of such responsibility) and must not participate in any debates on such matters at Council. In fact they are required to declare the conflict and leave the meeting room when such conflicts occur while the matter in question is being discussed by the other members of Council. Responsibilities of Council and Staff Liaisons Assigned Council and staff liaisons should: a.Attend as many of the organization’s meetings and functions as necessary to achieve the desired end result of good communications and a positive working relationship with the group. Recognizing regular monthly attendance may not be possible the Council liaison should discuss their intention to attend on whatever schedule makes sense with the group Community Organization Chair or Representative Community Organization Chair or Representative Community Organization Chair or Representative Council Liaison Council Alternate Liaison Staff Liaison Page 4 of 6 Policy 3.10 President at the outset of their assignment, to ensure clarity and avoid higher than can be delivered expectations. Having a staff liaison in attendance may provide a greater sense by Council members who are assigned liaison responsibility that the Municipality’s interests are being represented to some degree and may permit less frequent attendance by a Council liaison. If a staff and Council liaison have both been assigned to a group each should bring the other up to date on those matters of mutual interest to both the municipality and the organization which were discussed at a meeting their counterpart was unable to attend. b.Let the organization’s President or Secretary know when they are unable to attend a meeting at which they might otherwise be expected, and, if an alternate has been appointed, notify the alternate Council representative they will be unable to attend and determine if the alternate is available to cover the meeting. If they are available forwarding the agenda to the alternate is also required. c.Not vote and avoid participating in group debates as if they were a member of the organization’s Board of Directors. (see “g” above) d.Not make commitments on behalf of the Municipality which are not already covered by policy or a previously approved standard of service. Of course a Council liaison should be prepared to look into any request, passing that along to the appropriate senior staff member to investigate. The staff member’s obligation is to ensure the Council liaison is informed as to the outcome and response to the request. Council Committee and Commission Roles and Responsibilities (referenced here only to clarify the difference between liaison and committee roles and responsibilities) Council members will also be assigned to a variety of Municipally established committees and commissions whose role is to advance the Municipality’s mandate in their various areas of responsibility. The role of a member of Council on such committees is very different than that of liaison to an independent organization. To be more specific Council members who are assigned to such groups are expected to participate fully in the discussion and debate on subjects before such committees and are generally expected to vote along with the other appointed members of the committee or commission. All such groups are duly constituted by bylaws of the Municipality to carry out the Municipality’s business. In some cases they are advisory and in others they have been Council Liaison Council Alternate Liaison Staff Liaison Council Liaison Council Alternate Liaison Staff Liaison Council Liaison Council Alternate Liaison Staff Liaison Page 5 of 6 Policy 3.10 delegated the authority to act independently within parameters established by Council and allowed by the Community Charter and Local Government Act. In all cases the Council members assigned to these groups are expected to bring a Council perspective to the table. The legal opinions we have available to us indicate there is no conflict of interest for a Council member who participates in debates and discussions and votes on matters at a municipal committee or commission meeting and then considers and votes on a recommendation from the committee or commission at Council. This is because the committee or commission is a child of the Municipal Government and the business being conducted is therefore being carried out by the Municipality for the Municipality and not by an independently constituted organization. Role of Council members appointed by Council to legislatively constituted Boards involving organizations made up of several Municipalities collaborating on the delivery of services (referenced here only to clarify the difference between liaison and regional Board appointee responsibilities) Members of Council can be appointed by Council or by the Mayor to represent the Municipality on Boards of Directors of agencies which have been duly constituted to deliver services on behalf of several Municipalities acting together. Examples of this include the Fraser Valley Regional Library or the Metro Vancouver Regional District. In such cases the appointed member participates fully on the Board to which they have been appointed and are generally tasked with the obligation to vote as they personally feel is appropriate on matters that come before that Board. That is because it is assumed that, due to their involvement, the Council member sitting at the Board table has a greater appreciation for the broad responsibility of the Board than other Councilors not on the Board whose context is only the services provided locally. It is understood that a Council cannot compel a member representing the municipality on this type Board to vote in accordance with Council’s wishes expressed by a resolution of Council. With that said most of the Council members who serve as Board representatives to regional bodies do consult with the rest of Council to obtain their views before a particularly challenging subject is voted upon at a regional Board level. We are advised by the District’s legal advisors that despite the independence described above there is no conflict for a Council member who is appointed to sit on such a Board who then participates in debates and discussions at the Council table about the municipality’s continuing involvement in such a regional function or any other debate related to Council’s involvement with the regional body involved. Page 6 of 6 Policy 3.10 5.1