Northern Projects Management Office Initiative Evaluation (2015-16): Management Response and Action Plan

Management Response

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In Canada’s North, natural resources serve as the primary large scale economic driver for development and employment, and have the potential to generate significant social and economic benefits for Northerners, Aboriginal peoples and all Canadians.

The Northern Projects Management Office (NPMO) was established in 2010 within the Canadian Northern Economic Development Agency (CanNor) to improve the environmental review process for proposed major resource development and infrastructure projects in the territories. In March 2014, CanNor received enhanced funding under the NPMO Initiative to put in place the necessary capacity within the Agency to respond to the volume and complexity of major projects in the North. NPMO’s areas of responsibility include:

CanNor is supportive of the findings identified through this evaluation and is committed to addressing the recommendations that are within the Agency’s mandateNote de bas de page 1. In a few cases, the recommendations fall outside of CanNor’s direct purview, specifically:

Where possible and respecting CanNor’s roles and responsibilities, the Agency has identified actions it can take to respond to the nature of these recommendations.

The Action Plan below presents how the evaluation’s recommendations are being, or have already been, addressed by the Agency. The key findings of this evaluation support the long-term strategy to continue to build on and improve NPMO, based on a four pillar approach:

  1. formalizing partnerships and collaboration;
  2. implementation of tools and services;
  3. maximizing resource allocations; and,
  4. increasing awareness of NPMO’s service offerings.

Within its scope and areas of responsibility, CanNor is committed to addressing the recommendations found within the evaluation as set out in the Action Plan on the following pages. As the primary managers responsible for implementing all of the activities identified, the Director General of NPMO and Director of NPMO Policy will work in partnership on the development and implementation of the Agency’s Action Plan, and in collaboration with other senior managers where identified.

Management Response and Action Plan

Recommendations Actions Responsible Manager (Title/Area) Planned Completion date
Parterships and Collaboration
  1. Implement more formalized relationships and agreements.
    Several stakeholders believed that an increased formality to partnerships and collaborations was required to facilitate effective and timely regulatory reviews. Proposed formal agreements that stakeholders suggested included a more formalized governance structure outlined in a partnership framework and standard use of Northern Partnership Agreements with project partners.
NPMO will continue to build upon its successful engagement and collaborative practices and relationships, while taking the following actions:

Engage territorial counterparts to develop a preferred approach to implementation of MOUs with the Governments of Yukon and NWT.

Director General, NPMO By January 31, 2016 for engagement with the Government of NWT

By March 31, 2016 for engagement with the Yukon Government

In consultation with federal regulatory partners, complete the review of templates for northern project agreements.

Director, NPMO Policy By March 31, 2016
  1. Bridging external partnerships.
    A few stakeholders identified that there was a need for a stronger relationship between the Aboriginal communities and territorial partners. They recommended that NPMO would be well-suited to bridge the relationships, by bringing a representative from the territorial partners to the communities. This would help create formal accountability between the community and the territory.
While this recommendation falls outside of its scope of mandate, NPMO will examine its current approach to engagement with its partners and report to the President of CanNor on best practices that can be shared, in particular regarding engagement with Aboriginal communities. Director General, NPMO By March 31, 2016
  1. Early and intensive outreach to industry.
    NPMO should engage in outreach through industry events whenever possible and establish a better relationship with the Chamber of Mines. Most stakeholders felt NPMO could play an important role being involved with industry at an earlier stage; some felt as early as the explorations stage, while a few felt NPMO would be useful when proponents were looking at ways to resolve issues related to infrastructure. Another important role for NPMO could be a more deliberate and intensive outreach to new and/or smaller members of industry. Targeting these groups to publicize NPMO’s services would be key in attracting new investors.
NPMO will explore opportunities to expand its outreach practices, including:

Propose regular meetings with the northern Chambers of Mines and the Mining Recorder Offices to stay informed of new exploration proponents and disseminate information on NPMO services; and

Director General, NPMO By March 31, 2016

Review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities.

Director, NPMO Policy (in consultation with the Director, Communications) June 30, 2016
  1. Early and intensive outreach to Aboriginal groups.
    NPMO should engage in outreach to Aboriginal organization and communities whenever possible and establish MOUs or partnership agreements. By establishing relationships with Aboriginal communities, NPMO can also facilitate the development of the Impact Benefit Agreements (IBAs) and interactions with industry should a community participate in the Community Readiness Initiative (CRI).
Examine NPMO’s current outreach and engagement practices with Aboriginal groups and report back to the President of CanNor on potential opportunities to expand and/or formalize its engagement activities. Director General, NPMO September 30, 2016
NPMO will complete a review of the NPMO Community Readiness Initiative pilot and report on lessons learned. Director General, NPMO September 30, 2016
NPMO will review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities. Director, NPMO Policy (in consultation with the Director, Communications) June 30, 2016
  1. Greater collaboration with CanNor.
    It was noted that NPMO could be better aligned with CanNor to support programming particularly related to Community Readiness Assessments (CRAs) completed under the Community Readiness Initiative (CRI). Greater integration of complementary tools and services between CanNor and NPMO was recommended, such as using CRA Maps to facilitate the application of CanNor’s relevant programming to communities in need, promoting greater engagement and support for northern communities. Greater collaboration could also mean clearer messages are provided to Aboriginal organizations and proponents as to the specifics of programs and services offered by each, supported by an alignment of internal processes to increase efficiencies in operation
Implement internal measures to ensure greater integration of tools and services, as well as alignment of programming related to community readiness, including:

Implementing a common approach to the review of proposals in support of community readiness; and

Director, NPMO Policy December 31, 2015 [completed]

Creation of a Community Readiness Initiative GC Connex webpage to support the sharing of information and updates across the Agency.

Director, NPMO Policy November 30, 2015 [completed]
  1. Conduct reviews of major projects that did and did not proceed to identify lessons learned.
    NPMO is well positioned to conduct a review of major projects that appeared to be advancing to implementation but withdrew and those that proceeded to identify areas where NPMO and its partners (e.g., federal departments, territorial governments, and regulatory boards) may be able to make improvements to assist proponents of upcoming projects proceed with fewer challenges.
Review and update NPMO’s current standard operating procedures and northern project agreement templates to incorporate standard review of lessons learned related to major projects processes to inform NPMO processes going forward. Director, NPMO Policy March 31, 2016
  1. Hold a forum for regulatory boards, federal and territorial departments.
    To build relationships among the territorial governments and regulatory boards, a workshop-style forum could be held where participants share best practices and challenges related the regulatory review process.
Organize and host a 'pilot’ pan-territorial forum on northern regulatory issues, with feedback from the event to be used to inform NPMO-led events and activities going forward. Director General, NPMO February 28, 2016
Report back to the President on results and next steps from the forum. Director General, NPMO March 31, 2016
Tools and services
  1. Bring all existing internal databases and tools to a functional level.
    Some internal and federal stakeholders acknowledged that databases and tools intended to be used by NPMO were not completed or not used widely enough to contribute to NPMO’s anticipated outcomes. It was recommended that these databases and tools be completed, updated, and put online for use by NPMO staff and other federal departments.
Working with its IT system providers, NPMO will establish a series of priorities and a workplan to implement its existing tools and databases, as well as optimize their functionality for federal and external end users, including options to minimize data overlap. Director, NPMO Policy March 31, 2016
  1. Maximize the use of existing tools.
    The Project Tracker was largely unknown to most interviewees, and of those that had investigated the tool prior to the interview, did not believe that this tool had sufficient information to be useful to them. Potential users of this tool need to be made aware of its existence, and review of the tool to ensure it is meeting the needs of these end users may be helpful in encouraging its uptake and maximizing its usefulness. Reviewing databases for overlap and potential merging is also recommended. Some databases were in need of updating. Merging databases that contain similar or overlapping information would ease the burden on updating.
In addition to the actions outlined in response #8, NPMO will:

Review and update its standard operating procedures to outline requirements for regular updates/reviews of its tools and practices.

Director, NPMO Policy March 31, 2016

Establish shared opportunities with the Major Projects Management Office to better integrate project tracking and reporting on the status of major projects.

Director, NPMO Policy March 31, 2016

Create an NPMO GC Connex webpage to support the sharing of information and updates across federal departments.

Director, NPMO Policy January 31, 2016

Train NPMO staff to ensure that the tools such as project tracker are used effectively.

Director General, NPMO March 31, 2016
  1. Develop a Crown consultation tracker.
    Many federal department representatives expressed confusion about knowing the exact stage of various aspects of the Crown consultation record; for example, a federal department working on a project will conduct their own Crown consultation, but other federal departments working on that same project will not be aware of these consultation activities. Although there is a Crown Consultation table, having a Crown Consultation Database available on a single platform and across all regions would maximize the benefit and use to external stakeholders. Interviewees recommended the development of a Crown consultation tool, similar to the NPMO Project Tracker tool. Such a tool would be used within the Government of Canada’s relevant federal departments to keep track of, and disseminate, Crown consultation information for each project coordinated by NPMO, and would include information from all relevant federal departments.
Seek advice from the Department of Justice on potential risks and limitations to the dissemination of data collected through Crown consultation processes. Director General, NPMO March 31, 2016
Review and update where required existing Crown consultation documentation to ensure improved understanding of NPMO’s Crown consultation role and services among federal partners and industry. Director General, NPMO July 31, 2016
NPMO will review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities. Director, NPMO Policy (in consultation with the Director, Communications) June 30, 2016
Dependent on advice received from the Department of Justice, work with external IT providers to identify options to 'house’ relevant Crown consultation data under a single digital platform. Director, NPMO Policy March 31, 2016
  1. Provide open, public reporting and updates.
    NPMO would better serve stakeholders if they provided newsletters, which could include their mandate, guides to rules and processes to implement mandates, and upcoming or newly implemented changes to regulations or legislation.
NPMO will review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities. Director, NPMO Policy (in consultation with Director, Communications) June 30, 2016
Explore opportunities to optimize outreach through external events (e.g., Prospectors and Developers Association of Canada Annual Convention, Vancouver Roundup) and report back on findings to the President of CanNor. Director, NPMO Policy March 31, 2016
Establish opportunities with the Major Projects Management Office (MPMO) to incorporate major projects within NPMO’s portfolio as part of the quarterly reports on project activities released by MPMO. Director, NPMO Policy March 31, 2016
  1. Provide capacity funding for Aboriginal communities to participate in reviews.
    It was noted that a considerable barrier to Aboriginal communities’ meaningful participation in the Crown consultation process was a lack of expertise to interpret and respond to technical and scientific documents that are a part of the environmental review process. Some interviewees recommended that a capacity or participation fund be implemented, which would provide funding for communities to hire expert consultants on these matters to assist in responding to relevant documents during the Crown consultation and environmental review process. A few stakeholders recommended investigating models and best practices from the Alaska Industrial Development and Export Authority (AIDEA) – NPMO could expand their abilities by creating potential capital investment funds. Capacity or participation funding for Aboriginal communities to participate in Crown consultation could be provided either through NPMO or through the operations branch of CanNor.
While the creation of a capacity/participant fund falls outside of the scope of its mandate and is subject to broader Government of Canada policy and funding approval processes, NPMO will continue to engage and work closely with federal partners to outline the need for participant funding in the territories, including any potential legal risks with the current approach. Director, NPMO Policy n/a
  1. Complete Community Readiness Initiative (CRI) pilots and conduct review.
    Although significant potential benefits have been anticipated from the CRI, the pilots need to be evaluated to ensure goals have been achieved. If the results of the program review are positive, the CRI should consider any improvements prior to receiving more substantive funding (e.g., the challenges in initiating a CRA at the community level). Several interviewees indicated that CRI is not well-known in the territories and, as such, not as many communities are taking advantage of it as could be. Because this is a new program only in the pilot stage and unknown to most communities, it requires significant time for the communities to recognize the benefits of the program and come together to take advantage of it. Currently, program outcomes have not been fully realized as most of those pilots are still in process.
In addition to the actions outlined in response #5, NPMO will:    

Continue to work with communities taking part in the Community Readiness Initiative (CRI) pilot to complete their CRI reports.

Director General, NPMO March 31, 2017, however timing can be dependent on participating communities

Conduct an internal review of CRI pilot practices and results achieved to date, and present a report on the findings to the President of CanNor; and

Director, NPMO Policy March 31, 2016
Resource Allocation
  1. Increase staffing allotments for NPMO.
    Many of the shortfalls of NPMO, such as a lack of direct Crown consultation tracking, were attributed to insufficient staff at NPMO, particularly in offices outside of Yellowknife. Staff in these offices were identified as being overburdened and not able to complete all of their tasks, resulting in federal departments taking on some of the workload, such as filling out Crown consultation tables or reminding project coordinators to set up meetings. It was noted that having such a 'lean’ staff contingent meant that the organization was at risk when any one staff member left the organization. Many interviewees recommended that resources for staffing at NPMO be increased. It should be noted that NIRB and the water boards in Nunavut are located in western Nunavut; having an NPMO office in the same area would facilitate increasing efficiencies between the offices and be an advantage to NPMO to fulfill its mandate.
While any potential funding increases for NPMO are subject to broader Government of Canada policy and funding approval processes, to leverage existing capacity within the organization, NPMO will:

Review its current FTE capacity to ensure alignment of its resources against work volumes and the NPMO salary envelope, as well as ensure that priority positions are strategically identified in CanNor’s staffing plan.

Director General, NPMO (in collaboration with the Manager of HR) March 31, 2016
Publicity
  1. 'Brand’ NPMO and publicize the services and tools offered by NPMO to external stakeholders.
    Some interviewees believed that many external stakeholders (project proponents and Aboriginal communities) were not aware of the services offered by NPMO and often confused NPMO with CanNor. Increasing the profile of NPMO may facilitate consultation with industry and more meaningful involvement of Aboriginal communities in the regulatory review process due to improved community readiness. Overall, these early interactions would lead to improved collaboration in the North between Aboriginal communities, the Government of Canada, and industry proponents to facilitate sustainable resource development.
In addition to the actions outlined for recommendation #3, NPMO will review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities. Director, NPMO Policy (in collaboration with the Director, Communications) June 30, 2016
  1. Ensure external stakeholders are aware of what NPMO cannot do.
    Conversely to the above recommendation, some Aboriginal and industry interviewees experienced frustration with NPMO, as they were not aware of what NPMO’s role before requesting something that was beyond the mandate of NPMO. NPMO’s role as a coordinator and messenger, rather than a decision-making body, needs to be better communicated to proponents and Aboriginal groups.
NPMO will review and revise as required its communication strategies and web presence, while ensuring alignment with government-wide directions, with a focus on improved information on NPMO's responsibilities, services and activities. Director, NPMO Policy (in collaboration with the Director, Communications) June 30, 2016
  1. Earlier initiation of Community Readiness Initiative (CRI).
    NPMO could consider initiating community readiness sooner. Most stakeholders believed earlier implementation of CRI (e.g., at the oil and gas exploration stage) would be beneficial to Aboriginal communities and provide them with more time to learn about the project and navigate government processes. NPMO could also play an ongoing role helping communities understand what kind of opportunities the major project could offer that would be advantageous to them, such as new business opportunities for Aboriginal entrepreneurs. Also, earlier CRI would benefit Industry during the development of Impact Benefit Agreements (IBAs). One stakeholder recommended NPMO consider a "Regional Readiness" approach, particularly since the North is divided into regions with its land claims, and land and water boards.
In addition to the actions outlined for recommendations #5 and #13, outline CanNor’s approach to supporting community readiness as part of the review and lessons learned assessment of the Community Readiness Initiative pilot. Director General, NPMO (in collaboration with CanNor’s Regional Directors) June 30, 2016
  1. Publicize "lessons learned" from Aboriginal communities’ perspectives.
    NPMO could document a "lessons learned" or best practice record by bringing people from Aboriginal communities to describe their experiences with major resource development. This would be beneficial to other Aboriginal communities and Industry stakeholders to learn about the initial stage of resource development, various Aboriginal rights issues, and related consultation and community engagement issues.
While this recommendation falls outside of its scope of mandate, NPMO will undertake consultations with Aboriginal organizations throughout the course of its regular interactions on developing a potential outreach approach and sharing of 'lessons learned’ with other Aboriginal communities and industry. Director General, NPMO March 31, 2016

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