What we examined (see Focus of the audit)

In 1990, Cabinet issued the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals. The Cabinet directive, supported by guidelines, requires federal departments and agencies to consider environmental concerns early in the planning of policy, plan, and program proposals before making irreversible decisions.

This audit focused on whether the departments and agencies we examined adequately applied the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals; reported on the extent and results of their strategic environmental assessment practices; and met their commitments to strengthen these practices.

This audit also focused on whether the Privy Council Office and the Treasury Board of Canada Secretariat had mechanisms in place to support departments and agencies in applying the Cabinet directive to proposals submitted to Cabinet, including the Treasury Board. We also examined whether these central agencies confirmed that departments and agencies fully considered the Cabinet directive when developing such proposals.

Why we did this audit

This audit is important because ministers and Cabinet need to consider potential environmental effects, both positive and negative, to make informed decisions about government policies, plans, and programs that affect Canadians.

What we concluded

We concluded that the Cabinet directive was not applied to most policy, plan, and program proposals submitted for approval to an individual minister or to Cabinet, including the Treasury Board. Overall, from January 2013 to December 2016, the departments and agencies we examined did not apply the directive to almost 80 percent of proposals. Only the Public Health Agency of Canada conducted preliminary assessments for all proposals submitted to Cabinet and for almost all proposals submitted to its Minister.

We also concluded that of the six departments and agencies we examined, only Public Safety Canada did not report as required on the extent and results of its strategic environmental assessment practices.

We further concluded that except for the Public Health Agency of Canada, the departments and agencies we examined did not make satisfactory progress in meeting the Federal Sustainable Development Strategy commitment to strengthen strategic environmental assessment practices.

Finally, we concluded that the Privy Council Office and the Treasury Board of Canada Secretariat had mechanisms in place to support departmental and agency compliance with the Cabinet directive. However, these central agencies did not work with the six departments and agencies we examined to confirm that they fully considered the Cabinet directive when developing proposals for submission to Cabinet, including the Treasury Board.

What we found

Applying the Cabinet directive

Overall, we found that the departments and agencies we examined did not apply the Cabinet directive to almost 80 percent of their proposals. Only the Public Health Agency of Canada prepared preliminary assessments for all proposals submitted to Cabinet and for almost all proposals submitted to its Minister. We also found that when departments and agencies did apply the Cabinet directive, they met the directive requirements we examined in most cases.

These findings matter because ministers need complete and timely information on any potential important environmental effects of the proposals they consider, to make informed decisions that support sustainable development.

• Five of six departments and agencies did not apply the Cabinet directive to most policy, plan, and program proposals

  Recommendation. The following departments and agencies should apply the Cabinet directive to all policy, plan, and program proposals submitted for approval to their individual ministers or to Cabinet, as required:

  • the Atlantic Canada Opportunities Agency,
  • the Canada Border Services Agency,
  • Canada Economic Development for Quebec Regions,
  • Public Safety Canada, and
  • Western Economic Diversification Canada.

• For most proposals to which the Cabinet directive was applied, preliminary assessments met the directive requirements we examined

  Recommendation. The following departments and agencies should ensure that they conduct strategic environmental assessments early in the life of proposals and document when the assessments took place, as required by the Cabinet directive:

  • the Atlantic Canada Opportunities Agency,
  • the Canada Border Services Agency,
  • Canada Economic Development for Quebec Regions,
  • the Public Health Agency of Canada,
  • Public Safety Canada, and
  • Western Economic Diversification Canada.

• Only Public Safety Canada did not report as required on the results of its strategic environmental assessment practices

  Recommendation. Public Safety Canada and Western Economic Diversification Canada should ensure that they report each year on the results of their strategic environmental assessment practices.

Strengthening strategic environmental assessment practices

Overall, we found that except for the Public Health Agency of Canada, the departments and agencies we examined did not make satisfactory progress in meeting the Federal Sustainable Development Strategy commitment to strengthen strategic environmental assessment practices. For example, we found that departments and agencies did not apply the Cabinet directive to all their proposals and that most departments and agencies needed to improve their guidance and tools on applying the directive.

This finding matters because strengthening strategic environmental assessment practices helps departments and agencies to ensure that they fully consider environmental concerns early in the conceptual planning stages of policy, plan, and program proposals, before irreversible decisions are made.

• Only the Public Health Agency of Canada made satisfactory progress in strengthening its practices

  Recommendation. The following departments and agencies should develop or improve their guidance and tools on strategic environmental assessment:

  • the Atlantic Canada Opportunities Agency,
  • the Canada Border Services Agency,
  • Canada Economic Development for Quebec Regions,
  • Public Safety Canada, and
  • Western Economic Diversification Canada.

Supporting compliance—role of central agencies

Overall, we found that the Privy Council Office and the Treasury Board of Canada Secretariat had put in place guidance and tools to help departments and agencies apply the strategic environmental assessment process to policy, plan, and program proposals submitted for approval to Cabinet, including the Treasury Board. However, we found that these two central agencies did not confirm that departments and agencies fully considered the Cabinet directive when developing such proposals.

This finding matters because confirming with departments and agencies that they fully consider the strategic environmental assessment process for proposals to Cabinet increases the likelihood that decision makers will have the information they need to make informed decisions on the proposals they consider.

• Central agencies did not confirm that the six departments and agencies we examined had fully considered the Cabinet directive for proposals submitted to Cabinet

  Recommendation. The Privy Council Office and the Treasury Board of Canada Secretariat should work with departments and agencies to help improve the application of the strategic environmental assessment process to proposals submitted for approval to Cabinet, including the Treasury Board, by

  • updating their guidance and tools to include a requirement that departments and agencies confirm they conducted a preliminary assessment or documented any exemptions from Cabinet directive requirements, and
  • confirming with departments and agencies that they fully considered the Cabinet directive.

Entity Responses to Recommendations

The audited entities agree with our recommendations and have responded (see List of Recommendations).

Related Information

Report of the	Commissioner of the Environment and Sustainable Development
Type of product	Performance audit
Topics	Climate Change Environment
Entities	Atlantic Canada Opportunities Agency Canada Border Services Agency Economic Development Agency of Canada for Quebec Regions Public Health Agency of Canada Public Safety Canada Western Economic Diversification Canada
Completion date	19 July 2017
Tabling date	3 October 2017
Related audits	Report 4—Review of the 2015 Progress Report of the Federal Sustainable Development Strategy, 2016 Fall Reports of the Commissioner of the Environment and Sustainable Development Report 3—Departmental Progress in Implementing Sustainable Development Strategies, 2015 Fall Reports of the Commissioner of the Environment and Sustainable Development Chapter 5—Departmental Progress in Implementing Sustainable Development Strategies, 2014 Fall Report of the Commissioner of the Environment and Sustainable Development Chapter 8—Federal and Departmental Sustainable Development Strategies, 2013 Fall Report of the Commissioner of the Environment and Sustainable

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