Follow-up Audit on the Implementation of the Commissioner of the Environment and Sustainable Development Recommendations on Sustainable Development Strategies
Federal Sustainable Development Strategy
- The Federal Sustainable Development Act requires the federal government to develop a strategy intended to make environmental decision making more transparent and accountable to Parliament.
- The Federal Sustainable Development Strategy (FSDS), covering the period from 2016 to 2019, provides a government-wide perspective on environmental and sustainable development priorities, goals, targets, and implementation strategies.
- Departments are responsible for establishing their own sustainable development strategies and outlining how they intend to support the FSDS.
- Public Safety Canada (PS) developed its 2017-2020 Departmental Sustainable Development Strategy (DSDS), which aligns with the FSDS and is used for reporting annually on progress made towards achieving its goals.
- PS has committed to work towards the two following FSDS goals:
- Low-Carbon Government: The Government of Canada leads by example by making its operations low-carbon.
- Safe and Healthy Communities: All Canadians live in clean, sustainable communities that contribute to their health and well-being.
Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals
- The Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals (Cabinet Directive) requires all departments and agencies to perform a strategic environmental assessment (SEA) to inform the Cabinet of environmental effects of proposed policies, plans and programs.
- Departments are expected to conduct a preliminary assessment (scan) to screen proposals for potential important environmental effects, which can be either positive or negative.
- The focus of scans should be on identifying strategic considerations at a relatively general or conceptual level, rather than evaluating quantitative, detailed environmental impacts, as in a project-level assessment.
- If important environmental effects are identified, a detailed assessment is required.
- Departments must prepare a public statement of environmental effects when a full SEA has been conducted.
Commissioner of the Environment and Sustainable Development
- Under the Auditor General Act and the Federal Sustainable Development Act, the Commissioner of the Environment and Sustainable Development (CESD) is tasked with overseeing the government's efforts to protect the environment and promote sustainable development.
- On behalf of the Auditor General of Canada, the CESD provides parliamentarians with objective, independent analysis and recommendations on the federal government's efforts to protect the environment and foster sustainable development.
- The CESD conducts regular performance audits, and is responsible for:
- monitoring sustainable development strategies of federal departments;
- overseeing the environmental petitions process; and
- auditing the federal government's management of environmental and sustainable development issues.
2017 CESD Report and Recommendations
- In October 2017, the CESD released its annual audit report on Departmental Progress in Implementing Sustainable Development Strategies, as part of which PS' practices were assessed. The CESD issued 4 recommendations:
PS should:
- Apply the Cabinet Directive to all policy, plan, and program proposals submitted for approval to their individual Ministers or to Cabinet, as required;
- 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;
- Ensure that they report each year on the results of their strategic environmental assessment practices; and
- Develop or improve their guidance and tools on strategic environmental assessment.
- PS accepted each recommendation and committed to implementing a number of measures as part of its Management Action Plan.
2017 CESD Report and Recommendations – Public Safety Response
- In response to the recommendation from the CESD Audit, the Portfolio Affairs and Communications Branch (PACB) developed the Strategic Environmental Assessment Guidance Document and the Strategic Environmental Scan Template, which were distributed Department-wide in Fall 2017.
- Consistent with the requirements of the Cabinet Directive, the PS guidance documents outline the obligation of the department to:
- conduct preliminary scans for all proposals for the minister's or Cabinet's consideration to identify the direct and indirect outcomes associated with implementing the proposal, and whether these outcomes have an impact on the FSDS goals and target; and
- If the preliminary scan results in a positive response to any of the SEA outcome questions and the proposal is assessed as having important environmental effects, Branches are required to complete a full SEA review.
- Under the adopted PS governance model, each Assistant Deputy Minister is accountable for compliance with the Cabinet Directive for proposals that originate from their Branch.
- Starting in January 2018, PS established a requirement to review the status of all Departmental SEA practices twice per year at the Internal Policy Committee (IPC), through Mid-year progress reporting (January) and Year-end progress reporting (July).
- Assistant Deputy Ministers (ADM) are also asked to include analysis and considerations related to SEAs when presenting policy proposals at IPC.
- PS further committed to report on its Strategic Environmental Assessment practices in its Departmental Results Report.
- All four CESD recommendations were reported to the Departmental Audit Committee (DAC) as fully implemented and closed on October 30, 2018.
2018 CESD Report
- In October 2018, the CESD released its sixth annual report to Parliament on Departmental Progress in Implementing Sustainable Development Strategies, as part of which PS was assessed again.
- This audit focused on whether the organizations previously examined had adequately applied the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, and whether they had met their commitments to strengthening their strategic environmental assessment practices.
- PS was found to have been "largely compliant", having applied the Cabinet Directive to a majority of proposals the CESD reviewed. CESD also found that PS had developed internal guidance and tools to apply the Cabinet Directive. This had been deemed a "considerable improvement" from previous practices.
- CESD found that their past 2017 recommendations remained relevant with no new recommendations being made.
Objective and Scope
- The objective of this follow-up audit is to assess whether Public Safety Canada's planned actions have been effectively implemented to address the CESD recommendations on Sustainable Development Strategies.
- The follow-up audit examined SEAs developed in support of Treasury Board (TB) submissions and Memorandum to Cabinet (MC) led by Public Safety between April 2018 and June 2019.
- We did not review SEAs developed in support of other policy, plan and program such as budget proposals, Regulatory Impact Analysis Statement for Regulatory Submissions, etc.
- The audit did not assess:
- The quality of the analysis in the SEA and the decisions arrived at by Branches; and
- the MCs and TB Submission development processes.
Audit Approach and Methodology
- In conducting the follow-up audit, the following methods were used:
- Documentation review;
- Interviews with relevant stakeholders, including:
- Analysts who prepared SEAs that were in our audit sample; and
- PS management responsible for the development of the 2017-2020 Departmental Sustainable Development Strategy and for departmental reporting requirements.
- Consultations with representatives from:
- CESD to discuss audit methodology; and
- Environment and Climate Change Canada (ECCC), Health Canada, and Transport Canada to discuss best practices.
Conformance with professional standards
The follow-up audit conforms with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and the Government of Canada's Policy on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program.
Lines of Enquiry
In conducting the engagement, we assessed whether the following components are established at PS to effectively support the process for conducting strategic environmental assessment for all policy, plan and program proposals:
- PS established an effective governance framework to ensure oversight over the process for conducting SEAs.
- The Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals is consistently applied.
- PS reports on the extent and results of its DSDS and strategic environmental assessment practices.
Governance over Strategic Environmental Assessments
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Application of the Cabinet Directive
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Reporting on SEA practices
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Conclusions
PS has implemented previous management actions to address the CESD recommendations on Sustainable Development Strategies; however, improvements should be considered to increase the effectiveness of the current framework and practices and ensure that decisions are made with full awareness of environmental impacts.
- Clear oversight over SEA practices to ensure early integration, trained resources, and the systematic assessment of potential environmental effects when developing proposals with consideration of DSDS and FSDS targets.
- While some tools and guidance are available, opportunities for training are not readily available to PS analysts and there is no dedicated resource or network to support analysts in conducting SEAs.
- Information management practices should be reviewed to ensure that information used for reporting or in the context of future internal/external audits or evaluations is complete and accurate, as well as available for future policy development.
Recommendations
- All Assistant Deputy Ministers should work collaboratively to improve upon the current framework and practices by :
- Reviewing the current governance framework and establishing clear roles, responsibilities, and accountabilities over the process for conducting strategic environmental assessments on all policy, plan and program proposals.
- Ensuring that guidance, training and tools on strategic environmental assessments are commensurate with the needs of the department.
- Each Assistant Deputy Minister should improve current branch practices by :
- Establishing oversight mechanisms to support the iterative integration of potential environmental considerations throughout the life of a proposal.
- Ensuring that information management practices are adequate to fulfill documentation and reporting requirements.
Annex A: PS Management Action Plan
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June 2020 |
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December 2020 (and ongoing) |
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