At a glance – Evaluation of the Enforcement Modernization Initiative

This new approach involved a change in all aspects of EB’s work, including roles, responsibilities, and processes.  

Under the risk-based approach, each year, EB sets priorities and creates an IEP that lays out inspection priorities by region and intelligence and training priorities for EED and WED, such as national and regional risk-based projects, maintenance/compliance monitoring, reactive work, reinspection and other priority projects. The IEP is based on five principles. It is:

• Evidence-based
• Risk-based
• Operationally advisable
• Transparent and accountable
• Adaptive 

Several supporting projects were funded with the goal of establishing the foundation for modern, data-driven, and risk-based enforcement. The following projects were included in the present evaluation:

• Developing an Enterprise DataHub that would facilitate the transfer of enforcement data to a Protected B cloud-based environment.
• Using Microsoft Power BI to support integration of performance data for analysis and real-time monitoring of results.
• Developing and implementing a computer forensics laboratory. This project was intended to augment capacity to meet evidentiary standards in support of investigations.
• Creating a forum to align priorities and cooperation with key federal, provincial, and territorial enforcement partners and Indigenous counterparts. The aim was to have better information exchange and cooperative approaches and to potentially reduce the duplication with provinces and territories. 

2. Scope

The Enforcement Modernization Initiative evaluation covers the 4-year period from 2020-2021 to 2023-2024. The evaluation focuses on the following themes:

• Alignment with departmental priorities & efficiency.
• Design.
• Delivery.
• Change management.
• Performance measurement framework.
• Effectiveness – achievement of expected results.

3. Methodology

A variety of sources were used, including two site visits to the regions, as well as:

• Document and data review. Examined documents including process documentation, project plans and assessment reports, and financial data.
• Interviews. Interviews were conducted with EB staff from all divisions and with ECCC internal partners.
• Site visits. Two site visits were conducted at EB regional offices to gain an understanding of the operational realities for both WED and EED officers.
• Benchmarking analysis. A limited analysis of similar enforcement functions at Parks Canada and the Department of Fisheries and Oceans was completed.
• Survey. A survey was conducted to capture the regional and operational perspective.
• Case studies. Reviewed EED and WED documents for 13 national priority projects.

4. Findings

4.1. Alignment with departmental priorities & efficiency

The need for an Enforcement Branch modernized enforcement approach and for a focus on risks was evidenced. The modernization initiative is aligned with departmental priorities. However, the survey results indicate that there is an opportunity to enhance priority alignment.

4.2. Design

The Enforcement Modernization Initiative is meeting its principles of being risk/evidence based. While the integrated planning process has delivered annual inspection, training, and intelligence priorities in a timely way, there are opportunities for refinement in the processes.

4.3. Delivery

While the Enforcement Modernization Initiative design may prove to be effective in the long term, implementation during the evaluation period has prevented Law Enforcement Branch to fully achieve modernization objectives. Progress and improvements have been made towards areas such as effective communications. It is also noted that collaboration and engagement with the Integrated Enforcement Plan planning teams and partners remain important going forward. There are opportunities to clarify roles and responsibilities for all steps in the process, but particularly the intelligence function, to ensure roles are clear and collaboration, engagement, and transparency are improved.

4.4. Change management

Given the significant change it represents, the Enforcement Modernization Initiative required senior management commitment and investment to manage change. While progress has been observed, the Enforcement Branch still has opportunities to enhance implementation by ensuring optimization of the understanding of and adherence to the goals, governance structures, roles and responsibilities, and processes. 

4.5. Performance measurement framework

Quality and timely data entry and reliability of performance information have been ongoing areas identified for improvement, especially within the Wildlife Enforcement Directorate. Although several steps have been put in place to address these issues, opportunities remain for the Wildlife Enforcement Directorate to clearly define and update measures of success against initiative results in its performance measurement strategy.

4.6. Effectiveness-achievement of expected results

The evaluation found progress has been made towards the achievement of expected results and key outputs. A key achievement has been the development of real-time targeting of non-compliance in commercial trade.

Despite EB’s efforts to optimize the use of the computer forensics lab, a formal assessment is needed to determine its medium and long-term viability considering the current challenges that have led to its underutilization.

5. Recommendation, Management Response and Action Plan

Recommendation 1: The Chief Enforcement Officer should streamline the Intelligence function in both the Environmental Enforcement Directorate (EED) and the Wildlife Enforcement Directorate (WED) and clarify roles and responsibilities to ensure its efficiency and effectiveness.

Action 1: Review and implement a revised structure and governance of Intelligence functions. 

Recommendation 2: The Chief Enforcement Officer should assess the viability and sustainability of the computer forensics laboratory to provide cost-effective digital forensics services to Enforcement Branch in a timely manner.

Action 1: Review current operations of the computer forensics laboratory.

Recommendation 3: The Chief Enforcement Officer should review and update the Enforcement Modernization Initiative’s performance measurement and data collection strategy to better demonstrate value, costs and results. 

Action 1: Review, seek approval and update performance management indicators.