Review and Comments on the Draft 2016–2019 Federal Sustainable Development Strategy

24 June 2016

The Honourable Catherine McKenna, P.C., M.P.
Minister of Environment and Climate Change
Fontaine Building
200 Sacré-Coeur Boulevard, 2nd Floor
Gatineau, Quebec  K1A 0H3

Dear Minister:

I am pleased to provide you with my review and comments on the draft of the third federal sustainable development strategy, titled “Planning for a Sustainable Future: A Federal Sustainable Development Strategy for Canada 2016–2019, Consultation Draft” (the draft FSDS), which I received from Environment and Climate Change Canada on 26 February 2016.

Under the Federal Sustainable Development Act, the Minister of Environment (now the Minister of Environment and Climate Change) is required to prepare a federal sustainable development strategy based on the precautionary principle. The Act states that the Strategy “shall set out federal sustainable development goals and targets and an implementation strategy for meeting each target and identify the minister responsible for meeting each target.”

The consultation draft of the FSDS that was provided to my office was prepared within months of the new government being sworn in. I recognize that this has left little time for comprehensive policies and plans to have been put into place to support each of the goals and targets in the draft FSDS. I have also observed that a multi-pronged approach to consultation has been implemented in order to engage Canadians to comment on the draft FSDS. For example, an interactive electronic version of the draft FSDS has been posted. It provides reviewers with tools to search and navigate the content and to submit comments.

I am providing my review and comments in accordance with the duties specified under subsection 9(4) of the Federal Sustainable Development Act. Under the Act, I am required to review and comment on whether the targets and implementation strategies in the draft FSDS can be assessed.

This work was also conducted under the broader context of my mandate under subsection 23(2) of the Auditor General Act, which states that “the Commissioner shall, on behalf of the Auditor General, report annually to Parliament concerning anything that the Commissioner considers should be brought to the attention of Parliament in relation to environmental and other aspects of sustainable development.” With that in mind, the “Commissioner’s Perspective” that will be included in my Fall 2016 reports to Parliament will likely refer to some matters that came to my attention during my review of the draft FSDS.

The observations and comments that follow are based on a review of the draft FSDS. We carried out additional examinations to ensure that we correctly understood key elements in the draft FSDS strategy. We met with departmental officials to present our interim findings on 21 April and 19 May 2016.

International sustainable development goals and targets are incorporated into the draft Federal Sustainable Development Strategy

We found that the draft FSDS incorporates targets from international agreements such as the 2015 Paris climate conference agreement (target 1.1—National Leadership on Climate Change) and the Convention on Biological Diversity (for example, targets 3.3—Terrestrial Ecosystems and Habitat Conservation and 3.5—Marine Ecosystems).

I was pleased to find that the draft FSDS also refers to the 2030 Agenda for Sustainable Development. The 2030 Agenda, adopted by United Nations member states (including Canada) in September 2015, provides the global framework for sustainable development for the next 15 years. It integrates the social, economic, and environmental dimensions of sustainable development as well as peace, governance, and justice elements. The 2030 Agenda includes 17 Sustainable Development Goals, which are in turn supported by 169 targets.

For each of the goals in the draft FSDS, the corresponding goals from the 2030 Agenda are identified. Overall, 12 of the 17 sustainable development goals from the 2030 Agenda are referenced in the draft FSDS.

I noted, however, that the draft FSDS does not refer to the Agenda 2030 targets. I would encourage the Government of Canada to consider how the Agenda 2030 targets can be integrated into the FSDS.

The draft Strategy identifies the responsible ministers, departments, and agencies

We found that the draft FSDS clearly identifies the minister responsible for each of the 36 targets. Furthermore, each of the 36 targets contained in the draft FSDS clearly identifies the federal departments, agencies, or organizations that are responsible for contributing to each target.

All 26 federal departments and agencies that are required to prepare departmental sustainable development strategies under the Federal Sustainable Development Act have been assigned responsibility for contributing to FSDS targets 1.4, 1.5, 2.2, and 2.3, which relate to greening government operations or reducing the operational footprint of the federal government. However, the role of Public Services and Procurement Canada, which may include significant coordination related to greening government operations, has not been defined. It should be explained in the final FSDS.

Of these 26 departments and agencies, 19 have been assigned responsibility for contributing to FSDS targets that are not related to greening government operations. This number represents some improvement since our last assessment, which we reported in the 2013 Fall Report of the Commissioner of the Environment and Sustainable Development, Chapter 8—Federal and Departmental Sustainable Development Strategies. In that assessment, we found that only 16 departments and agencies had been identified as being responsible for targets that were not connected to greening government operations.

I am pleased to note that, in addition to these 26 departments and agencies, another 11 federal departments, agencies, or organizations have been identified as being responsible for contributing to the achievement of the targets (see Annex 4 of the draft FSDS).

Clear priorities have been identified in the draft Strategy

Through its goals, targets, and narrative, the draft FSDS generally identifies the key priorities of the government. Overall, we found the issues addressed in the draft FSDS to be important and reflective of some of the environmental challenges facing Canadians. We found, however, that the draft FSDS does not fully address the sustainable development challenges facing Canadians. In its June 2016 report, “Federal Sustainability for Future Generations – A Report Following an Assessment of the Federal Sustainable Development Act,” the Standing Committee on Environment and Sustainable Development recommended that the Government of Canada introduce amendments to the purpose provision of the Federal Sustainable Development Act

• to lead Canada on a path towards sustainable development and contribute to meeting the United Nations sustainable development goals, and
• to clarify that sustainable development encompasses and requires thorough consideration of economic, social, and environmental factors.

I completely support the Committee's recommendation.

While the 2010–2013 FSDS and the 2013–2016 FSDS contained over 200 implementation strategies, the current draft 2016–2019 FSDS contains 91 implementation strategies. The reduced number of implementation strategies has helped to improve the Strategy as a tool for communicating the government’s priorities during the consultation process.

Some targets and all implementation strategies are difficult to assess

When compared to the 2013–2016 FSDS, we found that there has been some improvement in the 2016–2019 draft FSDS regarding the extent to which the targets can be assessed. We found, however, that some of the targets, and all of the implementation strategies, require attention. Improvements to the design of the targets and implementation strategies could facilitate the ability of departments to make meaningful contributions through their departmental sustainable development strategies. Moreover, problems with the design of the targets and implementation strategies will affect the government’s ability and our ability to assess progress that is made.

Targets have improved since 2013, but details on their achievability are insufficient

Overall, the targets in the draft FSDS show improvements against 4 of the 5 criteria when compared to our assessment in 2013. However, for the remaining criterion, we found that the targets provide insufficient information to help assess whether they can be achieved. The criteria we used to assess the targets were whether they were relevant, measurable, time-bound, specific, and achievable. Our findings related to these criteria are as follows:

• Relevant—We found that all 36 targets are relevant, as they align with the five goals of the draft FSDS.

• Measurable—We found that 25 of the 36 targets (69 percent) are measurable. This represents a significant improvement compared with our 2013 finding that 38 percent of the targets included indicators or another approach that was measurable.

• Time-bound—We found that 28 of the 36 targets (78 percent) are time-bound. Again, this was an improvement compared with our 2013 finding that 53 percent of the targets were time-bound. Four of the current targets have identified interim targets, which is an improvement since our assessment in 2013.

• Specific—We found that 19 of the 36 targets (53 percent) are specific. Again, this is an improvement, as our 2013 finding was that 29 percent of the targets met this criterion.

• Achievable—We found that, given the lack of detail in nearly all of the implementation strategies (see the section on implementation strategies), we were unable to conclude on whether the targets were achievable. The information provided in the draft FSDS is insufficient to assess whether a particular set of implementation strategies will have a sufficient direct impact on progress in reaching each target.

With sufficient resources and actions, it might be possible to achieve all of the targets contained in the draft FSDS. However, given the limited information presented in the draft FSDS, we cannot conclude that the targets are achievable. Moreover, some of the findings from our past audit reports do not support the achievability of the stated targets.

For example, target 1.1 of the draft FSDS is to reduce Canada’s total greenhouse gas emissions by 17 percent by 2020 and 30 percent by 2030, relative to 2005 emission levels. In our 2012 Spring Report, Chapter 2—Meeting Canada’s 2020 Climate Change Commitments, we concluded that the federal regulatory approach was unlikely to lead to emission reductions sufficient to meet the 2020 target. Two years later, in our 2014 Fall Report, Chapter 1—Mitigating Climate Change, we concluded that the evidence was stronger that the growth in emissions would not be reversed in time, and that the target would be missed. In light of these previous audit findings, the information in the draft FSDS does not allow us to conclude that the planned implementation strategies and related activities will be sufficient to meet the 2020 target.

Target 3.5 of the draft FSDS sets ambitious targets for the conservation of coastal and marine areas through networks of protected areas and other effective area-based conservation measures. In the 2012 Fall Report of the Commissioner of the Environment and Sustainable Development, Chapter 3—Marine Protected Areas, we reported that Fisheries and Oceans Canada estimated that marine protected areas (MPAs) covered about 1 percent of Canada’s marine environment. At that time, we concluded that it would likely take many decades for Canada to achieve the target to conserve 10 percent of marine areas under the United Nations Convention on Biological Diversity. Environment and Climate Change Canada’s 2015 Progress Report of the Federal Sustainable Development Strategy states that as of 2014, MPAs covered only about 1 percent of Canada’s marine environment. Given our past audit findings, and the lack of progress since then, the information in the draft FSDS does not allow us to conclude that the planned implementation strategies and related activities will be sufficient to meet the 2017 target of 5 percent or the 2020 target of 10 percent.

Implementation strategies are not as specific or measurable as they could be

Overall, the 91 implementation strategies presented are relevant. However, all implementation strategies are not as specific or measurable as they could be, which will affect the ability of departments to report on performance and progress. The criteria we used to assess the implementation strategies were whether they were relevant, measurable, and specific. Our findings related to these criteria are as follows:

• Relevant—We found that all of the implementation strategies are relevant, as they align with all of the goals and targets contained in the draft FSDS.

• Measurable—We found that none of the 91 implementation strategies are supported by indicators or other measurement approaches. In guidance that Environment and Climate Change Canada has provided to departments regarding the development of implementation strategies for departmental sustainable development strategies, it has encouraged departments to develop supporting indicators or measurement approaches. In our opinion, the same approach should be applied to the FSDS.

• Specific—We found that nearly all of the 91 implementation strategies are not specific. While the implementation strategies are clear and understandable, they are generic; that is, they do not provide details to show how results will contribute to meeting the targets set out in the draft FSDS.

Plans to integrate sustainable development considerations into decision making are missing

In the Federal Sustainable Development Act, Parliament acknowledged the need to integrate environmental, economic, and social factors into the making of all decisions by government. In Annex 1, the draft FSDS states that it supports integrated decision making through strategic environmental assessments (SEAs), and highlights some of the key requirements of the Cabinet Directive on SEAs. This includes the requirement that departments and agencies must consider the potential impact of their proposals on FSDS goals and targets when conducting SEAs. In our 2013 Fall Report, Chapter 8—Federal and Departmental Sustainable Development Strategies, we recommended that Environment and Climate Change Canada should lead work aimed at including targets and implementation strategies related to integrating sustainable development considerations into decision making.

In 2013, 2014, and 2015, we found that many federal departments had not conducted the strategic environmental assessments required by the Cabinet Directive to policy, plan, or program proposals that are submitted to a Minister or Cabinet for approval. I am referring to

• the 2013 Fall Report, Federal and Departmental Sustainable Development Strategies;
• the 2014 Fall Report, Departmental Progress in Implementing Sustainable Development Strategies; and
• the 2015 Fall Report, Departmental Progress in Implementing Sustainable Development Strategies.

The draft FSDS does not specifically provide a target, plan, or steps to ensure the systematic integration of sustainable development considerations into decision making.

Financial information and resource needs are not included

In 2013, we recommended that Environment and Climate Change Canada, with the support of other departments and agencies, should begin to incorporate financial and resource information into the FSDS. We found that the 2016–2019 draft FSDS contains limited information on the financial or other resources that are required, or the savings that could be achieved from operating in a more sustainable manner. In our view, this information is essential to show the importance of targets and how they will be achieved. In addition to providing more transparency, including financial and resource information in the FSDS will give a more complete picture of the government's investments in sustainable development.

Conclusion

Overall, we found the issues addressed in “Planning for a Sustainable Future: A Federal Sustainable Development Strategy for Canada 2016–2019, Consultation Draft” to be important and reflective of the environmental challenges facing Canadians. We found, however, that the draft FSDS does not fully address the sustainable development challenges facing Canadians.

Many aspects of the draft FSDS targets show improvements since our assessment in 2013. We found, however, that there has been no improvement in relation to the information needed to assess whether the targets are achievable. All implementation strategies are not as specific or measurable as they could be, which will affect the ability of departments to report on performance and progress.

I have not identified any new recommendations, as I believe that the recommendations made in 2013 are still valid. Furthermore, they are consistent with recommendations that the Standing Committee on Environment and Sustainable Development made in its June 2016 report, “Federal Sustainability for Future Generations – A Report Following an Assessment of the Federal Sustainable Development Act.”

The government still has time to address the findings presented in this letter prior to finalizing the 2016–2019 FSDS. We would be happy to continue discussions with Environment and Climate Change Canada, as we believe that the FSDS could be an important tool for action by the federal government on environmental and sustainable development matters.

Yours sincerely,

[Original signed by]

Julie Gelfand
Commissioner of the Environment and Sustainable Development