Thank you.
I was explaining the current situation with respect to the sustainable development strategies.
In December of 2006, on tabling the fourth round of sustainable development strategies, the Minister of the Environment specifically noted the commissioner's observation in 2005 that the failure to develop a federal sustainable development strategy “ will leave Canadians and parliamentarians without a clear idea of the government's overall plan for sustainable development, how it will get there, and what progress it has made.” The minister noted that the government agreed with the commissioner that more needs to be done to improve sustainable development reporting, and indicated that a range of options would be examined, including legislation, with a view to making further progress towards putting sustainability at the heart of the government's activities.
Environment Canada began a review at that time, with a view to developing options for improvements for the fifth round of strategies beginning in 2009. Subsequently, the commissioner also undertook a 10-year retrospective evaluation of the existing approach and recommended that the government undertake a thorough review by October 2008, a recommendation which the government accepted.
I should tell the committee that Environment Canada has worked collaboratively with the commissioner and his staff throughout this process. The review that is currently underway has several areas of focus, including examining options for a strengthened framework or overall strategy with clear goals and indicators. I am confident that this work will be completed by the October deadline set by the commissioner.
Turning now to Bill C-474, I would like to note two issues that relate to the possible or the potential implementation of the bill as currently drafted—and this is based on my own examination of the bill.
First, the bill would require the development of a national, as opposed to a federal, sustainable development strategy. As the committee is aware, responsibility for the environment is not defined in the Constitution Act. Over time, a variety of mechanisms have been developed to facilitate federal-provincial cooperation in improving environmental quality in Canada, including a wide range of work done under the authority of the Canadian Council of Ministers of the Environment.
As a practical matter, if we expect the provinces to be full and willing partners in the implementation of a national sustainable development strategy, it would, in my view, be important to engage them in its development, including the definition of its goals and its targets and in a discussion of which level of government would be held accountable for their achievement.
That brings me to my second point—namely, the goals and targets that are currently proposed in the draft bill. I think the commissioner has been very clear that defining measurable goals and developing performance indicators to track progress towards those goals is essential to any effective sustainable development strategy. Indeed, these are characteristics of effective, accountable public management.
As currently drafted, clause 8, for example, requires the establishment, within two years of the act coming into force, of short-, medium-, and long-term targets and an implementation strategy for meeting each item listed in column 2 of the bill's schedule.
Clause 10 subsequently requires the minister, following the tabling of the strategy in the House, to make regulations prescribing targets and caps for each item. I assume these regulations would be based on regulatory authorities in other existing statutes, as the bill does not provide any new regulatory authorities.
As I understand it, these two provisions together would therefore require the government, potentially, to prepare regulations for all 60 of the items listed in the schedule, including all 323 of the discrete substances covered by the national pollutant release inventory, and to do so within 30 days of the tabling of the national sustainable development strategy.
Regulation can be a very important instrument in improving environmental outcomes. However, if regulation is to be successfully implemented, it requires good science, close cost-benefit analysis, and careful consultation with those who would potentially be subject to or impacted by any new obligations.
Experience suggests that there would be major challenges in developing such a large number of regulations in such a short timeframe. Furthermore, regulations may not be the most appropriate instrument for addressing each of the many items listed in the schedule.
I look forward to your questions.
Thank you.