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1993 Report of the Auditor General of Canada
Chapter 14—Department of the Environment—The Control and Clean-up of Freshwater Pollution
Main Points
Introduction
Importance of Fresh Water
Background
Previous Observations on Clean-up Programs
Jurisdictional complexities
Lack of a Great Lakes strategic plan
The Action Plan Approach to Water Quality
General Audit Scope
The Interdepartmental Committee on Water
Audit Criteria
Observations and Recommendations
Leadership opportunity
Need for advice on action plans
Need for improved monitoring and reporting
Need for federal strategic planning on water quality
The St. Lawrence and Fraser River Action Plans
Audit Criteria
The St. Lawrence Action Plan
Background
Observations and Recommendations
Lack of interdepartmental co-ordination
Co-ordination of federal and provincial activities
Clarity of objectives
Need for strategic planning
Mobilization of non-governmental stakeholders
Action plan management
Program evaluation
Program evaluation must be timely
Evaluation must address the strategic goal of the program
Evaluation findings can be used to improve programs
Accountability reporting
Incomplete information could be misleading
Fraser River Action Plan
Background
Contribution to the sustainable development of the basin
Observations and Recommendations
Lack of interdepartmental co-ordination
Stakeholder involvement
Cleaning up pollution
Renewing the productivity of the environment
A management program for sustainable development
Program evaluation
Conclusions and Lessons Learned
Need for a Federal Framework of Water Quality Objectives
Need for Federal Long-term Strategic Planning
Key Criteria for Successful Partnerships
Evaluating and Reporting on Action Plans
Assistant Auditor General: Elwyn Dickson
Responsible Auditor: Wayne Cluskey
Main Points
14.1 The federal government is implementing action plans to improve water quality in several areas, including the Great Lakes, the St. Lawrence and Fraser rivers and along the Atlantic Coast. The audit of the St. Lawrence and Fraser River action plans indicates that they are producing some positive results, while providing lessons to be learned and applied in future programs.
14.2 In view of the many interested parties involved in water management and use, the successful delivery of individual action plans depends on partnerships between governments, and among governments, industry and other stakeholders.
14.3 The Department of the Environment should be providing strong leadership, through the Interdepartmental Committee on Water, for the effective co-ordination and implementation of the action plan process.
14.4 While the St. Lawrence and Fraser River action plans are being managed satisfactorily at the regional level, there is a need for long-term strategic planning at the national level to achieve desired water quality objectives. This would involve the development of a federal framework of water quality objectives for major individual ecosystems, based on user needs, that can help to ensure the best allocation of limited resources. The present Canadian Water Quality Guidelines provide the scientific basis for such objectives.
14.5 Action plans should be subject to timely and comprehensive program evaluation to determine the degree of success in achieving objectives and in efficient use of resources.
14.6 Parliament and the public need information to help them determine the extent of progress of clean-up activities and assess the use of resources to achieve improvements in water quality.
Introduction
Importance of Fresh Water
14.7 Fresh water is one of Canada's most valuable natural resources. As a former Minister of the Environment said in the introduction to the Federal Water Policy released in 1987:Water is a remarkable substance...It is the genesis of and the continuing source of life. Without water, humankind - indeed, all forms of life on Earth - would perish.14.8 A significant portion of the world's fresh water is found in Canada. Much of this water drains toward the north, whereas approximately 90 percent of our population lives near the southern border. The availability of water in the most densely populated part of Canada is limited, and water is used extensively for a variety of purposes, including drinking water and agricultural and industrial processes. As a result, where water is in greatest demand it is also more susceptible to heavy pollution from a variety of sources, such as sewage disposal, agricultural run-off and industrial effluents. If the impacts of this pollution on human health and on fish and wildlife are to be avoided, all stakeholders must contribute to controlling the sources of pollution and enhancing water quality. The fact that pollution and water quality problems cross many jurisdictions leads one to conclude that there is a need for strategic planning to develop a national approach to water quality improvement. The approach should have the support of major stakeholders and accommodate the user demands on different ecosystems across the country. The Canadian Water Quality Guidelines, prepared by the Canadian Council of Ministers of the Environment, are now being used to establish water quality objectives at the regional action plan level. However, these need to be viewed in a national context to guide governments in planning programs and assigning limited resources on an ecosystem basis.
Background
Previous Observations on Clean-up Programs
Jurisdictional complexities
14.9 Our 1990 Report on the Department of the Environment included the observation that "the general public believe that governments at all levels must take immediate, co-ordinated and decisive action to halt further deterioration of the environment." Furthermore, we noted that the "consequence of these federal-provincial and interdepartmental divisions in responsibility for environmental matters is a patchwork that makes it almost impossible to assign public accountability for safeguarding Canada's environment." There is some evidence of improvement since then. However, the need for improved co-ordination and co-operation among federal departments, among different levels of government and with industry and environmental interest groups is still evident. Collective action by stakeholders is essential for the successful implementation of environmental programs.
Lack of a Great Lakes strategic plan
14.10 In 1991 we reviewed one of Canada's water quality control and clean-up initiatives in action - the Great Lakes Action Plan. Although this action plan was being managed adequately at the regional level, there was no strategic planning at that level to guide Canada in meeting its overall commitments to the Canada-USA Great Lakes Water Quality Agreement. A Canada-Ontario strategy was drafted, but as of 30 April 1993 had not been finalized. After conducting a follow-up to our audit, in 1992, we remained concerned about co-ordination of clean-up initiatives, and the lack of action by the federal Interdepartmental Committee on Water to address this particular problem at the national level. Subsequent to our follow-up, an ad hoc sub-committee was formed in late 1992 to prepare a strategic framework for the proposed second phase of the Great Lakes Action Plan. It should be noted that Cabinet made the parent Committee responsible for co-ordinating the federal components of that Action Plan.
The Action Plan Approach to Water Quality
14.11 In 1987, the Minister of the Environment released the Federal Water Policy developed under the Canada Water Act . This, together with the Canadian Environmental Protection Act , forms the legislative base and the federal policy framework for developing and implementing the federal components of action plans. The Federal Water Policy names the Interdepartmental Committee on Water as "the focal point for co-ordinating the policy among federal departments and agencies." It is chaired by the Department of the Environment. The policy also provides the strategic link between federal and provincial responsibilities for water quality. Thus, the Committee has a key role to play in co-ordinating federal-provincial action plans.14.12 The action plan approach addresses the ecosystem itself, in that it focusses on such items as the restoration and protection of wildlife habitat, protection of endangered species, and improvements in water quality and in overall ecosystem productivity. A variety of water quality programs are currently being implemented by the federal and provincial governments in most major ecosystems across Canada. Major efforts are being directed toward specific polluted ecosystems in the most densely populated areas of the country. Examples of these are the action plans operating for the St. Lawrence River (1988), the Great Lakes (1989), the Fraser River (1991) and the Atlantic Coast (1991). Together, the areas covered by these four plans comprise a significant portion of Canada's land mass (see Exhibit 14.1 ). Federal input to these action plans is entrusted to regional managers of participating departments who, with their provincial counterparts, are responsible for clean-up and related activities, such as the restoration and protection of wildlife habitat.
General Audit Scope
14.13 To assess the management of water quality improvement in the current action plan process, we examined both policy and operational elements. We looked at the Federal Water Policy as the source of direction for federal input to action plans, and at the role of the Interdepartmental Committee on Water in implementing this policy. We also examined the five-year St. Lawrence Action Plan begun in 1988, and the six-year Fraser River Action Plan introduced in 1991 as one of the Green Plan initiatives. This gave us an appreciation of an action plan whose first phase was close to completion at the time of our audit (St. Lawrence) and another that was in the early stages of implementation (Fraser River). We examined the implementation of the Federal Water Policy, and related strategic and operational issues. These issues are particularly important because water quality clean-up programs are complex, costly and difficult to implement. As progress may occur only over long periods, clear objectives and long-term resource commitments to individual plans by all parties are essential to ensure optimum value from expenditures. Examples of this are seen in the Great Lakes, where water quality clean-up has been going on for over twenty years, and in the St. Lawrence Action Plan, where the federal government has already announced a second phase to the program.14.14 The audit focussed on the Department of the Environment's responsibilities for, and activities under, the water quality aspects of these action plans. However, we also interviewed other federal and provincial government officials and private sector participants involved in the clean-up, to gain an appreciation of the Department's role and those of others.
The Interdepartmental Committee on Water
Audit Criteria
14.15 In keeping with its mandate, we expected to find that the Interdepartmental Committee on Water was monitoring and reporting on how the Federal Water Policy is applied to the action plan process, and how the process is linked to such federal-provincial co-ordinating bodies as the Canadian Council of Ministers of the Environment. We expected that, in carrying out its review and reporting role, the Interdepartmental Committee on Water would provide a focus for the development of a federal strategy to guide decision makers in the implementation of federal water quality improvements across Canada. In addition, we expected that the Committee would serve as the focal point for developing federal advice to the Minister of the Environment for federal-provincial discussions on this subject. Furthermore, we expected to find that the various federal components of action plans were co-ordinated effectively and that the means were in place to handle interdepartmental conflicts over policy, planning and funding as action plans are implemented.
Observations and Recommendations
Leadership opportunity
14.16 The Department of the Environment provides both the chairperson for the Interdepartmental Committee on Water and the Committee's Secretariat. It is also responsible for the Committee's agenda and for reporting to the Minister of the Environment on the Committee's work. The Committee has a wide range of water-related responsibilities, including water quality, one of the main components of action plans.14.17 The Federal Water Policy and the Terms of Reference of the Interdepartmental Committee on Water clearly give the Committee the authority to deal with all federal aspects of action plans, from strategic planning through to implementation of individual plans. In addition to the Department of the Environment, eight other departments with major water-related responsibilities are members of the Committee. Representatives from central agencies attend as observers. Its breadth of expertise, along with the government's intent to apply the policy through both federal-provincial and international co-ordinating mechanisms, give the Committee the status necessary to provide advice on water policy issues to federal departments and to federal-provincial bodies, such as the Canadian Council of Ministers of the Environment.
14.18 Given its strong terms of reference, its responsibilities under the Federal Water Policy and its membership of key departments, the Interdepartmental Committee on Water would be expected to provide federal leadership with respect to action plans. Activities could include developing a federal position on the need for the establishment of water quality objectives for each major ecosystem; and offering information and advice on water quality issues to the federal Minister of the Environment.
14.19 The Green Plan reaffirmed the goals and strategies of the Federal Water Policy, thereby recognizing its application to the government's movement toward sustainable development. In effect, the Green Plan broadened the Committee's area of responsibility, giving it the opportunity to advise on environmental issues that involve any aspect of water management or use under federal jurisdiction - including action plans.
14.20 The Committee has the responsibility and authority, the expertise and, with its major role in the Great Lakes Action Plan, the precedent to provide leadership for the action plan process. By virtue of its requirement to report to the Minister of the Environment, it can have action plan issues placed on the joint agenda of the federal and provincial governments through the Canadian Council of Ministers of the Environment.
Need for advice on action plans
14.21 Since receiving its new mandate in 1987, the Committee has not taken an active role, except for the Great Lakes Action Plan, in guiding the action plan process. There is little evidence that it has advised the Minister of the Environment on federal strategic planning for the action plan process, on related long-term implications, or on federal requirements under the Federal Water Policy to implement such a strategy. For example, no formal positions have been taken on any of these matters that could be useful to regional managers responsible for strategic and operational planning at the local level.
Need for improved monitoring and reporting
14.22 The Interdepartmental Committee on Water has recognized the need for more involvement in monitoring the implementation of the Federal Water Policy. The Committee recommended in its first Report, in 1990, that it "be used as a forum for improving integrated decision making at the federal level for policies and programs that may affect water." However, a review of Committee minutes and other documentation showed no evidence of any change in the Committee's functioning since then.14.23 In the draft of its second Report, covering the period 1991 to 1992, the Committee indicates that it intends to develop, on a priority basis, a report on the need for and timing of a comprehensive review and, if necessary, revision of the Federal Water Policy in light of current and emerging water-related issues subject to federal jurisdiction. This would provide an opportunity to examine the Committee's role in guiding the action plan process and in advising on the implementation of individual plans. The report is expected to be completed toward the end of 1993.
Need for federal strategic planning on water quality
14.24 Although initially conceived as a response to a specific pollution problem, e.g., in the Great Lakes, federal-provincial action plans now appear to be the preferred management approach to clean up polluted ecosystems across the country. However, Canada has no federal strategic plan for the water quality action plan process, to guide the development and implementation of its component individual action plans. Such a strategic plan could incorporate a federal framework of water quality objectives for each major ecosystem, developed in co-operation with major stakeholders. The framework could provide valuable benchmarks for future federal-provincial agreements on water quality control and clean-up, and could form the basis for setting priorities and allocating resources.14.25 In our opinion, the absence of a federal strategic plan hampers the development of links among action plans. For example, there is an obvious connection between the Great Lakes and St. Lawrence action plans: water quality in the St. Lawrence is significantly influenced by conditions prevailing in the Great Lakes and both have international impacts. However, we saw little evidence that decisions on program priorities and funding for either action plan recognize this relationship and take it into account. The lack of a federal strategic plan may also contribute to problems in funding, co-ordinating, evaluating and reporting on federal input to action plans. ( see Special Insert )
14.26 The Department of the Environment should, through the Interdepartmental Committee on Water or some similar mechanism, ensure that there is appropriate:
- discussion of the need for, and feasibility of, a federal framework of water quality objectives for major ecosystems across the country, based on user requirements; and
- discussion of the need for a federal strategic plan for the action plan process, which would incorporate such a framework as the guide for setting priorities, allocating resources and evaluating and reporting progress toward objectives for individual action plans.
The St. Lawrence and Fraser River Action Plans
14.27 The quality of water in the St. Lawrence and Fraser rivers is important to the health and economic well-being of approximately seven million Canadians. To improve and protect these two ecosystems, various departments of the federal government, with provincial, municipal and private sector co-operation, are acting to control pollution, clean up contaminated areas and enhance the productivity of these waters. Our audit focussed mainly on the contribution of the Department of the Environment to improving water quality under the St. Lawrence and Fraser River action plans.
Audit Criteria
14.28 We expected to find that: 1) partnership agreements or memoranda of understanding were in place and that they clearly spelled out the roles and responsibilities of major players; 2) action plan objectives were clearly defined and documented; 3) an appropriate action plan management structure was in place; 4) progress toward stated objectives was measured; and 5) results of action plan activities were appropriately reported to Parliament and the public.14.29 We applied all five audit criteria to the first phase of the St. Lawrence Action Plan, which concluded in March 1993. However, we excluded the reporting criterion from our review of the Fraser River Action Plan, because it was still in an early stage.
The St. Lawrence Action Plan
Background
14.30 The St. Lawrence River basin is the most heavily populated (five million people) and most highly industrialized area of Quebec. The river is the economic hub of the province, a major source of drinking water and a vital transportation link between the Atlantic Ocean and the Great Lakes. With its freshwater, brackish and saltwater ecosystems, the St. Lawrence River provides essential habitat for numerous species of fish, animals and birds.14.31 The federal and provincial governments have conducted a number of studies in the St. Lawrence River basin since 1970. However, it was not until 1988 that the federal government focussed its efforts on the river's water quality, through the St. Lawrence Action Plan. The Plan had a budget of $110 million spread over the five-year period ending 31 March 1993. Responsibility for financing and implementing the Plan is shared by three federal departments - Environment; Industry, Science and Technology; and Fisheries and Oceans: their total contributions are $84 million, $20 million and $6 million respectively. The Department of the Environment is the co-ordinator of the Plan ( see Exhibit 14.2 ).
14.32 The general objectives of the St. Lawrence Action Plan are threefold: to co-ordinate federal activities and encourage the participation of other levels of government, industry and the general public; to reduce pollution sources; and to update and increase environmental information about the St. Lawrence River ecosystem.
14.33 In June 1989, Canada and Quebec signed a "harmonization and co-ordination agreement for the depollution, the protection, the restoration and the conservation of the St. Lawrence River." Under this agreement, the parties agreed to harmonize more than $60 million of the Province's portion of its total St. Lawrence River pollution control and abatement activities with the federal action plan.
Observations and Recommendations
Lack of interdepartmental co-ordination
14.34 The St. Lawrence Action Plan requires that the departments of Environment, Fisheries and Oceans, and Industry, Science and Technology co-ordinate their activities to achieve common goals. We conducted a limited review of the co-ordination between Environment and Fisheries and Oceans and found no evidence of problems. Our examination focussed primarily on the co-ordination between Environment and Industry, Science and Technology, due to the latter's $20 million contribution to the $37 million technological development thrust of the plan. This overall thrust is aimed at developing, adapting and applying advanced environmental technologies to the clean-up of the St. Lawrence River.14.35 However, the focusses of the two departments are different. Environment's program focusses on the demonstration and application of technologies that meet the immediate needs of the 50 industries directly involved in the clean-up. Industry, Science and Technology's program focusses on the development and application of new and improved technology that can be marketed nationally and internationally, while being applicable eventually to St. Lawrence industries.
14.36 This difference in departmental objectives and program funding mechanisms led to co-ordination problems. Although an agreement was concluded between the two departments to provide for a management structure to co-ordinate their respective programs, it proved to be ineffective. An ad hoc arrangement between the two departments at the regional level improved co-ordination temporarily but did not fully resolve problems.
Co-ordination of federal and provincial activities
14.37 The Canada-Quebec Agreement is comprehensive and specific about the objectives, the activities to be conducted jointly or independently, and the financial obligations of each party. It provides an appropriate management structure and mechanisms to co-ordinate federal and provincial initiatives. Co-ordination mechanisms are simple and are oriented to the Agreement's objectives. The administration of the Agreement is assigned to a Management Committee, assisted by four harmonization committees corresponding to the four components of the Action Plan, namely, protection, conservation, restoration and state of the environment. The functions and responsibilities of these committees are clearly defined.14.38 All of the mechanisms generally operate as described in the Agreement. Based on interviews with federal and provincial officials and reviews of relevant documentation, the Management Committee appears, in general, to have performed its co-ordination function. However, the federal and provincial partners also recognize that not all of the harmonization committees have been equally effective.
14.39 The stakeholders we interviewed told us that the joint federal-provincial St. Lawrence action team, created to deal with industry, proved to be an innovative and positive approach to achieving co-operation in the first phase of the Plan.
Clarity of objectives
14.40 The three general objectives of the St. Lawrence Action Plan (paragraph 14.32) were translated into five operational objectives ( see Exhibit 14.3 ). These objectives are clearly defined and have served to guide subsequent decision making, to focus activities and to measure progress. Action Plan reports indicate that progress in achieving the objectives is being made. However, there is a need for explicit benchmarks against which existing water quality can be assessed, progress toward desirable water quality objectives can be measured and improvements reported to Parliament and the public. This would provide a basis for relating results at any given time to the current and future use of the water for drinking, swimming and fishing purposes and the impact on human health.
Need for strategic planning
14.41 The St. Lawrence Action Plan is the first step in what is now widely recognized as a long-term initiative. The first phase of the plan, which ended on 31 March 1993, developed a mechanism for co-ordinating federal-provincial clean-up activities while establishing the necessary environmental database on which to plan future activities. However, a federal-provincial long-term strategic plan for future clean-up activities in the St. Lawrence has not been developed. The lack of a strategic plan may have contributed to the delay in federal-provincial approval of the second phase of the St. Lawrence Action Plan. When approval of the federal component of the second phase was announced in April 1993, a formal commitment from Quebec to continue to co-ordinate its clean-up activities with the federal plan was not in place. Such a delay could lead to a loss of momentum, resulting in a slowdown of activities and a reduction in the commitment of key participants. In our opinion, this situation could lead to inefficient use of limited resources and could impede progress in the clean-up of the St. Lawrence River.14.42 The Department of the Environment, in collaboration with the other federal departments concerned and the Province of Quebec, should develop a long-term strategic plan for the clean-up of the St. Lawrence River.
Mobilization of non-governmental stakeholders
14.43 The government states in the Green Plan that it is committed to building productive partnerships with all environmental stakeholders. This implies that the federal government will work closely with the targeted industries and environmental groups in implementing the St. Lawrence Action Plan.14.44 Although there is no formal consultation process, the non-government stakeholders we interviewed were generally satisfied with the objectives of the Action Plan. However, environmental groups felt that such a process would be needed if they were to contribute more effectively to future phases of the Plan.
14.45 A group of non-government organizations took the initiative of creating committees at the community level to participate in developing remedial action plans for their respective areas of the St. Lawrence - "zones of priority action". The first local committee met in 1992. The Department of the Environment participates in this process. The consultation process may be continued in the second phase of the Action Plan.
14.46 The Department of the Environment, in collaboration with other stakeholders, should ensure that there is an appropriate process for public consultation and participation in the second phase of the St. Lawrence Action Plan.
Action plan management
14.47 St. Lawrence Action Plan management mechanisms were, on the whole, effective in the first phase. The project management approach provided for regular monitoring of work progress and for measuring results against operational objectives.14.48 Working groups were created and given responsibility for attaining major objectives. The roles and responsibilities of each working group were clearly defined and deadlines were established. In addition, a system was set up that allowed all working group members to identify their own contributions toward achieving operational objectives. Appropriate tools were developed and are being used for monitoring and controlling activities.
Program evaluation
14.49 The purpose of program evaluation is to ensure that federal departments have relevant, credible and objective information available on the performance of their programs and that they use that information to manage their programs in a cost-effective way. That is, the federal government should be able to determine the relevance of a program and the degree of success or failure in relation to objectives and resources used. This information should then be used in making decisions about the future direction and resourcing of programs. In addition, program evaluation should provide important information for Parliament and the Canadian public.14.50 An important early step in the evaluation process is the development of a comprehensive evaluation framework. The framework outlines what the evaluation is likely to entail and, more critical, describes the program profile and the information and data that are to be collected prior to and during the evaluation.
Program evaluation must be timely
14.51 Cabinet gave approval to the second phase of the St. Lawrence Action Plan in 1993, without the benefit of formal evaluation of the effectiveness of the first phase by the departments involved, i.e., Environment, Fisheries and Oceans, and Industry, Science and Technology. The Department of the Environment is of the opinion that it had sufficient information about results achieved in the first phase and about the state of the St. Lawrence ecosystem to know that there was a need for a second phase. However, without a timely evaluation, the government, Parliament and the public cannot judge if the Department has selected appropriate objectives for the second phase.
Evaluation must address the strategic goal of the program
14.52 In early 1993 the Department of the Environment began an evaluation of the first phase of the Action Plan. The Department recognized that the evaluation framework prepared in 1990 did not cover the full scope of issues that the evaluation should have included. It focussed on whether the program objectives were realistic in terms of timing and the resources allocated, but not whether they were the most appropriate to address the environmental problems. In particular, the evaluation framework did not fully address the strategic goal of the St. Lawrence Action Plan, which is the "clean-up, protection, restoration and conservation of the biological, physical and chemical integrity of the St. Lawrence River and the development of an environmental technology for the sustainable development of its resources."
Evaluation findings can be used to improve programs
14.53 Even though the decision to pursue the second phase of the Action Plan has already been taken, the Department still has the opportunity to use the results of the evaluation of the first phase to modify and improve the design of its program for the second phase. The evaluation of the first phase can also help identify any lessons learned to be used in preparing for the program evaluation of the second phase.14.54 The Department should conduct timely program evaluations that cover the full scope of evaluation issues, and use findings from the evaluations to improve or modify the programs evaluated or to confirm the continuing need for them.
Accountability reporting
14.55 Accountability to Parliament and the public depends on adequate information on the resources expended, the activities carried out and the planned outcomes and actual results achieved. Our examination focussed on the St. Lawrence Action Plan annual reports for 1988-89 to 1991-92, and Environment's Part III of the Estimates for 1991-92 to 1993-94.
Incomplete information could be misleading
14.56 We found that, although the reports provide information on the achievement of operational objectives of the St. Lawrence Action Plan, there is little explanation of their relationship to the overall health of the ecosystem, including water quality. For example, one of the Plan's principal objectives is a 90 percent reduction in discharges of industrial liquid toxic wastes. The reports provide the actual percentage reduction but no analysis of the likely impact on water quality. Furthermore, these reports do not address the impact of external factors such as plant closures and reduced production levels due to the recession or other circumstances, which may have contributed to the reduction in discharge of toxic wastes.14.57 Some environmental data have been accumulated over the five years of the plan, and a report on the state of the environment of the St. Lawrence ecosystem, including water quality, is planned for release before the end of 1993. This should enable the Department of the Environment, in collaboration with the Province and other stakeholders, to establish a set of water quality benchmarks against which future improvements can be measured. Such improvements need to be expressed in terms of actual water quality and the suitability of the water for the various user demands being placed on it.
14.58 We found no information on the obstacles, limits and uncertainties affecting the achievement of the Plan's general objectives, namely, to co-ordinate federal activities and encourage the participation of other levels of government, industry and the general public to reduce pollution sources; and to update and increase environmental information on the St. Lawrence River ecosystem. The initial five-year plan with a budget of $110 million is only the beginning of a long-term effort to repair environmental damage in this river system. Parliament and the public should be fully informed about the Plan's limitations and the estimated long-term costs that will have to be incurred to fully rehabilitate the St. Lawrence River basin.
14.59 The Department of the Environment should provide relevant, reliable and understandable information to Parliament and the public on the nature and magnitude of the problems being addressed by the St. Lawrence Action Plan, the scope and costs of the measures that are being taken to solve these problems and the results expected and achieved.
Fraser River Action Plan
Background
14.60 The Fraser River basin covers a quarter of British Columbia and is home to almost two million people. It is the fifth-largest river in Canada and produces more salmon than any other river in the world. It is a vital feeding and resting stop for migratory birds and an over-wintering habitat for several hundred thousand waterfowl. ( see Special Insert )14.61 In June 1991 the federal government announced the Fraser River Action Plan, a six-year, $100 million initiative under the Green Plan . The departments of the Environment and Fisheries and Oceans were each responsible for $50 million in program funding ( see Exhibit 14.4 ). The objectives of the Plan are threefold: to clean up pollution; to restore the productivity of the natural environment; and to develop, through partnerships with stakeholders, a sustainable management program for the Fraser River basin (one that integrates socio-economic and environmental concerns into planning and decision making).
14.62 As a consequence of a $5 million reduction in Environment's funding for the Fraser River Action Plan for 1992-93 to 1994-95, and in anticipation of further budget cuts, the Department completed a review of its component of the Plan. This included a review of partnership commitments, and has led to a reallocation of resources and a change in expected results. Adjustments to the program were achieved by eliminating some components (demonstration watersheds) and severely curtailing others (land acquisition to secure critical habitat). The objectives of the original program, however, were retained.
14.63 Although Environment and Fisheries and Oceans are equal partners in the Plan, our audit focussed on Environment's activities with respect to water quality.
Contribution to the sustainable development of the basin
14.64 The Fraser Basin Management Program was developed from the Fraser River Action Plan. This program focusses on sustainable development and incorporates federal, provincial, municipal and other stakeholder interests ( see Exhibit 14.5 ). A federal/provincial/ municipal agreement providing for the establishment of the Fraser Basin Management Program was signed in May 1992. The agreement calls for a Management Board, comprising government and non-government members, to influence and guide the co-ordination and integration of all stakeholders' ongoing activities, including those of the Fraser River Action Plan, toward achieving sustainable development in the Basin. The Board was established in August 1992 but does not yet include any representatives from non-government environmental organizations.14.65 We did not audit the Fraser Basin Management Program as a whole. The focus of our audit was mainly on the role of the Department of the Environment in the Fraser River Action Plan and its input to the Fraser Basin Management Program.
Observations and Recommendations
Lack of interdepartmental co-ordination
14.66 The Department of the Environment and the Department of Fisheries and Oceans are partners in the Fraser River Action Plan. Although each department focusses on its own responsibilities, co-ordination is critical to the Plan's success. For example, the rehabilitation of salmon stocks and the restoration of fish habitat - mainly a responsibility of the Department of Fisheries and Oceans - is very much dependent on the quality of the water - a responsibility of the Department of the Environment.14.67 There is evidence of a lack of co-ordination between the two federal departments in implementing the Action Plan. Attempts were made in the first year of the program to form interdepartmental work groups to co-ordinate the activities of the two departments. Some work groups seldom met and others no longer exist. In view of the departments' co-responsibility for the delivery of the Action Plan, a high degree of co-ordination would assist in the efficient achievement of objectives.
Stakeholder involvement
14.68 When the Fraser River Action Plan was announced in June 1991, there had been little, if any, consultation with the Province of British Columbia, despite the fact that the Province is an essential partner in the efforts to clean up and restore the river. Such a lack of early consultation can inhibit timely action and program development by potential partners.14.69 The agreement respecting the Fraser Basin Management Program provides the foundation for all stakeholders to participate. Public information, education and involvement are to be accomplished through the Management Program. By 30 April 1993, the federal Fraser River Action Plan was entering the third year of the six-year program. However, the Fraser Basin Management Program was just beginning the process of obtaining the participation of local communities and the general public. Furthermore, little information has been provided to the public. If the public is to be involved and to give its support to the Management Program, it is critical that it be fully informed and educated about the relevant environmental issues. The public should also be involved in developing objectives and plans that guide decisions on funding, through an appropriate participatory process extending to the community level.
14.70 The departments of the Environment and Fisheries and Oceans, in co-operation with other stakeholders, should request the Fraser Basin Management Board to develop and implement an appropriate public information, education and participation process.
Cleaning up pollution
14.71 The Fraser River Action Plan provides for the abatement and clean-up of contamination of the Fraser River ecosystem. Activities planned to meet the clean-up objective consist of identifying sources and amounts of pollution, developing abatement plans, monitoring the implementation of these plans by the polluter, increasing enforcement activities, monitoring the condition of the basin, setting objectives for water quality, and conducting water quality research.14.72 The water quality objectives for this Action Plan are clearly defined. The Department has put in place appropriate program management procedures and structures to implement and monitor activities under this part of the Plan. As we have already noted for the St. Lawrence Action Plan, however, there is also a need for specific benchmarks against which existing water quality can be assessed and progress measured in the Fraser River Action Plan.
14.73 The Department of the Environment is making a significant investment in the improvement of water quality. However, the activities of the Department alone will not clean up the river. Responsibility for activities that impact on water quality is shared among several federal departments and with provincial and local governments and the private sector. Co-ordination of stakeholder contributions is therefore required to ensure cost-effective implementation of clean-up programs.
Renewing the productivity of the environment
14.74 The Department of Fisheries and Oceans is largely responsible for the second objective of the Fraser River Action Plan - restoring the productivity of the natural environment. It has defined this as restoring the salmon populations to historic levels and maintaining them. As appropriate, we may examine that Department's contribution (approximately $39 million) to this component of the Action Plan together with that of the Department of the Environment (approximately $12 million) at some future date.
A management program for sustainable development
14.75 The third objective of the Fraser River Action Plan is to develop a management program that will provide for the sustainable development of the Fraser River basin. This will be done through the Fraser Basin Management Program. This challenging task is primarily the responsibility of the Fraser Basin Management Board. It is not clear how the current design of the program will provide for sustainable development. It is essential that the intended scope and meaning of sustainable development, as applied to the Fraser basin, be defined to the satisfaction of all stakeholders. This would then provide direction for program development and implementation.14.76 The Fraser Basin Management Program does, however, include elements for co-ordinating the activities of stakeholders, improving institutional relationships and management processes, fostering sustainable development, developing and applying a process for public education and involvement, and improving scientific data and knowledge. The multi-stakeholder Management Board established by the agreement has developed "A Strategic Plan for the Fraser Basin Management Program for 1993-98". This Plan, published in May 1993, should help guide the co-ordination and integration of the stakeholders' ongoing activities. One priority will be its co-ordination with the Fraser River Action Plan to ensure progress toward the achievement of sustainable development objectives.
14.77 The departments of the Environment and Fisheries and Oceans should encourage the other members of the Fraser Basin Management Board to indicate, in the context of the strategic planning process now being implemented, how the Fraser River Action Plan will be co-ordinated with the Management Program to achieve sustainable development objectives.
Program evaluation
14.78 The Department of the Environment has prepared an evaluation framework, comprising a program profile and an evaluation strategy for its portion of the Fraser River Action Plan. We found the strategy, which proposes to look at both program implementation and achievement of objectives, to be appropriate for a program such as the Fraser River Action Plan. We noted, however, that the collaboration of all parties to the Plan will be required so that all of the necessary data will be available for the evaluation.14.79 The federal/provincial/municipal agreement on the Fraser Basin Management Program does not include a formal requirement for program evaluation. However, the Fraser Basin Management Board has stated its intention to conduct annual audits of the state of the basin's environmental, economic and social systems; the state of the basin's management institutions; and the performance of the Management Program and Board. These audits, along with the program evaluations of the Action Plan that the Department of the Environment proposes to conduct, are essential to provide needed information for informed decision making.
Conclusions and Lessons Learned
14.80 The St. Lawrence and Fraser River action plans differ significantly in their development and implementation. They are not directly comparable. Both differ, in turn, from the Great Lakes Action Plan, although the physical link between the Great Lakes and the St. Lawrence River requires some degree of co-ordination in managing these plans. However, there are still enough common features among the action plans that lessons learned from one can be applied to the others.
Need for a Federal Framework of Water Quality Objectives
14.81 One thing shared by all three action plans that we audited is a common goal - water quality control and improvement. Furthermore, this goal is to be achieved within the bounds of the Green Plan , which stresses movement toward sustainable development through the use of partnerships among governments and other stakeholders. In our opinion, there is a need for a federal framework of desirable water quality objectives for the major ecosystems across Canada, as part of long-term strategic planning and to assist in setting priorities and allocating resources. This would provide a set of benchmarks against which local water quality and corresponding beneficial water uses could be established and measured. Such an approach would entail developing a federal proposal and placing it, as an important item, on the agenda of the Canadian Council of Ministers of the Environment for federal-provincial resolution.
Need for Federal Long-term Strategic Planning
14.82 There is a marked absence of strategic planning to guide decision makers. However, some planning has been done at the regional level, in that a draft strategic plan has been developed for the Great Lakes and recently a strategic plan for the Fraser River was published by the Fraser Basin Management Board. However, the lack of a federal strategic plan to provide a framework within which the individual action plans can be developed has led to problems in both communication and co-ordination. The federal government needs to know where it is going and how it is going to get there if it is to use its limited resources efficiently and effectively. The Department of the Environment has the major federal responsibility for water quality management. It should, therefore, take a lead role among federal departments with water interests to address the problem, thereby putting into practice the words of the Green Plan : "first and foremost, the federal government must lead by doing." A long-term strategic plan would provide a context for the federal framework of water quality objectives and would indicate when and how water quality improvements are to be attained. Such a document would, therefore, help decision makers to assign priorities to individual action plans and to allocate limited resources. It would also form the basis for evaluating and reporting on progress.
Key Criteria for Successful Partnerships
14.83 Partnerships are important and necessary to achieve results in a complex multi-jurisdictional environment. Although they will differ in structure and application, they need to meet certain requirements if they are to succeed. Partnerships should be put in place as early as possible in the planning stage to ensure that the participants are involved in setting objectives and designing program delivery mechanisms. Participants must be well informed and their roles and responsibilities clearly stated and documented, together with expectations and commitments.14.84 Partnerships operate at three levels: among federal departments, between federal and provincial governments, and between governments and other stakeholders. The Interdepartmental Committee on Water provides a structure for the co-ordination of federal action. However, until the Department of the Environment provides leadership and makes better use of the Committee, which in turn will encourage other participating departments to commit to the partnership, the present problems are likely to continue.
14.85 These conclusions also apply to public involvement. If participation rather than consultation is intended, action must be taken early in the process to ensure that the public is well informed. The St. Lawrence Action Plan provided a good public information program with respect to reporting on government activities, but with a view to obtaining the public's support more than its participation. The Great Lakes Action Plan has involved the public in remedial action plans. The Fraser River Action Plan has begun to involve the public directly, but rather late in the process. Governments must provide leadership and the public must be involved early if its participation is to be effective.
Evaluating and Reporting on Action Plans
14.86 The reporting of results provides accountability to Parliament and the public for resources expended. Annual reports give information on individual plans. State of the environment reports provide some general information on the health of major water ecosystems, but insufficient data for assessing the effectiveness of individual action plans. Only rigorous and timely program evaluation can determine if the action plans are achieving their intended objectives in the most cost-effective way, and if limited dollars are being spent where they have the most impact.14.87 Current government reporting does not provide consolidated information on the costs and achievements of the efforts to improve water quality. Parliament thus does not have access to important information to assist in its review and approval of the total funds, timeframes and approaches proposed for the rehabilitation of these major ecosystems.
14.88 There is no doubt that such rehabilitation is a prerequisite if Canada is to achieve its goal of sustainable development while providing clean water for future generations. However, as we have noted throughout the Chapter, all stakeholders must be involved and their activities co-ordinated if significant improvements in water quality are to be achieved and reported within a reasonable timeframe.
Department's response: One of the Green Plan's principles for environmental action is to "think, plan and act in terms of ecosystems", which implies the need for an integrated approach to making informed decisions for today's complex environmental issues. The regional action plans are being implemented through an ecosystem management approach. The framework for management of ecosystem-based water action plans includes the development of ecosystem-specific objectives and indicators and national water quality guidelines. Ecosystem objectives, which are being developed in consultation with a wide range of partners and stakeholders, define the longer-term state of the environment, while ecosystem indicators, based on new scientific information, measure the achievement of progress. Ecosystem indicators are a relatively new concept and the Interdepartmental Committee on Water has recently reviewed a draft process document entitled "National Framework for Developing Indicators for Evaluating and Reporting Ecosystem Health", developed by the Department of the Environment. The Canadian Council of Ministers of the Environment will be asked to review the document and, if they approve of the proposal, it could be published in early 1994 as the national framework and form the basis through which a national perspective on water quality objectives would be addressed.
Canadian Water Quality Guidelines are developed co-operatively by the federal government, the provinces and territories under the auspices of the Canadian Council of Ministers of the Environment (CCME). These guidelines are used as benchmarks to assess water quality problems and concerns in Canada and are used in conjunction with local water quality information to establish water quality objectives for specific sites. This is a sound approach for maintaining and restoring water quality impacted by toxic chemicals. However, water is only one important component of the ecosystem. Our experience with regional action plans has demonstrated that the long-term protection of the physical, chemical and biological integrity of an ecosystem requires an ecosystem approach, of which water quality guidelines are a part.
The Interdepartmental Committee on Water recognizes the value of pursuing a strategic orientation to its work and has encouraged regular attendance of observers from key federal departments. In developing its agenda for the coming few years, the Committee will examine the means by which it could contribute to enhancing co-ordination between the various current basin and coastal action plans.
As well as the Interdepartmental Committee on Water, there are a number of other formal and informal mechanisms in place for strategic planning purposes, such as: business planning and annual management contracts as an element of the departmental planning process; federal meetings and workshops between the responsible region to share experiences; the Canadian Council of Ministers of the Environment; and co-operative mechanisms in the area of planning and issue management among communities in the specific action plan areas.