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PACC Committee Report

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GOVERNMENT RESPONSE TO THE 23rd REPORT OF THE STANDING COMMITTEE ON PUBLIC ACCOUNTS

CHAPTER SEVEN OF THE APRIL 2003 REPORT OF THE AUDITOR GENERAL OF CANADA (NATIONAL DEFENCE – ENVIRONMENTAL STEWARDSHIP OF MILITARY TRAINING AND TEST AREAS)

Introduction

The Government of Canada has considered carefully the 23rd Report of the Standing Committee on Public Accounts with respect to Chapter Seven of the April 2003 Report of the Auditor General on the Department of National Defence’s environmental stewardship of its military training and test areas. The Government has taken note of the nine recommendations contained in the Standing Committee’s Report.

The Government remains committed to ensuring all its departments and agencies meet or exceed the letter and the spirit of federal environmental legislation, as well as provincial, municipal and international standards where appropriate. The Government also remains committed to ensuring its departments and agencies exercise due diligence in mitigating the effect of any activity that impacts on the environment.

The mission of the Department of National Defence (DND) and the Canadian Forces (CF) is to defend Canada, its interests, and values, while contributing to international peace and security. Operational readiness of military forces demands realistic training in a variety of geographic and climatic situations. As such, DND needs training areas to develop, practice, and hone the skills of Canadian Forces’ members, as well as sites to test its equipment. The Department recognizes that the environmental effects from these activities must be mitigated as much as possible, not only in the interest of ensuring the viability of its training and testing areas, but in the interest of the health and safety of its personnel and that of the surrounding communities. DND’s ongoing challenge is to strike an appropriate balance between sustaining military capabilities through realistic training and protecting the environment within available resources.

To meet this challenge DND continues to work cooperatively with other federal departments, agencies and interested partners to find appropriate ways to mitigate the effects of its activities. The Department’s environmental staff also works closely with regulatory departments and other technical experts to ensure that any mitigation activity meets current regulatory requirements. Moreover, DND is updating its current sustainable military training protocols of its testing and training areas and for the management of energetic contamination and of unexploded ordnance. Protocols are also being developed to assist with the delineation of potential energetic materials contamination in the Department’s testing and training areas.

The Response

This Response provides a concise overview of the Government’s position with respect to each recommendation. This Response also provides information on the plans and initiatives already in place with respect to the environmental stewardship of military test and training areas.

RECOMMENDATION 1:

That the Department of National Defence, in collaboration with Environment Canada and the Department of Fisheries and Oceans, immediately set up a working group composed of senior departmental officials, supervised by a steering committee, and mandated to find ways of better integrating sustainable development concepts within departmental activities, planning, and daily operations, to improve communication and coordination between National Defence headquarters and the field, and to establish clearer lines of accountability. That the working group submit recommendations directly to DND’s departmental management committee.


The Department of National Defence is committed to ensuring that its activities and operations are conducted in an environmentally sustainable manner via a multi-faceted environmental protection and stewardship program. Many of the environmental issues facing DND are exceedingly complex and increasingly global in nature. The Department cannot address these issues alone, but must work in co-operation with other federal departments and agencies and our military allies, in addition to Environment Canada and the Department of Fisheries and Oceans. There are always opportunities for improvement – opportunities that are identified by engaging other organizations. The integration of sustainable development principles into daily activities, improving communications and clarifying accountabilities are but three environmental subject areas in which DND recognizes the importance of continual improvement.

The International Organization for Standardization (ISO) Standards on Environmental Management Systems encourage organizations to use existing management, communication and accountability frameworks to advance their environmental agenda. The Department subscribes to this principle and is taking full advantage of existing external committee structures to engage other organizations with horizontal environmental issues, of which sustainable development, communications and accountabilities are a sub-component. The Department of National Defence is committed to the essential concept of continual improvement in environmental management and welcomes the opportunities identified by engaging other organizations in this process. The Department considers the use of existing committees as a preferable alternative to the creation of a new committee structure.

Historically, on environment and sustainable development issues, DND has worked at the Assistant Deputy Minister and subordinate levels internationally (e.g. North Atlantic Treaty Organization (NATO) Committee on the Challenges of Modern Society, the United States-Australia-Canada Trilateral committee on environmental challenges) and interdepartmentally (e.g. Interdepartmental Network on Sustainable Development Strategies, Federal House in Order initiative, Sustainable Development in Government Operations initiative). Interdepartmentally, Environment Canada and the Department of Fisheries and Oceans are also active participants and use these established interdepartmental mechanisms to bring forward their own issues. The Department of National Defence’s Assistant Deputy Minister (Infrastructure and Environment), as a member of the Defence Management Committee, has been able to bring horizontal environmental issues of a technical nature forward for consideration by the most senior levels within the Department and the CF. Additionally, the Assistant Deputy Minister (Infrastructure and Environment) is able to integrate these horizontal environmental issues into her sphere of responsibility.

The Department is able to integrate both technical and strategic environmental issues that have been co-ordinated with other government departments into its operations, and when necessary, to bring certain environmental issues to the most senior levels within the Department for consideration. A recent presentation to the Defence Management Committee by the President of the Canadian Environmental Assessment Agency is an example.

Greater interdepartmental consultation with departments such as Environment Canada and Fisheries and Oceans will be encouraged at DND facilities where the direct effects of training are managed. Members of the Department’s senior management will also be directed to bring forward, through the chain of command, issues susceptible of having either a regional or a national impact.

RECOMMENDATION 2:

That the Department of National Defence headquarters and its senior management ensure that Canadian Forces Base Commanders are made aware of their duties and responsibilities regarding relevant environmental legislation and regulations.


The Department of National Defence takes its environmental responsibilities seriously and is committed to compliance with environmental legislation and regulations. This commitment is reflected in DND’s environmental policy, Departmental Administrative Order and Directive 4003-0 Environmental Protection and Stewardship. The intent of this policy is to ensure civilian employees and members of the Canadian Forces respect the environment, exercise environmental stewardship, and protect public and non-public properties and assets held in trust. As part of this objective, DND and the Canadian Forces have adopted the following code of environmental stewardship.

“The Department of National Defence and the Canadian Forces shall:

  • integrate environmental concerns with other relevant concerns including those from operations, finance, safety, health and economic development in decision-making;

  • meet or exceed the letter and spirit of all federal environmental regulations and, where appropriate, be compatible with municipal, provincial, territorial, and international standards;

  • improve the level of environmental awareness throughout the Department of National Defence and the Canadian Forces through environmental awareness training, and encourage and recognize the actions of personnel leading to positive impacts on the environment;

  • recognize that the life cycle aspects of hazardous material management (initial selection, procurement, use, handling, storage, transportation and disposal) is an essential factor in all planning with particular emphasis on determining whether the material should even be acquired given its characteristics as outlined in Departmental Administrative Order and Directive 4003-1 Hazardous Materials Management;

  • ensure that environmental considerations are integrated into procurement policies and practices;

  • practice pollution prevention in day-to-day activities/operations by seeking cost-effective ways of reducing the consumption of raw materials, toxic substances, energy, water, and other resources, and of reducing the generation of waste and noise; and,

  • acquire, manage and dispose of lands in a manner that is environmentally sound, including the protection of ecologically significant areas.”
The SDS’s action plan is based on a hierarchy of strategic and operational direction through the Defence chain of command. The Assistant Deputy Minister (Infrastructure and Environment), the issuing authority for the Department’s environmental policy, provides horizontal planning guidance through regular oversight meetings, training, conferences and presentations to senior departmental officials and base/wing Commanders.

RECOMMENDATION 3:

That the Department of National Defence headquarters take all the required steps to ensure that Canadian Forces Bases, when they are contemplating using bartering arrangements or contracts with outside parties, strictly adhere to the government’s policy on Accounting for Non-Monetary Transactions, and, whenever possible, seek outside expertise and assistance in designing these arrangements and determining the fair market value of the contracts.


The Department of National Defence is already addressing the need for better control and management of bartering arrangements or associated contracts. The Department will follow four main approaches, namely:

  • including guidance in the recently proposed update to the Delegation of Authorities for Financial Administration for DND and the CF document, which identifies the requirement for persons to consult those with finance and contracting expertise prior to entering into such arrangements;

  • issuing a new policy document to provide contracting guidelines in such (potential) situations;

  • reviewing and modifying, as required, the departmental policy “Financial Directive 46 Recording of Non-Monetary Transactions” (issued in 1995 and based upon Treasury Board policy); and,

  • as an interim measure, issuing a memorandum to Departmental Group Comptrollers to communicate the recent concerns and to advise them of forthcoming policy clarifications and guidelines.

RECOMMENDATION 4:

That the Department of National Defence immediately establish a budget to complete the Manoeuvre Area Planning System (MAPS) protocol and then secure long-term, stable funding for the implementation of the protocol.


The Manoeuvre Area Planning System (MAPS) was developed to guide the management and use of training areas. The MAPS studies conducted at Canadian Forces bases providing recommendations for the mitigation of the impacts of military training on the training area environment are funded within existing funding allocations. In the Department’s action plan developed in response to a similar recommendation made by the Office of the Auditor General, DND is currently reviewing the status of all MAPS recommendations. Subsequent to this review, an action plan will be developed to address and prioritize those recommendations that the Department still needs to manage. This action plan will also indicate timelines and costs for the implementation of those activities identified through the review. Costing validation will only take place once the current studies are completed on 31 March 2004.

RECOMMENDATION 5:

That the Department of National Defence develop a comprehensive action plan to complete the MAPS, and that the action plan contain the appropriate budgets, priorities and implementation timetables. That the action plan be tabled in Parliament no later than 31 December 2004.


The Department recognises the importance of implementing the Manoeuvre Area Planning System and has included this as a target in its Sustainable Development Strategy since 1997. The Department’s current strategy requires that priority recommendations in the plans developed from the MAPS protocol be implemented by 31 March 2004. As indicated in the response to Recommendation 4, DND will develop an action plan to address all outstanding MAPS recommendations. Funding for these recommendations, once determined, will be considered in the context of the Department’s business planning process.

RECOMMENDATION 6:

That the Department of National Defence develop a comprehensive action plan to identify sites potentially contaminated by unexploded ordnance and implement the mitigation and restoration measures, and that the action plan contain the appropriate budget, priorities and implementation timetables. That the action plan be tabled in Parliament no later than 31 March 2004.


Military ranges and training areas can contain unexploded explosive ordnance (UXO) left over from past and current military operations. UXOs present a safety hazard in terms of the potential for accidental detonation. A site may become environmentally contaminated if energetic materials and metals contained in UXOs leach into the soil, surface water or groundwater, in concentrations posing, or likely to pose, an immediate or long-term risk to human health or the environment.

The Department’s active ranges and training areas continue to encounter UXOs because of ongoing activities. In spite of the high quality control standards used by manufacturers and stringent CF ammunition handling and weapons maintenance procedures, projectile failures (commonly referred to as “duds”) will nonetheless occasionally occur. To mitigate possible environmental damage and safety hazards posed by UXOs, clearing operations and special techniques are in place in each of the Department’s active range and training areas. However, these actions will only partially address the issue of UXOs until such time as technology allowing their complete and cost-effective elimination becomes available. In the meantime, DND and CF will continue managing the various aspects associated with UXOs on its owned or leased properties.

Contamination from energetic materials is a relatively new field of science and much research remains to be undertaken. The Department of National Defence continues to fund this field of study and its research efforts have been recognized internationally. Researchers at Defence Research and Development Canada at CFB Valcartier are conducting leading edge studies in this field. The Department realizes that it needs to provide additional policy direction on the management of sites potentially contaminated with energetic materials, and on the management of those sites where UXOs are present but where there is no evidence of environmental contamination.

The Department of National Defence has already initiated action to address the issue of sites contaminated by energetic materials by re-establishing its energetic materials Working Group. The Working Group will consider the impacts of energetic materials on human health and the environment and will provide scientific, technical and policy guidance and direction to the Department on this issue. It will also aid in the development of site investigation guidelines and protocols to identify potentially contaminated sites and determine an appropriate course of action for sites suspected or known to be contaminated by energetic materials. As required, the Working Group will also seek input of other government departments, such as Environment Canada and Health Canada in assessing and dealing with the potential environmental and human health risks posed by energetic materials. In addition to its on going energetic materials research, the Department is also funding investigations at select installations to ascertain the environmental impact of activities. This program has been underway for a number of years and is yielding valuable information.

A copy of the action plan prepared by DND in response to the Auditor General’s April 2003 Audit on military training and test areas, is attached as Appendix A. Concerning the specific recommendations outlined in paragraphs 7.71 and 7.72, the document outlines activities that the Department will undertake with regards to managing sites contaminated by energetic materials or where UXOs are present. However, mitigation and restoration measures can only proceed once mapping and identification activities are completed. Restoration and remediation measures will also have to take into consideration current and future use of the training areas as well as availability of resources. Based on this approach, DND will be in a position to begin reporting this information for the fiscal year commencing 1 April 2005. Funding for this action plan will be considered as part of the Department’s annual business planning process.

The Committee proposes that the action plan for sites contaminated by energetic materials be tabled in Parliament no later than 31 March 2004. Given that departments already provide contaminated sites management plans to Treasury Board on an annual basis (by 1 July), the Government intends to use this existing reporting structure to communicate the details of its action plan for contaminated sites. Progress that relates to the Department’s targets for training areas and contaminated sites outlined in its Sustainable Development Strategy will be reported annually in the Department’s Performance Report.

RECOMMENDATION 7:

That the Department of National Defence include in its annual Report on Plans and Priorities a section that lists all DND training and testing sites potentially contaminated by unexploded ordnance, together with a summary of the remediation and restoration measures and planning implementation timetables. That the Department begin reporting this information to Parliament for the fiscal year commencing 1 April 2004.


The Defence 2003 Sustainable Development Strategy tabled in Parliament on February 16th, 2004, spells out the environmental targets and the concrete, measurable activities DND will carry out to meet those targets. The 2003 Sustainable Development Strategy includes a target specifically aimed at measuring the sustainability of military activities at training and testing areas. By monitoring this target, the Department will be able to determine what changes are required to military activities to ensure sustainability at each site. Additionally, the target related to reducing Departmental Liabilities associated with contaminated sites will ensure the identification and the remediation of sites contaminated by energetic materials.

The Department of National Defence’s action plan to address the environmental impacts resulting from energetic materials is outlined in the response to Recommendation 6. As previously mentioned, funding for this action plan will be considered as part of the Department’s annual business planning process. Restoration and remediation measures will again have to take into consideration current and future use of the training areas as well as availability of resources. Given that departments already provide contaminated sites management plans to Treasury Board on an annual basis (by 1 July), the Government intends to use this existing reporting structure to communicate the details of its action plan on contaminated sites. Progress that relates to the Department’s targets for training areas and contaminated sites outlined in its Sustainable Development Strategy will be reported annually in the Department’s Performance Report.

RECOMMENDATION 8:

That the Department of National Defence incorporate in its departmental Performance Report a section containing information about results achieved against planned targets in the identification, remediation and restoration of DND training and testing sites potentially contaminated by unexploded ordnance. That the Department begin reporting this information to Parliament for the fiscal year ending 31 March 2004.


The Departmental Performance Report currently includes a section dedicated to the Department’s Sustainable Development Strategy. As stated in the response to Recommendation 7, this strategy, prepared every three years, spells out the environmental targets and the activities DND will carry out to meet those targets. The 2003 Sustainable Development Strategy includes a target specifically aimed at measuring the sustainability of military training and testing sites. The Departmental Performance Report tabled in Parliament each year will comment on progress made against all targets listed in the Department of National Defence’s Sustainable Development Strategy.

RECOMMENDATION 9:

That the Department of National Defence prepare a status report on the progress of the negotiations between the Government of Canada and the Government of Germany on cost-sharing the clean-up of contaminated lands at Canadian Forces Base Shilo, Manitoba. That the report be tabled in Parliament no later than 31 March 2004.


Departmental officials are prepared to appear before the Committee to answer questions on CFB Shilo, to the extent that is possible without prejudicing negotiations. The negotiation process, which began in July 2000, is continuing. The parties have met on four occasions. A report on the outcome of the negotiations between both nations will be tabled once they have concluded.