Evaluation at a glance: Horizontal evaluation of the Federal Contaminated Sites Action Plan
About the program
Contaminated sites pose a risk to the environment and human health. The Federal Contaminated Sites Action Plan (FCSAP) is a horizontal, cost-shared program that supports federal departments, agencies and consolidated Crown corporations in addressing the contaminated sites for which they are responsible, such as former mines and military sites and installations.
Created in 2005, FCSAP consolidates the federal government’s approach to dealing with contaminated sites. Eighteen federal partners participate in FCSAP. Fourteen custodial departments, agencies and consolidated Crown corporations receive funding under the program to conduct assessment and remediation activities at federal contaminated sites. In addition, there are four expert support departments that assist custodians in a technical or project management capacity: Environment and Climate Change Canada (ECCC), Health Canada (HC), Fisheries and Oceans Canada (DFO) and Public Services and Procurement Canada (PSPC).
The FCSAP program is administered by ECCC’s FCSAP Secretariat, with support from Treasury Board Secretariat (TBS). Since 2005, FCSAP has been funded in three phases:
- Phase I, from fiscal year (FY) 2005 to 2006 to FY 2010 to 2011
- Phase II, from FY 2011 to 2012 to FY 2015 to 2016
- Phase III, from FY 2016 to 2017 to FY 2019 to 2020
The primary objective of FCSAP is to reduce environmental and human health risks from known federal contaminated sites, as well as associated federal financial liabilities. The FCSAP program also helps support skills development, training and employment of Canadians, including Indigenous communities and others who live in Northern and rural areas. It also encourages Canada’s environmental industry to develop innovative and sustainable remediation technologies and approaches.
A 10-step process, represented in Figure 1, is used for managing federal contaminated sites.
Figure 1: the 10-step process to assess and manage federal contaminated sites
Figure 1 outlines the ten-step process for assessing and managing federal contaminated sites.
Steps 1 and 2 pertain to suspected sites. In Step 1, a suspected site is identified. In Step 2, a historical review is done to identify past activities and potential risks of contamination at the site.
Steps 3 to 6 describe the assessment activities carried out at active sites. In Step 3, an initial testing is conducted. In Step 4, the site is classified as high, medium or low priority for action. In Step 5, detailed testing is conducted. In Step 6, the site classification is reviewed and the site may be reclassified, based on new data.
Steps 7 to 10 describe the remediation activities carried out at active sites. In Step 7, a remediation and risk management strategy is developed for the site. In Step 8, the remediation and risk management strategy is implemented. In Step 9, confirmation sampling is conducted and a final report is developed. In Step 10, long-term monitoring is provided, if required.
At any step in the process, it can be determined that the risk has been reduced or that no further action is required.
What the evaluation found
The evaluation found that there is a clear ongoing need for FCSAP or a similar program to address outstanding liability and risks to the environment and human health associated with federal contaminated sites. Significant progress has been made since the start of the program, including the closure of more than 16,300 sites. However, as of August 2017, there remain more than 7,400 suspected or active contaminated sites in Canada, including more than 3,600 FCSAP-funded sites. As well, an estimated $4.0 billion in federal liabilities are expected to continue beyond the end of FCSAP Phase III in 2020. Alternative sources of funding are likely insufficient to address the liability and risks to the environment and human health associated with federal contaminated sites.
The FCSAP program is a priority for the federal government. It aligns well with current federal priorities such as environmental protection, job creation and skill development, and is seen as an important contributor to the reconciliation agenda. There is strong support among stakeholders, including Indigenous communities, program representatives and external stakeholders, for enhancing alignment with the government’s reconciliation priority through increased engagement and involvement by Indigenous communities in all stages of the FCSAP process. However, it is less clearly aligned with priorities related to innovation and climate change.
Federal responsibility for contaminated sites is articulated in Treasury Board policies. In addition, FCSAP is consistent with existing federal legislation such as the Fisheries Act, the Canadian Environmental Protection Act, 1999, the Canadian Environmental Assessment Act, 2012, the Species at Risk Act, the Migratory Birds Convention Act, 1994 and the Arctic Waters Pollution Prevention Act.
The roles and responsibilities associated with FCSAP’s key program functions are appropriate. However, there are opportunities to enhance efficiencies through improved communication, interaction and collaboration among expert support departments and custodians.
While the overall design of FCSAP is appropriate, encouraging geographic bundling of co-located sites could improve efficiency and promote the achievement of program outcomes. Many program stakeholders support revising the site prioritization process to include socio-economic, political and cultural factors. This has the potential to enhance alignment with the reconciliation agenda and benefit Indigenous peoples.
The efficiency of the FCSAP program has improved since it was last evaluated in 2014. During Phase II, about $1.10 in program costs were required to reduce federal liabilities by $1.00, compared to $1.20 in program costs in Phase I. In addition to allowing the bundling of sites and facilitating more extensive use of multi-year contracting, there is the potential to further enhance efficiency by, among other measures:
- encouraging the implementation of risk management approaches or less intensive remediation approaches, where appropriate
- improving the use of technology in program operation and management
- improving procurement processes
The FCSAP governance structure is appropriate and operating effectively.
Achievement of expected results
Overall, FCSAP assessment and risk reduction activities have reduced uncertainty associated with risk from federal contaminated sites. They have contributed to reducing the risk to the environment and human health associated with these sites. While aggregate liability associated with federal contaminated sites has not been reduced since the start of the program, the majority of FCSAP expenditures for risk reduction have been liability-reducing.
- Assessments and risk reduction plans. FCSAP funded assessment activities at 1,919 federal contaminated sites and completed assessments at 1,022 sites during Phase II and the first year of Phase III, reducing uncertainty associated with the risk from these sites. Although the program experienced some challenges in meeting performance targets for risk-reduction plans, remediation and risk management activities were completed at 271 FCSAP-funded high- and medium-priority sites over this period.
- Reduced federal liability. More than 90% of FCSAP expenditures for remediation and risk management activities have contributed to reducing liability. Nevertheless, aggregate liabilities for federal contaminated sites have not been reduced since Phase I. They were $2.2 billion higher at the end of Phase II than they were at the beginning. To a large extent, this outcome can be attributed to significant increases in liabilities at the Giant Mine and the Faro Mine. Of the $4.0 billion in total estimated liabilities expected to continue beyond Phase III, slightly more than half will rest with these two sites.
- Reduced risk to the environment and human health. By the end of FY 2016 to 2017, 1,169 FCSAP-funded high- and medium-priority sites had completed risk reduction activities. This implies that risks to the environment and human health have also been reduced at these sites. However, the FCSAP program does not directly measure risk reduction. There is widespread agreement that this is an area in which the program could improve its performance measurement and reporting.
- Employment creation in the environmental services industry. Program stakeholders believe FCSAP has contributed to job creation in the environmental services industry, government and Indigenous communities. However, some stakeholders think more could be done to ensure that the socio-economic benefits associated with the program flow to Indigenous communities. About 6,604 person-years of employment were generated or maintained through Phase II FCSAP expenditures.
There is also anecdotal evidence that FCSAP has generated positive, secondary benefits. These benefits include increased knowledge, skills and expertise within the environmental services industry and the Government of Canada related to contaminated sites, consolidation of the environmental services industry and increased capacity within Indigenous communities.
FCSAP has a well-developed performance measurement infrastructure, and performance data is timely and reliable. Finding ways to tell a meaningful performance story is an issue, particularly in light of the ongoing reliance on liability reduction as an outcome measure. Moving forward, greater emphasis should be placed on performance measures related to risk reduction. In addition, the program logic model should be refined to eliminate duplication and ensure that all expected outcomes are represented.
Recommendations and management response
Based on the evaluation findings, three recommendations have been formulated for the FCSAP program. Recommendation 1 is directed to Environment and Climate Change Canada’s Assistant Deputy Minister (ADM) of Environmental Protection Branch, as the senior departmental official responsible for the FCSAP Secretariat. Recommendation 2 is directed to Crown-Indigenous Relations and Northern Affairs Canada’s ADM of Lands and Economic Development and ADM of the Northern Affairs Organization. Recommendation 3 is directed to Environment and Climate Change Canada’s ADM of Environmental Protection Branch, in consultation with Treasury Board of Canada Secretariat.
The Assistant Deputy Ministers at ECCC and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) agree with the recommendations and have developed management action plans in response to each of them.
Recommendation 1: it is recommended that Environment and Climate Change Canada’s Assistant Deputy Minister, Environmental Protection Branch, promote efficiency in program delivery by encouraging bundling of geographically co-located sites, potentially combining higher-risk and lower-risk sites, for purposes of assessment, remediation and risk management and long-term monitoring.
The bundling of Class 1 or ongoing Class 2 sites with lower priority sites based on geography, as well as bundling on reserve or Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) northern sites, represents an opportunity to increase efficiencies and accelerate actions at federal contaminated sites.
Site work is currently planned by individual custodians and reviewed by the Contaminated Sites Management Working Group (CSMWG). As of FY 2020 to 2021, the FCSAP program would take a more integrated approach to planning in order to bundle sites cost effectively. This would include advanced planning of projects in-year and within the context of five-year work plans. Also, site prioritization would include lower priority sites where existing Class 1 and ongoing Class 2 sites can be bundled geographically with new Class 2 or Class 3 sites and where sites are located on reserves or in the North under the custody of Indigenous Services Canada or CIRNAC. Existing regional working groups that include custodians and expert support departments would take on new responsibilities to maximize collaboration among program partners, including bundling of sites for assessment and remediation activities and concurrent identification of contingency sites that could be moved forward quickly if other projects are unexpectedly delayed. Procurement specialists from Public Services and Procurement Canada (PSPC) and Defence Construction Canada (DCC) would be involved from the earliest planning stages through to project completion. They would work with program partners and industry to expedite work and ensure that the necessary tools and resources are available to meet project deadlines. The ADM Oversight Board would have the ultimate decision on work plans and strategic opportunities for investment.
The deliverables will be developed by the FCSAP Secretariat in collaboration, as appropriate, with Treasury Board Secretariat, the ADM Oversight Board, expert support departments, PSPC, DCC and custodians/CSMWG.
Recommendation 2: it is recommended that Crown-Indigenous Relations and Northern Affairs Canada’s Assistant Deputy Minister, Lands and Economic Development, and Assistant Deputy Minister, Northern Affairs Organization, improve information-sharing, engagement and collaboration with Indigenous communities throughout all stages of the FCSAP process, including assessment, prioritization and remediation of contaminated sites.
Management response 1 (Lands and Economic Development)
In partnership with Environment and Climate Change Canada, Crown-Indigenous Relations and Northern Affairs Canada’s Contaminated Sites on Reserve Program will improve information-sharing, engagement and collaboration with Indigenous communities throughout all stages of the Federal Contaminated Sites Action Plan (FCSAP) process, including assessment, prioritization and remediation of contaminated sites. This will include continuing to:
- engage with and build upon the existing positive relationships with Indigenous communities that have had experience managing FCSAP-funded contaminated sites projects
- work with Indigenous communities to share information to increase awareness and knowledge of the FCSAP program
- explore options with Environment and Climate change Canada to increase opportunities for Indigenous communities and organizations to become more involved in managing and prioritizing FCSAP contaminated sites projects
- share engagement best practices across all regional offices as part of the work of the Contaminated Sites on Reserve Program National Contaminated Sites Management Committee
- explore long-term options with Environment and Climate Change Canada to increase capacity both internally and externally related to information-sharing, engagement and collaboration with Indigenous communities
- work with departmental communications experts to produce updated content for the ISC/CIRNAC Contaminated Sites on Reserve Program internet pages to share additional information on the FCSAP and the Contaminated Sites on Reserve Program.
Management response 2 (Northern Affairs Organization)
In partnership with Environment and Climate Change Canada (ECCC), Crown-Indigenous Relations and Northern Affairs Canada’s Northern Contaminated Sites on Reserve Program will improve information-sharing, engagement and collaboration with Indigenous communities throughout all stages of the FCSAP process, including assessment, prioritization and remediation of contaminated sites. This will include:
- continuing to engage with and build upon the existing positive relationships with First Nations communities that have had experience managing FCSAP-funded contaminated sites projects with the NCSP program using FCSAP funds
- continuing to work with Northern regional offices to share engagement best practices and support relationship building on contaminated sites projects at the regional level
- continuing to provide ongoing communications updates on the progress of the major projects.
Recommendation 3: it is recommended that Environment and Climate Change Canada’s Assistant Deputy Minister, Environmental Protection Branch, enhance the approach to performance measurement and reporting to more clearly and meaningfully convey the Federal Contaminated Sites Action Plan program’s successes to Canadians.
While continuing to collect and record liability reduction data in a renewed program, the FCSAP Secretariat, in consultation with the Treasury Board Secretariat (TBS), will place greater emphasis on the program’s risk reduction outcomes for reporting purposes. The platform for this change will continue to be the FCSAP Performance Measurement Framework (PMF) and the goal will be to have in place the means and methods of collecting risk reduction data by the start of the renewed program in FY 2020 to 2021.
This will include a review of the current FCSAP logic model and PMF in order to strengthen and refine performance reporting by (1) eliminating any unnecessary duplication within the current logic model and PMF, and (2) revising the current FCSAP logic model to represent all of the program’s expected outcomes, along with a clearly articulated theory of change specifying how program activities and outputs are expected to lead to the outcomes. The updated logic model will include any new expected outcomes that are included as part of the program’s renewal. The review and refinement of the logic model and PMF will be done by the FCSAP Secretariat in consultation with TBS, custodians and ESDs.
About the evaluation
In collaboration with 17 federal partners, the evaluation was conducted by ECCC’s Audit and Evaluation Branch in FY 2017 to 2018. The evaluation focused on a six-year period from FY 2012 to 2013 to FY 2017 to 2018, covering the last four years of FCSAP Phase II and the first two years of Phase III. Several methodologies were used, including document and data review, interviews with 66 key informants, an analysis of similar programs in five other jurisdictions, five case studies and an expert panel. The report was approved by the Deputy Ministers of Crown-Indigenous Relations and Northern Affairs Canada and of Indigenous Services Canada on December 10, 2018 and by the Deputy Heads of Environment and Climate Change Canada on December 21, 2018.
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