One of the points I'm trying to make in this presentation is there have been so many new changes brought in over the last two or three years to improve accountability that we already have a very strong accountability regime at the federal level. This will just add more to it.
There are many unique elements in this bill; for instance, political party financing is quite new. However, when it comes strictly to administration of government, Mr. Alcock alone brought in 200 new measures regarding accountability. So my word of caution is that we have to make sure that the new ideas contained in Bill C-2 do not in any way overburden the system, to the extent that you end up with so many new rules and procedures that the time expended by public servants and others to comply will sometimes cost more in terms of effort than the outcome.
I don't really know at this point. I'm not referring to anything in particular; it's more of a general statement. So as you consider the clause-by-clause, I think you have to ask yourself what other kinds of regulations do we have when, for instance, it comes to whistle-blowing or conflicts of interest, and do these add marginally more value than not? In that case, you may decide that the current regimes are sufficient, at which point you may decide that you don't want or need to go any further.
In other instances, when it comes to the Public Appointments Commission, you may say that we don't have any regime similar to what is being proposed. So this is new, in my view. But when it comes to changing the accountability regime for deputy ministers, I would argue that much of what's contained in the legislation already exists.
You may want to see a value in having a special title around it, so that the public gets a better sense of what's intended. But in terms of actual practices, deputy ministers in this city are extremely accountable to Parliament today. They have been appearing on a regular basis as financial auditors—or responsible for financial activities—for at least 10 to 15 years, and they have been accountable to you for those activities for that period of time. The fact that you want to make this more formal adds to the conversation, and perhaps packages it a bit better, but it won't substantially change their behaviour.