Departmental Sustainable Development Strategy — Departmental Results Report 2019-20
On this page
- List of acronyms
- Section 1. Context for the Departmental Sustainable Development Strategy
- Section 2. Sustainable Development in the Department of Canadian Heritage
- Section 3. Departmental performance by FSDS goal
- Section 4. Integrating sustainable development
List of acronyms
- ABW
- Activity-based workplace
- ADM
- Assistant Deputy Minister
- BGIS
- Brookfield Global Integrated Solutions
- BIXI
- Bicycle sharing system
- BOMA
- Building Owners and Managers Association
- CCI
- Canadian Conservation Institute
- CEAA
- Canadian Environmental Assessment Agency
- CGG
- Centre for Greening Government
- DG
- Director General
- DSDS
- Departmental Sustainable Development Strategy
- ECCC
- Environment and Climate Change Canada
- FSDS
- Federal Sustainable Development Strategy
- FSTII
- Federal Science and Technology Infrastructure Initiative
- GC
- Government of Canada
- GHG
- Greenhouse gas
- LGE
- Litre per Gasoline Equivalent
- LGE/100km
- Litre per Gasoline Equivalent per one hundred kilometers
- MC
- Memoranda to Cabinet
- NOTE
- Take note
- PCH
- Canadian Heritage
- PSPC
- Public Services and Procurement Canada
- QAR
- Quality Assurance Review
- SDG
- Sustainable Development Goals
- SDO
- Sustainable Development Office
- SEA
- Strategic Environmental Assessment
- SSC
- Shared Services Canada
- TB
- Treasury Board
- TBS
- Treasury Board Secretariat
- UN
- United Nations
Section 1. Context for the Departmental Sustainable Development Strategy
The 2016–2019 Federal Sustainable Development Strategy (FSDS) presents the Government of Canada’s sustainable development goals and targets, as required by the Federal Sustainable Development Act. In keeping with the objectives of this Act to make environmental decision-making more transparent and accountable to Parliament, the Department of Canadian Heritage (PCH) supports reporting on the implementation of the FSDS and its Departmental Sustainable Development Strategy (DSDS) through the activities described in this supplementary information table.
Section 2. Sustainable Development in the Department of Canadian Heritage
The Department of Canadian Heritage Departmental Sustainable Development Strategy for 2017 to 2020 describes the department’s actions in support of achieving the FSDS goal of Low Carbon Government. This supplementary information table presents available results for the departmental actions pertinent to this goal. Previous years’ supplementary information table are posted on the department’s website. This year, PCH is also noting which UN Sustainable Development Goal target each departmental action contributes to achieving.
Section 3. Departmental performance by FSDS goal
FSDS Goal: Low Carbon Government – The Government of Canada leads by example by making its operations low-carbon.
The Department of Canadian Heritage supports the Federal Sustainable Development Act and the goals and targets of the Federal Sustainable Development Strategy (FSDS) that govern carbon emissions in Canada. However, all departmental facilities are owned by Public Services and Procurement Canada (PSPC) with the exception of the building that houses the Canadian Conservation Institute (CCI), all remaining custodial responsibilities rest with PSPC.
Canadian Heritage actively encourages sustainable workplace practices that support reduced carbon emissions. For example, the Department has implemented measures fully aligned with the federal Policy on Green Procurement to the extent that environmental provisions are included in all departmental tender documents. In order to further reduce the Department’s carbon footprint, a policy of “one device per user” has been implemented where each employee is encouraged to use one primary source of technology such as a laptop or tablet, rather than use multiple devices. The Department’s Printer Strategy eliminated personal printers so now an average of eight employees share one printer instead of four to one. The Mobile Workforce Initiative encourages employees to attend meetings with only their mobile devices to avoid excessive use of paper, and the Department’s videoconferencing project promotes the use of teleconferences and videoconferences over face-to-face meetings in order to reduce travel and the subsequent burning of fossil fuels.
The Department of Canadian Heritage’ actions in support of the Low Carbon Government goal directly support the following Sustainable Development Goals and targets of the UN’s 2030 Agenda for Sustainable Development:
Goal 12 – Responsible Consumption and Production
Target 12.7 - Promote public procurement practices that are sustainable, in accordance with national policies and priorities.
Goal 13 – Climate Action
Target 13.2 - Integrate climate change measures into national policies, strategies and Planning
Furthermore, the Department’s sustainable development activities support international agreements and initiatives including the North American Climate, Clean Energy and Environment Partnership, which is an action plan announced by Prime Minister Justin Trudeau, former U.S. President Barack Obama, and former President Enrique Peña Nieto of Mexico. This Action Plan identifies the deliverables to be achieved and activities to be pursued by the three countries as part of an enduring Partnership.
Commitments for the Department of Canadian Heritage
- Low-carbon government:
- The Government of Canada leads by example by making its operations low-carbon
- Responsible Minister:
- All ministers
- Canadian Heritage will contribute to the following FSDS target:
- Reduce GHG emissions from federal government buildings and fleets by 40% below 2005 levels by 2030, with an aspiration to achieve this reduction by 2025.
Canadian Heritage has identified five FSDS contributing actions
Corresponding departmental actions | Contribution by each departmental action to the FSDS goal and target and support for UN Sustainable Development Goal target. | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|---|
Continue to make readings of utilities (gas, water usage and electricity) for the only real property facility in the PCH portfolio, the Canadian Conservation Institute (CCI) building on Innes Road, Ottawa, aim towards efficiencies and avoid waste; and, elect to use clean energy, when possible. NOTE: “Clean" energy is inevitably bound by existing financial/budgetary commitments and the tenets of the current federal contract bidding and awards process. |
This action, along with the use of clean energy, reduces demand for energy and increases operational efficiency, which leads to marked reductions in GHG emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Readings continue to be collected and show efficiencies over time. Clean energy is used when possible. Starting point: Daily readings are taken for water and weekly readings for gas and electrical. |
Daily readings continue to be taken for water and weekly readings for gas and electrical. |
Implementation of a modern Workplace for the new public service. The GC Workplace fit-up standards—Activity-based workplace (ABW). Les Terrasses de la Chaudière complex in Gatineau, built in 1978, is launching major renovations that will take place over the next several years. The government will take advantage of this and will convert its allocated space to a GC Workplace fit-up Standards—Activity-based workplace (ABW). |
This action helps to reduce GHG emissions and enables public servants to work in a smarter, greener and healthier way. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Number and percentage increase in workplace Fit-up projects. Starting point: 100% of new major refit projects are based on GC Workplace’s directives. 25 Eddy Street, Suite 100, First and second floors were 100% converted into GC Workplace as per PSPC’s initiative. In the regions, Ontario’s regional office was converted into a GC Workplace in March 2019. Moncton and St. John’s offices are currently being redesigned into GC Workplace. Moncton completion date: November 2019. St. John’s completion date: May 2020. |
100% of new major refit projects are based on GC Workplace’s directives. Moncton and St. John’s offices are currently being redesigned into GC Workplace. Due to various site conditions, the project will be completed in December 2020 for the Moncton offices and postponed until 2021-22 for St. John’s locations. |
Improve the sustainability of workplace operations by endorsing and promoting information management practices that enforce the disposition of transitory information—paper, mail, network drives—in line with the Treasury Board Secretariat’s (TBS) Directive on Recordkeeping. |
This action increases operational efficiency by reducing the size of repositories of information of business value and when combined with the move to digitization, reduces the use of paper products that are a prime source of greenhouse gas emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicators: Percentage of planned disposition for paper information resources records completed. (TBS) Percentage of unstructured electronic information resources records maintained in designated corporate repositories. (TBS) Starting point: 85% - Planned disposition 2018-19 PCH Unstructured Electronic Information in Designated Corporate Repositories 45.36% Footnote 1 |
PCH has disposed 85% of the paper information resources that the department has authority to dispose of, including at headquarters and in the regions. Work is ongoing to continue transferring documents to Library and Archives Canada. |
Dispose of all e-waste in an environmentally sound and secure manner in accordance with the Directive on Disposal of Surplus Material. |
This action supports the reduction of GHG emissions by increasing levels of reuse, recycling and recovery of electronic waste like discarded computers, electronic office equipment and mobile phones. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Percentage of planned disposal of waste. Starting point: All e-waste is disposed in accordance with the “Directive on Disposal of Surplus Materiel” in an environmentally sound and secure manner. Departmental IT equipment that is declared surplus is donated to the Computers for Schools program. |
100% of e-waste is disposed in accordance with the “Directive on Disposal of Surplus Materiel” in an environmentally sound and secure manner. Canadian Heritage continues to donate IT equipment that is declared surplus to the Computers for Schools program. |
Repurpose/reallocate all reusable/recyclable materiel/assets deemed viable within the Department where needs are known. If no requirement exists items are posted for 10 days on GC transfer allowing other government departments to incorporate them into their inventory free of charge before being placed for open public bidding on Public Service and Procurement Canada (PSPC) - GC Surplus. |
This action supports the reduction of GHG emissions by increasing levels of reuse, recycling and recovery. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Number of reusable/recyclable material assets repurposed or reallocated. Starting point: All reusable/recyclable material/assets are repurposed/reallocated within the Department where needs are known. GC transfer is used to potentially transfer to other departments, and GC Surplus is used to sell surplus departmental assets and materials. No tangible data is available for this action. |
All reusable/recyclable material/assets are repurposed/reallocated within the Department where needs are known. GC transfer is used to potentially transfer to other departments, and GC Surplus is used to sell surplus departmental assets and materials. No tangible data is available for this action. |
Eliminate personal printers thereby increasing the ratio of number of employees per printer. |
This action reduces the demand for energy and leads to a reduction in GHG emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Starting point: Results Achieved: |
100% |
Implement a policy of “one device per user” where each employee is encouraged to use one primary source of technology, such as a laptop or tablet, rather than multiple devices. |
This action reduces the demand for energy and leads to a reduction in GHG emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Percentage of employees using one primary source of technology for day-to-day operations. Starting point: |
100% |
Encourage employees to attend meetings with only their mobile devices through the Mobile Workforce Initiative, to reduce the extensive use of paper. |
To encourage employees to work digitally reduces GHG emissions by diminishing paper production, which is a prime source of greenhouse gas. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Percentage of employees able to use mobile devices rather than paper, to conduct business meetings. Starting point: It is not possible to determine the percentage of employees who use mobile devices to organize meetings across the service, but we know how many of them can do so. However, 100% of PCH employees can use mobile devices to hold meetings. |
It is not possible to determine the percentage of employees who use mobile devices to organize meetings across the service; however, all employees are able to use mobile devices to organize meetings. |
Respond in an effective and timely manner to directives regarding issues of sustainable development from Public Service and Procurement Canada (PSPC), who are majority owners of Canadian Heritage facilities and fleets. |
To respond in an effective and timely matter to directives from lead agencies strengthens the Department’s commitment to support the goals and targets of the long-term aspirational goal of Low Carbon Government. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Response time to action the implementation of directives from lead agencies. Starting point: Building/facilities sustainability’s directives are led by PSPC and BGIS, and we are complying when and where required. PCH responds effectively and quickly to the sustainable development guidelines of PSPC, which is the majority owner of PCH’s facilities and fleets. No tangible data is available for this action. |
Canadian Heritage continues to respond effectively and quickly to the sustainable development guidelines of PSPC, which is the majority owner of PCH’s facilities and fleets. No tangible data is available for this action. |
Support the Department’s Strategic Environmental Assessment (SEA) process and ensure compliance with the Cabinet Directive on Policy, Plan and Program Proposals. |
This action ensures that environmental considerations are incorporated into Departmental operation and decision-making processes which inevitably reduce greenhouse gas emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Percentage of MCs, TB Subs and other proposals that include environmental considerations. Starting point: In a recent audit of the Commissioner of the Environment and Sustainable Development, 17 of the 18 or 94 percent of the proposals reviewed included environmental considerations. |
100% of MCs, TB Subs and other proposals include an assessment of environmental considerations |
Corresponding departmental actions | Contribution by each departmental action to the FSDS goal and target and support for UN Sustainable Development Goal target | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|---|
Track fuel consumption of the Department’s fleet to ensure it is in line with the objectives of the Federal Sustainable Development Strategy (FSDS). |
This action supports the FSDS target milestone to establish a complete and public inventory of federal greenhouse gas (GHG) emissions and energy use. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Overall fuel consumption (LGE). Starting point: In progress. |
Canadian Heritage continues to track overall fuel consumption using the ARI database, and average fuel consumption is constantly calculated. |
Respond in an effective and timely manner to directives regarding the modernization of government fleets from the Centre for Greening Government (CGG) who oversee all greenhouse gas (GHG) emissions activity on behalf of the Government. |
To respond in an effective and timely matter to directives from lead agencies strengthens the Department’s commitment to support the goals and targets of the long-term aspirational goal of Low Carbon Government. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Response time to action the implementation of directives from lead agencies. Starting point: PCH is currently well positioned to fulfill this requirement and will ensure that future acquisitions respect the long-term goal of Low Carbon Government, including low-carbon fleet vehicle solutions. |
No tangible data for this action. |
Purchase fuel-efficient and hybrid-electric vehicles. |
Moving away from fuels that produce high levels of carbon dioxide reduces GHG emissions. This action supports UN Sustainable Development Goal targets,12.7, 13.2 |
Performance indicator: Increase in purchase of fuel-efficient and hybrid-electric vehicles as a percentage of total vehicles purchased. Starting point: PCH is currently well positioned to fulfill this requirement and will ensure that future acquisitions respect the long-term goal of Low Carbon Government, including low-carbon fleet vehicle solutions. |
100% In 2019, the Department purchased one (1) hybrid vehicle and one (1) fuel-efficient, making the entirety of its fleet ecofriendly. |
Use of the charging stations at Les Terrasses de la Chaudière under the management of BGIS/PSPC. |
This action enhances the sustainability of the Department’s use of clean technology while reducing GHG emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Number of active charging stations. Starting point: PCH has access to 4 active charging stations. The number of terminals available to the public in 2020 will be 17 according to the information provided by PSPC. |
The Department still has access to 4 active charging stations. |
Corresponding departmental actions | Contribution by each departmental action to the FSDS goal and target and support for UN Sustainable Development Goal target | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|---|
Include environmental provisions in all departmental tender documents and encourage suppliers to integrate environmental considerations when submitting proposals to provide goods and services. |
These actions ensure the objectives of the goal of Low Carbon Government are promoted to the extent that they are embedded in procurement instruments used by private sector stakeholders. This action supports UN Sustainable Development Goal target 12.7 |
Performance indicator: Percentage of departmental tender documents that include environmental considerations. Starting point: 100% |
100% |
Require procurement and material management specialists to complete the most current Canada School of Public Service Green Procurement course. |
This action ensures the necessary level of subject matter expertise to effectively manage actions that support Low Carbon Government. This action supports UN Sustainable Development Goal target 12.7 |
Performance indicator: Number and percentage of specialists in procurement and materiel management who have completed training on green procurement. Starting point: 100%. Eight (8) of eight employees |
100% Eight (8) of eight employees |
Acquire audiovisual equipment, IT hardware, and office furniture through mandatory Public Service and Procurement Canada (PSPC) acquisition mechanisms, which are embedded with green procurement clauses. |
This action bolsters a common approach to sustainable procurement across government in keeping with recommendations in the Federal Sustainable Development Strategy (FSDS). This action supports UN Sustainable Development Goal target 12.7 |
Performance indicator: Percentage of dollar value of audiovisual equipment, IT hardware, and office furniture purchased via mandatory PSPC and SSC acquisition mechanisms. Starting point: Most (98%) AV Equipment is acquired through the Public Services and Procurement Canada (PSPC) acquisition mechanism which includes green procurement clauses. |
100% of audiovisual equipment and IT hardware is purchased through mandatory PSPC and SSC acquisition mechanism, which include green procurement clauses. |
Implement the best practice of requiring acquisition card users to take training in green procurement. |
This action allows the Department’s functional experts in procurement to educate and inform users and carry out due diligence of sustainable development practises. This action supports UN Sustainable Development Goal target 12.7 |
Performance indicator: Percentage and number of acquisition cardholders trained on green procurement. Starting point: All current acquisition cardholders have completed the Canada School of Public Service “Green Procurement” training. |
100% |
Ensure that support of and contributions toward green procurement is included in the performance evaluation of managers and functional specialists of the Contracting and Material Management Directorate. |
This action commits managers to support the objectives of green procurement as it relates to the goal of Low Carbon Government. This action supports UN Sustainable Development Goal target 12.7 |
Performance indicator: Number and percentage of managers and functional heads of procurement and materiel management whose performance evaluation includes support and contribution towards green procurement in the current fiscal year. Starting point: 100% |
100% |
Corresponding departmental actions | Contribution by each departmental action to the FSDS goal and target and support for UN Sustainable Development Goal target | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|---|
Promote and encourage teleconferences, online meetings and the use of web conferencing tools such as WebEx and Skype, over face-to-face meetings. |
Replacing traditional methods with those from digital platforms of engagement increases the efficient use of energy thereby reducing GHG emissions. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Percentage of non-face-to-face meetings from an average sample size. Starting point: No data available to date However, PCH employees could use teleconferences, WebEx, Jabber and Skype for Business for their meetings. |
It is impossible to identify a percentage; however, 100% of employees are equipped to conduct meetings virtually/digitally. |
Corresponding departmental actions | Contribution by each departmental action to the FSDS goal and target and support for UN Sustainable Development Goal target | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|---|
Renew BOMA Best certification for effective energy and environmental performance for the only real property facility in the Canadian Heritage portfolio, the Canadian Conservation Institute (CCI) building on Innes Road, Ottawa. |
This action and its subsequent efficiencies reduce the demand for energy and lead to a reduction in greenhouse gas (GHG) emissions and is in keeping with efforts to guard against the long-term impact of climate change. This action supports UN Sustainable Development Goal target 13.2 |
Performance indicator: Renewal of BOMA Best certification for effective energy and environmental performance. Starting point: The renewal of BOMA Best certification has been put on hold since the Canadian Conservation Institute Program will be relocated following an initiative by SPAC - Laboratories Canada (FSTII). |
The renewal of BOMA Best certification is still on hold pending the relocation of the Canadian Conservation Institute. |
Additional departmental sustainable development activities and initiatives
Program in which the departmental actions will occur: internal services
Additional departmental sustainable development activities and initiatives | Performance indicators for departmental actions and starting point(s) i.e.: results reported for 2018-19 | Results achieved (2019-20) |
---|---|---|
GroupEco is a group of employees at Canadian Heritage, dedicated to the promotion of day-to-day behaviours that can contribute to the reduction of the environmental footprint at work (and at home). Activities include, “point in time” promotions such as green Christmas, recycling of writing instruments and small electronics, and the use of reusable food containers. The group’s major annual event is “Canadian Environment Week” where, in collaboration with different external parties (including the cities of Gatineau and Ottawa), they promote a myriad of sustainable activities. |
Performance indicator: Number of on-line visits to GroupEco intranet page. Starting point: Comparative sample of activity over a 2-year period for the French intranet landing page: June 1, 2018 – Aug 5, 2019 Page Views:
Unique Page Views:
Avg. Time on Page:
Entrances:
Bounce Rate:
Exit Rate:
English landing page Page Views:
Unique Page Views:
Avg. Time on Page:
Entrances:
Bounce Rate:
Exit Rate:
|
Sample of activity for the French intranet landing page (in comparison to the starting point): Page views:
Unique page views:
Average time on page:
Sample of activity for the English intranet landing page (in comparison to the starting point): Page views:
Unique page views:
Average time on page:
|
Develop and implement an interactive outreach plan to inform and educate employees about effective workplace sustainable development practises, in support of environmentally aware change management. |
Performance indicator: A sustainable development outreach plan is developed and implemented. Starting point: No data available to date |
No data available to date |
Increase awareness and support alternative work arrangements such as teleworking. Support the use of environment-friendly transportation like the BIXI cycle system, which is in keeping with the range of new technologies that are changing the way we work. |
Performance indicator: Increase in the number of employees choosing to work under alternative work arrangements. Increase in the number of employees using environment-friendly modes of transportation. Starting point: Year 1 baseline numbers for telework agreements:
Reflects overall upward trend. |
Reflects overall upward trend. |
Include clauses related to environmental considerations in the performance objectives of key managers. |
Performance indicator: Number and percentage of key managers with clauses relating to issues of the environment. Starting point: No data available to date |
No data available to date |
Actively participate in Interdepartmental Assistant Deputy Minister (ADM) and Director General Meetings and forums that support the Federal Sustainable Development Strategy (FSDS) and the greening of government. |
Performance indicator: Participation at ADM and DG committee meetings and forums that support the objectives of the Federal Sustainable Development Strategy (FSDS). Starting point: 100% participation rate |
100% participation rate |
Active participation as a member of the Strategic Environmental Assessment (SEA) Working Group, SEA Working Group Tiger Team and the SEA Community of Practice. |
Performance indicator: Participation in SEA Working Groups, Tiger Teams and the SEA Community of Practice. Starting point: 100% participation rate |
No data available, given that the SEA Working Groups, Tiger Teams no longer exist. |
Section 4. Integrating sustainable development
The Department of Canadian Heritage has integrated environmental considerations into its operational processes and instruments to the extent that key templates and delivery mechanisms, such as common-use procurement tools and the approval process for Memoranda to Cabinet (MC), include a requirement to consider issues of the environment and sustainable development. By strict adherence to the directives of the lead environmental authorities: the Treasury Board’s Centre for Greening Government (CGG); the Sustainable Development Office (SDO) at Environment and Climate Change Canada (ECCC); and, the Canadian Environmental Assessment Agency (CEAA), the Department endeavours to stay true to its commitment to the objectives of the Federal Sustainable Development Strategy (FSDS).
Strategic Environmental Assessments
The Department continues to track and monitor Strategic Environmental Assessments (SEA) and has recently updated its SEA process to ensure that decision-making invariably includes consideration of the goals and targets of the Federal Sustainable Development Strategy (FSDS). In a recent performance audit of Departmental Progress in Implementing Sustainable Development Strategies, it was reported that Canadian Heritage “…demonstrated considerable improvement…” since the last audit in 2015, with a compliance rate of almost 90 percentFootnote 2.
The Department’s step-by-step SEA process has proven to be an effective analytical tool to assess the environmental impact of policy, plan and program proposals. Consequently, decision makers are well informed of the potential positive and negative issues regarding sustainable development. The SEA process is led by the Strategic Planning Directorate in conjunction with the Cabinet and Parliamentary Affairs group and the Financial Management Branch who deal specifically with Treasury Board submissions.
The Department of Canadian Heritage will continue to ensure that environmental considerations and responsibilities are clearly outlined in contribution agreements and partnership agreements governing a range of projects and initiatives such as the hosting of sporting events, like the Canada Games, and festivals and celebrations including Canada Day. Funding agreements for infrastructure projects that deal with a variety of subjects including, support for creative hubs and provincial/territorial educational infrastructure in official language minority communities, will also include commitments to the goals and targets of the Federal Sustainable Development Strategy (FSDS).
Public statements on the results of the Department of Canadian Heritage’s assessments are made public when an initiative that has undergone a detailed SEA is announced. The purpose of the public statement is to demonstrate that the environmental effects, including the impacts on achieving the FSDS goals and targets, of the approved policy, plan or program have been considered during proposal development and decision-making.
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