I have a few brief questions.
Mr. Keenan, I'm looking at this other document, “A Guide to Green Government”, which I think is affiliated. Unfortunately, there are no page numbers, but under section 2 it talks about “Planning and Decision-Making for Sustainable Development”, and then it talks about policy tools.
I'm puzzled. I would encourage you to adjust the document, because it makes no reference to the enforcement and compliance strategies and policies that are already in place in departments. The reason I'm mentioning this is that departments don't have broad access to those tools. They're already prescribed very clearly, and to the credit of the government, because that came about when the first CEPA was tabled. Minister Tom McMillan actually tabled the first enforcement compliance policy, which triggered similar policies across Canada. I think it's really important to reference that.
The other matter that you might want to reference is the commitment Canada has made under the North American Agreement on Environmental Cooperation. I think it's article 5 of that agreement which states that Canada commits to effective environmental enforcement. There have been a lot of agreements under that. In fact, when I was the head of law and enforcement there, I led a whole dialogue and agreement on how the three governments were going to measure and report on effective enforcement and compliance. My understanding is that the department developed that almost 10 years ago.
I think it gives credibility to this to reference documents and the good work departments have already done. You don't have to reply. I'm just pointing that out.
On page 25 of your draft strategy, “Protecting Nature”, I'm a little concerned with article 5.1.1, “Enabling Capacity”. DFO is reporting that they'll develop 100% of recovery strategies under mandated requirements by 2012. In fact, in many cases, that may mean they're not in compliance with the law because they are actually not complying with requirements, so it's a little awkward there to say that they're going to comply with this instead of what the law requires. Actually and amazingly, SARA prescribes deadlines for when they have to produce these strategies and so forth.
I have one other point. You said that actually it'll be in.... I think the document is useful because it points out areas that aren't there yet, where we don't have targets. One of the things I noticed under the section on water is that there is no target for or mention whatsoever of dealing with lakes and rivers. It talks about quality, but it doesn't talk about management, except for the Great Lakes. I would have hoped.... There is some kind of vague thing towards the end about things to do, but it doesn't actually mention what the government will do under the Canada Water Act, let's say, where they have a lot of powers to manage waters.
Also, it doesn't mention where they might be stepping up the monitoring programs in the field in specified areas. For example, we looked at the impact of the tar sands on water, and there are going to be recommendations out of this committee, but I would have anticipated that they would have said they're going to do something--that they're going to do targeted rivers or lakes or something. There doesn't seem to be anything there outside of the Great Lakes that talks about targeting.
You know, there used to be a huge program in Environment Canada called the Canada Water.... Does anybody remember what it was called? It was done away with. There is increasing pressure on the federal government, particularly for transboundary waters or where there is some kind of international obligation. What is the government doing? It's not always Environment Canada. Sometimes it's DFO and so forth. I was kind of surprised that there was nothing there at all, particularly in view of the review we've been doing in this committee.
I'm finished.
