2018-2021 Building Materials Evaluation Commission business plan
Learn about activities and plans for effectively evaluating and authorizing innovative building materials, products, and designs for use in Ontario.
Mandate
The Building Materials Evaluation Commission (the “Commission”) is a regulatory agency whose legislative authority is set out in section 28 of the Building Code Act, 1992.
The Commission has a mandate to evaluate and authorize, subject to conditions, any innovative construction materials, systems or building designs for use in construction in Ontario. In doing so, the Commission has the power to conduct, or cause to be conducted, research, analysis and evaluation of such innovative materials, systems and building designs. The Commission is not a testing body, but may require that testing be carried out by an applicant as part of its evaluation.
The Commission also has the authority to make recommendations to the Minister respecting changes to the Building Code Act, 1992, or the Building Code.
In exercising its mandate, the Commission receives all of its staffing and financial resources from the Building Services Transformation Branch of the Ministry of Municipal Affairs (the “Ministry”).
Guiding principles
As an agency authorized under the Building Code Act, 1992, the Commission exercises powers and performs duties in accordance with its mandate under that statute. The agency’s regulatory activities and decisions must be made, and be seen by the public to be made, independently and impartially. The Commission makes decisions independently from the Ministry and the Government of Ontario.
The Commission has signed a Memorandum of Understanding (MOU) with the Minister of Municipal Affairs (the “Minister”) relating to the exercise of its mandate. The MOU sets out the relationship between the Commission Chair and the Minister and the Ministry with respect to the Commission and the service it provides. The purpose of the MOU is to establish the responsibilities of these parties and to ensure that accountability is a fundamental principle observed in the management, administration and operations of the Commission.
As an agency of government, the Commission conducts itself according to the management principles of the Government of Ontario. The Commission’s proceedings are governed by the Building Code Act, 1992, the Building Code, the Building Materials Evaluation Commission’s Guidelines, Policies and Procedures Handbook, and Treasury Board/Management Board of Cabinet Directives. These principles and governance elements include ethical behaviour, accountability, excellence in management, wise use of public funds, and high-quality service to the public, through contributing to the health, safety, accessibility and energy efficiency of buildings in Ontario and by playing a positive role within Ontario’s construction sector.
Strategic direction
The Commission endeavours to provide a timely, cost-effective and non-adversarial process for evaluating and authorizing new and innovative materials, systems and building designs for use in Ontario. In doing so, the Commission has earned a reputation as an effective, useful and quality service provider within the construction industry. The Commission does, however, face certain challenges. To address these challenges and to improve its ongoing operations and client service delivery, the Commission plans to continue with the following initiatives in the coming years.
Review of existing authorizations
The Commission launched an initiative to manage and keep current all existing authorizations.
The first exercise involved an attempt to contact each holder of an authorization, dating back to 1976, to determine whether the authorization holder’s contact information on file with the Commission is up-to-date. Also, as part of this exercise, authorization holders were asked whether they still manufactured the innovative product, system, or building design detailed in the authorization, and whether the Commission’s information relative to this product was current.
The second initiative related to the review of existing authorizations for redundancy with other approvals for innovative products, such as Rulings of the Minister, as they relate to Evaluation Reports from the Canadian Construction Material Centre.
A third review was performed to update the existing authorizations to current Commission’s policies as well as to determine whether the existing authorizations require updating to current codes and standards, as they are set out in the 2012 Building Code.
In 2008 the Commission adopted an “Expiration Policy”, which would see an authorization expire five years after its date of approval. Updating to current Commission’s policies included adding an expiration date to existing authorizations, as well as substituting the existing General Terms and Conditions with the recently revised July 2017 General Terms and Conditions.
Further, with the release of each new Building Code, the Commission will need to review its existing authorizations in an effort to eliminate authorizations that may no longer be required. The Commission believes that this is a necessary exercise to ensure the credibility and accuracy of the inventory of authorizations as reflected on the web-page. The Commission believes that the public needs to feel confident that the information in authorizations is current and accurate.
Recommendations to the Minister
The Commission continually reviews its existing authorizations to determine whether there is a need to make recommendations to the Minister regarding changes to the Building Code and/or whether there is additional need for revocation of authorizations based on the current edition of the Building Code.
On September 28, 2017, the Chair of the Commission wrote to the Minister in regard to the application fee set by the Building Code Act, 1992 for authorizations. The Commission suggested that it may be appropriate for the Ministry to re-evaluate the $11,000 fee that will come into effect in January 2018.
The Commission indicated a concern that the application fee may be implicated in recent reductions in the number of applications for authorizations and could have ramifications for business and innovation.
Time to decisions/authorizations
Following receipt of an Application, the Commission aims to make a decision or issue an Authorization within 120 days of the initial consideration by the Commission. This time frame is an accurate reflection of the average time frame the Commission requires to evaluate applications.
Some decisions on applications may be made quickly because there are already existing authorizations for similar technologies, which may be used to guide consideration of subsequent applications. New and innovative technologies may require longer approval times because references need to be checked, additional testing is sometimes required, missing information may need to be supplied, etc.
The Commission strives to be transparent in their process with respect to the evaluation of an application and to improve documentation of the evaluation process.
The Commission continues to monitor and review its processes for making decisions to determine if there are efficiencies that can be achieved.
Succession planning
As part of succession planning, the Commission believes it is necessary to have a longer period of overlap between sitting members and newly appointed members than has been afforded in the past. Ideally an overlap of nine months would allow for knowledge transfer from existing members to newly appointed members and permit new members to be mentored.
At the end of November 2016, and beginning of December 2016, seven new members were appointed to the Commission. While these new appointments enable the Commission to continue to operate, it is still appropriate to try and stagger the terms of appointment for Commission so that Orders in Council expire in smaller groups. This will allow for newly appointed members to be mentored by experienced members, and supports knowledge maintenance within the Commission.
In addition to ensuring an adequate number of members, the Commission must also work at maintaining the knowledge base of its membership so it is important for the Commission to continue to solicit new members with expertise that reflects the full spectrum of technical disciplines (e.g. plumbing, mechanical systems, on-site sewage systems, etc.). As described in the MOU, the role of the Chair includes keeping the Minister informed of upcoming appointment vacancies and providing recommendations for appointments and/or reappointments to the Commission.
Ontario’s gender diversity targets
In June 2016, Premier Kathleen Wynne announced new gender diversity targets to ensure more women have the opportunity to reach top leadership positions at provincial agencies and other government organizations. The Ontario government has set a target that, by 2019, women should make up at least 40% of all appointments to every provincial agency, board and commission.
With seven new appointments, the Commission currently consists of 11 members.
As of November 30, 2017, two (20%) of the 11 Commission members are female. This is significantly less than the government’s 2019 target for 40% female representation.
Past experience indicates that, in order to provide the Commission with a sufficiently diverse range of experience, a membership of 15 is optimal.
Assuming Commission membership is set at 15, a female membership threshold of six must be achieved by 2019 in order to meet the government’s 40% objective. Opportunities exist to achieve the 40% target for female representation on the Commission because the Commission will be seeking further appointments. Presently, there is a strategy in place that would increase the percentage of female representation on the Commission.
To assist in achieving the government’s objective, staff plan to network with leading professionals to identify potentially qualified female members and encourage qualified candidates, to apply for any future appointment opportunities utilizing the internal communications channels of organizations such as the:
- Ontario Society of Professional Engineers
- Professional Engineers of Ontario
- Ontario Network of Women in Engineering
- Canadian Association of Women in Construction
- Ontario Building Officials Association
- Ontario Association of Architects
Annual survey of clients
The Commission intends to continue its independent survey which assists the Commission in determining satisfaction with levels of service delivery.
Green initiatives
The Commission will work with the Ministry to examine viable means to reduce the environmental impact of services provided.
Overview of key activities
Staff supporting the Commission is responsible for application management and customer service to persons wishing to apply to the Commission for an authorization. Upon receipt of an application, the Commission’s Secretary ensures that the prescribed information and documentation has been submitted. The Secretary asks the Canadian Construction Materials Centre (the “CCMC”) whether they have examined, or expressed an interest in examining, a product. If the CCMC has examined, or expressed an interest in examining a product, the Commission may lack the jurisdiction to carry out an evaluation, pursuant to subsection 29(8) of the Building Code Act, 1992.
The Coordinator of Building Innovation is the senior Ministry staff person assigned to support the Commission, and is responsible for overall administration and policy development as directed by the Commission. This involves working with the Minister’s Office regarding the appointments process, issues management, business planning, performance measurement, monitoring of expenditures, and ensuring compliance with agency sector requirements and Treasury Board/Management Board of Cabinet directives.
The Commission, as a whole, is required to make decisions on applications, but subcommittees are usually established to carry out detailed evaluations. These subcommittees consist of Commission members who are familiar with, and/or expert in, the field of technology associated with the application. The Commission may request comments from Ministry technical staff.
The number of evaluations conducted, and subsequent authorizations issued, are determined based on the volume of applications received. Typically, the Commission holds one general meeting each month, with approximately five to seven subcommittee meetings in the same period. The issuance of decisions by the Commission usually takes three to four months, depending on the complexity of the application and the additional information required of the applicants and the timeliness of their response.
The chart below provides a summary of the Commission’s caseload over the last five years:
Chart 1
|
Fiscal year |
Applications received |
Authorizations issued |
Authorizations amended or revised |
Authorizations |
|---|---|---|---|---|
| 2013-2014 | 14 | 6 | 4 | 7 |
| 2014-2015 | 6 | 5 | 2 | 21 |
| 2015-2016 | 4 | 2 | 1 | 4 |
| 2016-2017 | 3 | 3 | 10 | 11 |
| 2017-2018* | 5 | - | 3 | 7 |
* The actuals for 2017-2018 do not reflect the entire fiscal period. The numbers are interim actuals that cover the period from April 1, 2017 to December 31, 2018.
The rate of applications to the Commission has had some fluctuations during the past five fiscal years. A marked increase is noted for the 2013-2014 fiscal year, this may in part be the result of the 2012 Building Code coming into force on January 1, 2014. The Commission notes that the decrease in the number of applications received for the current fiscal year may be the result of continuing increases in the application fee.
In addition to new applications, the Commission also considers requests for amendments to existing authorizations and also reviews its existing authorizations for possible revocation. Applications for amendment are processed in much the same manner as a new application. The Commission reviews and evaluates the details of the proposed amendment as innovative products, systems and designs are modified and updated. The process for review and revocation adds to the work load of the Commission and its staff.
The Commission has noticed that both the technical and procedural complexity of the applications has increased, which results in lengthier reviews. The work required to communicate between the Commission and applicants for authorizations has increased, in that the correspondence prepared to provide the reasoning behind the denial of an authorization or the denial of part of an authorization has become much more detailed in recent years. Further, the number of occasions where the Commission has had to undertake a significant jurisdictional review of an application has increased. All of these factors have an impact on the number of subcommittee meetings required to fully evaluate new and innovative products.
Achievements
Several steps have been taken to enhance the Commission’s performance and accountability over the past several years, including continued monitoring of Commission-specific performance measures. The Commission identifies the following achievements:
- continued to provide a cost effective and expeditious mechanism for evaluation of new and innovative materials, systems and building designs
- continued its practice of surveying clients after the close of the fiscal year (i.e. after March 31, 2017 for this business plan)
- survey results of clients that used Commission services in the 2016-2017 fiscal year indicated that:
- 100% felt that the processes and procedures were clear and understandable
- 100% felt that members demonstrated an appropriate level of expertise regarding the matter under consideration
- 100% felt that they were treated with courtesy throughout the application process and 100% felt they were treated with courtesy during the evaluation process
- 100% were satisfied with the overall level of service provided by the Commission
- the Commission continued to maintain its compliance with the Management Board of Cabinet’s Agencies and Appointments Directive:
- its three year Business Plan was prepared, finalized and submitted within the specified time frame
- its Annual Report for 2016-2017 fiscal year was completed and submitted within the specified time frame
Resources
Human resources
The Commission presently has a total of 11 part-time members. All members are appointed by Order-in-Council. Management Board of Cabinet’s Agencies and Appointments Directive permits individuals appointed to the Commission to serve a combined term of appointment of up to 10 years.
The following divisions of the Ministry support the Commission in fulfilling the Agencies and Appointments Directive:
- the Municipal Services Division’s Building and Development Branch
- the Municipal Services Division’s Building Services Transformation Branch
- the Business Management Division’s Corporate Services Branch
- the Business Management Division’s Controllership and Financial Planning Branch
- Legal Services Branch
- Community Services I&IT Cluster
The direct support staff assigned by the Ministry to the Commission consist of a 0.8 Full Time Equivalent (FTE) Commission Secretary, a 0.4 FTE Coordinator, Building Innovation, and a 0.4 FTE Administrative Assistant.
Financial resources
The Commission has no financial budget of its own. The Commission is supported by Ministry staff. The operating expenses for this Commission are funded through the Ministry of Municipal Affairs’ budget
The chart below provides details on the costs associated with supporting the Commission:
Chart 2A
|
Expense |
2016-2017 actuals1 |
2017-2018 interim actuals2 |
2018-2019 estimates |
2019-2020 estimates |
2020-2021 |
|---|---|---|---|---|---|
|
Per diems |
$109,877 | $50,056 | $112,000 | $112,000 |
$112,000 |
|
Travel/meeting |
$23,992 | $50,056 | $55,000 | $56,650 |
$58,350 |
|
Other |
$6,822 | $3,612 | $9,000 | $9,270 |
$9,550 |
|
Subtotal |
$140,6913 | $60,5134 | $176,0005 | $177,9205 |
$179,9005 |
|
Full time |
1.6 | 1.6 | 1.6 | 1.6 |
1.6 |
|
FTE costs |
$138,225 | $66,565 | $152,000 | $156,560 |
$158,000 |
|
TOTAL |
$278,916 | $127,078 | $328,000 | $334,480 |
$337,900 |
1 The Commission’s fiscal year runs from April 1 to March 31. The actuals for 2016-2017 cover the period from April 1, 2016 to March 31, 2017.
2 The interim actuals for 2017-2018 do not reflect the entire fiscal period, the numbers cover the period from April 1, 2017 to November 30, 2017, rounded to nearest dollar.
3 The operating expenses cover costs associated with meetings, per diems for Commission members and reimbursement for out-of-pocket travel expenses related to meetings, including hotel accommodations, meal allowances (to maximum allowed through the Travel, Meal and Hospitality Expenses Directive), parking and public transit.
4 Some expense claims were not reflected, as the claims have not been processed.
5 The number of meetings is determined by the application rate. Member per diem compensation rates are established by the Management Board of Cabinet’s Agencies and Appointments Directive applying to part-time OIC appointed members. The expenditure estimates for 2018-2019 and ongoing are based on typical application rates (using historical data and projecting forward) and member per diem compensation rates.
Revenues
Revenues in the form of application fees are recorded as part of the Ministry’s non-tax revenues.
Starting on January 1, 2015, the application fee increased from $950 as seen in the following fee schedule:
- $5,000 per application, effective January 1, 2015
- $7,000 per application, effective January 1, 2016
- $9,000 per application, effective January 1, 2017
- $11,000 per application, effective January 1, 2018
The chart below provides details of the revenues associated with applications to the Commission:
Chart 2B
|
Revenues |
2016-2017 actuals |
2017-2018 interim actuals1 |
2018-2019 estimates |
2019-2020 estimates |
2020-2021 |
|---|---|---|---|---|---|
|
Application fees |
$27,820 | $47,340 | $66,000 | $66,000 |
$66,000 |
|
Total revenues |
$27,820 | $47,340 | $66,000 | $66,000 |
$66,000 |
The actuals for 2017-2018 do not reflect the entire fiscal period. The numbers are interim actuals that cover the period from April 1, 2017 to November 30, 2017.
Communications plan
The agency communicates with applicants and potential applicants through appropriate publications, forms and instructions, either posted on its public Internet site or distributed on request.
Telephone and email inquiries are responded to by the Secretary of the Commission or the Coordinator of Building Innovation.
Environmental scan
Changes in demand
The increased complexity of applications received by the Commission and the move to green technologies, many of which may be considered innovative, will influence the need for appropriately skilled Commission members and the degree of administrative support required by the Commission. Skilled members and adequate staffing are required to maintain service levels.
When the 2012 edition of the Building Code came into force on January 1, 2014, the Commission began reviewing its existing authorizations against the new Building Code requirements to determine whether the Code has established requirements for materials, systems or building designs that were previously specified by individual authorizations.
A similar exercise will need to be undertaken when a new edition of the Building Code comes into force, these reviews may have an impact on the workload of the Commission.
In addition, the Commission instituted a five year expiry date on its authorizations. If current authorizations holders wish to continue to hold an authorization they would need to apply to the Commission every five years. This may have an impact on the workload of the Commission.
The increase in application fees may affect the number of applications received which would also have an impact on the workload of the Commission.
New commission members
The Commission will need to work at maintaining its membership both in terms of sufficient numbers of members and sufficient expertise to reflect the full spectrum of technical disciplines (e.g. plumbing, mechanical systems, on-site sewage systems, etc.). In addition, as noted above, the Commission will need to aim for gender diversity among its members in order to meet the government 40% target by 2019.
In previous Business Plans the Commission has indicated that it would be appropriate for new members to be appointed to the Commission before the existing membership had been decreased. This would allow existing members to mentor the newer appointees. Ideally an overlap of at least nine months would allow for knowledge transfer from existing members to newly appointed members and permit mentoring of new members.
While this did not occur for this round of appointments, the Commission strongly urges that this be taken into consideration for any future appointments.
Financial pressures
As part-time appointees, Commission members receive remuneration in the form of a per diem as established by Treasury Board/Management Board of Cabinet. This per diem ranges from $429 for members to $530 for the Vice-Chair and $676 for the Chair. Commission members are also reimbursed for out-of-pocket expenses associated with attending Commission meetings in Toronto and elsewhere in the province. Costs and expenses associated with Commission activities, including operating costs and member per diems, form part of the overall budget for the Ministry.
Changes to the Commission’s application rate and/or complexity of issues directly impact the Ministry’s budget in support of Commission activities.
Performance measures and targets
The Commission has adopted the recommendations for performance measurement established in 2000 by the Agency Reform (Guzzo) Commission. These are: fairness, accessibility, timeliness, quality and consistency, transparency, expertise, optimum cost, and courtesy. While not all of the goals were rated as “high” priorities for the Commission, there are processes in place to ensure that all goals are integrated into the Commission’s operation and are, therefore, adequately addressed. Chart 3 below indicates how the Commission rated the goals.
Chart 3
|
Goals |
Ranking |
|---|---|
|
Fairness |
High |
|
Accessibility* |
Low |
|
Timeliness |
High |
|
Quality and Consistency |
High |
|
Transparency |
Medium |
|
Expertise |
High |
|
Optimum Cost |
Low |
|
Courtesy |
Medium |
* It should be noted that the term “Accessibility” for the purposes of the performance measurement recommendations of the Agency Reform Commission was related to providing seamless and simple access so that the public can receive quality and timely services regardless of their familiarity with the system.
Performance measures were developed for goals that were rated “high” and “medium” in Chart 3 and the results of the Commission’s performance can be found in Chart 4.
Chart 4
|
Outcomes |
Measures | Targets | 2016 – 2017 status |
2018 – 2021 commitments |
|---|---|---|---|---|
|
Fairness |
Applicants are satisfied that the process was balanced, appropriate and fair. | No more than 10% of Commission decisions should result in judicial review on an annual basis. | Target met. No complaints or judicial reviews in the 2016 - 2017 fiscal year. |
Not more than 10% of Commission decisions should result in judicial review on an annual basis. |
|
Timeliness |
a) Average number of months from receipt of application to decision. | a) Decisions made within an average of four months after the first Commission consideration of an application. |
a) Target met. Decisions made within an average of four months after the first Commission consideration of an application. |
a) Decisions made within an average of four months after the first Commission consideration of an application. |
|
Timeliness |
b) Timely posting of authorizations on Commission Internet site. | b) 85% of authorizations will be posted on the Commission internet site within 10 working days after French translation has been received. | b) Target met. 85% of the final authorizations posted on the Commission internet site within 10 working days after French translation was received. |
b) 85% of authorizations will be posted on the Commission internet site within 10 working days after French translation has been received. |
|
Quality and consistency |
Applicants are satisfied that the Commission process was conducted with a high degree of quality and consistency. | 85% of applicants feel that the process had a high degree of quality and consistency. | Target met. 2016-2017 survey results indicate 100% of Commission clients felt that the process had a high degree of quality and consistency. |
85% of applicants feel that the process had a high degree of quality and consistency. |
|
Transparency |
Applicants are satisfied that the Commission process and procedures were clearly understood. | 85% of applicants feel that the process and procedures were clear and understandable. | Target met. 2016 -2017 survey results indicate that 100% of Commission clients felt that the process and procedures were clear and understandable. |
85% of applicants feel that the process and procedures were clear and understandable. |
|
Expertise |
a) Applicants are satisfied that the Commission members demonstrated an appropriate level of knowledge and technical competency | a) 85% of applicants feel that Commission authorizations reflected a high degree of technical knowledge and expertise appropriate to the proposal. | a) Target met. 2016 -2017 survey results indicate that 100% of Commission clients feel that Commission authorizations reflected a high degree of technical knowledge and expertise appropriate to the proposal. |
a) 85% of applicants feel that Commission authorizations reflected a high degree of technical knowledge and expertise appropriate to the proposal. |
|
Expertise |
b) Timely notice to the Minister’s Office regarding upcoming Commission member terms of appointment expiration. | b) Six months’ notice is provided to the Minister’s Office in advance of member’s appointments expiring. | b) Target met. The Minister’s Office was provided with six months’ notice in advance of member appointments expiring in the fiscal year 2016 - 2017. |
b) Six months’ notice will be provided to the Minister’s Office in advance of member’s appointments expiring. |
|
Courtesy |
Parties are satisfied that they were treated with courtesy throughout the application and evaluation process. | 80% of parties surveyed feel that they were treated with courtesy throughout the application and evaluation process. | Target met. 2016 -2017 survey results indicate that 100% of clients felt that they were treated with courtesy by Commission staff throughout the application process and 100% felt that they were treated with courtesy by the Commission members. |
85% of applicants feel that they are treated with courtesy throughout the application and evaluation process. |
Risk assessment
Based on the Commission’s strategic directions and objectives, the following two risks to performance have been identified. Mitigation strategies (including contingency plans, mitigation controls, and monitoring where required as part of prudent risk management protocols) are identified.
The Reference Impact and Probability Matrix used in this assessment is below.
Risk evaluation matrix
|
Impact |
Low Probability | Medium Probability |
High Probability |
|---|---|---|---|
|
High |
Mitigation controls / contingency plans |
Mitigation controls / contingency plans; monitor closely |
Take urgent remedial action; |
|
Medium |
Tolerate; monitor | Mitigation controls / contingency plans |
Mitigation controls / contingency plans; |
|
Low |
Tolerate; no action | Tolerate; monitor |
Mitigation controls / contingency plans |
Risk #1: Lack of knowledge transfer/succession planning impacting timeliness and quality
Issue:
Insufficient overlap between sitting members, whose terms are nearing expiration, and newly appointed members has historically resulted in slower processing of applications. Newly appointed members are unfamiliar with Commission processes; therefore there are delays in processing applications. Familiarity with past applications and Commission processes is important, and quality and speed of work suffers when there is insufficient overlap of member tenure.
The Commission has expressed an interest in having more overlap between sitting members and newly appointed members than has been afforded in the past.
Probability: medium
There are two members who reach their 10-year maximum term during the three fiscal years covered by this plan. However, seven members of the Commission will have their current term of appointment expire in November 2018, during the three fiscal years covered by this plan. If members are not interested in being reappointed, then this risk of insufficient knowledge transfer and reduced authorization production will increase.
Impact: medium
Extensive simultaneous changes in Commission membership can result in a disproportionate workload on some members, and creates difficulty in determining the appropriate composition of a hearing panel. Newer members, while they may be technically experienced, ideally should be phased in to learn the processes of the Commission.
The Commission Chair and staff will work with the government and the Public Appointments Secretariat to seek appointments of new members more often and in smaller groups, so that their terms of appointment do not all expire at once.
This strategy will allow the Commission to improve succession planning; achieve appointment overlaps, allowing for knowledge transfer from existing members to newly appointed members; achieve an appropriate balance of geographical representation; promote mentoring of new members; and achieve and maintain membership having expertise in all technical disciplines (structural, fire safety, plumbing, mechanical systems, on-site sewage systems, etc.).
With this risk being evaluated as "Medium" probability and "Medium" impact, the Commission, together with Ministry staff and other government bodies will develop strategies to distribute appointment expiry dates in a more staggered fashion.
Risk #2: Shortage of membership expertise
Issue
The Commission needs to ensure that the membership continues to consist of a sufficient number of members having the appropriate skills and expertise.
Probability: low
The Commission operates at its best with between 14 and 16 members, including the Chair and Vice-Chair. The membership currently sits at 11 members which is a satisfactory number of members for the Commission to fulfil its mandate. The Commission would benefit from an additional four to five members with emphasis on expertise in on-site sewage systems and HVAC/plumbing.
Impact: low
The Commission’s membership currently sits at 11 members. This is a satisfactory number of members to enable the Commission to fulfil its mandate.
With this risk being evaluated as "Low" probability and "Low" impact, the Commission will tolerate this risk and consider whether additional appointments would enhance the availability of Commission expertise.