ARCHIVED - Evaluation of INAC's Contaminated Sites Management Policy and Programming - Follow-up Report Status Update as of September 30, 2009
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Northern Affaires, Lands and Economic Development, Chief Financial Officer, Regional Operations - As of September 30, 2009
Northern Affairs, Lands And Economic Development, Chief Financial Officer, Regional Operations
Evaluation of INAC's Contaminated Sites Management Policy And Programming (200711)
AEC Approval Date: 04/DEC/2009
|1. Provide comprehensive and strategic input to the FCSAP Secretariat for the FCSAP 2010 renewal process to ensure INAC needs are represented, best practices are put forward, and that departmental programming and policy continues to support and be consistent with this initiative.||NAO-NCSP continues to participate in CSMWG meetings and provides input into the MC renewal process. NAO-NCSP has met with EC in June and will be meeting with PCO and EC in September to discuss the MC and the Faro annex to the MC.
IIABL-CSMP met with EC on September 3, 2008 to provide input into the FCSAP evaluation process, and is continuing the dialogue. IIABL-CSMP continues to participate in CSMWG meetings and will also continue to provide input directly to FCSAP Secretariat as required to support the renewal process.
The Chief Financial Officer Sector will contribute to the development of the department's input into FCSAP as required for the management of any eligible department-owned contaminated sites.
The department will coordinate input into FCSAP to ensure consistency of INAC's response.
|February 2010||The Lands and Economic Development (LED) sector is defining a strategic approach to Departmental lands activities. This approach will be presented to the Departmental Senior Executive at the Forum on Strategic Issues in December 2009. All audit action plan activities will be implemented within the context of this newly defined strategic approach to lands.
As of 30/09/2009:
Northern Affairs Organization (NAO) - Northern Contaminated Sites Program (NCSP)
The NAO-NCSP continues to participate in Contaminated Sites Management Working Group (CSMWG) meetings and has been invited to participate in a Director-level working group, lead by the Federal Contaminated Sites Action Plan (FCSAP) Secretariat, to further develop the policy. This working group is anticipated to be established in the Fall of 2009.
NAO and LED will continue to provide input to the FCSAP Secretariat in a coordinated fashion to ensure consistency and united messages.
IIA CSM Program
The Indian and Inuit Affairs (IIA) Contaminated Sites Management (CSM) Program has initiated a Program Management Review that directly addresses Recommendation 1 of the October 2008 Evaluation. Several aspects of the Program Review have been tailored to produce deliverables that will constitute comprehensive and strategic input to the FCSAP Secretariat and support the renewal process.
For example, Phase I of the 3-Phase Program Review aims to validate the IIA CSM Program's database of contaminated sites in order to provide the FCSAP Secretariat with more accurate financial cost and liability estimates.
In addition, Phase II of the Program Review will aim to develop targets and a planned management strategy linked to the achievement of FCSAP's long term objective to eliminate by 2020 the environmental risks and liabilities associated with historic (pre-1998) contaminated sites.
Furthermore, Phase III of the Program Review will aim to develop a Human Resource Strategy for the IIA CSM Program over the next five years for submission to the FCSAP Secretariat in advance of their renewal process.
For more information on the Program Review, please see the Program Response for Recommendation 3.
As part of its ongoing operations, the IIA CSM Program continues to participate in the government-wide Contaminated Sites Management Working Group (CSMWG).
|2. Develop a comprehensive human resources strategy for program delivery that address human resourcing issues, both within and external to the department, including the development of a training strategy that promotes Aboriginal training and skills development.||Human Resources has been identified as a strategic risk through the NAO-NCSP IRM process and a mitigation plan has been developed which will be implemented. As part of this process the NAO-NCSP will be consolidating the HR strategy between the regions and HQ, as well as PWGSC.
NAO-NCSP has committed to provide up to 2% of project costs to implement training and skills development, through the ABP.
The NAO-NCSP will also be developing regional socio-economic strategies to compliment the contaminated sites procurement policy, in consultation with aboriginal groups and HRSDC, as identified in the program review completed in 2007.
IIABL-CSMP will monitor regional delivery to ensure adequate human resources are in place for regional delivery. This will be done in the context of the review of management practices for CSMP (see Recommendation 3).
Regional capacity to support the management of custodial contaminated sites is uncertain and will be assessed by the end of the current fiscal year. Training to enable the fulfillment of regional custodial contaminated site management responsibilities will be arranged as required (through the Canada School of Public Service).
As of 30/09/2009:
The NAO-NCSP has completed a 3-yr Human Resources Strategic Plan. This integrated plan includes a pan-Program strategy and approach to addressing HR risks. The 2% target supports the Program's RMAF and its associated indicators. This commitment has been incorporated into the NCSP Procurement Strategy and is achieving excellent results.
The NAO-NCSP has developed a template to guide the regions in producing socio-economic strategies. It's anticipated that each region will finalize their strategies in fiscal year 2010-2011.
IIA CSM Program
Phase III of the Program Review will directly address Recommendation 2 of the October 2008 Evaluation. For example, risks and issues related to internal and external human resource capacity at headquarters and in the regions will be identified and recommendations on how best to address them will be developed.
In addition, an analysis of human resource requirements at headquarters and in the regions over the next five years will be conducted in order to develop a five year Human Resources Strategy.
Aboriginal training and skills development are being addressed through several upcoming workshops in November and December with headquarters and regional stakeholders, and will also be addressed in the IIA CSM Program renewal process, to be completed by March 31, 2011.
|3. Conduct a program management review for IIABL-CSMP prior to program renewal in order to improve overall program performance and management. The review will include developing annual targets for assessment and remediation and management practices to achieve targets. NAO-NSCP best practices will be leveraged.||NAO-NCSP will ensure best practices are shared, as required. IIABL-CSMP will be invited to the semi-annual NAO-NCSP program meetings to ensure sharing of best practices.
IIABL-CSMP will conduct a review of management practices. A Program Review Framework was developed March 31, 2008 for this purpose. The framework will now be refined to reflect the results of the evaluation and the work on development of performance indicators led by FCSAP.
The management review will focus on:
1. establishing the necessary structures and procedures in order to achieve program objectives and improve program delivery
2. adapting FCSAP annual CSMP specific targets for assessment and remediation with the aim that all FCSAP eligible sites will be remediated by 2020
3. human resource requirements and effective monitoring and reporting systems, nationally and regionally
4. a planning regime that allows CSMP to maximize leveraging of FCSAP's funding and includes early project submission processes to have funds available on April 1 of the project year
5. ensuring all relevant interdepartmental linkages are in place. IIABL-CSMP will participate in NAO-NCSP semi-annual program meetings.
As of 30/09/2009:
The NAO-NCSP has shared Program documents and is continuing to work closely with IIABL-CSMP. An invitation has been extended to attend the annual NAO-NCSP Project Manager's meeting in November 2008 and November 2009.
IIA CSM Program
The IIA CSM Program has hired a contractor to conduct the Program Management Review. The objective of the Program Review will be to undertake an examination of the CSM Program's implementation in order to improve overall program performance and management and inform the CSM Program renewal process.
The IIA CSM Program Review was divided into three distinct phases, each phase having its own set of deliverables related to issues identified in the October 2008 Evaluation and more recent internal Audits.
As indicated above, Phase I will provide the FCSAP Secretariat with more accurate financial cost and liability estimates and is nearing completion.
Phase II will encompass the majority of the work towards examining the CSM Program's implementation. During this phase, each of the focus areas identified in the Action Plan will be addressed. In addition, targets will be revised during this phase to align program activities towards meeting the FCSAP 2020 target of eliminating environmental risks and liabilities associated with historic (pre-1998) contaminated sites.
Phase III of the Program Review will focus on consolidating information found during Phase I in order to provide more accurate financial estimates to the FCSAP Secretariat. In addition, Phase III will focus on analyzing human resource requirements for the IIA CSM Program over the next five years in order to develop a Human Resources Strategy.
|4. Further strengthen the management and technical expertise provided by Headquarters for the NAO-NCSP to respond to human resourcing issues and increased risk associated with large scale remediation efforts.||NAO-NCSP has developed a Human Resource strategic plan and will actively work on staffing vacant positions, such as attending university career fairs to recruit post-secondary graduates. Currently staffing actions are in progress for generic PC-03 and -04 positions with colleague directors. A consultant acting as senior advisor has been hired to work with HQ and the regions to identify areas where project estimates can be revised and make appropriate changes to planning documentation and the financial system. A consultant has started a budget/forecast planning and change control process review and will revise/develop processes and tools as needed.||March 2010||Status:
As of 30/09/2009:
The NAO-NCSP has successfully completed four staffing actions, including three technical positions, since the beginning of the fiscal year. The Program used the Post-Secondary Recruitment process and existing pools to fill a PC-04, PC-03, PC-02 and AS-01 position.
As mentioned above, NAO-NCSP hired a consultant earlier this fiscal year to develop a human resources strategy
The NAO-NCSP completed a financial review in 2008-09 which included recommendations to improve the current processes and procedures. Implementation of these recommendations is on-going and is expected to be completed in fiscal year 2010-11.
IIA CSM Program
Not applicable to the IIA CSM Program. No status update required.
|5. Consider creating a new funding authority that provides dedicated funding to support departmental contaminated sites policy and programming. This funding authority would facilitate the achievements of targets and the leveraging of FCSAP funds for both IIABL-CSMP and NAO-NCSP and consider the requirements of contaminated sites found on custodial operational real property assets.||NAO-NCSP and IIABL-CSMP will work with the Chief Financial Officer Sector and Regional Operations Sector, as well as other areas of Northern Affairs Office (NAO) and Lands and Economic Development Sector (LED) to determine; whether the CFMP (Capital Facilities Maintenance Program) is still a viable source of funding or; whether there is a need for a dedicated and/or enlarged source of funding and, if so; identify options for and evaluate the merits of creating a new funding authority. The IIABL-CSMP review of management practices (see Recommendation 3) will support this process as it will focus on:
- a planning regime that allows CSMP to maximize leveraging of FCSAP's funding; and
-ensuring all relevant intradepartmental and interdepartmental linkages are in place.
Discussions on this issue have been initiated with NAO-NCSP (October 30, 2008) and Community Infrastructure Branch (November 3, 2008)
As of 30/09/2009:
A new funding authority, effective June 1st, has been established which allows the Department to transfer funds to the Yukon Government for the remediation of Type II mine sites, as identified in the Devolution Transfer Agreement.
IIA CSM Program
The IIA CSM Program is awaiting the results and the recommendations of the Program Review before determining a course of action with regard to Recommendation 5. Currently there are several funding options available to the CSM Program, one of which is to consider creating a new funding authority. The Program Review will examine and weigh these options in consultation with the Chief Financial Officer Sector, the Capital and Facilities Maintenance Program, NAO, First Nations Land Management Directorate, and regional stakeholders to determine the best approach to resolving funding issues identified in the October 2008 Evaluation.
Decisions on which funding option to pursue will be taken during the IIA CSM Program renewal process, to be complete by March 31, 2011.
6. Enhance the intradepartmental linkages contaminated sites programming has with key departmental strategies, including linkages regarding environmental protection, land management, economic development, consultation, and contracting. This includes:
-Effective linkages with FNLMI.
-Undertaking further study to ensure compliance with legislation, regulations and policy requirements related to contaminated site clean up, particularly in the area of obligations stemming from comprehensive land claim agreements.
-Finding mechanisms to ensure the clean up of contaminated sites that are not eligible for FCSAP funding, such as waste sites that have remained active after 1998, and
-Ensuring steps are taken for the prevention of future liabilities to the Crown as a result of the creation of new contaminated sites on lands under departmental custodial responsibility.
|NAO-NCSP will organize intradepartmental meetings to ensure linkages are created, or maintained, as necessary as related to the NCSP.
The NAO-NCSP has implemented a comprehensive auditing procedure to ensure compliance with relevant legislation, regulation and/or policy requirements. NAO-NCSP is working with the INAC implementation branch, legal, PWGSC and others to review procurement within land claims. NAO-NCSP provides expert advice on remediation costs to INAC departments responsible for providing input into regulatory approvals to ensure the prevention of future liabilities.
IIABL-CSMP will organize intradepartmental meetings to ensure linkages are created, or maintained, as necessary as related to the CSMP. This will be done in the context of the review of management practices for CSMP (see Recommendation 3). This meeting will involve the Lands and Economic Development Sector, Regional Operations Sector and Education and Social Development Programs and Partnerships Sector and NAO to review ways in which future liabilities to the Crown as a result of the creation of new contaminated sites on reserve land can be addressed.
As part of this process, IIABL held a national training session and workshop on the new federal fuel storage tanks regulations in September, 2008 and has recently established a national working group on solid waste disposal sites. A training workshop is also planned for the Contaminated Sites Management Program for February 2009 to maintain a common understanding on the procedures/rules, administrative requirements, and legal implications.
IIABL-CSMP will develop a business case to fund sites that have emerged after 1998, to be presented to FCSAP for consideration.
The Chief Financial Officer Sector will release an updated departmental policy for Real Property Management by the end of the current fiscal year. Updated policy requirements for real property management will minimize the creation of any new custodial contaminated sites.
Additionally, department-owned fuel storage tanks will be managed in compliance with recently-updated requirements under the Canadian Environmental Protection Act (CEPA). The sound management of custodial fuel storage tanks is expected to further minimize the risk of contamination due to departmental operations.
As of 30/09/2009:
A meeting was held with representatives from NCSP, Implementation Branch, PWGSC, NWT procurement and PSAB experts to review and update the NAP-NCSP's Procurement Strategy. The Program will continue to consult, internally and externally if necessary, when developing or updating Program strategies.
The NAO-NCSP continues to complete annual Environmental, Health & Safety audits to ensure compliance with relevant legislation, regulations and policy requirements. In 2009-10, the Program completed audits at Cape Christian (NU), Nation Mine (YK), Colomac (NWT) and Giant (NWT).
NAO-NCSP is developing a database to track all cost information that can be used to estimate future costs. This database will be completed in fiscal year 2010-11.
IIA CSM Program
The IIA CSM Program will work towards enhancing intra and interdepartmental linkages within the context of Phase II of the Program Review currently underway. Please see the Program Response to Recommendation 3 for more information.
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