Draft Federal Sustainable Development Strategies

Draft Federal Sustainable Development Strategies

Preliminary Comments on the Draft 2022–2026 Federal Sustainable Development Strategy

Under the Federal Sustainable Development Act, the Minister of Environment and Climate Change is required to prepare a federal sustainable development strategy at least once within every 3‑year period. This will be the fifth federal sustainable development strategy since 2010.

Under the act, the Minister shall submit the draft strategy to the Commissioner of the Environment and Sustainable Development for review and comment, including as to whether each target is measurable and includes a time frameFootnote 1. My formal comments on target measurability and time frames will be submitted to you by the close of the review period (9 July 2022).

I have elected to provide you with these preliminary comments to inform you of my significant concerns about the narrow approach of the current draft strategy. These comments are focused on what can be done so that the strategy better reflects the act’s broad vision, rather than just what may be needed to meet the act’s bare legal requirements. In providing you with these comments well ahead of the deadline, it is my hope that you and the committee referred to in section 6 of the act will be able to provide timely direction to those working on the draft strategy. Should an improved draft strategy be produced, I would be pleased to review and comment on it within a reasonable time frame.

I strongly recommend that the draft strategy fully integrate the environmental, economic, and social factors of sustainable development in decision making so that the federal government can effectively deliver on its sustainable development commitments and initiatives. As you know, the 3 factors of sustainable development are enshrined in the act.

Preliminary results of my review

These preliminary comments focus on 2 key observations:

  1. The draft strategy does not fully integrate the environmental, economic, and social factors of sustainable development.
  2. The lack of coherence among federal government frameworks related to sustainable development for Canadians creates confusion.

The draft 2022–2026 federal sustainable development strategy does not fully integrate the environmental, economic, and social factors of sustainable development

The 2019 amendments made to the act clearly shifted the focus from environmental decision making to sustainable development decision making (Exhibit 1). It is also noteworthy that the purpose section now explicitly promotes coordinated governmental action and includes a vision aimed at improving Canadians’ quality of life, not just improving the environment. These are further indications of the significant broadening of the act’s focus.

Exhibit 1—Changes in the purpose of the Federal Sustainable Development Act

Exhibit 1—Changes in the purpose of the Federal Sustainable Development Act
Federal Sustainable Development Act (2008) Amendments made to the Federal Sustainable Development Act (2020)

3 The purpose of this Act is to provide the legal framework for developing and implementing a Federal Sustainable Development Strategy that will make environmental decision-making more transparent and accountable to Parliament.

3 The purpose of this Act is to provide the legal framework for developing and implementing a Federal Sustainable Development Strategy that makes decision making related to sustainable development more transparent and subject to accountability to Parliament, promotes coordinated action across the Government of Canada to advance sustainable development and respects Canada’s domestic and international obligations relating to sustainable development, with a view to improving the quality of life of Canadians.

Your predecessor, Catherine McKenna, confirmed the act’s shift in focus when she stated the following:

…the bill proposes a new purpose, which clarifies that the focus of the act and the federal sustainable development strategy would be sustainable development, not strictly related to the environment. It would shift the act’s focus from planning and reporting to driving action and improving Canadians’ quality of life, and it would specify that the federal sustainable development strategy must respect Canada’s domestic and international obligations.

The full integration of the environmental, economic, and social factors of sustainable development in the strategy would not only reflect the intention of the revised act but would also make sustainable development decision making more effective, inclusive, and accountable.

In reviewing the draft strategy, I have noted that progress has been made in the form of moving from addressing 13 goals in the last strategy to 17 goals that reflect the 17 Sustainable Development Goals (SDGs) of the United Nations’ 2030 Agenda for Sustainable Development. The SDGs address all 3 factors of sustainable development. The integration of the SDGs into the federal sustainable development strategy would be a welcome improvement except that the draft does this in a very limited manner. The draft strategy remains focused on “environmental decision making” instead of “decision making related to sustainable development.” This is a failure to reflect the importance of the amendments that were made to the act’s purpose section.

It is also worth noting that the act includes “the principle that sustainable development is based on an efficient use of natural, social and economic resources and the need for the Government of Canada to integrate environmental, economic and social factors in the making of all of its decisions” [emphasis added]. In line with this statement, the integration of environmental, economic, and social factors to support decision making and coordinated action across government is essential in order to advance sustainable development and improve Canadians’ quality of life.

The draft strategy states that it sets out the government’s sustainable development goals, targets, milestones, and implementation strategies from an “environmental perspective.” Even though the chapters of the draft strategy are organized according to the 17 SDGs, the strategy explicitly focuses on just 1 factor. The practical effect of this narrow focus is illustrated well in chapter 1, which relates to the goal of no poverty (SDG 1). Instead of addressing the main elements of the federal government’s wide-ranging work to eliminate poverty, chapter 1 focuses on supporting Canadians’ preparedness for disaster and emergencies.

While such preparedness is clearly important, the “environmental perspective” of the strategy results in the exclusion of most of the many other federal initiatives that address this goal (Exhibit 2). In short, chapter 1 fails to promote coordinated sustainable development action across all of the government departments and initiatives implicated in the fight against poverty. Similar problems arise in many of the other chapters of the draft strategy, where the “environmental focus” has the effect of excluding the key economic and social aspects of the government’s work in implementing the various SDGs.

Exhibit 2—Chapter 1, Support Canadians’ Preparedness for Natural Disasters and Emergencies, in the draft strategy does not fully reflect the Sustainable Development Goal of no poverty (Goal 1)

Exhibit 2—Chapter 1, Support Canadians’ Preparedness for Natural Disasters and Emergencies, in the draft strategy does not fully reflect the Sustainable Development Goal of no poverty (Goal 1)
Draft strategy, Chapter 1, Support Canadians’ Preparedness for Natural Disasters and Emergencies Examples of other federal government initiatives that address the goal of no poverty (Goal 1) that are not covered in the chapter

Aspect covered: Emergency management and disaster risk reduction

Target: By March 2023, 55% of Canadians are aware of disaster risks facing their household (Minister of Public Safety, Minister of Emergency Preparedness)

Short-term milestone: Publish National Risk Profile reports and issue public reports on the National Risk Profile on a biennial basis. These reports will improve Canadians’ understanding and awareness of disaster risk.

Support for the Global Indicator Framework for SDG target 1.5: By 2030, build the resilience of the poor and those in vulnerable situations and strengthen their capacity to respond to and recover from climate-related extreme events and other economic, social and environmental shocks and disasters

Employment and Social Development Canada is the lead department for Opportunity for All—Canada’s First Poverty Reduction Strategy, which includes a national target of a “50% reduction in the poverty rate by 2030,  relative to 2015 levels” and which is related to SDG target 1.5. The Poverty Reduction Strategy includes also dozens of interrelated strategies, programs, and benefits under 3 pillars that address multiple aspects of Goal 1. The following are some examples:

Lifting Canadians out of poverty by ensuring everyone’s basic needs are met

  • National Housing Strategy
  • Canadian Drugs and Substances Strategy
  • On-Reserve Water and Wastewater Infrastructure

Helping Canadians join the middle class by promoting full participation in society and equality of opportunity

  • Youth Employment Strategy
  • First Nations and Inuit Youth Employment Strategy
  • Gender Results Framework

Supporting the middle class by protecting Canadians from falling into poverty and by supporting income security and resilience

  • Canada Workers Benefit
  • Wage Earner Protection Program
  • Prescription Medications and Health Innovation

Other Goal 1 targets not covered in this chapter

1.1 By 2030, eradicate extreme poverty for all people everywhere, currently measured as people living on less than $1.25 a day.

1.2 By 2030, reduce at least by half the proportion of men, women and children of all ages living in poverty in all its dimensions according to national definitions.

1.3 Implement nationally appropriate social protection systems and measures for all, including floors, and by 2030 achieve substantial coverage of the poor and the vulnerable.

1.4 By 2030, ensure that all men and women, in particular the poor and the vulnerable, have equal rights to economic resources, as well as access to basic services, ownership and control over land and other forms of property, inheritance, natural resources, appropriate new technology and financial services, including microfinance.

The draft strategy’s narrow approach will allow for the continued disconnection of environmental considerations from key decisions made by central bodies of government (the Privy Council Office, the Treasury Board of Canada Secretariat, and Finance Canada) and other federal organizations. So long as the draft strategy remains an “environmental decision-making” strategy, there is a significant risk that it will not bring about meaningful change to sustainable development decision making across the federal government.

The amendments to the act also sought to support a whole-of-government approach through a vast expansion of the list of federal entities that are required to prepare supporting sustainable development strategies (from fewer than 30 organizations to nearly 100). The draft strategy’s limited “environmental perspective” increases the risk that the federal government will continue to take a siloed approach to managing environmental matters separately from the rest of government decisions that relate to the broader notion of sustainable development. This is important as the federal government is called on to manage increasingly complex issues, like reconciliation and climate change. As stated in our 2021 audit report, Implementing the United Nations’ Sustainable Development Goals, horizontal issues require collaboration among federal departments and agencies to improve policy coherence that would allow for the implementation of programs and policies that support the sustainable development objectives and targets in federal frameworks. Moreover, there is a risk that this narrow approach will limit the meaningful participation of many of the new organizations that are now subject to the act. The draft strategy’s narrow “environmental perspective” will exclude many of the broader sustainable development contributions that these organizations could make through their own departmental sustainable development strategies.

The lack of coherence among federal government frameworks related to sustainable development for Canadians creates confusion

The federal government currently has several frameworks that set objectives, targets, or measures related to sustainable development for Canadians. These frameworks are led by separate federal departments. They include the Federal Sustainable Development Strategy (Environment and Climate Change Canada), the Gender Results Framework (Women and Gender Equality Canada), the Canadian Indicator Framework for the Sustainable Development Goals (Statistics Canada and Employment and Social Development Canada) and Measuring What Matters: Toward a Quality of Life Strategy for Canada (Finance Canada). All of these frameworks seek to establish objectives or targets for Canadians that are measured by indicators (Exhibit 3).

Exhibit 3—Examples of federal government frameworks related to sustainable development

Exhibit 3—Examples of federal government frameworks related to sustainable development
Federal government framework Stated purpose Federal leads

Federal Sustainable Development Strategy

The draft 2022 to 2026 Federal Sustainable Development Strategy sets out the Government of Canada’s sustainable development goals and targets and outlines implementation strategies and short-term milestones for achieving them, from an environmental perspective. It provides a whole-of-government view, bringing programs, priorities, and actions to advance sustainable development together in one place. This draft strategy is the first step in establishing the Government of Canada’s environmental sustainability plan for the next 4 years.

Environment and Climate Change Canada

Gender Results Framework (2018)

The Gender Results Framework represents the Government of Canada’s vision for gender equality, highlighting the key issues that matter most. Under this framework, the federal government has identified six key areas where change is required to advance gender equality.

Women and Gender Equality Canada

Canadian Indicator Framework for Sustainable Development Goals (2021)

The Canadian Indicator Framework contains a series of indicators developed by Statistics Canada in collaboration with the SDG Unit at Employment and Social Development Canada and other federal departments.

Statistics Canada,
Employment and Social Development Canada

Measuring What Matters: Toward a Quality of Life Strategy for Canada (2021)

The framework includes five broad domains of quality of life which are well-aligned with evidence and the views of Canadians: Prosperity, Health, Environment, Society, and Good Governance. The purpose of these domains is to promote holistic thinking about all the different determinants of quality of life.

Finance Canada

Former Interim Commissioner Andrew Hayes brought the issue of disconnection and confusion within the federal government’s approaches to sustainable development to the attention of Parliament in 2019:

…I am concerned by the lack of coordination between various tools intended to move sustainable development forward in Canada. Layering disconnected strategies on more strategies is confusing for government officials trying to make a difference and for Canadians trying to understand the country’s progress toward meeting sustainable development commitments.

This lack of coordination is a persistent problem, both across and within federal organizations. Specifically, Environment and Climate Change Canada leads the implementation of the Federal Sustainable Development Strategy, while Employment and Social Development Canada leads federal and national implementation of the United Nations’ Sustainable Development Goals (SDGs). The issue I see is that both approaches aim to achieve the same objective and yet have separate strategies, which remain largely uncoordinated and disconnected.

The situation has grown even more uncoordinated with the introduction of a new and separate “Measuring What Matters: Toward a Quality of Life Strategy for Canada” in 2021. The federal government elected to place this new framework outside the federal sustainable development strategy framework even though the act specifically refers “improving the quality of life of Canadians” in its purpose section.

The various uncoordinated federal frameworks relating to sustainable development create confusion for Canadians and federal departments and agencies. This confusion contributes to the likelihood of 2 significant risks: a) that necessary actions are not planned or undertaken and b) that duplicate or apparent cross-purpose actions are planned or take place. The current draft strategy exacerbates the siloed approach and does not help to promote coordinated action across the federal government for advancing sustainable development.

Conclusion

If the draft strategy retains its “environmental decision-making” focus, then Canadians will have an inferior federal sustainable development strategy that will not result in the important expected improvements to their quality of life. Although the federal government uses many frameworks, the federal sustainable development strategy remains the only one that is legislated. Therefore, the strategy should comprehensively reflect the work of the federal government as a whole and how it contributes to all 3 factors of sustainable development for Canadians. Fully integrating the various frameworks relating to sustainable development into a comprehensive strategy would be a significant first step to mainstreaming and integrating sustainable development decision making all across the federal government as envisioned by the act. As I indicated above, should an improved draft strategy be produced, I would be pleased to review and comment on it within a reasonable time frame.

Previous Reviews

2019–2022

Review and Comments on the Draft 2019–2022 Federal Sustainable Development Strategy

2016–2019

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

Response to the Review of the Draft 2016–2019 Federal Sustainable Development Strategy

2013–2016

Review of the Draft 2013–2016 Federal Sustainable Development Strategy

Response from Environment Canada to the Review of the Draft 2013–2016 Federal Sustainable Development Strategy