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The evaluation evidence shows that the Enforcement Program is relevant to federal government priorities and addresses a valid need to manage risks to the environment, wildlife and human health through the enforcement of federal legislation and regulations. There is a clear, legislated mandate for the federal government’s involvement in the enforcement of environmental laws and the enforcement of these laws is necessary for the achievement of the federal government’s environmental objectives. Furthermore, Canadians support an active role for government in this area.
Based on the available evidence, the Enforcement Program appears to have made considerable progress on most of its outcomes. There is also evidence that, beyond the time frame of the evaluation (2004–2005 to 2007–2008), further efforts to address shortcomings are being undertaken.
The evaluation findings indicate that the Enforcement Program has been most successful in contributing to the achievement of the following outcomes:
Regarding other key intended outcomes of the Program, evidence indicates that, although some progress has been made toward improved awareness of the responsibilities of the Enforcement Program and the benefits of enforcement, there continue to be gaps in understanding of the Enforcement Program within and outside the Department. There is also evidence that progress has been made toward the development of staff knowledge and skills, though there are some gaps, including the lack of a formalized basic training course for Wildlife Enforcement Directorate officers and an overall need for more regulation-specific training and specialized knowledge and skills. As well, through the use of intelligence, progress has been made toward increasing the knowledge available to inform Enforcement Program planning and decision making. However, the capacity of the intelligence function varies by region and there is a need to develop a more strategic approach to this function in the Wildlife Enforcement Directorate.
Evidence collected for the evaluation was largely qualitative, based heavily on the views of interviewees supplemented by some documentation and data. Conclusions regarding the achievement of intended Enforcement Program outcomes were made based on available information; however, a lack of documentation and performance information on several outcomes limited the degree to which interviewees’ observations on outcomes could be corroborated. Accurate and timely performance data on key measures such as rates of compliance with regulations were not available from the Enforcement Program. This lack of meaningful performance measurement is a serious shortcoming, as it inhibits the Enforcement Program’s ability to understand the degree to which it is meeting its objectives which, in turn, creates a gap in the information available for decision making.
Ensuring a clear understanding of the respective roles and responsibilities of Enforcement and its internal partners is critical for regulatory development and review, the establishment of priorities for enforcement, and supporting the achievement of regulatory compliance. Internal partners, however, do not have a complete understanding of precisely where the responsibilities of Compliance Promotion, environmental protection programs, the Canadian Wildlife Service and the Enforcement Program begin and end in the continuum of activities required to support regulatory compliance. This lack of understanding results in gaps where compliance promotion is not occurring and instances where Enforcement’s viewpoint is not included in the development or amendment of regulations. Findings also point to a lack of understanding within the Enforcement Program regarding the division of responsibilities between National Headquarters and the regions for the major functional areas—inspections, investigations and, in particular, intelligence. A lack of finalized policy documents clarifying the operations of the Enforcement Branch is a contributing factor to this lack of understanding.
Related to the need to ensure a clear understanding of roles and responsibilities, communications and coordination with internal partners are another area for improvement for the Enforcement Program. As noted, the Enforcement Program’s strategic targeting of enforcement activities relies in part on an annual consultative planning process to identify priorities for enforcement. The concept of this approach of consulting with key stakeholders to determine priority areas for enforcement is widely supported. Despite this, perceived weaknesses in the Enforcement Program’s coordination with key internal partners involved in the planning exercise, coupled with insufficient formal processes for communications and information exchange, have resulted in shortcomings in the implementation of this targeting strategy. Internal partners do not fully understand or feel fully engaged in the process, thereby limiting their level of commitment to the plan and the degree of alignment between their activities and Enforcement’s priorities.
The Enforcement Program also collaborates with a wide range of external partners to deliver its mandate, reduce duplication and support cost-effective Program delivery. This evaluation found that the strength of individual relationships in the regions augments existing formal agreements and mechanisms to maintain the quality of communication and coordination between the Program and its external partners. This helps to ensure a clear understanding of when and how these external partners should interact with Enforcement. It is critical, however, for the Enforcement Program to maintain those existing relationships that are already very strong and to work to improve those that are not optimal.
For the most part, the Enforcement Program is being delivered adequately and as intended. The creation of a separate Enforcement Branch, with clear lines of authority under the direction of the Chief Enforcement Officer and a centralized reporting structure, is an effective and efficient structure for the Program, as is the placement of Wildlife Enforcement and Environmental Enforcement within the same organization. However, the wildlife enforcement function and the environmental enforcement function continue to operate independently of each other in many respects, despite being placed organizationally within the same Branch. Although this was not specifically a focus of the evaluation, it became clear through interviews and the document review that there are a number of inconsistencies between these two directorates and there may be opportunities to standardize some aspects of operations and reporting and leverage efficiencies, while still recognizing their uniqueness.
Finally, in interviews for the evaluation, resource shortages were frequently cited by representatives of the Enforcement Branch and internal partners as a factor exerting a negative influence on Program delivery and success. This includes resource shortages on the part of both the Enforcement Program and its internal partners, thereby limiting their ability to respond to Enforcement’s needs. Additional resources approved in 2007 and 2008, to be allocated over a five-year period, have been provided to the Enforcement Program and are currently being used to address some of these deficiencies.