Environment Committee on Feb. 12th, 2007

[The Chair, Conservative, Bob Mills]

I would like to start off by welcoming our guests. Many of us have seen these guests before and are aware of who they are. I want to particularly welcome them.

Just for the members' interest, the way I would like to operate today is to end our cross-examination of the witnesses at 4:45. That would leave us from 4:45 until 5:30 to discuss the motion at hand, the intention being to vote by 5:30 so that members can go on to the Bill C-30 committee.

If I don't hear any objections, those will be the timelines I will follow. I'll ask you to be very precise in your questioning, and let's try to finish by 4:45 for our witnesses.

For our witnesses, let's begin. Mr. Toner, do you have a statement you wish to make?

[Glen Toner, Member, Panel of Advisors, Office of the Commissioner of the Environment and Sustainable Development, As an Individual]

Yes, Mr. Chair. I have about a 10-minute oral statement that I will make to the group.

By way of context and background, let me just tell you a bit about myself and how I ended up here in front of you today. I was educated at the universities of Saskatchewan and Alberta, and at Carleton, where I've taught for the last 24 years. My research interests are in energy, environment, and sustainable development policy. An example of the work I do is the recent UBC press book entitled Sustainable Production: Building Canadian Capacity. I also edit an annual volume entitled Innovation, science and environment: Building Canadian Capacity, and with a group of colleagues, I'm also organizing a major conference this fall entitled Crafting the Future, Learning from the Past: The Path to a Sustainable Canada, 1987 to 2027. So we're going to look back 20 years and then look forward 20 years.

From 1989 to 1991 I was an advisor to the deputy minister of Environment Canada during the development and launch of the Mulroney government's green plan under Ministers Bouchard, de Cotret, and Charest. In 1990 I wrote a paper on the relationship between industrialists and environmentalists, which led to the creation of the New Directions Group of corporate and environmental group leaders.

My first involvement with the Office of the Auditor General was prior to the creation of the commissioner, when I participated on an advisory committee on the audit of energy megaprojects. In 1994 I was asked by officials of Environment Canada to chair the multi-sectoral advisory committee for the Chrétien government's A Guide to Green Government, which, as you know, provided the framework for the creation of the commissioner within the Office of the Auditor General.

Because of this background and work with all these different groups or elements of the policy community, in 1996 the first commissioner, Brian Emmett, asked me to create his multi-sectoral advisory committee. I did, and I've been a member of that panel since. I've also been an advisor on specific audit chapters each year. I'm currently an advisor on two audit chapters this year.

In 2004 I appeared as a witness before the Senate Standing Committee on Energy, the Environment and Natural Resources that produced the report “Sustainable Development: It's Time to Walk the Talk”.

Therefore, my views have been forged as a participant and an observer in these issues and processes.

For the record, the commissioner's advisory panel is a group of distinguished Canadians from a broad range of backgrounds. I do not speak on its behalf. My comments today are my views only.

The question before us is, what lessons have we learned over this 10-year institutional experiment known as the Commissioner of the Environment and Sustainable Development within the Office of the Auditor General? It has produced 10 annual reports. These are of a consistently high quality and are particularly good on the performance audits. This is not surprising. It builds on the great strength of the Office of the Auditor General, producing ex-post, rear-view mirror types of financial and performance audits. On the other hand, we have seen the underdevelopment of the commissioner-type functions, being a champion, for example, for sustainable development.

For example, think of the Commissioner of Official Languages. That independent officer of Parliament is expected by everyone to promote the use of both official languages in the Government of Canada and to encourage the growth and use of both official languages in the country to ensure that all citizens can participate in federal institutions and be well served by them. The goal is to keep the country together, even to make it a model for other bilingual countries. These are honourable, forward-looking, commissioner-type functions.

In my view, two factors have contributed to the underdevelopment of the commissioner-type functions. The first is the stature of the commissioner as a second-level officer, an Assistant Auditor General within the Office of the Auditor General. This stature is too low a profile compared to other commissioners, either domestically or internationally.

Second, the legitimate, appropriate, and historic prohibition against the Auditor General's commenting on policy or offering policy advice--as the chief financial auditor of the Government of Canada--is understandable; however, there is no question that this factor has constrained the voice of the commissioner, who is, in this arrangement, an agent or employee of the Auditor General.

Hence the evidence to date shows us that the institutional experiment of the Commissioner of the Environment and Sustainable Development has been incomplete. It's strong looking backward; it's weak in looking forward and in effecting change in the government practice that affects future action.

Does looking forward matter? If the 19th and 20th century development model were still working well, we would not be having this discussion. There would be no Commissioner of the Environment and Sustainable Development, no House of Commons Standing Committee on Environment and Sustainable Development, no departmental sustainable development strategies, arguably, no Our Common Future, no green plan, no Guide to Green Government, no millennium ecosystem assessment, and no IPCC “Fourth Assessment Report”. All of these reports, domestic and international, recognize that we have to look forward and change our development path to a sustainable one.

Indeed, sustainable development emerged from this international process over these past 20 years, and while it may be relatively early days in attempting to institutionalize sustainable development in our daily practices in the private and public sectors, we do know that sustainable development is inherently a forward-looking orientation.

In other words, we must employ foresight and consider seriously, before a decision or a policy is made, the environmental, economic, and social impacts, and the costs and benefits. The Conservatives' green plan made this argument very eloquently.

The scientific evidence is clear. The natural capital that sustains life now and that will in the future is under stress almost everywhere. The millennium ecosystem assessment began with the phrase, “At the heart of this assessment is a stark warning”. You have just read the summary of the fourth assessment report of the IPCC. You've heard what the scientific evidence is telling us across the board. All of these drivers are real. They are not going away. Evidence indicates that these issues are more important to Canadians now than ever. Is this an issue that requires our parliamentarians to look forward? I think so. You have children; you have grandchildren. They are your constituents too. Is this an issue that requires your officer of Parliament to look forward? In my view, it is, absolutely.

What is to be done? If no changes are made, if the status quo structure is retained, let's be honest with Canadians and change the statute to rename the Commissioner of Environment and Sustainable Development the environmental auditor general, or actually just environmental auditor, because there can only be one auditor general.

That is an honest description of the current office within the womb of the OAG. The environmental auditor can do excellent performance audits of existing environmental programs and report authoritatively to Parliament on the findings, no question. Yet, in 2007, as the Auditor General herself has noted, many Canadians are calling for a broader role for the commissioner. If you conclude that it is relevant for the commissioner to exercise commissioner-type functions, then the office has to be made independent of the Auditor General's Office. The Auditor General, I think, agrees with this.

An independent commissioner's office would determine independently what issues to explore. It could investigate innovative developments in other countries. It could anticipate problems and undertake special studies to show how they have been addressed in the private sector or at other levels of government and bring them to the attention of the parliamentary committee on environment and sustainable development and, through you, to the government.

As an independent officer of Parliament, the commissioner could make research-based recommendations but he could not make policy. He's not part of the executive. He would only have the powers of review and recommendation. Hence, the commissioner would be free to assess the performance of government programs. He would not be auditing himself. If the commissioner continued to audit departmental sustainable development strategies and government programs, then the independent commissioner could, without the current constraints of the OAG, comment on the broader implications of the performance audits' factual findings.

Is there a reason that an independent commissioner could not do high-quality performance audits? I do not know of any theoretical reason why this could not be done. Over the years, the Office of the Auditor General has developed rigorous processes and systems for doing performance audits, but auditors exist in private organizations and within government departments. As a recent innovation, for example, Environment Canada has a director general of audit and evaluation reporting directly to the deputy minister.

The commissioner's office could adopt the same high audit standards for its work, and perhaps some of the audit professionals who now do this work in the OAG would be willing to transfer their intellectual capital and experience to a fellow parliamentary officer's organization.

I see no reason why an independent commissioner could not carry out the majority of environmental and sustainable development performance audits, say three to six a year, as is now the case. The OAG would still have its ongoing audit work on the rest of the Government of Canada's programs. If, in that process, it identified environmental performance issues that should be raised, it could do so. Such an arrangement would minimize duplication of effort.

There's absolutely no reason I know of why two independent officers of Parliament could not work collegially and responsibly in this area. This is what happens in New Zealand. This broader scope of activity would raise the profile of the commissioner and perhaps increase the likelihood that it would be more effective in getting the government to take its fact-based audit findings seriously.

Such a commissioner's office would be an independent expert body that would make reasoned research-based arguments in favour of strengthening sustainable practices within the Government of Canada.

Sustainable development is not a partisan issue. It's not a Conservative, a Liberal, an NDP, a Bloc, or a Green issue. Political parties will continue to advocate certain types of policies and programs in this area. Companies and industry associations, environmental groups, academics, and others will continue in the finest democratic tradition to advocate changes of various kinds.

An independent commissioner would not displace or replace these actors. It could, however, be a venue for the housing of considerable expertise on sustainable development and environmental issues on behalf of all Canadians and could make reasoned, research-based arguments in this area to Parliament.

In conclusion, Mr. Chair, the experiment has been run and the evidence is in. The model of a commissioner as an agent of the Auditor General has run up against its institutional limitations. This is not a personnel problem; it's a structural problem. Environment and sustainable development issues are more significant today than they were in 1994. It is time to strengthen the role of the Commissioner of Environment and Sustainable Development. An independent commissioner is entirely necessary, viable, and doable.

Thank you.

[The Chair, Conservative, Bob Mills]

Thank you, Mr. Toner.

Mr. Desautels.

[L. Denis Desautels, Former Auditor General of Canada, As an Individual]

Thank you, Mr. Chairman. Bon après-midi à tous.

I'll be rather brief, Mr. Chairman. I have, in preparation for this afternoon's meeting, reviewed fairly carefully the proceedings of this committee that led to the creation of the function of Commissioner of the Environment back in 1995, to make sure I had a fresh memory of what took place, although I was quite personally involved in all of those discussions at the time.

I've also reviewed the proceedings of your committee held in the last two weeks, and I found many similarities between the questions and concerns that were raised back in 1995 and those that are raised today, including, for example, the question of the expectation gap, which was well identified in 1995.

Let me just say that after considering all of what's been said in the last two weeks and what was said back then, my overall position is that the structure adopted in 1995 still makes sense. I think it's just as effective, if not more effective, than other approaches that could be adopted, such as that of a stand-alone officer of Parliament. In fact, this particular model has been recently adopted by the Province of Quebec, which has just appointed a commissioner of the environment following exactly the same model, the same structure, as in the federal government.

The expectation gap, of course, will always be a challenge. However, if an aggressive advocacy role is what is wanted by Parliament, as opposed to that of what I would call a vigilant watchdog, then Parliament should create a separate office. But in my books, there's no guarantee it will necessarily be more effective. I would also say that there are limits to how much advocacy an independent commissioner can really carry out and still respect the relationship with Parliament.

In any case, before a final decision on this is made, I think a proper analysis of the pros and cons of this structure and other comparable structures should be carried out, including an analysis of the successes and the failures of other approaches and models found in other jurisdictions.

On that, Mr. Chairman, I'll be quite pleased to answer questions of the committee.

[The Chair, Conservative, Bob Mills]

Good. Thank you very much, Mr. Desautels.

Mr. McGuinty.

[David McGuinty, Liberal, Ottawa South, ON]

Thank you very much, Mr. Chair.

Thank you very much, Professor Toner. Good to see you again, Monsieur Desautels. Toujours un plaisir. I'd like to put a question to you, and I don't mean to put you on the spot because there are differing views here.

Professor Toner, I think you were quite clear that it was time. To re-quote you, “The model has run up against its institutional limitations”.

Monsieur Desautels, you said you think the expectation gap might be overcome by a vigilant watchdog. You suggested there was no evidence to support that hiving off the position would strengthen the function, and yet there's no evidence to support that it wouldn't.

You both are experienced practitioners. I guess the question I'd put to you both is a very direct one. I'm not asking you to mind read or to mind-meld or to cast too far out, but given the practice of the past...is it now 10 or 12 years, Professor Toner?

[Glen Toner]

It's 10 years. There are nine substantive reports, plus the early report in 1997, so it's 10 reports in 10 years.

[David McGuinty, Liberal, Ottawa South, ON]

Okay. I'm going to come to the practice over a decade, as well as all of the reports that have been issued that were from time to time critical of our government, critical of the new government, critical of the bureaucracy itself, and so on and so forth. I'm just trying to match the expectations gap in society particularly, Mr. Desautels. Most Canadians want to see their governments' feet held to the fire on this.

The position has evolved; the role has evolved; we live in a very competitive communication world. Don't you think--and both of you can comment--that the independence of this kind of position with the strength and advocacy role would go some distance in holding any government's feet more immediately to the fire? Don't you think this would help Canadians understand more about what is actually going on and what is not going on? I'm trying to get anything that would suggest this is not a good idea; I can't find it in the testimony from either of you.

[Glen Toner]

You can't find...what's not a good idea?

[David McGuinty, Liberal, Ottawa South, ON]

I mean not splitting off the position. I can't see a reason that would preclude splitting off this position and having it evolve as you suggested, Professor Toner. It's time now to give the position full flight and to strengthen it. It can work symbiotically, as the New Zealand experience has demonstrated, and I think as even the Ontario experience with the Ontario environmental commissioner has shown to a certain extent.

[L. Denis Desautels]

I'm going to try that.

First of all, let me say that back in 1995 there were good reasons for asking the Office of the Auditor General to take this on. I think those reasons are quite well laid out in the testimony that came out back then, but if I may just refresh our minds on that, I think the arguments were that in terms of resourcing the functions with as much expertise as possible, the office brought to the function a body of expertise--not just in terms of environment, but also in terms of investigation and in terms of auditing--that was clearly important to the role of a new officer like the Commissioner of the Environment.

I think the notion of carrying out environmental work as part of a bigger whole and therefore respecting better the notions of sustainable development also made sense at the time, and it was one of the arguments used to justify putting it in the Office of the Auditor General.

I think as well that when you talk about independence, I'd be careful, because I would like to think that the Auditor General is quite independent; an officer within the Office of the Auditor General would be quite independent, maybe not from the Auditor General, but from the rest of the world, I would imagine. I think it's not necessarily a question of independence in that sense; I think the autonomy to do things on their own would be another way to look at it.

I think the good reasons for putting it in the Office of the Auditor General back then are still essentially there. Somebody said earlier that the environment is more important now than it was back then; I'm not so sure. It was very important back then; it was seen as an urgent issue, and I don't think that has necessarily changed a whole lot.

One thing I found difficult when it was under my control, one thing that was always a challenge, was to make sure the commissioner had an identity of his or her own and had sufficient autonomy to carry out the role in his or her name vis-à-vis parliamentarians and vis-à-vis the outside world. I think that is a delicate balancing act. I think it's doable, and I suppose other steps could be taken to give parliamentarians a bit of reassurance on that front if we continue with that model.

[David McGuinty, Liberal, Ottawa South, ON]

That's fine, as long as we were reassured that the commissioner wasn't going to be fired by any source other than Parliament itself. That's part of the problem we're facing here.

I'd like to hear Professor Toner on this in terms of the evolution of the role.

You mentioned sustainable development, to paraphrase, not being a destination but rather a direction. Can you help us understand?

[Glen Toner]

Well, on your first point about the watchdog function, that is one function. If we look at these types of offices around the world, they all have that sort of function in some way where they do try to hold the government to account in some way for its past practice.

The way it's been done in this model is through performance audits of existing policies. They're planned out well in advance, and a rigorous process is applied over a year to bring them to fruition. So there's a certain amount of that done in the performance audits and even on an annual, ongoing basis on the sustainable development strategies.

With respect to the autonomy of the commissioner within the Office of the Auditor General, it's important to remember that in practice those reports coming to you are coming to you from the Auditor General. Therefore, the Auditor General's office has a great deal of concern--this balancing act that Mr. Desautels was talking about.

The reality is that on personnel decisions, on the scoping of audits, what will be done, what topics will be audited in terms of actually reporting, whenever the commissioner writes a report it's sent to the editorial staff, the communications people of the Office of the Auditor General to be vetted and reviewed. That makes sense if you're the Auditor General, because you have to be able to defend these documents when they go forward in your name.

So the autonomy of the commissioner within the office is one that is not great. It has evolved over time, but it's one that is not great.

In terms of sustainable development, these sorts of commissioner-type functions that I was talking about, looking forward, looking at other examples around the world, some of them have ombudsman-type functions that deal with public complaints, some of them review and evaluate policy--holding the watchdog role, if you will--while others do investigate sustainable development issues, like in transportation or fisheries. Some of them do anticipatory research to get ahead of the policy debates; others hold public consultations. In the U.K. they educate public officials. They can recommend government action, and some of them audit government programs. So there's a wide range of activities that these types of offices can undertake if they're autonomous.

Within the current construct, of course, working as an officer, an employee, of the Auditor General, there's a much narrower focus because of the legitimate constraints of the Auditor General.

[David McGuinty, Liberal, Ottawa South, ON]

Can I put two other points, then, to both of you?

Last week the former Minister of the Environment, Sheila Copps, who shepherded this legislation originally through the House, wrote in her column that the interdepartmental opposition to an independent environmental auditor general was “so ferocious” that in order to get it through it had to be watered down. The compromise was to create the office administered through the Auditor General's office. That's point number one.

Point number two, with respect to the staff that would be required, the expertise that you referred to earlier, Mr. Desautels, doesn't this commissioner's office in the AG already possess that talent? Aren't we talking here about a more different formal division of staff that is already divided, effectively, in the AG's office? We're not talking here about massive bureaucracies; we're talking about strengthening the existing role of the staff and the budget they possess.

[The Chair, Conservative, Bob Mills]

I'm going to ask both of you to be very brief. Our time is just about up.

[Glen Toner]

With respect to Ms. Copps' arguments, yes, there was no question that there was a strong opposition amongst the bureaucracy. The point of parliamentary officers is not to please the bureaucracy--let's get that very straight. Their job is to hold their feet in the fire, that is to say, to be rigorous in their assessment of them. So, sure, there's opposition at the parliamentary level to being held to account. That's not a surprise.

The other thing, of course, is they were laying off 40,000 people at the time, too, and cutting back, so therefore they didn't want to be seen creating a new organization at the same time they were cutting back.

With respect to the staff within the office, the commissioner's group within the office of the Auditor General, again, what I'm about to say makes sense from the Auditor General's point of view. To go to your question, in terms of expertise, as you know, there's a new interim commissioner. They've also just taken out two of the long-standing principals--that's the level just below the Assistant Auditor General--who have been in the office for five years, and they've moved them off to another place in the office.

Now, from the AG's point of view, this makes a lot of sense because you view these principals as a corporate asset, and they rotate them every five years through various functions within the place. It does mean that the commissioner's staff is constantly evolving. In this current machinery it's constantly evolving, and people are moving in and out, and the commissioner doesn't have the autonomy over the personnel and staffing of that office.

[The Chair, Conservative, Bob Mills]

Mr. Desautels.

[L. Denis Desautels]

On the opposition in 1995 to the creation of a separate office, there probably was some of that. But I recall that even more important than any internal opposition was the desire on the part of the government to not create a new organization. In 1995 we were in the middle of program review, and all departments were being cut back. I think there was a very strong desire to not create a separate office. That was perhaps one of the driving factors for asking us to take it on.

There is a group of people within the commissioner's office right now with very strong technical expertise on environmental issues and sustainable development. I think they're doing a very credible job. The rest of the group strengthens this smaller group in certain aspects. It strengthens them in normal evidence gathering and auditing. It supports your conclusions much more strongly in terms of communications and evaluation of results.

So I think the presence of the rest of the office, in my experience in the five years I saw it at work, gives the smaller group more strength, and there is better coverage of the whole government. You have over 600 people on the lookout for issues and feedback for the benefit of the commissioner. The point I'm trying to make is that the bigger office helps the smaller group.

We keep coming back to the issue of whether it would be more effective to have a separate stand-alone office. We use as examples other officers of Parliament, such as the Commissioner of Official Languages, the Privacy Commissioner, and so on. There are quite a number of stand-alone officers of Parliament both here in Ottawa and in other jurisdictions. I would suggest to the committee that if you analyze the impact of each one of those on whatever mission they have, it's not always what you might think it is.

I think there's a lot of frustration out there on the part of these officers of Parliament. When I was Auditor General, a number of them came to me and said they wished they had the influence I had in changing things. In other words, being alone is not always fun. They had their levels of frustration as well, and many times they envied the attention we were getting with our reports and our ability to move things sometimes.

[The Chair, Conservative, Bob Mills]

Thank you.

Mr. McGuinty, there is a five-minute debt that you owe the rest of the members, so we'll try to figure out how to handle that.

Mr. Bigras.

[Bernard Bigras, Bloc, Rosemont—La Petite-Patrie, QC]

Thank you very much, Mr. Chair.

Welcome, Mr. Toner, Mr. Desautels.

First, I'd like to tell you, Mr. Desautels, that, in the past, we have always appreciated the rigour of your reports and those of Ms. Fraser. Among other things, your work enabled the opposition to question the government more effectively. Your reports were very rigorous in that regard.

I'd like you to go back to the end of your sentence because that's ultimately the main argument. We wonder why the Commissioner of Official Languages and the Privacy Commissioner have their own offices, whereas the Commissioner of the Environment can't be independent. What do you think warrants us having an independent Commissioner of Official Languages and a Commissioner of the Environment who has to report to the Auditor General? I suppose that, before getting around to creating that position, some factors led us to make it so that the Privacy Commissioner and the Commissioner of Official Languages didn't have to report to the Auditor General.

Why then is that possible for official languages, but not for the environment?

[L. Denis Desautels]

That's a tough question. Mr. Chair, in most cases — and this may be the case in other areas as well — some parliamentary officials have a fairly clear, precise and specific mandate. Whether it concerns access to information, privacy or elections, generally these are very specific mandates that can be carried out exclusively, without risk of duplication or overlap with the mandates of other parliamentary officials.

As regards the environment, this isn't that clear. Even before people began to talk about creating the position of Commissioner of the Environment, it was clear that the Auditor General had felt the need to conduct thorough environmental audits. I remember working on the audit of the Great Lakes Remedial Action Plan Program and the St. Lawrence and Fraser River remedial action plans.

Often, when you audit a lot of government programs, it's hard to separate the environment and sustainable development aspect from the rest. That's why, in these cases, it could be argued that there are certain advantages in combining performance audits and environmental audits.

Other fields are like that, such as, for example, everything pertaining to human resources management. The Public Service Commission of Canada reports to Parliament, in theory, and has quite specific human resources management functions. The Auditor General and the Public Service Commission people have occasionally had to talk to each other in order to divide responsibilities. Occasionally, it has even been suggested that the Auditor General should go further and cover some of those aspects.

Consequently, it may be that some areas, which are under the authority of a parliamentary official, may not be isolated as easily as certain other areas, such as privacy, elections or official languages.

[Bernard Bigras, Bloc, Rosemont—La Petite-Patrie, QC]

It's interesting to see that these two questions, these two very important issues for Canada, come under the authority of an independent commissioner. With regard to official languages, we don't need to redo the history of Canada to know that this issue was fundamentally important for governments, particularly the Trudeau government. Privacy is also something fundamental in Canada.

Isn't the fact that this independence is granted to these commissioners a sign of the importance that Canada attaches to these two issues: shouldn't the creation of a commissioner position be linked to values rather than an audit? I wonder.

[L. Denis Desautels]

Mr. Chair, I agree with Mr. Bigras: creating these positions, whether it be that of Commissioner of the Environment or that of Privacy Commissioner, immediately indicates and sends the message that these are important and fundamental questions for the Parliament of Canada.

That said, does creating that kind of position within an existing organization diminish the importance that Parliament attaches to a question? It is possible not to agree on that point. I think that creating this kind of position in an organization highly respected by the general public can have the contrary effect. The original plan was to give the office the most credibility possible as quickly as possible by establishing it within an organization that already enjoyed a certain amount of respect from the public.

That argument can be used to contend that an attempt was made to reflect the importance the Canadian government attached to it by creating this position within an organization that already enjoyed a certain reputation.

[Bernard Bigras, Bloc, Rosemont—La Petite-Patrie, QC]

I have a final question.

About a year and a half ago, I took part in a mission with the Speaker of the House of Commons, in particular to Australia and New Zealand. At that time, I had the opportunity to meet New Zealand's Commissioner for the Environment. He has independent powers. That's clearly stated in the act.

According to the definition of functions in the document our research officer has prepared for us, the Commissioner for the Environment is a guardian and an advocate.

Here's what I'm reading about one of the functions of New Zealand's Commissioner for the Environment:

Advocate: investigating concerns that citizens raise about the environmental performance of public agencies, and encouraging preventative measures and remedial actions.

That's a broad power. It isn't quite defending a cause, but almost. He's also an auditor, information provider and advisor.

You said earlier that before making that kind of decision, that is to say recommending that the Commissioner be independent, an analysis must be conducted of the advantages and disadvantages.

What disadvantage do you clearly see in the Commissioner of the Environment becoming independent? Is there any disadvantage so significant with regard to audits that the Commissioner should continue to report to the Auditor General?

[L. Denis Desautels]

Mr. Chair, as regards disadvantages, there would simply be the loss of certain economies of scale and a certain degree of efficiency. That stems from the fact that that role is now played within an entity that already covers pretty much the universe of government.

In my view, in operational terms, the fact that the two are in the same box, a box of that size, reinforces an efficiency that, to a certain degree, would be lost if they were separated.

Of course, that's not insurmountable, but, if there were a separate office, that office and the Office of the Auditor General would have to agree on a division of the area and avoid needless overlap. That's obviously feasible, but there would nevertheless be a certain loss of efficiency.