Thank you, Chair and members of the committee, for the opportunity to appear before you today as part of your review of the proposed regulations related to part VII of the Official Languages Act.
You've introduced me, Sylvia Martin-Laforge, as the director of TALQ. It's an organization representing the English-speaking community in matters of public policy and governance. Our focus is on legislation, federal funding frameworks and intergovernmental agreements that shape the vitality and sustainability of our community. Joining me today is our counsel, Marion Sandilands.
Before turning to the substance of our remarks, I would like to acknowledge the extensive and good-faith efforts undertaken by the Treasury Board Secretariat to consult TALQ and other stakeholders from the English-speaking community during the drafting of these regulations. The engagement has been meaningful, and we recognize the effort.
TALQ welcomes the draft regulations. We didn't welcome the act, but we're here to say that we welcome these draft regulations. They introduce long-needed structure and procedural discipline to part VII, making it more difficult for federal institutions to overlook their obligations. By requiring a part VII analysis at key decision points—when programs are created, renewed, modified, ended or transferred—the regulations improve visibility and accountability for Parliament and for the Commissioner of Official Languages.
However, our core message today is this. The regulations operationalize process, not outcomes. In doing so, they expose structural gaps within part VII of the act, gaps that Parliament should address during the statutory review.
The regulations require institutions to analyze impacts, identify affected communities, consult stakeholders and document their reasoning. What they do not require is a demonstrable result. A department may fully comply with every procedural requirement and yet leave conditions on the ground unchanged. That is not a flaw in the regulations. It reflects a structural limitation of the act. The regulations can discipline decision-making, but they cannot compel measurable improvements in community vitality.
This issue is particularly significant in Quebec, because Quebec is unique under part VII. It is the only province where the federal government must simultaneously protect and promote French as a minority language in Canada, while enhancing the vitality of the English-speaking community of Quebec. These obligations coexist, but they do not always align seamlessly.
The modernized act also adds Quebec's Charter of the French Language into federal statutes, despite concerns raised by English-speaking Quebecker stakeholders. The draft regulations provide no guidance on how institutions should navigate the resulting tensions. There is no framework for balancing competing obligations, no requirement to explain trade-offs and no obligation to demonstrate that the interests of English-speaking Quebeckers were assessed independently rather than absorbed into broader policy objectives.
When guidance is absent, decisions default to discretion. In Quebec, that discretion often favours preserving federal-provincial relations over advancing minority vitality. Without clearer statutory direction, there is a risk that part VII becomes procedurally satisfied but substantively diluted.
This concern is not theoretical. TALQ recently filed a complaint with the Commissioner of Official Languages regarding the Canada-Quebec agreement implementing the action plan for official languages. The complaint highlights shortcomings in the application of part VII—