Evaluation of the Water and Wastewater On-Reserve Program

Background

This evaluation focuses on two programs:

1. Infrastructure and Capacity Program - Water andWastewater, also referred to as the First Nations Water and WastewaterEnhancement Program. The key activity is the provision of proposal-basedfunds under the Capital Facilities and Maintenance Program for the planning, procurement, design, construction/acquisition, commissioning, assessment, and operations and maintenance of public water and wastewater systems. The ultimate goal is that First Nations people have reliable and sustainable public water and wastewater systems in their communities.
2. Public health-related water and wastewater activities supported by the Environmental Public Health Division of the First Nations and Inuit Health Branch within ISC. The Environmental Public Health Program provides direct or financial support to First Nation communities south of 60° for a range of public health-focused water and wastewater activities including drinking water quality monitoring for bacteriological and chemical parameters. The ultimate goal is that First Nations, Inuit and partners contribute to decreased environmental public health risks.

Evaluation Scope and Methodology

The scope of the evaluation covers the years 2012-2013 to 2016-2017 and also selected activities undertaken from March 2017 up to March 2019 to recognize and provide feedback on new initiatives stemming from Budget 2016.^{Footnote 1} The evaluation was led by an evaluation team from the Evaluation Directorate within ISC, supported by an external consultant. Additionally, although not within its original scope, the evaluation outlines early impacts of the COVID-19 pandemic upon the Water and Wastewater Activities On-Reserve Program, as well as how it has addressed them.

The Methodology Report was approved in September 2019, with primary data collection occurring from September 2019 to February 2020 and September to October 2020. The evaluation relied on a mixed-methods approach that included the following lines of evidence: a document, literature and media review; 35 key informant interviews; survey of 221 First Nations water and wastewater system operators and managers; survey of 52 community-based water monitors; and site visits to 6 First Nations communities in Nova Scotia, Newfoundland and Labrador, British Columbia and Alberta.

Key Finding

Recommendations

1. Implement policy and procedures that result in the federal government providing 100% of the operation & maintenance costs for water and wastewater infrastructure in First Nations communities. Insufficient operation & maintenance funding contributes to the occurrence of drinking water advisories and long-term drinking water advisories, decreased water system operator retention and certification rates, and reduced operational lifespan for infrastructure investments.
2. Increase the number of wastewater infrastructure projects undertaken. To-date wastewater infrastructure projects have received disproportionally less attention and funding than drinking water projects. Many communities have inadequate wastewater services and much of the existing infrastructure has been assessed as a high or medium risk.
3. Where applicable, support regions to provide 5-year rather than 1-year funding agreements for the Circuit Rider Training Program and where demand exists among First Nations communities, to expand the model to include other forms of infrastructure. Where used, the 1-year funding agreement model is inconsistent with the importance of the Circuit Rider Training Program and imposes unnecessary financial uncertainty on Circuit Rider Training Program administrators and circuit-rider trainers.
4. Proactively incorporate climate change adaptation and mitigation into infrastructure design and construction as well as source water protection. The response to climate change impacts by the Water and Wastewater Activities On-Reserve Program has been primarily reactive instead of proactive. Program engineers and environmental public health staff should be engaged to determine what relevant policies or guidelines could be implemented in the short-term and what additional data or information is required before additional policies or guidelines can be implemented.
5. Determine the impact on First Nations communities by program area as a result of current environmental public health officer staffing levels and priorities. There is compelling evidence that the current number of Environmental Public Health Program environmental public health officers is insufficient, however, overall, the Program is able to deliver drinking water activities successfully. An evaluation of all Environmental Public Health Program program areas as opposed to a single area, as is the focus of this evaluation, is necessary to fully understand the impact of current staffing levels.

Overall Management Response

Action Plan Matrix

2.1 Background

Responsibility for safe drinking water on reserves is shared between First Nations communities and the Government of Canada.

ISC-RO provides funding and advice regarding planning, procurement, design, construction, upgrading, operation and maintenance and commissioning of water treatment facilities on First Nations reserves. They also provide financial support for the training and certification of water system operators.

ISC-FNIHB works with First Nation communities to protect public health by assuring verification monitoring programs are in place to provide a final check on the overall safety of drinking water at tap in public water systems, semi-public water systems, cisterns and individual wells in First Nations communities.^{Footnote 4} ISC-FNIHB monitors systematically all systems with 5 or more connections, as well as systems with less than 5 connections where the public has a reasonable expectation of access. For remaining systems, ISC-FNIHB offers residents, upon request and free of charge, bacteriological testing services of their well water.

Chief and Council are responsible for planning and developing their capital facilities that provide for the basic infrastructure needs of the community, including drinking water. They are also responsible for the day-to-day operation of water and wastewater systems on reserves, including sampling and testing drinking water (operation monitoring).

2.2 Program Narrative

Both FNWWEP and EPHP activities align with the Truth and Reconciliation Commission's Call to Action #19, which calls upon "the federal government, in consultation with Aboriginal peoples, to establish measurable goals to identify and close the gaps in health outcomes between Aboriginal and non-Aboriginal communities, and to publish annual progress reports and assess long-term trends."^{Footnote 6}

The Government of Canada's 2015 Speech from the Throne promised a renewal of the relationship between Canada and Indigenous peoples and the Government's first budget proposed an end to long-term boil water advisories by investing an additional $1.8 billion over five years, starting in 2016-17. As part of Budget 2016, the Government formally announced their commitment to eliminate LT-DWAs by March 2021. As acknowledged by the Minister of Indigenous Services Canada in December 2020, the original target of March 2021 will not be achieved. The Government of Canada will continue to work in partnership with communities to end all LT-DWAs on public systems on reserves as soon as possible.

FNWWEP expected outcomes are:

Immediate Outcomes:

• Public water and wastewater systems are planned, designed, constructed/acquired, renovated and repaired/replaced in First Nation communities.
• ISC has the information it needs to make strategic decisions and First Nation communities have the information they need to allocate resources to manage their public water and wastewater systems within established health and safety standards.
• First Nation communities are supported in managing their public water and wastewater systems.

Intermediate Outcomes:

• First Nations' public water and wastewater systems meet established standards.
• First Nation communities have public water and wastewater systems that protect health and safety and which enable participation in the economy.
• First Nation communities have developed the skills and capacity to adequately operate and maintain their public water and wastewater systems and are, consequently, better equipped to transition to a multi-year and community infrastructure plan-based funding approach.

Ultimate Outcome:

• First Nations people have reliable and sustainable public water and wastewater systems in their communities.

EPHP expected outcomes are:

Immediate Outcomes:

• First Nations have access to EPH risk identification activities.
• First Nations, Inuit and partners have knowledge of EPH issues, risks and practices.
• First Nations have capacity to engage in investigation of environmental hazards.

Intermediate Outcomes:

• First Nations, Inuit and partners use environmental public health risk reduction practices.

Ultimate Outcome:

• First Nations, Inuit and partners contribute to decreased environmental public health risks.

3.1 Scope and Evaluation Issues

The scope of the evaluation covers the years 2012-2013 to 2016-2017 as per Treasury Board Requirements^{Footnote 7} and also selected activities undertaken from March 2017 up to March and including fiscal year 2018-2019 to recognize and provide feedback on new initiatives stemming from Budget 2016. Moreover, although not part of the original scope, the evaluation also incorporates more recent data and actions taken by ISC to address water and wastewater programming on reserve in the narrative. The evaluation was led by an evaluation team from the Evaluation Directorate within ISC, supported by an external consultant. Additionally, although not within the original scope of the evaluation, it will also outline early impacts of the COVID-19 pandemic upon the WWP, as well as how it has addressed those impacts.

The evaluation was undertaken to provide a neutral and evidence based assessment of: relevance; performance in the areas of infrastructure, environmental public health activities and training and capacity development; relationships; and, best practices. Appendix A of this report lists the specific questions and issues that guided the evaluation.

3.2 Design and Methods

The evaluation was led by a team from the Evaluation Directorate within ISC, supported by an external consultant. The Methodology Report was approved in September 2019, with primary data collection occurring from September 2019 to February 2020 and from September to October 2020.^{Footnote 8}

The evaluation relied on a mixed-methods approach that included the following lines of evidence: a document, literature and media review; 35 key informant interviews with ISC-RO and ISC-FNIHB representatives and external stakeholders including the AFN , FNHA, OFNTSC and TSAG; a survey of 221 First Nations water and wastewater system operators and managers; a survey of 52 Community-Based Water Monitors (CBWM); and site visits to 6 First Nations communities in Nova Scotia, Newfoundland and Labrador, British Columbia and Alberta.

Following the initial data collection phase described above, the evaluation team also investigated the impacts of Covid-19 on water and wastewater activities by conducting follow-up interviews with ISC-RO and ISC-FNIHB staff at both headquarters and in the regions. 

3.3 Limitations

Site visits were carried out in communities located in the Atlantic, Alberta and British Columbia Regions, but not in other regions as a result of COVID-19 pandemic travel restrictions. Data collected from the survey of water and wastewater system operators and key informant interview data helped to compensate for the change to the data collection plan by providing data from regions that were not visited. The change in the number of site visits did not have an impact on the overall findings, conclusions and recommendations of the evaluation.

The survey of community-based water monitors was not available to CBWMs in all regions due to the availability of contact information from ISC regional offices. As a result, findings from the CBWM survey includes responses from only Quebec, Atlantic, Manitoba and Alberta regions.

3.4 Indigenous Engagement

The issue of water and wastewater on-reserve is of great significance to First Nations in Canada.^{Footnote 9} As such, Assembly of First Nations collaboration, input, and advice was sought to provide input into the evaluation in terms of scope, lines of inquiry, evaluation questions, and appropriate informants. Additionally, the evaluation team participated on-site at the Alberta First Nations Technical Services Advisory Group (TSAG) Regional Drinking Water Safety Forum conference in Calgary, AB, which brought together many water system operators (WSOs) and community-based water monitors from many First Nations communities in southern Alberta. The purpose of the Forum was to seek feedback from participants on service gaps and additional water and wastewater needs in First Nations communities, as well as to inform Program direction.

4.1 Continued need for the FNWWEP

ISC provides funding and support for over 725 water and 450 wastewater systems in approximately 620 communities with the goal of bringing on-reserve water and wastewater systems to a level of service comparable to what is enjoyed by Canadians living in other communities of similar size and circumstances.^{Footnote 10} This goal has not yet been achieved, as people living in some First Nations communities lack access to clean drinking water or adequate wastewater infrastructure, and too many water and wastewater systems are considered to be at a medium- or high-risk for failure.

Significant progress has been made in increasing the safety of drinking water in First Nations communities and towards meeting the federal government's commitment of eliminating all long-term drinking water advisories on public systems on reserves. Since November 2015, through these investments and the work undertaken in partnership with First Nations communities and other partners, the number of LT-DWAs in effect on public systems on reserves declined from 105 to 59 as of March 31, 2019.^{Footnote 11} However, continued investment is needed as new LT-DWAs on public systems on reserves continue to be issued and systems in many communities are approaching or have exceeded their expected life.

There is also a continued need to provide funding for operations and maintenance (O&M) as well as training and capacity development. These investments are necessary to ensure that First Nations community members have access to clean and safe drinking water and wastewater services and to avoid drinking water advisories. Appropriate levels of investment in O&M and WSO training maximizes the lifespan of infrastructure assets and 'protects' the investments made by government and communities.

According to key informants, there are several opportunities to expand the scope of the existing programming to focus on, for example, private wells, source water protection, and a greater focus on wastewater systems. Beyond these additional needs, many First Nations communities are growing and new subdivisions, schools, and a variety of other community buildings will require drinking water and wastewater services.

4.2 Continued need for the EPHP

All people are entitled to basic public health provisions and most communities do not have the breadth of that expertise internally. While nearly half (45/108) of all EPHO have been transferred to First Nation entities such as Tribal Councils, there remains an ongoing commitment by the federal government to fund these positions. In addition, there is a strong consensus from key informants that there is a demonstrable and continued need for the Program.

Previous evaluations have found a similar need for the Program. The 2016 evaluation of Health Canada's First Nations and Inuit Health Branch's Environmental Public Health Program found that many First Nations communities continue to experience significant environmental public health risks compared with other Canadian communities including poor drinking water quality, poorly operated wastewater systems and a lack of certified WSOs; as such, the Program supports a continued and growing need among many First Nations communities to identify and address human health risks associated with exposure to hazards within natural and built environments.^{Footnote 12} The report states that there continues to be a strong, demonstrated need for a program like EPHP to influence health promotion and disease prevention outcomes in First Nations communities, and the need is expected to increase. Drinking water was cited as an EPH Risk area by 95% of EPHOs surveyed in 2016, up from 91% in 2011, and was identified as a high priority by 88% of respondents in 2016, more than for any other EPH risk area. Wastewater risks were cited as an EPH risk area by 72% of respondents, down from 80% in 2011. The 2015 evaluation of the CBWM Program also found a continuing need for the Program because it protects the health of residents of First Nations communities. The evaluation stated that the CBWM Program provides objective verification on the overall drinking water system and drinking water quality through: timely sampling and testing of water; community capacity by training Community-Based Drinking Water Quality Monitors; and, increased awareness of drinking water issues.^{Footnote 13}

5.1 Infrastructure

As of September 30, 2020, a total of 365 water and wastewater projects were completed and an additional 292 projects were ongoing for a total of 657 water and wastewater projects across 581 First Nations communities.

As shown in the figure below, the share of Public Water Systems with treated water that meets the Guidelines for Canadian Drinking Water Quality (GCDWQ) reached 92% in 2015-16 and remained relatively constant for the five-year period from 2015-16 to 2019-20, thus meeting the March 2021 target of 90%. The share of Public Wastewater Systems producing treated effluent that meets the Wastewater Systems Effluent Regulations increased from 63% in 2013-14 to 80% in 2015-16 before declining to 66% in 2019-20. Despite this decrease, the 2017-18 ISC Departmental Results Report indicates that the 85% target for wastewater systems by March 2021 will be met as more infrastructure projects funded through Budget 2016 are completed.^{Footnote 14}

Source: Data provided by ISC Strategic Water Management Team. Targets contained in ISC Departmental Results Reports.

Text alternative for Figure 1: Percentage of On-Reserve Public Systems meeting the Guidelines for Canadian Drinking Water Quality and the Wastewater Systems Effluent Regulations

Figure 1 is a line chart illustrating the percentage of on-reserve public systems meeting the guidelines for Canadian drinking water quality and wastewater systems effluent regulations by fiscal year.

In 2012-2013 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 69%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 68%.

In 2013-2014 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 74%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 63%.

In 2014-2015 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 74%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 77%.

In 2015-2016 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 92%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 80%.

In 2016-2017 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 92%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 75%.

In 2017-2018 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 92%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 69%.

In 2018-2019 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 93%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 65%.

In 2019-2020 the percentage of on-reserve public systems which met the guidelines for Canadian drinking water quality was 94%. The percentage of on-reserve public systems which met wastewater systems effluent regulations was 66%.

The March 31, 2021 target for on-reserve public systems meeting the guidelines for Canadian drinking water quality is 90%. The March 31, 2021 target for on-reserve public systems meeting the guidelines for Canadian wastewater systems effluent regulations is 85%.

An evaluation of the management risk levels associated with each system is performed as part of the Annual Performance Inspection (API). An API assesses five main components of a system (i.e. effluent/water source risk; design risk; operation and maintenance risk; record keeping and reporting risk; and operator risk) to determine an overall system management risk score. Systems are given a risk score of low, medium or high.^{Footnote 15} As shown in Figure 2, the share of water systems with a low risk score increased between 2012-13 (38%) and 2014-15 (57%), but has been relatively consistent between 2014-15 and 2019-20 (57%). The share of public wastewater systems with a low risk score has fluctuated somewhat over the eight-year period, but the share in 2019-20 (48%) was the same as in 2014-15. The performance targets, which have not yet been achieved, call for the percentage of public systems that have low risk ratings to be 65% for both water and wastewater systems by March 31, 2021.^{Note de bas de page 16}

Source: Data provided by ISC Strategic Water Management Team. Targets contained in ISC Departmental Results Reports.

Text alternative for Figure 2: Percentage of On-Reserve Public Water and Wastewater Systems that have Low Risk Ratings

Figure 2 is a line chart illustrating the percentage of on-reserve public water and wastewater systems that have a "low risk" rating.

In 2012-2013, 38% on-reserve public water systems had a low risk rating, and 43% of wastewater systems on-reserve had low risk ratings.

In 2013-2014, 44% on-reserve public water systems had a low risk rating, and 52% of wastewater systems on-reserve had low risk ratings.

In 2014-2015, 57% on-reserve public water systems had a low risk rating, and 48% of wastewater systems on-reserve had low risk ratings.

In 2015-2016, 56% on-reserve public water systems had a low risk rating, and 45% of wastewater systems on-reserve had low risk ratings.

In 2016-2017, 56% on-reserve public water systems had a low risk rating, and 43% of wastewater systems on-reserve had low risk ratings.

In 2017-2018, 57% on-reserve public water systems had a low risk rating, and 45% of wastewater systems on-reserve had low risk ratings.

In 2018-2019, 56% on-reserve public water systems had a low risk rating, and 48% of wastewater systems on-reserve had low risk ratings.

In 2019-2020, 57% on-reserve public water systems had a low risk rating, and 48% of wastewater systems on-reserve had low risk ratings.

The March 2021 target for on-reserve public water and wastewater systems having low risk ratings is 65%.

In the survey of WSOs undertaken to inform this evaluation, respondents were asked to rate the average quality of their community's water and wastewater infrastructure since 2013. As shown in the following table, those from Yukon (72%), Atlantic (50%), and Manitoba (50%) Regions were most likely to respond good or very good. Respondents from Alberta were the most likely to respond poor or very poor (40%). Since Alberta has very few LT-DWAs, the survey results imply that LT-DWAs are not always a comprehensive measure of a sustainable system.

WSOs were also asked to indicate if the quality of their community's water and wastewater infrastructure had improved, worsened or had not changed since 2013. As shown in Table 2, the share of respondents that indicated their community's infrastructure had improved ranged by region from a low of 22% (Ontario) to a high of 50% (Manitoba), while the share that indicated it had worsened ranged from a low of 11% (Atlantic) to a high of 30% (Alberta).

WSOs were also asked whether they agreed or disagreed that their community's drinking water and wastewater services were to a level and quality of service comparable to that enjoyed by Canadians living in non-First Nations communities of similar size and location. As indicated in the following table, overall 76% of WSOs indicated that their community's drinking water services were comparable while only 51% of WSOs indicated that their wastewater services were comparable to that in non-First Nation communities. In all regions, the share of respondents that indicated their community's drinking water was comparable was higher than the share indicated for wastewater services.

5.2 Operations and Maintenance

The CFMP provides operations and maintenance funding as a subsidy to assist First Nations in the delivery of community infrastructure services on-reserve. The policy for drinking water and wastewater systems is to provide 80% of the average cost required to operate and maintain equivalent off-reserve capital assets to generally acceptable standards. Unlike capital projects, O&M funding is not based on proposals submitted by First Nations, but is established annually through an internal formula-based system contained in CFMP's Cost Reference Manual. The formula is run automatically using the Integrated Capital Management System (ICMS) each year and is applied to all eligible on-reserve assets contained in the ICMS inventory.^{Footnote 17} Notwithstanding inflationary increases, the formula has been unchanged for nearly two decades and does not adequately reflect new technologies and escalating cost pressures such as the cost of electricity.

The federal government is aware of the problems associated with the funding formula. As stated in the 'Deep Dive' Summary Report into the issue, "insufficient Operating and Maintenance funding for drinking water systems is a huge challenge across First Nations communities" and was highlighted as a significant issue by every region and organization included in the research.^{Footnote 18} Key informants included in this evaluation echoed these concerns and indicated that in addition to the formula not accurately estimating 80% of water and wastewater operating costs, it falsely supposed that communities possess available funds for the remaining 20%. Inadequate O&M funding can impact the provision of water and wastewater services in several ways, including: low salaries for WSOs relative to nearby municipalities, which contributes to WSO turnover; a lack of back-up WSOs and WSOs-in-training; and, an inability to conduct proactive as opposed to reactive maintenance which leads to higher overall costs and reduces the length of time the infrastructure remains operational.^{Footnote 19}

Some ISC regional offices have developed top-up programs that are meant to reduce the negative impacts resulting from the formula and Budget 2019 included additional funding to support O&M. However, it is premature to assess the impact of this funding over the short run as the negative impacts of insufficient funding are cumulative. Data organizations are working in collaboration with The Assembly of First Nations to study the issue and arrive at a more sustainable formula or approach for O&M funding.

Key informants indicate that the most sustainable way to address the issue of O&M funding is through an asset management approach and long-term funding agreements with First Nations. This approach involves describing what infrastructure is owned, what it is worth, its condition and remaining service life, when maintenance is required, how much operations, maintenance and replacement will cost and when those costs will occur, and the financial plans to ensure affordability in the long term.

5.3 Assessments

The CFMP Program Manual indicates that Annual Performance Inspections (APIs) of First Nations water systems have been required since the introduction of the Protocol for Centralised Drinking Water Systems in First Nation Communities in 2006 and the Protocol for Centralised Wastewater Systems in First Nation Communities in 2010. The CFMP Program Manual indicates that APIs include site visits conducted by a qualified person (e.g. licensed consulting engineer, licensed Tribal Council engineer, provincial water systems inspector or a water system operator) who is certified to a level equivalent to the level of the system being inspected and is not a member of the band involved.^{Footnote 20} According to ISC, a total of 784 water APIs were completed in both 2016-17 and 2017-18, and a total of 511 wastewater APIs were competed in both 2016-17 and 2017-18.^{Footnote 21} It should be noted that APIs are not a measure of public health risk.

Key informants indicated that APIs provide a high-level overview that is helpful for determining which systems require more focused attention. While the APIs are the source of risk measurement available for systems, some key informants indicated that the approach is not easily understood due to the complexity of the API process and is less useful than a priorities-based approach.

As stated in the CFMP Program Manual, comprehensive assessments of water and wastewater systems serving First Nations are conducted periodically.^{Footnote 22} The most recent comprehensive assessment of water and wastewater infrastructure on-reserve was conducted between 2009 and 2011, during which consultants visited 571 participating First Nations communities to assess the condition of the water and wastewater assets, identified the capital and O&M needs and recommended future servicing options for the period 2010-2020.^{Footnote 23} Key informants indicated that another comprehensive assessment is now required to provide more accurate and up-to-date data for use by communities and ISC.

5.4 Climate Change

A 2008 AFN report describes the significant impact climate change could have on First Nations relationship with water throughout Canada and states that successful adaptation will require solutions that acknowledge and work with on-reserve water conditions. The report notes that impacts could include changes to seasonal water flow patterns; changes to precipitation patterns; warmer surface water temperatures; variations in surface water quantities; changes in surface water and groundwater levels and a higher incidence of drought, which together will result in widespread changes to water quality; and water availability and watershed vitality. Lower water levels eroding shorelines, unpredictable water movement and warmer water temperatures can impact water quality through a range of ways including increased erosion of exposed soils resulting in higher water turbidity levels, greater movement of pollutants into watercourses and larger quantities of solid matter requiring filtration, increased bacteria and fungi concentrations, increased summer phosphorus concentrations, and other effects.^{Footnote 24} Additionally, Health Canada has outlined several ways in which climate change could affect the health of communities, for example, by impacting water sources for food gathering, recreational and cultural use.

Overall, the report states that drinking water and wastewater treatment infrastructure will have to cope with filtering the degraded quality of water and will have to be designed and constructed to deal with everything from extreme weather to poorer water quality. Water infrastructure will need to withstand flooding in areas that have not historically been susceptible to floods and sewer systems may have to carry larger volumes of water than have been historically necessary as a result of heavy rains or quick spring ice-melt. Wastewater treatment must emphasize protection against breaches resulting in contamination from changes to 'normal' water levels as a result of climate change.^{Footnote 25}

Key informants indicated that increased fires, floods and drought conditions have already affected source water and threatened infrastructure in First Nations communities. In addition, they stated that the extent to which potential climate change impacts are accounted for during infrastructure design and planning phases varies significantly based on the consultants involved in the program, and to date has been primarily reactive instead of proactive.

6.1 Achievement of Outcomes

Monitoring bacteriological parameters in drinking water may be done by either an EPHO or a CBWM trained to conduct testing or through samples sent to accredited laboratories for analysis. According to the 2018 Performance Information Profile for the Water and Wastewater Program, the percentage of communities with access to trained CBWMs or EPHOs to monitor drinking water quality has met the target of 100%.^{Footnote 26}

According to the GCDWQ, Public Water Systems (PWSs) should be sampled four times per month evenly spaced, for a total of 48 out of 52 weeks. To reflect regional realities and challenges in sampling PWSs four times per month (e.g. band office closures, holidays, staff turnover, etc.), eligible PWSs are considered to be in compliance with recommended sampling for bacteriological parameters if it is sampled 85% (44 out of 52 weeks each year).^{Footnote 27} The following table indicates the number of PWSs monitored weekly, monthly and not at all during the five year period from 2012-13 to 2016-17. According to key informants, the decrease in the share of PWSs monitored weekly from 64% in 2012-13 to 42% in 2014-15 was primarily a result of travel restrictions imposed by senior management which limited the number of community visits that could be done by EPHOs.^{Footnote 28}

The method described above and presented in Table 4 considers a system to be compliant if the system was monitored 48 out of 52 weeks (or 44 weeks for eligible systems). If a system was monitored, for example, 47 weeks out of 52 instead of 48, it would be considered non-compliant and the 47 weeks of actual monitoring would not be recognized or tabulated. In an effort to improve the statistical analysis of bacteriological monitoring, Statistics Canada was enlisted to suggest a method that could better reflect the bacteriological monitoring taking place. They suggested an averaging method where the sampling frequency of each system is calculated based on the monitoring taking place and not a "pass vs. fail" method. For example, if a system was monitored 47 weeks out of 52 weeks, the system would be considered to have a sampling frequency of 98% (i.e. 47/48).^{Footnote 29} The following table reports the average sampling frequency for PWSs has increased from 75% in 2012-13 to 80% in 2016-17. According to the EPHP Performance Information Profile, the target value is 84% by March 2022.^{Footnote 30}

As shown in the following table of survey results, most WSOs across all regions agreed that the frequency at which their community tests drinking water (verification monitoring) for quality is appropriate, with respondents from communities in Ontario (100%), Atlantic (100%), Quebec (93%) and Alberta (90%) most likely to have agreed. One-in-five (21%) respondents from Saskatchewan disagreed. Most WSOs indicated that there are a sufficient number of CBWMs in their community but based on survey responses, there may be demand for more CBWMs in certain regions where a higher share of respondents disagreed with the statement including Manitoba (33%), Atlantic (30%) and Saskatchewan (29%).

As indicated in the following table of survey results, 77% of all WSOs agreed that their community has confidence in its drinking water while 14% disagreed. The WSOs from communities in Saskatchewan (30%) and Atlantic (20%) were the most likely to disagree. WSOs were also asked if their community has the capacity to identify water quality problems and potential waterborne diseases. Overall, 80% of WSOs surveyed indicated they had such capacity and 11% indicated they did not. WSOs in Saskatchewan (25%) and Quebec (21%) were most likely to indicate that they lacked that capacity, most often because the community lacked the sufficient equipment to test water locally and must instead send samples away to an accredited lab for analysis.

6.2 Program Design and Delivery

Most key informants characterize the design of the EPHP as being very appropriate, despite being under-resourced. EPHOs spend much of their working time in communities and so tend to have effective relationships with community leadership, health and infrastructure managers, WSOs, and others. This element of the Program design is said to be a key strength and is consistent with the 2016 evaluation of ISC-FNIHB 's EPHP which found that the Program has demonstrated capacity to work effectively with First Nations communities to identify and to assess risks, and to provide recommendations with respect to addressing environmental risks. In addition, nearly half (45/108) of all EPHOs have been transferred to First Nations control, with ISC continuing to fund environmental health programs through grants and contributions.

Despite the Program's achievements, there have long been concerns raised about available resources for the Program. The Drinking Water Program Reports published by ISC-FNIHB from 2012-13 through 2016-17 states that "the current A-base and FNWWAP allocated FTE positions are insufficient to successfully deliver the program".

Water issues on reserves are a longstanding concern and have received multiple cycles of targeted investment to address specific issues since 2003. Since 1970, with the exception of drinking water, investments have not been made in EPHO capacity and associated resources.

In February 2018, the Deep Dive report estimated the shortfall of Environmental Public Health Officers to be 54 FTEs.^{Note de bas de page 31} Findings from key informant interviews reinforce the perception that there is a long-standing deficiency in the total number of Environmental Health Officers providing service to First Nations communities.^{Note de bas de page 32} The level of demand for EPHO services has increased over time due to limited A-base funding in Regions, population growth in communities, and large infrastructure investments made within communities. The extent to which each of these pressures impacts the provision of EPH services to First Nations communities are subject to variation due to factors such as region, remoteness, community capacity and others.

Key informants also revealed that the EPHP appears to be very reliant on the funding it receives for water and wastewater, despite these being just two of eight Program areas. Notwithstanding emergency issues that arise, the ability to focus on other EPH Program areas in a proactive and timely manner is said to be limited by the clear direction to focus on the Drinking Water Program from the priority placed on eliminating LT-DWAs by the federal government.

7.1 Water System Operators

As shown in Figure 4, the percentage of public water systems that have primary WSOs certified to the level of the system in their communities increased from 64% in 2012-13 to 74% in 2019-20. For wastewater systems, the rate has fluctuated over the eight-year time period shown in the figure; however, the value in 2019-20 (60%) is similar to the value in 2012-13 (61%). The Departmental Results Reports do not state a target value for this indicator. It appears that adequate opportunities for certification training are available, but other factors limit overall certification rates including WSO turnover and lack of back-up WSOs, as well as community remoteness and other barriers to advanced education.

Source: Data provided by ISC Strategic Water Management Team.

Text alternative for Figure 3: Percentage of Public Water Systems and Public Wastewater Systems that have Primary Water System Operators Certified to the level of the System

Figure 3 is a line chart illustrating the percentage of public water systems and public wastewater systems that have primary water system operators certified to the level of the system that they run.

In 2012-2013, 64% of public water systems had operators certified to the level of the water system that they run. 61% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2013-2014, 68% of public water systems had operators certified to the level of the water system that they run. 58% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2014-2015, 66% of public water systems had operators certified to the level of the water system that they run. 56% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2015-2016, 67% of public water systems had operators certified to the level of the water system that they run. 55% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2016-2017, 69% of public water systems had operators certified to the level of the water system that they run. 59% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2017-2018, 71% of public water systems had operators certified to the level of the water system that they run. 62% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2018-2019, 74% of public water systems had operators certified to the level of the water system that they run. 58% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

In 2019-2020, 74% of public water systems had operators certified to the level of the water system that they run. 60% of public wastewater systems that had operators certified to the level of the wastewater system that they run.

The presence of a certified primary WSO is important for the safe operation of water and wastewater systems, but an additional concern is having enough WSOs available. As shown in the following table of survey results, 79% of respondents indicated that their facilities have certified WSOs, but nearly half of all respondents (46%) indicated that there were not a sufficient number of trained WSOs. Respondents from Manitoba (69%), Alberta (60%) and Saskatchewan (58%) were most likely to indicate that there are not enough trained WSOs to ensure safe drinking water and wastewater services.  Key informants stated that while there is funding available for WSOs to pursue certification, the shortfall in certified WSOs is primarily due to turnover and low pay levels making it difficult to recruit and retain certified WSOs as well as lack of funding for back-up WSOs. 

7.2 Circuit Rider Training Program (CRTP)

The CRTP is a long-term capacity building program that provides training and mentoring services to operators of First Nations drinking water and wastewater systems. It is one of the primary mechanisms by which ISC supports ongoing training and capacity development among WSOs. The general CRTP model involves qualified experts, known as 'Circuit Rider Trainers' or simply 'trainers', who provide support to a given number (i.e. a circuit) of First Nations communities by providing hands-on training to operators of water and wastewater systems. Trainers visit communities on a scheduled basis and teach about the specific equipment that is installed in the community. Trainers assist WSOs in obtaining and maintaining their certifications and may also provide advice to Chiefs and Councils. Trainers will also provide remote assistance on an as-needed basis to WSOs experiencing minor operation and maintenance issues and endeavor to provide 24/7 emergency support^{Footnote 33}

The CRTP supports many WSOs to obtain and maintain certification and to operate systems in a safe manner. The key strength of the Program is that it provides hands-on in-community training to WSOs. The hands-on component has multiple benefits, but two are most apparent. First, training is based on the equipment a given WSO uses on a day-to-day basis; and second, the training could not be replaced by other forms of centralized training. In many communities there are not a sufficient number of trained and certified WSOs to allow for individuals to leave the community for training. If in-community delivery of Continuing Education Units (CEUs) through trainers was no longer available, WSOs would be unable or significantly challenged to maintain their certification.

Some regions have extended the CRTP model to include other community infrastructure. For example, in Quebec, the Regroupement Mamit Innuat Tribal Council provides Building Maintenance Trainer activities to 18 communities; and in Manitoba, the Dakota Ojibway Tribal Council delivers a similar Program focused on school infrastructure called the School Maintenance Training Program. Key informants indicated that expansion of the Program could be an opportunity for other regions as well, but that the tendency to fund the CRTP annually as opposed to providing ongoing sustainable funding is a barrier to expansion and a risk to the current delivery of the Program overall.

7.3 EPHP-Delivered Training and Capacity Development

The training of CBWMs comprises most of the training and education delivered by EPHOs in First Nations communities. Given the importance of monitoring drinking water for safety and quality, most key informants indicated that this is a very appropriate focus for EPHOs. Materials used for training have not been updated recently (e.g. they refer to Health Canada and not ISC).^{Footnote 34}

The other focus of the EPHP with respect to education initiatives is the development of communication and educational material. According to ISC-FNIHB representatives, many of these products have been developed in collaboration with First Nations. To date, the primary focus has been on communicating and educating with respect to drinking water advisories. There is an opportunity and demand for additional information for water and wastewater, such as those that relate to manganese, trihalomethanes, mercury, lead, etc.

The 2016 evaluation of the ISC-FNIHB EPHP found continued effort and emphasis placed on the development of public education and awareness materials with over 250 materials in various formats related to EPH risks, including drinking water and wastewater, among others. The 2016 evaluation reported that approximately two-thirds of respondents to the EPHO survey (64%) stated that there had been a positive shift in the community members' awareness and knowledge of EPH risks in the past five years. Most EPHOs (83%) reported that the EPHP had made at least some contribution to community members' levels of awareness of EPH risks through the active dissemination of information, education and site visits.^{Footnote 35}

8.1 ISC-RO and ISC-FNIHB

The distinction between infrastructure and public health programming means that, effectively, there tends not to be overlap between ISC-RO and ISC-FNIHB . For example, there are far fewer ISC-FNIHB engineers than there are at ISC-RO, so ISC-FNIHB engineers have less capacity to review proposed infrastructure. While ISC-RO engineers do look at health risks in reviewing proposed infrastructure, when ISC-FNIHB engineers are involved, they offer a different perspective rather than an overlap. The lack of ISC-FNIHB engineer capacity is significant as the importance of public health risks (as opposed to infrastructure risks) may not receive the necessary attention.

The focus on drinking water and the commitment to eliminate LT-DWAs on public systems on reserves has led to greater integration among ISC-RO and ISC-FNIHB , and has provided opportunities for staff and managers to become acquainted and work in unison towards a shared goal. According to key informants, most other program areas have not experienced the same level of integration.

8.2 Headquarters and Regions

Regional key informants from ISC-RO are supportive of the commitment to eliminate LT-DWAs on public systems on reserve and to see money flowing from Budget 2016 and the FNWWEP, but the commitment has been delivered through a centralized approach, leaving regions with less ability to allocate dollars based on regional priorities as opposed to national ones.

Key informants have raised the concern that as a consequence of the move towards centralized decision-making, regional needs and priorities may not be met, as well as a lessening of focus on unique regional contexts.

9.1 Summary of Best Practices

Transformation of ISC: Several existing and/or proposed organizations are considered to be best practices and examples of how the Transformation of ISC can occur, in that they are led by First Nations or are otherwise independent from the federal government and have taken on roles once held by Canada to provide services to First Nations communities. Examples of organizations/initiatives include:

• The Alberta First Nations Technical Advisory Services Group (TSAG) and the Ontario First Nations Technical Services Corporation (OFNTSC) both of which provide technical support to First Nations communities and deliver the CRTP in their respective regions.
• The BC First Nations Health Authority (FNHA), which is the first and only provincial health organization of its kind in Canada, provides environmental public health services, including through a Drinking Water Safety Program, to First Nations communities in British Columbia.
• The Atlantic First Nations Water Authority which is being developed by the Chiefs Secretariat of the Atlantic Policy Congress of First Nations and if implemented would be the first water authority constructed, owned and operated by First Nations.
• Another practice that can be thematically linked to the Transformation of ISC has been the devolution of EPHOs to First Nations communities and Tribal Councils and other entities that operate public health programs for their member communities. ISC funds the transferred EPHO positions through grants and contribution agreements.

Prioritization of LT-DWAS: The prioritization of LT-DWAs on public systems on reserve, and the federal government commitment to end LT-DWAs has been highlighted as a best practice because it represents an unprecedented investment in water and wastewater infrastructure and it has demanded high levels of communication and collaboration among stakeholders.

Support for WSOs and systems: WSOs are the front line professionals responsible for water and wastewater systems in First Nations communities. Several best practices are focused on providing training and support to WSOs and on increasing WSO retention. Examples of these approaches include:

• Training and support programs such as the CRTP and the HUB model which has been implemented in Ontario among eight tribal councils supporting 48 communities with hub services. A hub provides economies of scale by providing qualified oversight and assistance to multiple First Nations water and wastewater systems across communities within the hub.
• Including WSOs as much as possible during the design and construction phase of infrastructure projects and ensuring in the contract that training and ongoing support will be provided by the system designer/contractor for a period of time such as the first year of operation.
• Some Regions, including British Columbia and Saskatchewan, have developed a wage subsidy enhancement program for water and wastewater system operators that gain or maintain certification to the level required for their community's system. It is considered a best practice in the context of the current O&M funding arrangement because it can lead to increased rates of certification and retention of WSOs in First Nations communities.
• The FNHA has permitted and supported First Nations communities to undertake in-community testing of water samples using approved technologies. Duplicate samples are also sent to accredited labs periodically for quality assurance, but in-community sampling has allowed communities to test their own water system for total coliform and e-coli. The initiative was first undertaken to assist communities that, due to remoteness, could not supply samples to accredited labs within the required timeframe, but has since expanded to most (approximately 180) First Nations communities in BC.
• Use of technology that facilitates remote, real-time, centralized operational monitoring that can alert various entities if a problem arises at a facility.

Procurement, design and construction: Best practices were identified that relate to the procurement, design and construction phases of infrastructure projects. For example:

• Two pilot projects were carried out by ISC and First Nations communities in 2019-21 to identify potential options for modifying tendering policies that would result in greater participation of First Nations-owned companies in the design and construction of water and wastewater infrastructure.
• The Lytton First Nation in British Columbia partnered with RES'EAU-WaterNET, a strategic network of organizations and academics devoted to providing innovative solutions for the drinking water challenges of small, rural and Indigenous communities. This partnership resulted in the selection of a small, custom-built water treatment plant that fits inside a modified 20-foot shipping container for the community.
• The Government of Ontario's Showcasing Water Innovation Program was conceived to fund a small number of high value drinking water, wastewater and storm water projects, and showcased these projects to all Ontario communities. The Program included projects carried out in Ontario municipalities as well as in three First Nations communities between 2011 and 2015.
• The BC Region funds the work of a project manager who is available to communities that are undertaking infrastructure projects. The practice was developed because of a concern that communities did not otherwise have the resources or capacity to ensure that contractors adhere to timelines and other expectations.

Municipal Type Agreements: Municipal Type Agreements (MTAs) are another area of best practice. Through a MTA, a First Nations community and a neighboring municipality enter into a long-term agreement to share infrastructure and costs. Studies have shown that MTA participation reduces the probability of a system having a high-risk ranking, and for a system failing the Guidelines for Canadian Drinking Water Quality. According to the most recent data, approximately 19% of drinking water systems and 22% of wastewater systems in First Nations communities rely on an MTA^{Footnote 36}. MTAs have been used for recent infrastructure projects including in Semiahmoo First Nation where a project is underway to install pump stations and pipes to connect to the City of Surrey, BC; and another agreement exists between Wauzhushk Onigum Nation and the City of Kenora, Ontario.

Outreach and promotion: A number of best practices relate to recognizing the profession and individual WSOs and to reaching out to youth to promote the profession. Efforts such as these are important to addressing concerns about WSO retention and succession over the longer term. Examples of such initiatives include:

• The Water First Internship, which provides hands-on training and work experience in water treatment and environmental monitoring to Indigenous youth in their communities and leads to certification as a Water Quality Analyst and Operator-in-Training. The first cohort consisted of 10 individuals and was initiated in 2017 in collaboration with the United Chiefs and Councils of Mnidoo Mnising, Wiikwemkoong Unceeded Territory and the Union of Ontario Indians and was delivered in seven First Nations on Manitoulin Island. In February 2020, the Bimose Tribal Council in northwestern Ontario announced their partnership with Water First Education & Training Inc. to deliver the internship to 14 individuals from 10 participating First Nations communities across the Bimose Tribal Council Region. Funding is provided by ISC.
• The National First Nations Water Leadership Award was created by ISC in March 2018 to recognize First Nations individuals or organizations that have demonstrated leadership and outstanding dedication to the advancement of clean and safe drinking water in First Nations communities. Recipients are presented with the award by the Minister of Indigenous Services Canada.
• The Water Awareness Grants were launched in 2016. First Nations communities in BC are invited to submit proposals for a community water awareness day event. The purpose of the grant is to support awareness and preservation of First Nations' community drinking water sources by providing small grants to communities to support hosting these events.

Planning for sustainable systems: A set of best practices were identified that relate to planning approaches that have not yet been applied broadly, but address overall sustainability of systems and the long-term provision of safe water and wastewater services to First Nations communities and community members.

• Source water protection, including source assessments and source protection plans are used to understand water sources, document the observe hazards and manage the risks associated with natural and human-made hazards. It is considered the first step in protecting a drinking water source. The ISC Protocol for Centralized Water calls for First Nations to create a source water protection plan (SWPP); however, to date there has been no general funding attached to the development of SWPPs.
• Asset Management Planning is an increasingly common practice among municipal infrastructure owners but has not yet been broadly applied to First Nations infrastructure. Simply put, asset management planning is a long-term approach to the management of assets. It involves describing what infrastructure is owned, what it is worth, its condition and remaining service life, when maintenance is required, how much operations, maintenance and replacement will cost and when those costs will occur, and the financial plans to ensure affordability in the long term.
• Water Safety Planning is a global best practice with no formal application to date in Canada. It involves the development of water safety plans to ensure the safety and acceptability of a drinking-water supply. According to the World Health Organization, water safety plans require a risk assessment including all steps in the water supply from catchment to consumer, followed by implementation and monitoring of risk management control measures, with a focus on high priority risks. Where risks cannot be immediately addressed, the WSP approach allows for incremental improvements to be implemented systematically over time.^{Footnote 37}

11.1 Conclusions

Relevance

• Is there a demonstrable and continued need for FNWWEP?
• Is there a demonstrable and continued need for providing environmental public health services to First Nations?
• Are the current roles and responsibilities of the federal departments and regional bodies involved in water and wastewater infrastructure appropriate and sufficient?
• In what ways can water and wastewater infrastructure activities support the Transformation of ISC? How can the program lead to independent First Nations ownership and operation of water and wastewater systems in their community?

Effectiveness and Efficiency by Results Chain

Water and Wastewater Infrastructure

• Is the process for the planning, design, construction, acquisition, renovation, repairs, and replacements of water and wastewater infrastructure projects working well?
• Is the tendering process for the construction/maintenance of water and wastewater systems functioning appropriately?
• Are the expected outputs being produced?
• Are the expected outcomes being achieved?

Monitoring for Potential Public Health Hazards – Water and Wastewater Systems

• Is there adequate support (e.g. financial, infrastructure, human resources, training, etc.) for the environmental public health needs of First Nation communities for drinking water and wastewater, and, to the extent that they relate to water and wastewater, other areas covered by Environmental Public Health Officers (e.g. housing)?

Assessments

• Is the process for assessing water and wastewater infrastructure on-reserve working well?
• Are the expected outputs being produced?
• Are the expected outcomes being achieved?

Training and Capacity Development

• Is the process for training and capacity development with regards to water and wastewater infrastructure on-reserve working well? How well is the Circuit Riders Training Program working?
• Are the expected outputs being produced?
• Are the expected outcomes being achieved?
• How well and appropriately are EPHP water and wastewater education initiatives meeting their intended audiences and targets?
• What is the best way to ensure that First Nations have adequate succession plans? How can the program facilitate succession planning in communities?

Operations and Maintenance

• Is the process for operations and maintenance of water and wastewater infrastructure on-reserve working well? 
  • Is the 80% funding level for operations and maintenance appropriate?
• Are the expected outputs being produced?
• Are the expected outcomes being achieved?

Relationships

• Does there exist collaboration, complementarity and/or overlap between ISC-RO and ISC-FNIHB programs and employees regarding water and wastewater infrastructure? Is the relationship working well? How could it be enhanced?
• Are there appropriate resources and services across and between regions to assist First Nations in accessing the water and wastewater infrastructure program?

Environmental Public Health Program in First Nations Communities

• Does the design and delivery of EPHP activities effectively and efficiently meet the needs of First Nation communities? How well is the CBWM program working?
• What are the barriers which prevent the implementation of recommendations of Environmental Protection Health Officers?
• Are EPH services comparable to that available off-reserve and consistent from region to region?

Environmental Sustainability

• How is climate change impacting water and wastewater infrastructure on-reserve?

Results

• What progress has been made towards achieving the ultimate outcome of the water and wastewater infrastructure program?
  • How has the water and wastewater infrastructure program responded to previous evaluation recommendations? (See Annex B)
  • How has the Environmental Public Health Program responded to previous evaluation recommendations concerning water and wastewater on-reserve?
  • Do program results vary significantly for First Nations communities based on geography (e.g. remote vs. non-remote, provincially, etc.) or any other systemic reasons?
• Are the performance measurement indicators and tools for this program the best options?
  • If not, what are some tools and indicators that will enhance performance measurement?
  • Do they meet the needs of First Nations?
• Are there internal barriers in the program which prevent full First Nation care and control of water and wastewater systems?
  • If so, what are they and how can the program address these barriers?

Best Practices/Lessons Learned

• What are the best practices and service gaps from regions across the country?