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Agree.
The Strategic Enforcement Framework (and work now underway to implement the vision it defines), developed by the Enforcement Branch and approved by the Executive Management Committee (EMC), is designed explicitly to respond to these gaps. The Branch has recognized that clear performance goals and the data and requisite data collection/analysis processes to measure progress against those goals are imperative for enabling strong management of the Enforcement Program, and to more clearly portray to Canadians, senior management and parliamentarians the results realized by the Enforcement Program. Work is now underway to
Performance indicators and data collection/management will be in place for all immediate outcomes for the beginning of 2010–2011, with reporting featuring new performance indicators delivered by 2011–2012 (reporting on the 2010–2011 year).
Agree.
Where EED is concerned, the Compliance Promotion and Analysis Division (CPAD), also referred to as Compliance Promotion, and the Enforcement Branch are increasing the scope and depth of their collaboration. Particularly in planning for 2009–2010, CPAD and Enforcement have worked together to streamline the program priorities submission process. Improvements in this respect will continue as we plan for 2010–2011, where CPAD and Enforcement will develop a fully integrated proposal for compliance promotion and enforcement priorities, and a high-level integrated plan for delivering on those priorities.
In the 2009–2010 fiscal year, work is proceeding jointly on the development of, and plans for implementation of the Interim Compliance Strategy for the Wastewater Sector. The Compliance Analysis and Planning (CAP) program in CPAD is also actively involved in the implementation of the Enforcement Program performance measurement strategy and will be offering online performance measurement reports through its data warehouse technology to the Enforcement Branch.
Where WED is concerned, the Directorate’s key internal partner is the Canadian Wildlife Service (CWS), which plays a leading role in regulatory development and compliance promotion. WED also plays a role in compliance promotion, and we acknowledge that these interdependencies and shared responsibilities necessitate a better-coordinated approach. To that end, the Enforcement Branch and CWS will conclude a formal agreement that clearly articulates the expected roles and responsibilities of each organization with respect to regulatory development, compliance promotion, and the establishment of priorities for enforcement, including the roles of regional and National Headquarters units within both organizations. Annual processes between the two organizations will also be described. This will be completed by June 2010.
Additionally, CWS and WED will develop a plan that articulates short-term enforcement priorities and a three-year overall compliance promotion plan for wildlife legislation – Migratory Birds Convention Act,1994, Species at Risk Act, Wildlife Animal and Plant Protection Regulation of Interprovincial and International Trade Act, and the Canada Wildlife Act. This will be completed by June 2010. The subsequent delivery of such a plan will be contingent on effectively determining the respective roles and responsibilities of CWS and WED, as well as the human and financial resources available from both organizations.
With respect to the second component: clarifying roles and responsibilities within the Enforcement Branch, with a focus on intelligence
Agree.
The Enforcement Branch is now finalizing the Enforcement Operations Manual, which will spell out roles and responsibilities for all staff, and which will be disseminated throughout the Branch. The regional restructuring undertaken in 2009–2010 is integrating the inspections and investigations functions in all regions, and the National Directors are now formalizing within their respective organizations the processes for fully completing this change. Finally, with respect to intelligence, the Enforcement Branch has created the Intelligence Working Group, co-chaired by directors from EED and WED with a mandate to examine intelligence roles and responsibilities, and make recommendations for improving consistency and overall performance in the intelligence function.
Moreover, and particularly in light of the new regional structure and the Intelligence Working Group, the Enforcement Branch will produce a document describing the roles and responsibilities of all organizations within the Branch. This will be completed and communicated to staff by the end of 2009–2010.
Agree.
In partnership with the Communications Branch, the Enforcement Branch is now finalizing a long-term communications strategy, consistent with, and to deliver on, the new Strategic Enforcement Framework. This strategy will focus particularly on communication/engagement with external partners, with the goals of building capacity through partnerships and raising public awareness of the enforcement program. The strategy will be approved and implementation begun in fall 2009. Communications will adopt an ecosystemic approach in portraying the impact of enforcement work on species and habitat conservation.
Moreover, and as noted in the response to recommendation 2 above, the joint EED –CPAD annual priority-setting and planning process planned for 2010–2011, and consequent regular communication/coordination with risk managers within the Department, is a significant vehicle for internal communication and information sharing.
Concerning WED and CWS, as noted in the response to recommendation 2, the two organizations will collaborate to develop both formalized roles and responsibilities and annual planning/communication processes. These annual processes will include national and regional co-ordination of strategic and operational planning, exchanges of letters regarding priorities and results, and communications commitments. This agreement will be concluded by June 2010.
In addition, the Chief Enforcement Officer’s membership on the ES Board and EP Board provides for important information exchange and decision-making coordination at a strategic level.
Agree.
With respect to human resources, the Enforcement Branch moved in 2009–2010 to complete the integration of the Branch by means of a nation-wide organizational restructuring initiative designed to harmonize organizational structures across regions and the two operational directorates. Classification and organizational structures are now consistent across the Branch. The Branch is also developing a corporate human resources framework that will define a single human resources management vision across both operational directorates. The framework will be in place by the end of 2009–2010.
With respect to planning and reporting, the performance indicator/reporting project now underway is building performance indicators for both wildlife and environmental enforcement that measure the environmental benefit of enforcement actions in each directorate. As well, the results of the framework are integrated, down to the Intermediate outcome level. This will enable a consistent reporting and performance management approach for the entire Enforcement Branch. In addition, priority setting will be integrated between the two directorates for 2010–2011. Indicators will be fully developed by the end of 2009–2010, with data collection beginning the following year to enable reporting against new indicators in 2010–2011.
With respect to training, the Branch acknowledges that strengthening training for WED is a priority. In 2009–2010 the Branch is developing corporate training priorities that reflect the needs of both directorates, and will seek to integrate the provision of Basic Enforcement Training to the greatest extent possible, including the development of a common curriculum, where appropriate. In addition, and in order to build greater consistency across the Branch, an enforcement operations manual is currently being developed and will be implemented as a pilot project by the end of 2009–2010. All enforcement officers will be trained in how to use the manual, resulting in the implementation of common practices not only between WED and EED, but also for all regions. The manual will also help protect enforcement officers through common, sound occupational safety and health practices.
With respect to intelligence, as noted above, the Enforcement Branch has created the Intelligence Working Group, co-chaired by directors from EED and WED, with a mandate to examine intelligence roles and responsibilities and to make recommendations for improving consistency and overall performance in the intelligence function. The Working Group will produce a report by October 2009, with implementation of accepted recommendations by the end of 2009–2010.