ARCHIVED - Evaluation of INAC's Contaminated Sites Management Policy and Programming - Follow-up Report Status Update as of March 31, 2011

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Action Plan Implementation Status Update Report to the Evaluation, Performance Measurement and Review Committee - As of March 31, 2011

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/2008

Project Recommendations Action Plan Expected Completion Date Program Response
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 policy renewal process. NAO-NCSP has met with EC in June and will be meeting with PCO and EC in September.

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 Status: Complete

Update/Rationale:
As of 31/03/2011:

NAO-NCSP: continues to participate in CSMWG.

  • Proposals are drafted and will proceed for approval in Q1. 2011/12.
  • NCSP has worked on all costing related to FCSAP renewal.

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
The IIA-CSMP continues to participate in Contaminated Sites Management Working Group (CSMWG) meetings led by the Federal Contaminated Sites Action Plan (FCSAP) Secretariat. In addition, senior managers from Lands and Economic Development (LED) and Regional Operations (RO) sectors continue to participate in the Director and Director General-level committees held by the FCSAP Secretariat.

FCSAP Secretariat has looked to the IIA-CSMP's National Priority Ranking System for Contaminated Sites on reserve as a best practice in addressing contaminated sites on a national scale.

IIA-CSMP has and will continue to provide strategic input as part of the ongoing FCSAP program renewal process anticipated to be complete in Fall 2011.

The ADM has provided the IIA-CSMP input to FCSAP Secretariat on November 30, 2010.

AES: recommend to close, completed.

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 complement 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 humanresources 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).

February 2010 Status: Partially Complete

Update/Rationale:
As of 31/03/2011:

  • The strategic management of human resources remains a priority for NCSP.
  • The NCSP is preparing a 5-year strategic plan considering the new funding availability from FCSAP. This will be a consolidation program plan and include HR.
  • PWGSC is implementing a procurement approach that promotes socio-economic benefits.

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
The IIA-CSMP developed a comprehensive 5-Year human resources strategy in order to meet FCSAP's 2020 objective as part of the Program Review (see Recommendation #3). However, proposed funding allocations for the IIA-CSMP have reverted to pre-Canada's Economic Action Plan (CEAP) levels and have therefore been reduced significantly. Further analysis is required on which components of the human resources strategy can be implemented given the change in funding allocations.

AES: underway

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-NCSP 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.
February 2010 Status: Close

Update/Rationale:
As of 30/09/2010:

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
Following the Program Review Framework developed in 2008, the IIA-CSMP conducted a management practices review (Program Review) of the CSMP. The Program Review fully addressed Recommendations 1, 2 and 3 of the Evaluation, while informing the process to address Recommendations 5 and 6 of the Evaluation.

For example, one of the deliverables under the Program Review was to provide strategic input to FCSAP Secretariat for their renewal process. This was accomplished with the development a tool to more accurately estimate future costs to the program. This tool was used to provide 5-Year Funding Estimates to FCSAP Secretariat.

AES: Close- Fully Implemented

NAO NCSP:
Same Status as March 31st, 2009:

NAO NCSP
The NAO-NCSP has shared Program documents and is continuing to work closely with IIABL-CSMP.

AES: Close – Fully Implemented

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: Underway

Update/Rationale:
As of 31/03/2011:

Generic exercise is Departmental decision. NCSP participated in the generic ENG positions and would assist in other development of generic PC positions if requested.

Corporate procedures are updated annually and will consider the review of planning and forecasting.

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
Not applicable to the IIA-CSMP. No status update required.

AES: underway

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)

February 2010 Status: Close

Update/Rationale:
As of 30/09/2010:

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
The IIA-CSMP has undergone consultations with its partners in Regional Operations (RO), Education and Social Development Program and Partnerships (ESDPP) and the Chief Financial Officer (CFO) sector. RO and ESDPP have agreed to provide dedicated funding to the IIA-CSMP in order to access available funds from the FCSAP fiscal framework.

NAO NCSP
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.

AES: Close – Fully Implemented

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.

January 2010 Status: Complete

Update/Rationale:
As of 31/03/2011:

  • NAO-NCSP continue to work collaboratively with other sectors including CFO, Implementation Branch and others.

Indian and Inuit Affairs (IIA) – Contaminated Sites Management Program (CSMP)
In order to enhance intradepartmental linkages, the IIA-CSMP has established a Trilateral DG Committee between LED, RO and ESDPP that meets every three weeks to discuss issues of mutual concern.  Participation in the CSMWG will continue throughout the FCSAP renewal process and beyond.

In addition, discussions have begun with FNLM in order to integrate their contaminated sites management activities into existing performance reporting frameworks. Furthermore, the IIA-CSMP and NAO continue to share best practices and work jointly on such initiatives as the National Priority Ranking System for Contaminated Sites and the Environmental Liabilities Management Control Framework.

AES: recommend to close, completed

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