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The following recommendations were developed for action by the Ecosystem Sustainability Board (ES Board) and Environmental Protection Board (EP Board), based on evaluation findings and conclusions.
Recommendation 1: It is recommended that a useful performance measurement strategy for the Enforcement Program be developed and implemented. While it is acknowledged that the Enforcement Program has already initiated the development of an improved approach for measuring its results, more work is required to provide meaningful, accurate and accessible data on the delivery of the Enforcement Program’s outputs and degree of achievement of its intended outcomes. Although some performance data were available in Enforcement’s NEMISIS database, there was insufficient evidence to demonstrate the Enforcement Program’s progress towards its intended outcomes. A standardized process for collecting data and reporting on specific, measurable indicators that are linked to outputs and outcomes in the Enforcement Program logic model would be useful to senior management for decision making and would enable the Enforcement Program to tell its performance story.
Recommendation 2: It is recommended that roles and responsibilities be clarified and articulated, particularly the respective roles and responsibilities of the Enforcement Program and its key internal partners for the achievement of regulatory compliance and the division of the Enforcement Program’s responsibilities between National Headquarters and the regions. The Enforcement Program requires a clear and coordinated approach when carrying out the enforcement function due to the breadth of its mandate and responsibilities. There is ongoing confusion, however, both within Enforcement and among its internal partners, on the division of responsibilities for various roles in the achievement of regulatory compliance, including regulatory development, compliance promotion and the establishment of priorities for enforcement. There are gaps where compliance promotion is not occurring and a clear compliance plan and enforcement plan do not exist for each regulation. Although compliance and enforcement policies are intended to outline what is expected of those who share a responsibility for protection of the environment, the policies for the Fisheries Act and for wildlife legislation are very general in terms of who conducts compliance promotion. The policy for the Canadian Environmental Protection Act, 1999 does not delineate the respective responsibilities of Compliance Promotion and the programs. The evaluation also points to a need for a clearer articulation of the division of responsibilities between National Headquarters and the regions for the functional areas of inspections, investigations and, in particular, intelligence to ensure effective and efficient Enforcement Program delivery. A need was identified for finalized written policy documents to clarify the operations of the Branch, for instance, the exact responsibilities and relationships between national managers and regional managers of these three functional areas. Clarification of roles and responsibilities both within and outside the Enforcement Program, therefore, would improve relationships and the Enforcement Program’s ability to carry out its enforcement activities.
Recommendation 3: It is recommended that mechanisms and processes for improving the Enforcement Program’s communications and information sharing with internal and external partners be examined and implemented at both the National Headquarters and regional levels. Because the Enforcement Program’s strategic targeting of enforcement activities relies on a consultative planning process and coordination with partners, effective communications with internal partners are essential for the successful implementation of this targeting approach. Similarly, good communications with external partners are required for the Enforcement Program’s coordination of enforcement operations and strategies with those in other jurisdictions. The development of an overall communications strategy could help to improve information exchange and coordination, as well as strengthen relationships with partners. The development and consistent implementation of more formal communications and coordination mechanisms could be focused on meeting the information needs of all parties and improving communication flow.
Recommendation 4: It is recommended that opportunities to reduce imbalances and increase consistency and standardization be explored between the environmental enforcement and wildlife enforcement components of the Enforcement Program, and implemented where appropriate. Although Environmental Enforcement and Wildlife Enforcement have been combined into one Branch, some imbalances and inconsistencies between the groups remain in areas such as reporting (e.g., different formats of planning documents), training (e.g., provision of the standard Basic Enforcement Training (BET) program for new officers for the Environmental Enforcement Directorate but not the Wildlife Enforcement Directorate), human resources (e.g., classification of enforcement officers) and intelligence (e.g., differences in the extent of development of this function). While it is acknowledged that the focus and requirements of these two directorates within the Enforcement Branch are different and may vary by region in some cases, there is the potential for further benefits to be achieved through greater standardization. This could improve the Branch’s efficiency, effectiveness and ability to report on results for the overall Enforcement Program.