Evaluation of the Education Facilities Program

Relevance

The evaluation finds a continued need for the EF program and its alignment with ISC and Government of Canada priorities; however, the magnitude of existing and future demands of education facilities far exceeds the funding available. A few intensifying or emerging factors, including population growth on-reserve, impacts of climate change and COVID-19 and the growing needs of diverse segments of the communities have placed additional pressure on already limited resources. While the EF program is deemed relevant in addressing some education facilities' needs, some gaps were identified in relation to meeting health and safety standards, impacts of climate change, students with special needs, and teacherages.

Effectiveness

The evaluation examined the extent to which the EF program has been effective in supporting First Nation communities to construct and upgrade education facilities in their communities, to develop the capacity to plan and manage education facilities, and to maintain their ISC-funded assets. The evaluation finds that the EF program delivered numerous schools and education facility projects to First Nations communities which helped meet the needs and address education facilities gaps on-reserve; however, the reliability and sustainability of these facilities could not always be ensured due to funding constraints and program design. Moreover, the CFMP's overarching objectives of maximizing the life cycle of assets, mitigating health and safety risks and ensuring assets meet applicable codes and standards were not fully achieved. The availability and reliability of performance data continue to be an issue as identified by the evaluation. In reporting on the achievement of the program, there is a lack of performance data and the department mostly uses data at the output level as specified in the program Logic Model (Annex A); alternative performance measurement approaches were proposed to measure the success of the infrastructure investment on-reserve more effectively by integrating a wellbeing or human rights centered lens.

The evaluation also looked at the effectiveness of the funding approach, oversight and support of program delivery, including the First Nations Infrastructure Investment Plan (FNIIP) process. The evaluation finds that the current planning does not support strategic long-term planning and the asset management principles; also the prioritization criteria used in the FNIIP process does not sufficiently consider emerging key factors identified by communities such as public health, climate change and accessibility and other community-based priorities. Issues identified in accessing EF program funds included the timing of funds, application criteria and rationale for the approval of proposal-based funds, community capacity, access inequality and transparency. Further, a lack of regular maintenance due to funding availability and backlogs, compounded by worsened weather conditions and lesser quality of materials, resulted in the lifespans of community infrastructure shorter than elsewhere in Canada. While it may be early to assess the full impacts of including the Operations and Maintenance (O&M) as part of educational programming that took place in 2019-20, some limitations were raised during the evaluation in relation to the transfer of the O&M component to the Education and Social Development Programs and Partnerships Sector (ESDPP).

In addition to the expected outcomes of the program, the evaluation finds that the EF program provided employment and training opportunities, increased on-reserve enrolment and academic success, positive impacts on the wellbeing of community members, especially children, and increased community pride.

Efficiency

The evaluation assessed the extent to which the EF program demonstrated efficiency and economy. The findings suggested that while the program has implemented initiatives to generate more efficiency in program delivery, opportunities exist in improving cost-efficiency and generating more value for money through more integrated planning based on lifecycle asset management principles, applying a whole-of-community approach based on the unique needs and realities of the communities and taking more proactive and preventative measures in repairs and maintenance of investments.

The evaluation finds that the planning and approval of EF program projects did not take into consideration infrastructure investments in other sub-assets under the CFMP, which had resulted in instances where schools were built without proper enabling features. The delivery of infrastructure funding in asset-based silos made it difficult to align processes and deadlines, hindering the coordination of funding sources. Further, cost-efficiencies in the EF program were not fully achieved as a result of insufficient maintenance and repair. Moreover, the evaluation noted a lack of a cohesive approach towards capacity building for asset management, which inhibits the efficiency in delivering education facilities outcomes. Related to capacity issues, was a high turnover of staff, both ISC and First Nation communities, results in inefficiencies due to loss of capacity and additional efforts by First Nations.

Several alternative delivery models were implemented during the evaluation period to realize more cost-effective ways of delivering the EF program, which included the Innovation Fund and school bundling initiative. The evaluation finds that nine projects were announced as part of the Innovation Fund investments, however few First Nations respondents were aware of the Innovation Fund. When it comes to the school bundling initiative, despite not generating the cost-efficiencies as anticipated, the school bundling approach allowed for greater engagement and decision-making of First Nations communities in the design and build of their schools as compared to the non-bundled approach, which resulted in the integration of more community-focused and culturally relevant design elements into the school projects. The evaluation finds that the selection of communities in a bundle affected the outcomes of the project - the project with communities belonging to the same tribal council, sharing geographic similarities and located adjacent to each other reported less challenges in its implementation.

Crosscutting Findings

The evaluation of the Education Facilities program was conducted simultaneously with the evaluations of the On-Reserve Housing program and the Other Community Infrastructure and Activities program. These evaluations revealed that the infrastructure programs are sharing many similarities when it comes to the challenges being faced, from funding insufficiency, program design and delivery, capacity and staff turnover, to data and results measurement. Moreover, the findings point out the interlinkages among the programs that are integral to take into consideration in closing the infrastructure gaps on-reserve. More specifically, the asset-based approach through targeted investments and siloed programming, means communities with differing priorities are challenged to adequately plan ahead or address their needs. This resulted in loss of efficiencies and missed opportunities to better meet communities' infrastructure needs and achieve better health and safety.

Overview

• This Management Response and Action Plan was developed to address the recommendations presented in the Evaluation of the Education Facilities Program. It was developed by ISC-Regional Infrastructure Delivery Branch (RIDB) and ISC-Community Infrastructure Branch (CIB) in collaboration with the Evaluation Directorate.
• RIBD and CIB recognize the findings outlined in the evaluation regarding the performance and delivery of the Education Facilities Program.
• The Evaluation provides four recommendations to improve the delivery and effectiveness of the Education Facilities Program. All recommendations are accepted, and the attached Action Plan identifies specific activities to move towards meeting these recommendations. The Program would like to note that while it concurs with the recommendations related to funding in principle and continue to seek funding through the avenues available, funding decisions are beyond direct program control.

Assurance

• The Action Plan presents appropriate and realistic measures to address the evaluation's recommendations, as well as timelines for initiating and completing the actions. Over the next two years, the department will proceed with a phased response to analyse, develop and implement operational and policy improvements to the Education Facilities Program, in consideration of our departmental priorities and ongoing initiatives to modernize the delivery of on-reserve education facilities infrastructure programs and services.
• Many action items involve engagement with partners and relevant stakeholders, with changes to be implemented following these discussions. A status update on this Management Response and Action Plan will be conducted by the Evaluation Directorate regularly and presented to the Departmental Performance Measurement Evaluation Committee to monitor progress and activities.
• The phased approach recognizes program complexities and provides time to engage First Nations and other partners in a meaningful development process.

Capital Facilities and Maintenance Program

According to the 2016 CFMP Program Manual, the CFMP invests in the planning, design, construction, renovation, acquisition and operations and maintenance of community infrastructure that supports First Nations to build healthy, safe and prosperous communities and enables engagement in the economy. Through the CFMP, more than $2 billion per year is invested in four program areas, including housing, education facilities, water and wastewater systems, and other community infrastructure. Program activities are governed by the terms and conditions of the Contributions to support the construction and maintenance of community infrastructure Transfer Payment Program Authority.

ISC allocates funding for the construction and the maintenance of community infrastructure to First Nations at a regional level through formula, proposal-based project funding or as a combination of both. Formula-based funding includes operation and maintenance funding, formula-based minor capital funding, and housing funds. While proposal-based funding, including all targeted funds, covers acquisition, construction, renovation, or repair projects, whether they are major or minor projects.

Funded under three streams, i.e. operations and maintenance (O&M)^{Footnote 8}, minor capital (for projects under $1.5 million), and major capital (for projects over $1.5 million), the intended objectives of the CFMP are to make investments that:

• maximize the life cycle of physical assets;
• mitigate health and safety risks;
• ensure assets meet applicable codes and standards; and
• ensure assets are managed in a cost-effective and efficient manner.

Contributions to eligible recipients under the CFMP provide financial assistance to plan, construct and/or acquire and operate and maintain community capital facilities and services (infrastructure, including schools) and housing (residential) consistent with approved policies and standards. This assistance is provided to First Nations on-reserves, as well as First Nations and other eligible recipients on Crown land or recognized Indian land.

Education Facilities Program

The EF program falls under the Core Responsibility of "Governance and Community Development Services" in ISC's 2022-23 Departmental Results Framework and contributes to the Departmental Result of "Indigenous people have reliable and sustainable infrastructure."

Administered under the CFMP, the EF program funding is provided to First Nations on-reserve and First Nations and other eligible recipients on Crown land or recognized Indian land to:

• plan, design, construct/acquire, renovate, repair, replace, and operate and maintain federally or band-operated elementary and secondary education facilities (including teacherages^{Footnote 9} and student residences), and related facility services;^{Footnote 10}
• acquire, replace, and repair furniture, equipment, and furnishing for schools, teacherages and student residences;
• identify education facility needs and develop education facility plans; and
• design maintenance management practices.

From 2016-17 to 2020-21, ISC provided an average annual base (A-base) of approximately $131M (excluding O&M funding under Education and Social Development Programs and Partnerships Sector's authority since 2020). In addition to construction and renovation costs, Regions and First Nations can use these funds to support minor capital expenditures projects and capacity development. During the evaluated period, the EF program also received time-limited targeted (B-base) funding for educational facilities projects through Budget 2014 and Budget 2016 announcements for a total of approximately $1 billion over seven years:

• Budget 2014: $500 million over seven years (2015-16 to 2021-22) for the Education Infrastructure Fund;^{Footnote 11}
• Budget 2016: $969 million over five years (2016-17 to 2020-21) for the Enhanced Education Infrastructure Fund.

While these time-limited funds were used for new constructions, additions, renovations and major repairs to existing schools in First Nations communities, two initiatives were funded to explore innovative and cost-effective ways of delivery:

• The Innovation Fund: It was created in 2012 as part of the Education Infrastructure Fund.^{Footnote 12} ISC extended the Innovation Fund as part of Budget 2014 and Budget 2016 for a total of $50 million from 2016-17 to 2020-21 to build school facilities using innovative methods.
• School Bundles: School bundling is a specialized project classification that allows communities to combine school projects that spans multiple First Nations. As part of the Budget 2014 and Budget 2016 announcements, ISC was to deliver three school bundles projects:
  1. Manitoba Schools Initiative,
  2. Lake Winnipeg School Bundle, and
  3. Northwestern Ontario School Bundle.

Some A-Base funding allocated to education facilities can also be used to complement projects supported by targeted B-base funding. In addition, other infrastructure needed to support schools, such as road and sewer upgrades and teacherages, are typically funded through other ISC infrastructure programs (i.e. sewers are water and wastewater funding).^{Footnote 13}

Program Expenditure

The following table summarizes the EF program expenses (both A-base and B-base) over the evaluation period. Overall, the EF program spent approximately $1.88 billion over five years, which was split between seven regions and HQ. Across the regions, Manitoba spent $547 million followed by Ontario of $415 million and Alberta of $360 million. The lowest expenditure was in the Atlantic region of $63 million.

First Nations Infrastructure Investment Plan

As indicated on ISC's website^{Footnote 16}, the FNIIP is a planning tool to help ISC assess infrastructure needs and strategically plan infrastructure investments in First Nations communities across Canada. FNIIPs are how ISC manages CFMP funding and are developed in partnership with First Nations based on community-identified infrastructure needs, which covers all CFMP asset areas. The deadline for a First Nation to submit their infrastructure investment plan to a regional office is September 30 of each year. Investments are prioritized through the National Priority Ranking Framework (NPRF), a planning tool that helps direct funding to the highest priorities using a consistent and transparent process across all regions. Higher-ranked projects are placed in earlier years of the plan, while lower-ranked projects are placed in later years. The amount of money available to support projects identified in the FNIIP varies from year to year due to time-limited, targeted funding programs.

National Priority Ranking Framework

The prioritization of proposed projects is based on several factors covered under the NPRF, including:

• protection of health and safety as well as assets (assets require upgrading or replacement to meet appropriate standards);
• health and safety improvements (upgrades of existing assets, new construction/acquisition projects to mitigate an identified significant risk to health and safety);
• recapitalization/major maintenance (extend the useful operating life of a facility or asset, or maintain the original service level of the asset); and
• growth (anticipated community growth requiring new construction, expansion or procurement of assets to maintain the level of service standards).

School Priority Ranking Framework

In addition to the NPRF, the School Priority Ranking Framework (SPRF) is another tool used to guide education infrastructure investment decisions, which considers the following criteria:

• condition of existing facility (with a focus on health and safety);
• overcrowding;
• accessibility to off-reserve schools;
• design (grade distribution and amenities offered);
• cost-efficiency opportunities (external funding sources and aggregation);
• state of project readiness;
• cost-sharing opportunities;
• opportunities to achieve efficiencies; and
• innovative solutions and financing.

During the investment planning allocation of Budget 2014 and Budget 2016 for education facilities, the SPRF tool was used as a factor to prioritize both at the national and regional levels; however, it was not consistently applied across regions.

School Space Accommodation Standards

ISC's Space Accommodation Standards (SSAS) outlines the department's level of service standards for the construction and major renovation of First Nation schools on-reserve that may be funded by the department. The SSAS determines the total gross floor area allowance of a school for which funding may be provided by ISC. The SSAS does not determine which school is eligible for funding or which school will be funded. The SSAS complements the CFMP terms and conditions. In the event of a conflict between the SSAS and the CFMP terms and conditions, the CFMP terms and conditions shall prevail.

First Nations seeking a new educational facility (or major renovation or addition to an existing facility) are required to apply for funding through the FNIIP process, following the standard procedure for submitting proposals under the CFMP. If approved, funding will be provided on the basis of the Total Gross Floor Area allowance pursuant to the SSAS application methodology. First Nations desiring a facility that is larger than what is allowed by the SSAS may fund the additional cost of the project from own-source funding, from funding from a non-governmental third party, or from funding from another level of government. Applying the SSAS is a requirement for eligible school projects to move forward and obtain Departmental project approval and is a condition to obtain capital funding.

The SSAS has been updated over the years since the original document was developed in 1993. The latest SSAS took effect as of April 1, 2023, which supersedes the previous versions dated 2021, 2016, 2013 and 2000. The SSAS is an evergreen document. During the evaluated period, the 2016 version was being applied in funding education facilities projects.^{Footnote 17}

Crosscutting Issues with Other Infrastructure-related Evaluations

Two other evaluations were conducted during the same period as the EF program on other infrastructure-related programs under the CFMP (i.e. On-Reserve Housing program and the Other Community Infrastructure and Activities program), which were subject to the same authority and requirements under the CFMP and involved overlapping regional contacts and First Nations partners across the three programs.

To reflect the similarities, independencies and other crosscutting issues across the three programs in delivering infrastructure programs and services to First Nations communities, the Evaluation team assessed these crosscutting aspects that are applicable to all three evaluations in order to provide a more holistic view to inform ISC's infrastructure program and service delivery beyond a single program.

Finding #1: The EF program aligns with ISC and the Government of Canada priorities.

According to a report from the Canadian Council for Public-Private Partnerships entitled "Bridging the First Nations Infrastructure Gap", the infrastructure deficit for First Nations on-reserve alone was estimated at $30 billion in 2016. The deficit is due in part to the remoteness of some communities, a range of socio-economic challenges, outdated O&M policies, and decades of under-funding. In addition, current investments are not keeping pace with population growth, the rate of inflation, and the needs of First Nation communities.^{Footnote 20}

Activities under the EF program are aligned with the Government of Canada's priorities to address infrastructure gaps on-reserve. The Prime Minister's 2021 Mandate Letter to the Minister of Indigenous Services indicated:

"To achieve equity, you will continue to collaborate with Indigenous partners by working together to close socio-economic gaps and improve access to high-quality services. This includes continuing work to eliminate all remaining long-term drinking water advisories, and closing the infrastructure gap by 2030, with a focus on building sustainable and affordable housing."^{Footnote 21}

The EF program contributes to ISC's core responsibility of governance and community development services and contributes to the departmental result of "Indigenous people have reliable and sustainable infrastructure" and its mandate of improving the quality of services delivered to non-self-governing Indigenous communities. A 2022 letter from the Indigenous Services Minister announcing the 2022-23 Departmental Plan reaffirmed the alignment of the ORH program with the department's core mandate to:

"Improve access to high-quality services for First Nations, Inuit, and Métis, to support self-determination and Indigenous-led service delivery, and to address the fundamental issue of closing socio-economic gaps. We will deliberate and create strategies to better measure the gaps and report on them, so we can all show progress in our work and investments. We will remain focused on our urgent commitment to identifying and closing infrastructure gaps, clean drinking water, safe and affordable housing, health infrastructure, educational facilities. The absence of any of these […] hurts successive generations."^{Footnote 22}

Finding #2: Many First Nation schools are aging, overcrowding, and in need of replacement, which contributes to the gaps in providing education programming on-reserve. The standards specified in the 2016 SSAS did not address communities' educational needs in terms of school size.

Many interviewees indicated that their schools are at or beyond capacity, some before they had been completed, leading to the need for more schools or additions to existing facilities. Some communities are addressing overcrowding by employing other community infrastructure such as community halls as gymnasiums and classrooms. In one community studied, a school opened just two years ago designed for 450 students, it now hosts 570. One First Nation organization estimated that there were over 200 on-reserve schools across the country experiencing overcrowding and over 50 schools that needed replacement due to age and deterioration. Several First Nations reported having to transport students outside of their community, especially those in grade eight or higher because there is no room in their current school for these grades. These respondents indicated that students can be bused daily to schools up to 80km from their reserve; some remote communities must send their children to board in non-Indigenous communities to attend high school.

Interviewees from First Nation communities and organizations and several government staff also pointed to the need to host early childhood programs in schools, which are common among off-reserve schools but are not eligible for EF program funding, as they are beyond the current CFMP authority. Regional project officers work with FNIHB regional staff to fund Aboriginal Head Start On-Reserve (AHSOR) programs in new schools. Regional project officers work with FNIHB regional staff to fund AHSOR programs in new schools. Interviewees explained several reasons for children attending an off-reserve school by choice including, parents wanting to provide their children with educational opportunities not available at the on-reserve school; and parents pulling younger students from the reserve school once the eldest has reached a grade no longer offered on-reserve so that all their children can attend the same school. First Nations are concerned about the impact, stating the lack of early childhood education can hinder graduation rates and overall community-wellbeing.

Many First Nations interviewees mentioned their schools lack the space to provide their students with learning opportunities that students attending non-Indigenous schools can access, further limiting access to education and giving parents cause to consider sending their children to non-Indigenous schools. For example, many communities need space for teaching trades related skills such as mechanics, welding, hair and aesthetics, carpentry, culinary, science and computer labs, and performance spaces. An even greater need exists for space for language (immersion programs) and cultural programs, traditional activities, ceremonies, and elders.

Among survey respondents, 50% indicated that their community could not meet its education facilities needs (Figure 4.1).

Text alternative for Figure 4.1: Agreement with Current Community Needs

Figure 4.1 "Agreement with Current Community Needs" outlines the responses to the question "To what extent do you agree with the following statements about your community" from the "ISC Evaluation Survey 2022". For each statement, the survey offered the response options "Agree/Strongly Agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "The community has sufficient revenues to meet its overall infrastructure needs", 6% reported agree/strongly agree; 4% reported neither agree nor disagree; 84% reported disagree/strongly disagree; and 3% reported don't know.

For the statement "There is sufficient workforce exists within the community", 14% reported agree/strongly agree; 18% reported neither agree nor disagree; 66% reported disagree/strongly disagree; and 2% reported don't know.

For the statement "The community can meet its education facilities needs", 18% reported agree/strongly agree; 26% reported neither agree nor disagree; 50% reported disagree/strongly disagree; and 6% reported don't know.

For the statement "There is sufficient public infrastructure in the community to support new education facilities, 38% reported agree/strongly agree; 18% reported neither agree nor disagree; 40% reported disagree/strongly disagree; and 4% reported don't know.

For the statement "There is sufficient land to support new infrastructure build", 60% reported agree/strongly agree; 6% reported neither agree nor disagree; 32% reported disagree/strongly disagree; and 2% reported don't know.

For the statement "The community has the skills and experience to operate and maintain infrastructure projects", 60% reported agree/strongly agree; 8% reported neither agree nor disagree; 30% reported disagree/strongly disagree; and 1% reported don't know.

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements about your community? Respondents n=50.)

Some interviewees noted that, under the 2016 SASS, when a new school is approved, space for inclusion of students in higher grades was often not approved due to the low number of students in these grades. Many First Nation interviewees shared that the formula for determining school size does not account for expected growth, equipment storage, or special needs programming. Other First Nations noted that they cannot get funding to accommodate a larger school or include higher grades because they cannot include children attending an off-reserve school by choice in the funding formula to justify the school size needed.

The 2021 SSAS^{Footnote 23} made improvement to the 2016 SSAS to provide additional types of spaces and increased the size of existing space allocations to support education programming. It also gave First Nations more flexibility in determining the space distribution within the allocation, as compared to the previous SSAS, which was more prescriptive.^{Footnote 24} The 2021 SASS also required demographers to properly determine the enrolment projections at the fifth year of the school operation. However, many First Nation interviewees expressed that only schools built post the 2021 SSAS can take advantage of this extra space, as older schools are not automatically provided with the funding to retrofit their buildings in order to meet the current SSAS.

Finding #3: Teacherages are identified as a gap to be addressed as funding to build, repair and maintain teacherages is not always included in new builds and O&M budgets.

Many First Nations, especially northern and remote communities, rely on teacherages to attract and retain qualified non-Indigenous teaching staff, specialists and school administrators to deliver education programs on-reserve. While a few teacherages projects received targeted funding prior to 2019 through Budget 2014 and Budget 2016, teacherages were not funded as part of school projects in order to maximize the funding allocations through the two Budgets. The evaluators heard from First Nations interviewees that, during the evaluated period, it was difficult to obtain funding to build teacherages. Many indicated that the limited funding meant they often must choose between funding for a new school or addition and funding for new teacherages; the school is always the priority. Teacherages are also not considered as a top priority housing project as the need for housing for members of the community takes priority.

Some teacherages were decades old and in need of major repairs. A 2021 AFN study noted that the average construction year for teacherages on-reserve was 1996 and the average general condition rating was 6.3 out of 10 on the ACRS inspection.^{Footnote 25} According to 54% of survey respondents (Figure 5.1), they disagreed that the EF program responded to the needs of their communities in relation to teacherages. A First Nations Education Infrastructure Capital Needs Assessment conducted by the AFN estimated $1.57 billion capital costs over 20 years for teacherages as per the 2021 SSAS. A follow-up AFN study on First Nations Education Infrastructure O&M needs found that the annual O&M requirements for teacherages were approximately $68 million.^{Footnote 26}

Interviewees noted that the availability, proximity and condition of teacherages had limited their ability to hire professionals, and suggested that teacherages should be intertwined into school projects. Some First Nation communities use own-source revenues to construct and maintain teacherages. One respondent shared an innovative solution where their community applied for a grant to build a tiny home constructed by students for use as a teacherage, while the community provided the lot and connection to services.

Finding #4: First Nation communities have increasing needs for education facilities to better accommodate First Nations children with special needs and mental health issues, which requires special equipment, quiet rooms and space for specialists.

First Nation communities are often not able to meet the education facilities needs of diverse members of their community. Almost half (46%) of survey respondents indicated that the EF program did not adequately respond to diverse segments of the population in their community. Among these survey respondents, the most frequently mentioned groups were children with mental health challenges (87%), followed by children living with physical or intellectual disabilities (74%). Other groups mentioned included adult learners, and Elders and knowledge keepers (Figure 4.2).

Text alternative for Figure 4.2: Groups Not Supported by Education Facilities Program

Figure 4.2 illustrates the perceptions of First Nation survey respondents who disagreed or strongly disagreed regarding the adequacy of education facilities program in meeting the needs of diverse members within their community. Regarding children with mental health challenges, 87% disagree or strongly disagree. Regarding children living with physical or intellectual disabilities, 74% disagree or strongly disagree. Regarding Two-spirited, gay, lesbian, bisexual, transgender, queer, questioning community, 61% reported disagree or strongly disagree. Regarding girls, 35% reported disagree or strongly disagree. Regarding other, 39% reported disagree or strongly disagree.

ISC Evaluation Survey 2022 (Question: Which of the following groups is not being adequately served by the Education Facilities program? Asked of those who disagreed or strongly disagreed Education Facilities program serves diverse segments of the community's population. Multiple responses permitted. Respondents n=23.)

Although a majority (61%) of survey respondents indicated that the EF program did not serve the needs of the two-spirited, gay, lesbian, bisexual, transgender, queer, or questioning community members, some progress is being made here as a few First Nation and government interviewees indicated that some communities have adopted gender neutral bathrooms in their schools. Some First Nations noted that they were able to simply switch the signage on some bathrooms, while others indicated that they included gender neutral bathrooms as part of their new school design. During the evaluated period, schools built were required to have barrier-free designs under the 2016 SASS, many First Nation respondents noted that their older buildings required significant upgrades to make them accessible for those with physical limitations such as entrance ramps, automatic doors, wider door openings, and lifts to access upper levels.

The majority of First Nation communities have a significant proportion of students with special needs (i.e. autism spectrum disorder, trauma-type disorders, and prenatal alcohol) which increases the need for special equipment, quiet rooms, and space for specialists supporting these children. A 2021 AFN study estimates that 30% of all First Nations students on-reserve have special education needs.^{Footnote 27} Some interviewees indicated that finding space to support children with special needs was challenging, and they needed to operate without spaces such as gymnasiums, staff rooms, and offices in order to accommodate children with special needs. Several First Nation and AFN respondents stated that children with special needs, especially those with multiple special needs, are not adequately considered when determining space allocation.

As compared to the 2016 SASS, the 2021 SASS included additional spaces above standard allocation for counseling, elders office and other special needs spaces, and improved the approach in calculating special needs spaces, which helped address the gap and respond to the areas identified in the AFN study. However, it was raised by ISC staff that most schools could not update their schools to include these additional special needs spaces due to a lack of funding. The revised policy did not come with extra funding to retrofit existing schools – the policy was only applied to schools that were in the feasibility study or design stage. At the time of evaluation reporting, ISC respondents indicated that they were working with the AFN on phase two of SSAS policy revisions, which is expected to include more improved special needs space allocation along with environmentally friendly and climate resilient infrastructure.

Finding #5: Health and safety standards and climate change were identified as top needs to be better addressed by the EF program. While climate change is increasingly and negatively impacting community infrastructure, there is currently no centralized approach in planning and design taking into consideration infrastructure resiliency to address and mitigate these impacts on communities.

Health and safety standards were the most frequently mentioned needs not addressed by the EF program (64% of survey respondents), followed by climate change and resilience (54%), and environmental building standards (50%). Other mentions of needs not met by the program included annual upgrades to education facilities, accessibility for disabled individuals, and infrastructure to support school facilities (i.e. sidewalks, street lighting, fencing to protect from wild animals) (Figure 4.3).

Text alternative for Figure 4.3: Additional Needs Not Addressed by Education Facilities Program

Figure 4.3 illustrates the perceptions of First Nation survey respondents who disagreed or strongly disagreed regarding the education facilities program's ability to address additional community needs. Regarding health and safety standards, 64% reported disagree or strongly disagree. Regarding climate change and resilience, 54% reported disagree or strongly disagree. Regarding environmental building standards, 50% reported disagree or strongly disagree. Regarding other, 54% reported disagree or strongly disagree. And 7% reported, prefer not to say.

ISC Evaluation Survey 2022 (Question: Which of the following needs are not being addressed by the Education Facilities program? Asked of those who disagreed or strongly disagreed Education Facilities addressed community needs. Multiple responses permitted. Respondents n=28.)

Schools in many First Nations communities are not up to current standards and lack many of the amenities required for today's school environments such as secure and accessible entrances, proper heating, cooling, and ventilation. Several First Nations indicated their portable classrooms cannot withstand winter climates, have poor air circulation, and develop mould. Other First Nations noted that overcrowded schools led to more rapid deterioration and increased health and safety issues in the facilities, and these ultimately impacted learning.

Focus group participants noted that since taking possession of their new school, it has been plagued with defects resulting from poor construction including broken pipes in their in-floor heating system, faulty locking system, drinking fountains that do not work, leaking plumbing pipes that destroyed the camera security system, and rodent infestation, which led to health and safety risks. They stated that the ongoing faulty school infrastructure was having a negative impact on the learning environment and teacher retention.

Interviewees from the Environmental Public Health Division of FNIHB stated that the same public health issues remain over time in First Nations community infrastructure and yet they are not systematically addressed in the CFMP programs, including the EF program. They noted that the current project planning does not prioritize public health to preventatively address health and safety concerns which put the health of students and staff at risk. Further, ISC respondents indicated that while the EF program Logic Model (Appendix A) indicates that building more infrastructure increases health, it cannot be achieved if schools are not being built or retrofitted with consideration for impacts of the environment and the enforcement of standards.

Many older schools are more vulnerable to climate change and costly retrofits as they may have poor heating/cooling and ventilation systems meaning that students and teachers endure uncomfortable temperatures in their classrooms. Some buildings have leaking roofs and poor drainage that also make them vulnerable to flooding and extreme climate conditions. Climate change also impacts the busing of children as flooding washes out roads causing additional wear on vehicles, and winter road quality and length of use are decreased causing longer commutes.

Close to one-third (32%) of survey respondents indicated that harsh climate and/or catastrophic weather events had impacted their community to a great extent in recent years, with a further 36% saying it had somewhat impacted their community (Figure 4.4). Some of the climate related events that impact education infrastructure include floods, heatwaves, forest fires, and permafrost thaw. To support communities through these disasters there will be an increased need for schools to be climate resilient as many act as community hubs for cooling stations and evacuation centers.

First Nations interviewees noted that when planning new schools, they try to ensure that the buildings are being designed and constructed to withstand many of the impacts of climate change, such as using greener energy, improved ventilation, air conditioning and more resilient building materials. Although First Nations were signaling needs for backup generators and commercial kitchens etc. as part of new schools builds, the program does not have a centralized approach to address these requests. Current demands from First Nation communities for more climate resilient infrastructure are typically funded by gathering dollars from other programs.

Interviewees from the Environmental Public Health Division underlined the significant risks to health that climate change poses in remote communities without climate resilient infrastructure. Many government and First Nation respondents cited the need for climate projections and mapping for the next 40 years to better plan how infrastructure should be constructed to be more resilient to the impacts of climate change.

Finding #6: First Nation education facilities have not been sufficiently funded for many years. The expanded scope in education program created additional pressure on already limited education infrastructure funding.

Schools in First Nation communities have not been sufficiently funded for decades. A 2021 AFN study estimated the total capital needs for education infrastructure will be approximately $2.8 billion over the next 5 years, with a further $8.4 billion in the 15 years thereafter.^{Footnote 28} A follow up AFN study on First Nations education infrastructure O&M needs found an annual 32% to 64% gap in funding required to maintain schools (varies by region).^{Footnote 29}

As previously shown in Figure 4.1, the majority (84%) of survey respondents indicated that their community did not have sufficient revenues to meet its overall infrastructure needs, including education infrastructure. Among First Nation respondents who had been approved for funding to build a new school, many indicated that the funding did not cover all of the costs for the build that would meet their needs. Thus, they were often required to modify plans to fit within the funding formulas. This meant reducing the number of classrooms and eliminating space for staff offices and specialized programs such as a trades shop which increased their education infrastructure gaps as they had to continue the use of their old school in parallel to avoid overcrowding, which effectively doubled their O&M costs. Additionally, not being able to provide programming equivalent to that offered in non-Indigenous schools increased the education gaps for their students.

Further, education programming are consistently evolving and have expanded in scope. For example, in 2018 when full day kindergarten was implemented, the Education Program received a large funding allocation in Budget 2022. However, although education infrastructure is to support education programming, there was no additional funding allocated to education facilities to support the program expansion. Multiple ISC respondents stated that despite a large budget influx during the period under evaluation, there is still not enough EF program funding to address high priority health and safety issues in schools, let alone the other school facility needs in communities where they went beyond the mandate of the EF program as part of the CFMP, (i.e. supporting K-12). The cumulative impacts of Education Program expansion also impact the ability of the EF program to respond to First Nation needs over time.

Finding #7: Capacity continues to be a challenge, especially in smaller First Nations that struggle to plan and develop education infrastructure.

First Nation communities, particularly smaller ones, lack the capacity to plan, identify and develop their education facilities and infrastructure. Some communities do not make the best use of their FNIIP perhaps because there are higher priority needs within the community, or a lack of collaboration among those responsible for education infrastructure and those who update the FNIIP. While First Nation technical service organizations do assist communities with such tasks, they note that the community must reach out to them for assistance. Some community interviewees noted that with few staff to manage their education facilities, there is not time or resources for planning or developing projects.

Interviewees from all categories (communities, organizations and government) noted that many smaller First Nations are also at a disadvantage when having to compete for proposal-based projects as they often do not have the capacity within their community to create strong proposals and do not have the funds to hire external consultants to develop their proposals. These respondents mentioned the processes for funding infrastructure favors strong proposal writing over needs within communities; this perpetuates poor socioeconomic conditions for lower capacity communities. ISC staff noted that capacity development should be promoted as a higher priority funding area due to its essential role in communities. First Nation organizations also stated that to keep strong capacity in communities, staff must be paid with a competitive salary.

Finding #8: COVID-19 has not only posed additional challenges in implementing infrastructure projects and highlighted the lack of community infrastructure, but also exacerbated other existing challenges in relation to construction costs, skilled labor within the community.

Survey respondents detailed how the COVID-19 pandemic has impacted their communities with 58% indicating that COVID impacted their community to a great extent and a further 26% saying the pandemic somewhat impacted their communities. Both interviewees and survey respondents identified several impacts on education facilities experienced by their communities as a result of the COVID-19 pandemic, including:

• Limited or no space for social distancing for in-person learning due to overcrowded schools or undersized schools;
• Challenges with online or hybrid learning, given the slow and unreliable internet in some communities;
• Lack of proper ventilation in older schools;
• A need for additional physical materials (i.e. barriers, hygiene stations, masks) to help protect students and staff;
• Loss of economic opportunity for community members due to the need to separate them from non-community workers on construction sites (as a safety precaution many community members were not hired for these projects);
• Increased prevalence of behavioural and mental health issues among students;
• Increased stress and burnout among teachers and school staff; and
• Some communities used their schools as isolation centres which highlighted the need for emergency preparedness plans.

COVID also had a direct impact on the delivery of the EF program, including cost increase, project delays, and stoppage of work where communities were closed. Because of isolation requirements, some communities had to finance workers camps to ensure urgent projects were completed. Issues with supply chains impacted the availability of materials, which in turn increased their costs or use of poorer quality building materials. Project delays were caused by the availability of materials, the difficulty accessing manpower, and with the ability to access communities that were closed. Other respondents noted a reduction in the amount of collaboration between First Nations and ISC staff as they could no longer meet in person and poor connectivity in some First Nations limited their ability to meet virtually.

The increased costs of construction were a challenge indicated by 98% of survey respondents (across the three programs) with 86% indicating being impacted to a great extent and 12% being somewhat impacted. Another impactful community challenge was the shortage of skilled labor or experienced contractors within the community (38% of survey respondents indicated to a great extent and 38% indicated as somewhat impacted by the shortage) (Figure 4.4).

Many respondents noted that the pandemic highlighted the lack of community facilities. For example, many communities do not have hospitals and had to use schools and community centres to treat those with COVID and/or evacuate them to non-indigenous communities. Some noted that once they were back in school full-time, with many students returning to school with behavioral issues, teachers and school staff were not equipped to handle. This put added stress on staff and faculty already contending with crowded classrooms.

Text alternative for Figure 4.4: Extent Challenges Impact Community

Figure 4.4 "Extent Challenges Impact Community" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent does each of the following present challenges in your community?". For each statement, the survey offered the response options "To a great extent", "Somewhat", "Very little", "Not at all", and "Don't Know".

For the challenge "Increased construction costs", 82% reported to a great extent; 16% reported somewhat; and 2% reported don't know.

For the challenge "Collaboration with federal/provincial/territorial partners", 42% reported to a great extent; 36% reported somewhat; 14% reported very little; 6% reported not at all; and 2% reported don't know.

For the challenge "Availability of skilled labour or experienced contractors to operate in the community", 38% reported to a great extent; 38% reported somewhat; 22% reported very little; and 2% reported don't know.

For the challenge "Harsh climate and/or catastrophic weather events in recent years", 32% reported to a great extent; 36% reported somewhat; 20% reported very little; 10% not at all; and 2% reported don't know.

For the challenge "Remoteness of the community", 22% reported to a great extent; 38% reported somewhat; 22% reported very little; 16% reported not at all; and 2% reported don't know.

Lastly, in terms of "other" challenges impacting the community, 32% reported to a great extent; 12% reported somewhat; 2% reported very little; and 54% reported don't know.

ISC Evaluation Survey 2022 (Question: To what extent does each of the following present challenges in your community? Respondents n=50.)

Finding #9: The EF program delivered numerous schools and education facility projects and has helped address some infrastructure gaps in First Nation communities.

As per ISC reporting, since 2016, and as of December 2022, ISC has invested $1.73 billion in targeted funding towards 273 school facility projects on-reserves across Canada. Of these projects, 168 are complete. These investments are estimated to be benefiting 285 First Nation communities serving approximately 35,000 students and 325,000 community members.^{Footnote 30} More specifically:

• 77 projects resulting in the construction of 67 new schools;
• 151 projects resulting in renovations or upgrades to 137 existing schools;
• 12 supporting projects and initiatives toward capacity building; and
• 33 feasibility studies and design projects.

However, more than half (56%) of survey respondents disagreed that the EF program adequately responded to education infrastructure needs in their community as compared to 14% who agreed. Additionally, fewer than one-third (30%) of survey respondents agreed that overall the EF program helped address education infrastructure gaps in their community. When asked whether the program addressed the need of the various types of facilities within a school, most of them were deemed as not being sufficiently supported by the majority of the survey respondents, in particular in relation to space for knowledge keepers and other professionals, cafeterias in school, teacherages and recreational outdoor space. (See Figure 5.1 for details)

Text alternative for Figure 5.1: Extent EF Program Responds to Community Need

Figure 5.1 "Extent EF Program Responds to Community Needs" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent do you agree with the following statements? The Education Facilities program responds to the need in my community for…". For each statement, the survey offered the response options "Agree/Strongly Agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

Regarding the gymnasium, 38% reported agree/strongly agree; 22% reported neither agree nor disagree; 30% reported disagree/strongly disagree; and 10% reported don't know.

Regarding classrooms (including special education), 24% reported agree/strongly agree; 18% reported neither agree nor disagree; 46% reported disagree/strongly disagree; and 12% reported don't know.

Regarding administration space, 24% reported agree/strongly agree, 16% reported neither agree nor disagree; 50% reported disagree/strongly disagree; and 10% reported don't know.

Regarding cultural teaching space, 20% reported agree/strongly agree; 20% reported neither agree nor disagree; 48% reported disagree/strong disagree; and 12% reported don't know.

Regarding sports fields/courts and running track at school, 18% reported agree/strongly agree; 20% reported neither agree nor disagree; 52% reported disagree/strongly disagree; and 10% reported don't know.

Regarding recreational outdoor space at school, 16% reported agree/strongly agree; 20% reported neither agree nor disagree; 52% reported disagree/strongly disagree; and 12% reported don't know.

Regarding special purpose rooms, 16% reported agree/strongly agree; 20% reported neither agree nor disagree; 52% reported disagree/strongly disagree; and 12% reported don't know.

Regarding space for knowledge keepers and other professionals, 12% reported agree/strongly agree; 18% reported neither nor disagree; 58% reported disagree/strongly disagree; and 12% reported don't know.

Regarding cafeteria in school, 12% reported agree/strongly agree; 18% reported neither agree nor disagree; 58% disagree/strongly disagree; and 12% reported don't know.

Regarding teacherages, 10% reported agree/strongly agree; 24% reported neither agree nor disagree; 54% reported disagree/strongly disagree; and 12% reported don't know.

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements? Respondents n=50.)

Interviewees indicated that targeted funding of the EF program has helped to reduce education facility gaps by supporting the construction of new and bigger schools. However, the EF program funding was insufficient on its own; First Nation communities reduced their gaps by combining ISC funding, own-source revenues and other federal/provincial/municipal programs. A greater proportion of survey respondents disagreed that ISC supported their community to develop more reliable and sustainable education infrastructure in the past 5 years (38% compared to 28% who agreed).

With respect to the extent to which the EF program has supported First Nations communities, a greater proportion of survey respondents agreed that the EF program provided the information needed to allocate resources to manage education facilities (48% compared to 22% who disagreed) and helped to identify education facility needs (36% compared to 34% who disagreed). Comments provided by survey respondents about why they felt their community was not being supported centered on overcrowding issues and the lack of space, inadequate funding to support upgrades to increase accessibility for disabled individuals and infrastructure (i.e. sidewalks, street lighting, and fencing) to support school facilities, and the need for a school located on-reserve.

Finding #10: Despite the overall satisfaction for the EF program was moderate, many viewed the quality of the services offered by ISC as having improved over the past five years.

The overall satisfaction with the EF program as indicated by the survey was moderate, with 32% indicating they were dissatisfied and 30% indicating they were satisfied with the program. Reasons for satisfaction with the EF program included community partnerships with other First Nations to better improve education. Reasons for dissatisfaction with the EF program included: school facilities not having space to meet the needs of a growing population; no space or capacity to deliver the same programs as non-Indigenous schools; and wanting more control over the design and location of education facilities in their community. One First Nation organization stated that although education standards have changed and as First Nation populations continue to grow, the EF program has remained stagnant.

However, more survey respondents (approximately 44%) stated that the quality of the EF program's services offered at the community level had improved over the past five years, while 16% said the quality had stayed the same, and 24% noted it was worse than five years ago (Figure 5.2). Reasons for improved quality included: greater prioritization of educational facilities; improved funding for education facilities; and greater community control over the education facilities funding. Reasons for decreased quality included: the need for communities to supplement costs associated with education facilities; limited funding for education facilities; and the need for better data to support decisions around education facilities planning.

Text alternative for Figure 5.2: Improvement in the Quality of EF Program Over Past 5 Years

Figure 5.2 "Improvement in the Quality of EF Program Over Past 5 Years" outlines the responses to the ISC Evaluation Survey 2022 question "How has the quality of the Education Facilities services offered at the community level changed over the past five years or so, has it…". 4% reported as improved significantly; 40% reported improved somewhat; 16% reported stayed the same; 12% reported somewhat worse; 12% reported significantly worse; 12% reported don't know; and 4% prefer not to say.

ISC Evaluation Survey 2022 (Question: How has the quality of the Education Facilities services offered at the community level changed over the past five years or so, has it… Total may not add to 100% due to rounding. Respndents n=50.)

Finding #11: The current EF program funding model and allocation cycles limit the ability of First Nations communities to build education facilities. Predictable, sustainable and flexible funding is necessary to support more long-term and strategic planning.

The majority (58%) of survey respondents and virtually all interviewed indicated that the EF program funding was insufficient given that A-base funding has not been increased in decades and the program has been relying on time-limited B-base funds through budget announcements over the years, which was seen as a 'band-aid' solution that addressed the most urgent gaps but not predictable and sustainable. Both First Nation and government respondents stated that this funding model was constraining, and it did not allow for long-term planning. The majority of respondents supported committed, long-term, flexible funding so that communities can plan strategically, and many suggested the funding to be for twenty years or more to reflect the lifecycle of an infrastructure, otherwise it disincentivizes communities from developing strategic plans and realizing the maximum values for investments.

The AFN Special Chiefs Assembly resolution 12/2021 was regarding support for closing the infrastructure gap by 2030, which urged the federal government to commit to sustained long-term funding over the next five to fifteen years. Resolution # 18/2022 re-affirmed the need for long-term predictable funding and for the government to "transition the insufficient housing and infrastructure investment commitment timeframes of 5 to 10 years to long-term commitments of 25 to 30 years or more to provide on-going, predictable, and sustainable funding."

When being asked whether the funding approach is flexible enough to address community needs, 42% of the survey respondents disagreed (see Figure 5.3). Reasons provided by respondents included that: the funding approach needs to allow for greater flexibility and priority decision making on education infrastructure projects, no funding to build teacherages, lack of consideration for the growth of First Nations communities when planning for education infrastructure, and lack of support and funding for facility maintenance. Program documents revealed that during the evaluated period (2016-17 to 2020-21), annual prioritization took place at both the national and regional levels using both the NPRF and the SPRF; and a ranked national list of school projects was created to determine the number of projects to be funded within the targeted funds through Budget 2014 and Budget 2016. This approach limited the flexibility in the regions to better respond to infrastructure needs identified by First Nations.

At this time of evaluation reporting, documents indicated that the Budget 2021 allocation, which took place in February 2021, had adopted a formula-based national allocation approach based on number of students, number of schools, number of poor and fair rated schools (according to a shovel ready list), with a minimum amount per region to allocate a portion of the budget to each region with the intention to provide more flexibility.

Text alternative for Figure 5.3: Agreement with Funding for Education Facilities Program

Figure 5.3 "Agreement with Funding for Education Facilities Program" outlines the responses to the ISC Evaluation Survey 2022 question "The following questions are about ISC funding for the Education Facilities program. To what extent would you agree with the following statements?". For each statement, the survey offered the response options "Agree/Strongly Agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "The funding requirements are clear", 36% reported agree/strongly agree; 28% reported neither agree nor disagree; 36% reported disagree/strongly disagree; and 16% reported don't know.

For the statement "The funding is allocated in a timely manner", 30% reported agree/strongly agree; 28% reported neither agree nor disagree; 24% reported disagree/strongly disagree; and 16% reported don't know.

For the statement "The funding approval is enabling a whole-of-community approach", 20% reported agree/strongly agree; 34% reported neither agree nor disagree; 30% reported disagree/strongly disagree; and 16% reported don't know.

For the statement "The funding approach is flexible enough to address community needs", 10% reported agree/strongly agree; 34% reported neither agree nor disagree; 42% reported disagree/strongly disagree; and 14% reported don't know.

For the statement "The funding is sufficient", 6% reported agree/strongly agree; 20% reported neither agree nor disagree; 58% reported disagree/strongly disagree; and 16% reported don't know.

ISC Evaluation Survey 2022 (Question: The following questions are about ISC funding for the Education Facilities program. To what extent would you agree with the following statements? Respondents n=50.)

Funding Allocation Cycles

When being asked whether the funding allocation is timely to address community needs, 30% agreed as compared to 28% who disagreed (see Figure 5.3). Several interviewees noted that funding can be ill-timed in relation to their construction season causing delayed or postponed projects. Infrastructure projects are dependent on building seasons, which could vary among communities depending on their location. For example, communities that are easily accessible or located in southern regions of the country would prefer to receive funding in early spring so they can begin projects immediately. Northern communities require funding mid-winter so they can move materials using the ice roads and are prepared to begin construction when the ground thaws. This could help explain the split of opinions of survey respondents.

The current funding allocation aligned with the federal government's fiscal cycle, where annual funding approval and regional allocation take place towards end of March or early April, does not necessarily allow for optimal timelines for construction, and the impacts are most evident in remote communities. For other in-year approved projects, funding could arrive in the regions anytime during the year. ISC staff also indicated that for new Budget funds, funding could be allocated to regions later than March-April. Both internal and external interviewees noted that the timing of funding can be a challenge as funding could be allocated late in the construction season when communities receive their funds.

Related to the timing of funding are the timelines for spending the funds. First Nation respondents noted that they are required to spend their funding within a given period, usually within the fiscal year in which funding is received. However, project delays could happen and the fund cannot always be spent within the specified timelines. Communities must then request extensions to expand the timeline for spending the funds, which in turn can impact reporting timelines and can jeopardize future funding approvals if reporting is submitted late.

Finding #12: The current EF program funding process through FNIIP is effective for identifying projects, but not for funding them. The prioritization criteria being used in the FNIIP process do not sufficiently consider public health and environment-related standards and considerations.

First Nation respondents were divided as to the effectiveness of the FNIIP. Many indicated that the FNIIP was effective for identifying projects. Some First Nation respondents used the FNIIP five-year plan to guide their longer-term planning. However, many First Nation respondents indicated that their FNIIP was ineffective in getting projects funded. They likened the FNIIP to a 'wish list'. Some expressed frustration with having projects remain on the list for years that may never be funded. One respondent noted that they use the FNIIP solely as a planning tool and do not expect that a project listed on the FNIIP will get funded. Moreover, some First Nation respondents indicated that the FNIIP, while useful for new projects, was not effective for planning upgrades or repairs.

"First Nations do not really plan well beyond the first year because they don't have any indication that they will get funding the following year, so the best they can say is what I need next year without expecting it to be funded. That is the weakness of the FNIIP."

A June 2021 AFN position paper on education infrastructure investment process highlighted the extent to which projects identified and ranked through the allocation process received funding.^{Footnote 31} Using ISC data on 375 project funding requests from 2014 to 2020-21, the paper estimated that less than half (47%) of project funding requests resulted in a new school or major renovation by March 2022, with an additional 19% of projects having received funding for project planning such as for feasibility studies and/or design. Among the 34% of projects that did not receive funding, more than half (51%) were requests submitted before 2018-19. Program recipients also raised issues in relation to FNIIP prioritization criteria, justification and transparency around funding decisions. Some mentioned having to complete the FNIIP yearly but not receiving explanations from ISC for the reasons they did not get funding.

Many interviewees mentioned that with limited funding, the focus on 'urgent health and safety' associated with the deficiencies indicated through ACRS inspections in ranking projects left other projects unfunded for years only until the infrastructure became unsafe to be prioritized. With ACRS inspections focusing on repairs and maintenance work needed to preserve the infrastructure investments, public health related factors may not be equally considered. Also, environment-related standards and considerations, as well as impacts of climate change are not currently fully integrated in the current infrastructure planning process.

Access to environmental public health officers (EPHO) services to support service standards can mitigate risks for housing, water, wastewater systems and public buildings. EPHOs bridge infrastructure and health outcomes by promoting public health standards, and monitoring and preventing public health risks at all stages of infrastructure planning, design, construction and operation. For environment-related, consistent climate-informed infrastructure standards and mapping over the next 20 to 40 years to give indication of how infrastructure should be constructed to mitigate and adapt to climate change impacts are urgently needed, especially for remote communities where risks to health are more prominent.

"You need to provide the adequate support to protect investments, but also to protect the health and safety of communities so, for example, that the water treatment plants keep on producing water for the First Nations from a health perspective."

Respondents from external organizations noted that the FNIIP does not encourage First Nations to plan infrastructure beyond a few years, mainly because communities do not know what, if any, projects will get funding from year to year. Both internal and external respondents agreed that the FNIIP and the associated funding should span beyond five years, suggesting the duration be extended to twenty years or more. They stated that funding determined on a yearly basis (or even on a five-year basis) disincentivizes communities from developing strategic long-term plans to adequately support their investments. They noted that major infrastructure such as water treatment plants (which is comparable to schools) should last for up to 50 years and funding should be provided for the life cycle of the facility.

Finding #13: A number of issues were identified in accessing EF program funds through the proposal-based process in relation to application criteria, approval rationale, community capacity, access inequality, transparency and communications.

EF program funding requirements are not always clear to potential applicants. Equal proportions of survey respondents (36%) agreed as disagreed that the funding requirements were clear (Figure 5.2). However, the majority of First Nation interviewees indicated that the direction, policy advice and oversight of the EF program were not always clear or effective for program delivery to achieving expected results. Some First Nations noted that the coding, labeling and reporting requirements were not easy to understand, and the ISC website was hard to navigate.

Challenges in accessing education facility funds through the proposal-based approach included: complicated, time-consuming applications, re-submissions of proposals, and the withholding of funds due to incomplete or non-submission of reports. Many First Nation respondents expressed frustration with the lengthy and complicated approvals process, noting that it often required multiple revisions and resubmissions of their proposals even after they received notification that their project would be funded. Focus group participants indicated that the process for obtaining funding, design approval and construction of their new school took approximately seven years.

Some First Nation respondents noted that for them to prepare successful application proposals, having a clear understanding of all the steps needed to secure funding was crucial. To this end, one respondent indicated that, as a best practice, their First Nation Schools Association (B.C.) had worked with ISC to develop a tool kit to assist with the steps needed to fund a First Nation school. The Tool Kit for Building, Renovating and Expanding First Nation Schools was published in 2019.^{Footnote 32}

A few First Nation respondents experienced having funding withheld for incomplete or unsubmitted reports on previous projects. One respondent noted that it took several years for a report erroneously flagged as delinquent to be cleared. One organizational representative commented that communities struggling to complete reports should not be penalized by having funding withheld; instead, they should receive additional support to increase their capacity to adequately fulfill reporting requirements in a timely manner.

Interviewees noted that the application process was lengthy and complicated. Eligible funding required communities to meet specific and, in some cases, multiple layers of criteria. As a result, communities sometimes lacked the expertise to prepare successful proposals. Some indicated that the proposal-based approach is fundamentally inequitable as it creates a bias toward more organized, wealthier communities that can afford to pay consulting firms to develop proposals. Moreover, some First Nation reported that often the timeline to apply for funding was too short, making it more difficult for communities with limited capacity to access funding.

Both internal and external interviewees stated the need for greater transparency around how proposals are assessed and the rationale for when proposals are denied. Many First Nation communities desire more understanding around how funding decisions are made and how funding is distributed. Some First Nations suggested the government produce an annual report to show who received funding, the amount of funding received and what was funded. The report should also include a rationale for what was spent and, if applicable, why any allocated funds were not used. The AFN flagged transparency as a key issue.

"All First Nations have issues understanding how to access funds. At headquarters, they push First Nations to regional offices. First Nations always think they are in line for schools, but in reality, there is no actual list. ISC does not keep records or status of how First Nations are in line to access funds nationally. Transparency is [a] huge issue here."

First Nation respondents also suggested that ISC could do more to communicate information about available funding for infrastructure from the infrastructure related programs or initiatives. They noted that often when new funding is announced, there is little engagement with communities. For example, one First Nation respondent mentioned that previously field services officers gave workshops to First Nations and tribal councils to inform them about available funding for the upcoming year; now such valuable information is covered in one sentence on social media.

Finding #14: The amount for repairs and maintenance received through the EF program is not sufficient to mitigate health and safety concerns and to ensure education facilities achieve their full lifecycle. While the transfer of O&M funding stream from Regional Operations EF to ESDPP resulted in increased funding flexibility to First Nations through the Education Interim Regional Funding Formulas, it also created challenges in relation to governance and asset management of the EF program.

Through the CFMP, there are three funding streams, i.e.:

• O&M: Funding provided to First Nations for the maintenance and operation of existing assets (formula-based);
• Minor Capital: Funding provided to First Nations for construction, acquisition, renovation or minor repair projects with value below $1.5 million (can be both formular or proposal-based); and
• Major Capital: Funding provided to First Nations for specific, construction, acquisition, renovation or significant repairs projects with value exceeding $1.5 million (proposal-based).

Both the O&M and Minor Capital streams fund the repair and maintenance projects and activities needed to mitigate the most urgent health and safety risks and help ensure existing and new education facilities achieve their full lifecycles. First Nation respondents indicate that the funding cannot cover their backlogs of repairs, especially major repairs. The majority of First Nation respondents commented that their funding for repair and maintenance was inadequate and it impacted their ability to effectively maintain their infrastructure leading to further deterioration. A lack of regular maintenance due to the backlogs, compounded by worsened weather conditions and lesser quality of materials, resulted in the lifespans of community infrastructure shorter than elsewhere in Canada.

Further, due to limited infrastructure funding, some communities (especially those with less resources) used formula-based operation and maintenance funds to build or renovate community infrastructure, which further contributes to the lack of repairs for education facilities. Many interviewees shared that First Nations that have the capacity and are wealthier put money aside to do the maintenance and complete repairs, but those with less capacity, experience, and money use the totality of their funding to build or renovate those in need. Some ISC respondents cautioned that using a population-based formula creates an unfair disadvantage for smaller communities as the costs to maintain some infrastructure can be the same as for larger communities.

The transfer of the EF program O&M component to ESDPP in 2019 as part of the Education Transformation process was intended to increase First Nations control over First Nations education.^{Footnote 33} As a result of the transfer, the O&M component was imbedded within the Education Interim Regional Funding Formulas, which led to funding provisions being more in line with the respective province As per ISC reporting, education funding for First Nations has increased by approximately 80% for education program funding to First Nations since 2015-16. Also, through transformative mechanisms such as the Regional Education Agreements (REAs), First Nations have the flexibility to identify more specific needs-based funding such as the need for more O&M funding given their specific circumstances.

However, input from the ISC interviewees indicated that this change limited the extent to which education facilities could maintain health and safety standards. Having O&M as part of a school's education programming budget does not allow for a clear understanding of the annual maintenance O&M funding as the amount is not specifically identified. This makes it difficult for community education infrastructure managers to track the amount of O&M funding available and to plan for repairs from the asset management perspective. In addition, the inclusion of O&M in the education programming allocation means it can be reallocated away from its intended purpose to other needs such as teacher salaries or other needs related to educational programs. A lack of regular maintenance could lead to faster deterioration and earlier re-investments to repair the damage.

While ISC respondents indicated that it was too early to assess the full impacts of including O&M funding as part of educational programming, several expressed concerns related to this program change and suggested that the education facility maintenance gaps increased over the evaluation period due in part to the transfer of EF program O&M to the ESDPP. These respondents noted that O&M was already not sufficiently funded, and this change could lead to further strain of O&M funding should First Nations divert these funds to other educational needs. ISC regional office interviewees also shared several limitations in the new O&M approach, including the absence of consideration for First Nation capacity development needed for O&M in the new formula allocation; the potential to discourage First Nations from implementing the best practice of lifecycle management as the O&M funding is separated from capital; and the need to consistently support ESDPP to carry out its responsibility as education programming does not require infrastructure engineering technical expertise.

Moreover, during the evaluation conduct, the Evaluation team also observed governance issues between EF and ESDPP as a result of the transfer of the O&M stream, which included unclarity in funding coverage and differing understanding on the O&M component in relation to asset management planning.

Finding #15: COVID-19 related funding was viewed as timely and effective in helping communities in addressing the unprecedented situation.

The majority (61%) of First Nation survey respondents involved with the EF program were satisfied with the COVID-19 funding they received and acknowledged that receiving COVID related funding was timely and helpful as it allowed those responsible to better respond to the impacts of COVID in their community. First Nation communities were helped by the federal government as they: planned for a safe return to school and upgraded ventilation systems (including fogging machines for buses and classrooms). First Nation communities employed these funds to hire additional staff to screen for COVID symptoms and to sanitize classrooms, and provide hand sanitizers, masks, and plexiglass barriers. Other communities used the funding to develop protocols for addressing COVID issues at schools and to provide safety guidelines. The implementation and guidelines for spending COVID related funding were generally viewed as clear to most recipients.

Finding #16: In reporting on the achievement of the program, performance data is mostly at the output level. Alternative performance measurement approaches were proposed to measure the success of the infrastructure investment on-reserve more effectively by integrating a wellbeing or human rights centered lens.

Currently, the EF program reports on results using data such as the number of schools built and amount of funds spent. While these data are useful in demonstrating the scale of investments and implementation efforts, they are not fully corresponding to what communities and partners view as the most appropriate way of measuring success in relation to education facility outcomes and closing the infrastructure gaps on-reserve. Moreover, reporting on the number of units built at the output level does not demonstrate to what extent the program has achieved its outcome of providing sustainable education infrastructure that meets health and safety standards.

The evaluators also observed the lack of baseline data and clear targets for measuring performance of the EF program. Not all the outcomes had defined indicators in the program's Performance Information Profile approved in 2018, and not all indicators had been tracked. Canada's first Federal Housing Advocate, Marie-Josée Houle, suggested during the 2022 First Nations Housing Forum to go beyond the numbers of units built and apply a human rights centered approach, which values participation, non-discrimination, equity, transparency, empowerment and respect for human rights and obligations. Similarly, the Institute of Fiscal Studies and Democracy (IFSD) has proposed implementing a wellbeing centered housing and infrastructure performance measurement framework by assessing service level performance. According to the IFSD, applying the well-being lens to infrastructure helps transform the First Nations infrastructure investment narrative from focusing on fixing legacy issues to a holistic system-wide approach on-reserve.

Finding #17: Data availability and reliability remain as issues in project tracking, reporting and capturing asset conditions.

Data availability and sufficiency were identified as an issue by both internal and external respondents. Many interviewees, both internal and external, noted that the actual extent of infrastructure gaps was unknown or under reported due in part to lack of available data on the condition and needs of First Nations infrastructure. Some indicated that the ICMS does not capture sufficient data on infrastructure projects. Others noted that the ACRS was not up to date to capture the current condition of infrastructure assets for many FNs communities.

ISC respondents indicated that historically poor data on school infrastructure and its condition hindered the delivery of the program. During the evaluated period, the EF program conducted an exercise in the ICMS to validate the list of existing school buildings to eliminate duplications and as a result, a more accurate set of baseline data was created in 2020-21 and the initial count of approximately 600 schools was confirmed to be around 400. Several ISC respondents noted that the asset condition rating collected for education facilities in the ACRS was not of high quality, as the inspections conducted are superficial and cursory in nature and the estimated scale of work is not as accurate when compared with project estimates. While the ACRS is intended to assess a community's infrastructure, many noted that the system does not provide helpful information in determining the true costs of maintenance. Several First Nation respondents called for the federal government to conduct a detailed assessment of all First Nation education facilities to determine actual cost gaps.

Consistency was raised as a concern in relation to data entry into the ICMS and interpretation of the various fields in the ICMS among users. As projects are self-reported by First Nations, regions must enter the data they receive from First Nations into the ICMS. While regional officers make every effort to ensure accuracy when entering project information into the ICMS, their interpretations of certain fields and requirements may vary, as there is not a set of specified definitions associated with these fields. This created inconsistency in data entered not just among regions but also users in the same region, which resulted in discrepancy on project data and unreliability in reporting. Moreover, regional practices vary on what to enter into the ICMS, with some entering only funded projects into the ICMS, others entering all project proposals. Further, during the evaluated period, limitations existed on verifying the accuracy of the data entered into the ICMS. While data review takes place at the national level on a quarterly basis, data entry and verification mostly took place at the regional level. Finally, regions indicated the challenge of obtaining data from First Nations in the first place, which could be delayed by one to three years in some regions and the received data could be missing or incomplete.

During the evaluation data collection, the evaluators learned that some features were not available in the ICMS for tracking projects to certain causes. For example, impacts of projects in strengthening resilience to the effects of climate change could not be measured due to a lack of tagging ability for projects. Also, ISC staff noted the extent to which A-base funding contributes to the achievement of intended program outcomes could not be sufficiently measured as there was no performance information related to A-base funding. There was also deficiency in linking the financial system and the ICMS, the example of which was provided under section 3.3 Challenges and Limitations of this report.

First Nation respondents expressed their desire that ISC streamline the reporting processes. For example, using an online system whereby new data can be entered or updated and feed into the reports would help ease the reporting burden for First Nations.

Finding #18: The EF program provided employment and training opportunities, increased on-reserve enrolment and academic success, positive impacts on the wellbeing of community members, especially children, and increased community pride.

First National communities have experienced additional benefits as a result of the EF program. Generally, a greater proportion of survey respondents agreed than disagreed that the EF program had positive social and economic impacts on their community, including contributing to the wellbeing of their community, improving children's health and wellbeing, opportunities for their community to provide input on how the program is delivered, increased community capacity to manage education facilities projects and program, and contributing to economic development of their community. (Figure 5.4).

Text alternative for Figure 5.4: Agreement with Social and Economic Impacts of EF Program on Community

Figure 5.4 "Agreement with Social and Economic Impacts of EF Program on Community" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent do you agree with the following statements?". The response options for this question are "Agree/strongly agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "Contributes to the wellbeing of my community", 54% reported agree/strongly agree; 16% reported neither agree nor disagree; 18% reported disagree/strongly disagree; and 12% reported don't know.

For the statement "Improves children's health and wellbeing in my community", 52% reported agree/strongly agree; 16% reported neither agree nor disagree; 20% reported disagree/strongly disagree; and 12% reported don't know.

For the statement "Allowed opportunities for my community to provide input on how the program is delivered", 48% reported agree/strongly agree; 16% reported neither agree nor disagree; 22% reported disagree/strongly disagree; and 14% reported don't know.

For the statement "Increased my community's capacity to manage education facilities projects and program", 44% reported agree/strongly agree; 26% reported neither agree nor disagree; 20% reported disagree/strongly disagree; and 10% reported don't know.

For the statement "Contributes to economic development of my community", 40% reported agree/strongly agree; 20% reported neither agree nor disagree; 26% reported disagree/strongly disagree; and 14% reported don't know.

For the statement "Results in reliable and sustainable education infrastructure in my community", 20% reported agree/strongly agree; 24% reported neither agree nor disagree; 22% reported disagree/strongly disagree; and 14% reported don't know.

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements? The Education Facilities program: Respondents n=50.)

First Nation and ISC respondents indicated that the EF program has contributed to increased employment opportunities for community members through the construction of new schools (i.e. contractors, trades and labourers) and with school support staff. Respondents in First Nation communities close to larger non-Indigenous communities also indicated that building schools in their communities increased the number of students enrolled in their schools as students have the option to stay on-reserve to receive their education rather than attending a non-Indigenous school.

A greater proportion of survey respondents agreed the EF program and services had increased academic success over the past five years (38% agreed compared to 24% who disagreed and 24% who held a neutral position). Reasons for agreement with the EF program's contribution to academic success included having space to accommodate all their children on-reserve and providing their children with a quality education based on their culture, language and values. Reasons for disagreement with the EF program's contribution to academic success included the negative impact of overcrowded school facilities on learning, lack of proper ventilation, heating/cooling issues, and increased mental health issues and learning challenges among the children.

Another positive outcome is the increased pride community members have when new construction and upgrades are done in their community schools. First Nation respondents stated that having new schools in their community increased community pride not only because of having a new school but also because the new facility leads to fewer students dropping out of school and the potential for more students pursuing postsecondary education. Focus group participants also stated that teachers and students exhibited a sense of pride in their new school.

"We still have issues but there is a big difference. It gives us all, teachers and kids alike, a sense of pride to have a new school. It lets the kids know that they deserve to be in a school that works."

Finding #19: Despite positive social and economic impacts of the EF program, communities struggled to maintain health and safety standards in schools, which exacerbated health issues of students and school staff.

Many First Nation communities interviewed have experienced a number of health and safety issues that negatively impacted their students and school staff, including poor heating and ventilation systems that exacerbated health issues such as respiratory illnesses, broken and damaged equipment were safety hazards, and learning being impacted when classrooms have to relocate while repairs were being made as students become easily distracted and disengaged when they are not in their usual learning environment. In addition, many First Nations have a large portion of their students with behavioural issues and do not cope well with disruptions to their school environment.

Despite the reports of positive social and economic impacts of the EF program on First Nation communities, a slightly greater proportion of survey respondents disagreed that the program resulted in reliable and sustainable education infrastructure in their community (22% vs. 20% who agreed) (Figure 5.3). Reasons for disagreement with reliable and sustainable education infrastructure included requests for additional funding so the community can address health and safety issues within their educational facilities and the need for a school located on-reserve.

Another unintended outcome cited by some First Nation communities and organizations was the challenges of teacher retention. While teacher retention is not an EF mandate, the building of teacherages where required, contributes to the success of the retention among other reasons that are beyond the control of the EF program such as teacher salaries, etc. Approximately 30% of survey respondents disagreed that the EF program and services had increased teacher retention over the past five years, compared with 28% saying they agreed and 28% that neither agreed nor disagreed. Reasons for disagreement in relation to the EF program included: lack of funding to build and maintain teacherages that would help attract teachers.

Finding #20: The asset-focused and project-based approach in delivering the EF program without systemic integration with other asset areas under the CFMP has not only resulted in more administrative burdens on First Nations in seeking infrastructure funding but also lost opportunities to support First Nations with the capacity to address the needs and priorities identified by their own communities from a whole-of-community lens.

During the evaluated period (i.e. 2016-17 to 2020-21), while the planning for EF projects was community-driven in principle stemming from the FNIIPs developed by the communities, the approach in prioritizing and approving EF projects was mostly by CFMP asset area. More specifically, for Budget 2014 and Budget 2016, a ranked national list of school projects was used based on the NPRF, the SPRF, and other criteria to determine the number of projects to be funded within the targeted funds and consequently which projects got funded in each region. For Budget 2021 funding allocation (which took place in February 2021), a formula-based regional allocation format specific for the EF program was used, which allowed the regions greater flexibility to prioritize and manage school projects in their regions. However, regardless of the approach, the regions must work within the national asset-based funding allocation frameworks (including EF), which can vary across the CFMP asset areas in terms of funding formulars and allocation processes.

Moreover, how regions prioritize and allocate their funding from budget allocations to First Nations also vary, where some use the SPRF as a tool, others focus on health and safety and protection of assets. Other considerations that regions consider in prioritizing include contractual obligations and other commitments. Given these complexities, while the regions make every effort to coordinate across the different asset areas and timing of projects to be more community-centered, it may not always to be possible to perfectly coordinate and synchronize projects across different CFMP assets, including off-site and supporting infrastructure,^{Footnote 34} such as upgrades to roads, water, sewer, fencing and fire sprinkler systems, etc. to ensure an asset could be used immediately in a safe and effective manner. This is a limitation as a result of the current CFMP program design and authority.

Moreover, the project and proposal-based approach means that the administrative burdens are on First Nations to request for funding for projects under various sub-assets which were not guaranteed to be approved at the same time. The organization of infrastructure funding in asset silos also makes it difficult to align all of the processes and deadlines in a way that serves First Nations well by allowing them to coordinate funding from multiple programs and make more efficient use of funding. Many First Nation and government interviewees agreed that infrastructure siloes should be broken down to support logical and holistic community infrastructure planning. Such an approach would lead to better outcomes for all community infrastructure programs including the EF program and realize greater cost efficiencies in the long term. However, it should be noted that some First Nations may still be developing the capacity to support a whole-of community lens. Until all First Nations have this capacity, equity in supporting projects based on health and safety priorities is accomplished through the current asset-based approach.

A universal sentiment expressed was that all community infrastructure assets are interrelated. For example, off-site infrastructure (such as lighting, roads and sidewalks) is needed to support schools, and for many communities, the school is the hub of their community acting as a gathering place for ceremonies and celebrations, and sheltering stations during climate events and emergencies. Several First Nations indicated that their long-term strategic plans look at the community as a whole, highlighting ways to integrate the development of education infrastructure with other community assets such as recreation facilities and community spaces.

Finding #21: In addition to other CFMP programs, the delivery of the EF program also requires effective collaboration with other sectors within ISC, which could be further aligned for better efficiency.

While there is some collaboration with the ESDPP as the O&M component is now part of the education programming budget, many internal interviewees stated that this has created a disconnect between education infrastructure and education programming due to the fact that the two functions are housed in different sectors. Concerns were raised regarding the level of expertise in the EF and educational programs, indicating that the EF program could benefit from integrating more education expertise to support evolving education programs, and vice versa for education program to integrate more infrastructure expertise. First Nation respondents called for better integration of education programming with education facility planning to better align the space needed in schools to accommodate education programs and ensure sufficient O&M to increase the lifecycle of schools, which could lead to more efficient use of EF program funds.

Similarly, the split of the CIB as policy lead and the RIDB as implementation lead within the Regional Operations sector in delivering the program also raised issues in terms of efficiencies. Despite the initial intention to have a clear division of the policy and implementation functions, the two functions were mixed under both branches and the four CFMP asset areas were split between the two, with RIDB mostly for EF and OCI and CIB mostly for water and housing. However, in the case of the EF program, while RIDB is responsible for program delivery, CIB is responsible for the SSAS updates. Also, while RIDB is responsible for investment planning and funding allocation, CIB is responsible for the coordination of the process. Some ISC staff raised efficiency issues in these divisions.

In addition to infrastructure-related outcomes, education infrastructure also has cross-over impacts on health and social outcomes, as well as general community well-being. As noted previously in the Relevance Section of this report, the current EF program does not prioritize public health to preventatively address public health-related health and safety concerns. Many ISC interviewees suggested that integrating public health into education facility planning would make the EF program and overall health spending more efficient. For example, funding environmental public health officers through the EF program would realize better health and safety outcomes. Further, co-developing more appropriate health indicators with First Nations could better support education facility planning and project ranking.

Finding #22: Cost-efficiencies in the EF program were not fully achieved as a result of insufficient maintenance and repair, and that project approval decisions tend to opt for the lower-costs options rather than based on long-term asset management planning.

The importance of asset management was raised by many respondents, as it is crucial in assessing the condition of infrastructure assets, estimating costs for repairs and upgrades, and accommodating community growth to facilitate planning to extend the lifespan and value of infrastructure. Both First Nation and ISC respondents agreed that having a fully developed asset management plan allows them to outline what is needed to manage the asset, including the required funds for human resources to operate and maintain community assets, and the adequate support to protect investments and uphold the health and safety of community assets.

Asset management is also tied to long-term capital planning as it takes into consideration lifecycle maintenance costs and timelines. Some First Nation respondents reported being informed that funding for a new facility was ten or more years away even though the cost of a new school was less than the costs to repair and maintain their old school over that same period of time. First Nation respondents stated that rather than trying to realize cost savings in building and maintaining educational facilities in the short term, ISC should be looking to increase their investment as a cost benefit over the long term. These respondents suggested that in order to promote long-term cost effectiveness, a lifecycle approach to infrastructure funding would be superior and would better address the education infrastructure gaps on-reserve.

Some First Nation respondents commented that while they try to find less expensive materials and cheaper energy sources for construction (i.e. oil-fired furnaces), these workarounds often result in added costs for maintenance and repairs. Again, other First Nation respondents pointed to outdated allocation formulas that do not reflect the rising costs of materials, delivery fees, and inflation. They noted that the outdated formulas mean the funding does not cover the actual costs to build the facilities, forcing communities to build less expensive infrastructure that is often unsuitable for the environment.

Many First Nation respondents pointed to the need for up-to-date databases that would help develop asset management plans. While ACRS provides information on the condition of infrastructure assets, it requires an inspection by a certified ACRS inspector every three years. Many FNs do not have such a professional and must contract this work to an external consultant. As such, many First Nation respondents called for funding to train community members to complete these inspections. Respondents say that having this expertise in-house would be a more efficient use of EF program funds and would help First Nations prepare for service transfer.

Finding #23: There is a lack of a cohesive approach towards capacity building for asset management in the communities, which inhibits the efficiency in delivering education facilities outcomes. The pilot Circuit Rider Training Initiative of the EF program was seen as beneficial for operation and maintaining education facilities.

Many First Nation respondents cited the lack of trained staff as the main reason inhibiting the reform of their community infrastructure programs and in turn making their programs less efficient or cost-effective. They noted that the lack of repair crews, project managers and support staff to help administer community infrastructure meant they were less focused on efficiency as they were struggling to manage assets. Many communities relied on costly external consultants for support in preparing proposals, reports, and needs assessments, and in hiring inspectors to ensure buildings and assets met construction standards.

As noted previously in the Relevance Section of this report, professional training and capacity development remains a gap in the EF program. First Nations desire the internal capacity and resources to adequately plan for education infrastructure as part of strategically developing all community infrastructure. This includes the expertise to assess and manage educational infrastructure assets and lifecycle planning, and for succession planning to ensure best practices are carried forward to future program managers. First Nation and ISC respondents indicated that the EF program could better support communities to develop their capacity and implement asset management programming long-term across all assets, including schools.

As part of Budget 2014, the EF program received funding through the Education Infrastructure Fund to be allocated for the First Nation Circuit Rider Training Program (CRTP) for schools to address the challenge of early rust-out of school infrastructure on-reserve by enhancing First Nations capacity through the creation of a training and education program, based on the success of the CRTP for water and wastewater, to support operations and maintenance activities in school. A pilot Circuit Rider Training Initiative took place in 2019-20, where regions received funding ranging from $150K to $900K. Although this was not a full implementation and that regional experiences varied, among the interviewees who could speak to the Initiative, many found it to be valuable as their circuit rider was the 'go-to' person for all of the facility operators in their community and they relied on this person to help troubleshoot issues with operating systems, including those in their schools. They pointed to the Initiative as part of capacity development and a key support for operating and maintaining school and community infrastructure. They suggested that the Circuit Rider Training Initiative should be considered foundational to overall EF program success. A few ISC respondents noted that the pilot Circuit Rider Training Initiative program has not had the same success as the CRTP implemented under the Water and Wastewater Program due to low in-take in some regions and communities because of the short duration of funds.

Finding #24: High turnover of staff across infrastructure programs, both ISC and First Nations' sides, results in inefficiencies due to loss of capacity and additional efforts by First Nations.

First Nations community and organization respondents observed that the high turnover of both FNs and ISC staff (both national and regional) has hindered their ability to deliver their infrastructure programs. The high turnover of FNs staff due to burnout or staff taking on positions outside of the community means that communities must invest additional effort and funding to train new staff. The turnover also results in less efficient management of infrastructure as there are fewer staff to complete infrastructure maintenance leading to further deterioration. ISC staff turnover impacts First Nation communities as knowledge and lessons learned are not always transferred to new staff. Several First Nation respondents indicated that the time spent developing relationships with ISC staff and helping them to understand their community's infrastructure situation and unique needs is lost when the ISC staff leave, and they must anew with other ISC staff.

The high turn-over of ISC staff in infrastructure programs was raised by many First Nations respondents, which was viewed as an inefficient management practice of infrastructure programs as there was no sufficient knowledge transfer following the departure of staff. Based on an assessment of the staffing numbers across the three programs (including both NRC and Regions),^{Footnote 35} the data reviews that there has been a total of 829 counts of turnovers, including both new hires and departures from 2016-17 to 2020-21 (Table 6.1).

Finding #25: Some noted that the EF program was cost-effective as many First Nations identified education infrastructure costs borne by their communities that could be considered by ISC to include in the program.

Some costs that are directly tied to building and maintaining education infrastructure are not eligible under the EF program. As a result, First Nations communities need to share those costs in order to access the EF program funding, which means the communities without the financial resources are often unable to effectively leverage the funding. A total of 42% of survey (Figure 6.1) respondents indicated there were education facility related costs borne by their community that were not covered by the EF program but could be considered by ISC to include.

Text alternative for Figure 6.1: Education Facility Related Costs Borne by Community and Not Covered by Education Facilities Program

Figure 6.1 illustrates the perception of First Nation respondents regarding education facility related costs borne by their communities that could be considered by ISC to include in the Education Facilities program. 42% reported yes; 8% reported no; and 50% reported don't know.

ISC Evaluation Survey 2022 (Question: Are there education facility related costs borne by your community that are not covered by the Education Facilities program but could be considered by Indigenous Services Canada to include? Total may not add to 100% due to rounding. Respondents n=50.)

Some examples^{Footnote 36} of the costs borne by communities (during the evaluated period) included:

• space/facilities for adult upgrading, trades training and employment programs;
• space/facilities for land-based teachings and projects;
• space for elders and knowledge keepers; and
• fencing and landscaping school facilities.

Focus group participants spoke of the additional costs they incurred to repair their newly built school. One participant noted that not all repairs needed were covered by warranties as many of the warranties had expired due to lengthy construction delays and their O&M budget of $15,000 per year did not cover the needed repairs to their new school. Another focus group participant indicated that much of their time was spent pursuing other funding sources to bridge the funding gaps not covered by the EF program at a given time. For example, they received non-ISC funding for playground equipment and a washer and dryer for the school. Another participant received funding from Jordan's Principle to hire an aide to support a student who is non-verbal and has behavioral episodes.

Some First Nation respondents noted that for some projects they are reimbursed by ISC at a later date; however, fees to borrow the money are not recovered. Better timing of funding would allow communities to avoid construction delays and related cost increases.

"It can take as few as a couple of months to a few years to receive ISC funding for a project. In order to keep the project moving forward, some First Nations will pay from their own source funding and when the ISC funds come through, they will repay the funds borrowed/used from the other source."

When First Nations interviewees were asked whether they thoughts the delivery of the EF program was cost-effective, some provided comments on how the EF program could be more efficient in their view, including:

• Less restrictive policies such as the 2016 SSAS and program so communities can plan and build for growth over time so new schools are not overcrowded as soon as they are built;
• Support to build in-house expertise to develop strong proposals and reduce the reliance on external consultants;
• Conduct annual reviews or audits of educational facility assets to better plan for O&M costs; and
• Support for asset management capacity development to develop cost-effective solutions and maximize the lifecycle of schools.

Finally, some First Nations interviewees stated that the EF program needs to better promote self-determination of communities. First Nations control of their education is supported by the United Nations Declaration on the Rights of Indigenous Peoples and has been a longstanding priority of First Nations across Canada. To respect the sovereignty of each community, First Nations children should have the option to be educated in their community.

Innovation Fund

As noted in Section 2 (Program Context and Description) of this report, the Innovation Fund provides funding to build school facilities using innovative methods. A project can receive up to $10 million depending on the kind of innovation used such as cost-sharing, or alternative models for financing, procurement, construction, education reform or cost savings. Budget 2014 invested $50 million over six years beginning in 2016-2017 in the Innovation Fund. A maximum investment of $10 million per education facility project was available for infrastructure costs.

Nine projects were announced as part of the Innovation Fund investments:

• Squiala First Nation (British Columbia);
• Old Massett Village Council First Nation (British Columbia);
• Westbank First Nation (British Columbia);
• Adams Lake Indian Band (British Columbia);
• Blood Tribe/Kainai (Alberta);
• Meadow Lake Tribal Council (Saskatchewan);
• Fisher River First Nation (Manitoba);
• Southeast Resource Development Council Corp (Manitoba);
• Innu Takuaikan Uashat mak Mani-Utenam First Nation (Quebec).

In interviewing with both internal and external respondents, few First Nations and ISC respondents were aware of the program. A First Nation organization indicated that the lack of awareness may stem from how innovation is defined for the program, noting that it has more to do with cost savings than new and true 'innovative' ideas for the design of schools. One First Nation respondent affirmed that their community had partnered with another nearby First Nation to access the fund to expand their schools using similar designs, cost sharing and the same contractor to complete both projects.

A few First Nation respondents commented that the fund favoured communities that were in a position to share costs with partners, suggesting that a community needed substantial own source revenue to access the fund. While the results achieved through the Innovation Fund are yet to be further observed, ISC respondents stated that the projects funded via the Innovation Fund were mostly for feasibility studies while funding for innovative materials or design approaches may have been more appropriate. Some ISC program staff suggested that First Nations may be less inclined to put forth proposals for innovative approaches to designing and building schools as ISC is expected to fully fund EF program projects.

School Bundles

A case study was conducted to assess the School Bundling Initiative that was implemented as a model to generate more efficiencies in building schools on-reserve with the intended outcomes of: increasing speed of delivery of school projects through consolidating or amalgamating core project management functions, attracting larger and more experienced construction firms, creating greater competition and economies of scale as companies bidding on any number of schools, achieving value for money (overall project costs reduced), and reducing the administrative burdens on First Nations.

As part of the EIF Budget 2014 and Budget 2016 announcements, ISC was committed to delivering three bundling schools projects (i.e. Manitoba Schools Initiative, Lake Winnipeg Bundle, and Northwestern Ontario Schools Bundle). The composition of the communities in each bundle and their community profiles are in Table 6.2.

The purpose of the case study was to assess the extent to which the bundling initiative has achieved its intended outcomes; more importantly, the study examined the success factors and lessons-learning from its implementation with the intention to inform similar undertakings in the future. The key findings below are primarily based on document review, interviews and a site visit in the God's Lake First Nation community.

Finding #26: Despite not generating the cost-efficiencies as anticipated, the school bundling approach allowed for greater engagement and decision-making of First Nations communities in the design and build of their schools as compared to the non-bundled approach, which resulted in the integration of more community-focused and culturally relevant design elements into the school projects.

The bundles tendering process did not attract the larger construction companies as intended, instead middle-sized contractors were granted the contract. Reasons include lack of desire and experience of large construction companies in working in remote northern communities. Further, the school bundling tender process had the unexpected impact of eliminating some contractors with remote and regional experience who were too small to bid on a bundle. Both ISC staff and communities highlighted this issue and reiterated that it does not promote capacity development of local and/or First Nations owned companies.

In terms of costs, despite challenges in obtaining financial data to compare the costs of school built through the bundling approach and those through the single school process, the evaluation team heard from every First Nations participant and regional staff interviewed that the bundling project was costly to build and the schools ended up costing more than a single school, sometimes significantly higher. Some indicated that the only savings were in design costs, but the amount was minimal in relation to the total project cost. Cost overruns were noted as one of the main reasons for the high project cost – according to the interviewees, there appeared to be many during the construction. For example, significant work needed to be done to correct issues in relation to site selection due to the nature of the terrain as a result of inadequate geotechnical assessments on the outset.

Some suggested investment in more comprehensive despite more expensive geotechnical assessment before construction starts to mitigate the risk of cost overruns. Another factor that contributed to the cost overruns was the inaccurate estimation of project costs. Some noted that the estimation did not sufficiently consider remoteness and inflation. (On a positive note, LWB had more accurate budgeting after learning from the MSI experience.) These unexpected cost overruns posed additional pressure on regional operations and impacted the delivery of their other infrastructure projects. A number of planned infrastructure projects in the Manitoba region had to be delayed so the fund could be re-allocated to the school bundling projects, which prevented other communities from benefiting from the investments.

In terms of project timelines and administrative burdens, the overwhelming opinion from both internal and external respondents was it took longer to build school bundling projects. In the case of MSI, it took about twice the length of a typical build (i.e. six years versus three years). In LWB, it cannot be accurately determined due to the impact of COVID-19. It was also noted that the administrative burden was increased on First Nations' end in comparison to typical school projects. Community representatives for LWB expressed the painstakingly slow process with an excessive number of meetings for decision-making due to long chains of review (i.e. the Lake Winnipeg Bundle consultant proposed 40 meetings but it had in excess of 300 in the end). The consensus building among participating communities, as part of project commitment, appeared to extend the time required as well due to the diversity among the communities.

Despite these challenges, the value and benefits mostly acknowledged by First Nations communities are the ability for the communities to include additions not typically in other schools (i.e. space for elders and cultural teaching features). As well, communities within the same bundle reported being able to learn from one another's decisions and build a sense of broader community, in their own words:

"This [Lake Winnipeg Bundle] had much more community involvement (in comparison to a standard school build). Now communities are going to expect this. Communities enjoy this approach – this allows community to voice their needs."

"The biggest positive was for the ability for these communities to work together and have input into what kind of school they would have. They feed off of other ideas to get [the] best school within the budget. They were able to advocate for design choices and personal touches."

Finding #27: The selection of communities in a bundle affected the outcomes of the project – the project with communities belonging to the same tribal council, sharing geographic similarities and located adjacent to each other reported less challenges in its implementation. While the potential benefits of bundling projects were acknowledged by all, it was suggested that certain conditions should be considered in selecting the communities or projects to be bundled in order to maximize the bundling model.

Multiple interviewees underlined that the bundles approach does not offer any intrinsic benefits that would not be achieved in typical school construction, unless the bundled communities were strategically chosen to achieve costs savings. Many of the challenges in implementing arose from the lack of geographic proximity of construction sites, difficulties in transporting materials to communities in different remote areas (some with road access while others are fly-in only), involvement of multiple tribal councils, and the use of separate contractors. Some ISC regions are hesitant in taking a bundled approach due to the vast variety of First Nations communities that are very different from each other and require their own unique design. In the case of the Northwestern Ontario Schools Bundle, fundamental differences in community circumstances and characteristics made it extremely challenging to coordinate and align project activities and schedules within some bundles, where the two communities decided relatively early in the process to pursue their school projects independently, by mutual agreement.

Other interviewees suggested that a bundling approach could be more effective in road-accessible communities where very similar buildings are being constructed. Additionally, working within tribal councils or other organizations with existing community relationships will facilitate consensus building amongst multiple communities. While all respondents agreed on the fundamental principle and abundant benefits of bundling projects, some alternative thinking to approach bundling was proposed. For example, one idea presented was to bundle the design portions of the projects but not construction since the construction process is distinct to each site.

Another idea was to move from bundling schools, to bundling other types of infrastructure projects where less cultural diversity features are required. Furthermore, some suggested to consider bundling construction components from the whole-of-community approach (i.e. to source materials for all the construction projects during the same period in one community, which would generate cost savings in procurement and transportation tremendously).