Recommendation number two in is regard to harmonization and flexibility to reflect provincial interests.
This recommendation is to ensure there is better harmonization and flexibility. For example, it is important that local interests are considered before implementing a prohibition under the act. There may be opportunities to simplify the process that provinces and territories must follow to request and use a proposed exemption to a prohibition, especially for projects or decisions that support mutual objectives.
The review of the act should also explore opportunities to improve the sharing of information on local issues and impacts. In some instances, the ability to communicate local issues and perspectives may have become more challenging due to the thematic focus within the federal fisheries protection program. For example, federal staff who are based in Manitoba may have the expertise to review a local oil and gas project, even though the project would typically be assigned to staff located in another province.
Provincial and territorial input is essential in determining impacts to the long-term sustainability and productivity of fisheries, including the determination of the cumulative impact of smaller projects. Greater flexibility in submitting and sharing information will facilitate evidence-based decision-making in support of mutual objectives.
Recommendation number three relates to the consistency of monitoring, with clear standards and rationale.
As part of the Fisheries Act review, steps could be taken to improve the consistency of monitoring requirements for proponents, which include providing them with clear standards and rationale. Consistent monitoring processes will support proponents in acquiring the data they need to move projects forward without undue costs or delays. For example, a template could be developed that provides guidance around essential information for monitoring to assist proponents in collecting high-quality meaningful information that is needed for timely decisions.
Recommendation number four relates to transparency and information sharing.
We also feel there may be opportunities to improve transparency by sharing more information with provinces and territories. In general, we believe that information should be provided to jurisdictions before it is provided to a proponent. This will give a province or territory an opportunity to facilitate or, if needed, to interject.
There are also opportunities to improve data sharing related to monitoring and compliance, especially in regard to serious harm to fish. For example, a tracking site, such as a public registry, could be developed to share information on proposals, project status, and other activities, including cumulative impacts. Additionally, improved clarity around policies and procedures on the interpretation and implementation of the Fisheries Act would be useful for proponents as well as provincial and territorial jurisdictions.
Our last recommendation relates to alignments of responsibility and related resources.
Like many other jurisdictions, Manitoba Sustainable Development has limited capacity to undertake additional activities related to assessment, monitoring, and compliance. If provinces are expected to perform additional work adequately, such as assessing risks to fish habitat, then additional resources from the federal government will be needed. That said, a more co-operative approach to the review process could also help to reduce duplication and allow jurisdictions to use limited resources more effectively.
I'll turn it back to Jim.