The Capital Asset Reference Guide (the CARG) was developed by BC’s Ministry of Advanced Education for use by BC’s public post-secondary institutions in connection with capital projects that are funded by the Ministry, whether in whole or in part. The CARG was informed the Provinces Capital Asset Management Framework (the CAMF) and by a study undertaken by the Ministry on capital planning, approvals, implementation close out processes employed in other government agencies in BC and other jurisdictions. The current version of the CARG (Version 1.1, April 10, 2013) can be found at http://www.aved.gov.bc.ca/cppm/ and replaces the previous version of February 20, 2013, which in turn replaced the edition which was last updated in 2005.
The CARG is intended to ensure that governmental planning and institutional priorities are effectively communicated and realized and that there is a high level of accountability in relation to capital investments, as contemplated in the Government’s Accountability Framework Standards Manual. The CARG is a comprehensive document which sets out a framework for analysis and decision making and it reflects developing best practices in relation to the procurement of publicly funded capital assets, regardless of the sector. Although the CARG does not apply to projects which are not funded by the Ministry (for instance, campus parkades and food service facilities), many of the principles in the CARG would be of assistance with regard to decision making in relation to these sorts of projects as well.
Objectives of the CAMF
The CARG reflects two key objectives of the CAMF: (a) to establish best practices across the public sector; and (b) to support provincial public-sector agencies to think creatively and find the most efficient ways to meet BC’s infrastructure needs. A key theme is accountability, with the institutions accountable to their respective Ministries and the Ministries and institutions accountable to the public. As part of this accountability, institutions are required to submit reports and plans which form part of the long term financial planning process of the Government as set out in the Accountability Framework Standards Manual.
Categories of Capital Project
The CARG identifies five different categories of capital project, each of which is subject to different requirements:
- New Priority Projects, the primary driver for which is to accommodate growth and labour market demand capacity with a secondary benefit of new system capacity;
- Whole Asset Replacement and Renewal Projects, the primary driver for which is to improve the condition of the institution’s physical assets and reduce deferred maintenance backlog, with a secondary benefit of increased system capacity due to functional efficiency;
- Innovation Projects, the primary driver for which is to improve efficiency in the delivery of core programs with a net positive financial return over the lifecycle of the capital asset, with a secondary benefit of new system capacity or increased capacity, or maintenance or extension of the life of or, a modification to, infrastructure;
- Maintenance and Rehabilitation Projects, broken into Major Projects (which are >$250,000), Minor Projects (which are $250,000) and Emergency Projects. The primary driver for these types of Projects is to improve the condition of assets and reduce deferred maintenance backlog, with a secondary benefit of maintaining or extending the life of the asset; and
- Upgrade and Renovation Projects, the primary driver of which is to improve functionality, efficiency or for policy reasons (such as heritage preservation) with a secondary benefit that existing infrastructure is required but does not result in net new programming.
For each of the five categories of project, the CARG sets out a detailed capital planning, approval and implementation flow chart. The CARG sets out the process to be followed from the initial identification of a possible project or opportunity through initial assessment and evaluation during the planning stage, through Ministerial approval, progress reporting during implementation and close-out reporting on completion. The requirements vary depending on the nature and cost of the project. The expectations and requirements for each category of project are set out in detail, including illustrative time lines and expectations of the cost of planning processes in relation to the overall cost of the project.
Process for Capital Projects
Typically, following identification of an opportunity or idea, the institution will prepare an opportunity assessment report followed by a capital project proposal. The project will be evaluated through a concept plan report and, where the concept plan warrants further development, a business case report.
If the project is approved, depending on the scale of the project, the Ministry will issue a letter of approval or a certificate of approval. As the project is implemented, the institution will prepare a design development report, quarterly financial and progress reports, a project risk register, a procurement report, a year end funding summary and year end expenditure report. The Ministry may audit the activities and reports of the institutions at any time, and in particular, with respect to compliance with the procurement process mandated by the CARG. Upon completion, there will be a financial and compliance report and a project close out report. We are advised by the Ministry that the various reports required by the CARG are reviewed by the Ministry and the Ministry follows up to ensure that they address the Ministry’s concerns in order to permit continued funding of the projects on the basis upon which they were approved.
Projects with a cost in excess of $50 Million remain subject to the requirement that they must be evaluated by Partnerships BC during the concept plan report phase to determine if they should be developed as public-private partnerships.
Dispositions of Property
The CARG references the obligation of institutions to obtain the approval of the Ministry before making a disposition of property (see section 50(2) of the University Act and see section 50(2) of the College and Institute Act). The CARG outlines the procedure and gives guidance on timing for these approvals. In addition, the CARG reminds institutions of the government’s duty to consult with First Nations in connection with dispositions. The CARG states that institutions are to engage with First Nations as soon as they identify a proposal to dispose of land and have information about a proposed future use of the lands. The extent of consultation and possible accommodation required will be identified in consultation with the Ministry and its advisors and will depend on the impacts of the disposition on the relevant First Nation(s) when the Province determines whether or not it will give its approval.
The CARG is 94 pages long and is followed by Appendices A through H, which are process flow charts for the various categories of project. The CARG is fulsome in its detail on procedures, processes and reporting. It should help ensure that capital expenditures are thoroughly evaluated and thought through. If followed, the CARG should also give institutions confidence that they will know the steps to be undertaken to obtain Ministry support for worthwhile projects.
Clark Wilson LLP would like to thank Catherine Nickerson (Director, Post-Secondary Capital) and Raj Goyal (Manager, Post-Secondary Capital) of the Ministry of Advanced Education for their insight and comments on this article.