Placemat - Evaluation of the Contaminated Sites on-Reserve (CSOR) (South of 60°) Program
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Evaluation of the Contaminated Sites on-Reserve (CSOR) (South of 60°) Program
Evaluation Scope
- The evaluation covered fiscal years 2014–15 to 2019–20, and the early impacts of the COVID-19 pandemic. The total materiality over the 5 year scope was ~275M.
- The evaluation assessed relevance; effectiveness; efficiency; and cross-cutting themes (service transfer, COVID-19; climate change; GBA Plus; and Indigenous children and families). The 11 major findings on this page are grouped thematically based on the ideas that were most present in the information shared with the evaluation team.
- The First Nation Land Management Resource Centre (FNLMRC) and representatives from the National Aboriginal Land Managers Association (NALMA) were invited to provide comments and feedback on the evaluation scope, methodology, and preliminary findings.
Evaluation Assessed the Following Domains
- Relevance
- Achieving Results
- Challenges
- Process
- Roles and Relationships
- Service Transfer
- External Forces
Relevance
- The CSOR Program remains relevant as it is aligned with Canada-wide commitments and priorities, and is key to addressing Canada's legal obligations on reserve and to supporting the exercise of Indigenous rights over their lands and resources.
- There is a continued need for the CSOR Program as it benefits Indigenous communities holistically, with a particular consideration for vulnerable populations.
Achieving Results
- The CSOR Program has made progress in achieving its objectives to remediate known high-risk sites and reduce risks to public health and safety, while also opening First Nations' land up for future development. Over the scope of the evaluation, federal liabilities reduced with the completion of projects and simultaneously rose due to increasing project costs as well as the addition of new sites with liabilities via assessments
Challenges
- The main challenges in delivering the CSOR Program lie in both the amount and the sources of funding. Particularly, reliance on the Federal Contaminated Sites Action Plan's funding structure creates challenges for ISC to respond to its own unique context in terms of both the types of activities undertaken and the processes to fund activities; and there is a greater demand for the Program than the current budget can address.
- Human and technical capacity in both ISC and in First Nations is a challenge in delivering the CSOR Program effectively. Having a sufficient number of staff who are, dedicated, qualified, and appropriately compensated is necessary to achieve good results.
Process
- The CSOR Program has found some internal efficiencies by collaborating with other government departments and programs to access surplus funding, and through the bundling of its sites. Working with First Nations has produced additional efficiencies during the lifetime of projects. However, the Program's administrative requirements are a source of inefficiency, and the current mechanisms for tracking performance are not sufficient to measure progress toward the ultimate outcome of the CSOR Program's interventions.
Roles and Relationships
- The CSOR Program has a good structure internal to ISC, with Headquarters providing national guidance and financial reporting supports, and Regions working directly with First Nations to carry out projects. Involving local representatives from First Nations in all aspects of the projects builds trust with communities and ultimately facilitates effective project management.
Service Transfer
- To advance service transfer within the CSOR Program's current structure, there is a need to appropriately define and resource Indigenous training and procurement processes that could support First Nations to build further capacity in contaminated site assessment and remediation activities. The current performance measurement strategy does not reflect First Nations' definitions of success.
- To achieve transformative change and facilitate service transfer, the CSOR Program should better reflect First Nations priorities, but this is complicated by the status of sites as federal liabilities.
External Forces
- The CSOR Program has experienced impacts from climate change, including unpredictable seasonal weather and new sources of potential contamination. First Nations and ISC are beginning to incorporate adaptation and mitigation strategies to address the impacts of climate change on contaminated sites.
- The COVID-19 pandemic has added to the unmet demand for funding from the CSOR Program. While the Program was able to advance some projects during the COVID-19 pandemic, other projects were delayed or stalled. The resulting backlog of sites to be addressed, combined with rising activity costs, has meant that the Program is expected to address additional sites with reduced purchasing power.
Management Response and Action Plan (MRAP)Footnote 1
Recommendation 1
Working with Human Resources, the CFRDO and Regional Offices, take steps to assess existing internal human resource needs and capacity for contaminated site management to ensure a consistent level of service to First Nations across the Program.
Action 1.1: Collaborate with Human Resources and Regional Offices to conduct a comprehensive review of current staffing levels dedicated to contaminated site management, assess the skills and expertise required for effective site management, and identify any gaps in the existing staffing structure (Q4, 2024–25).
Action 1.2: Engage Regional Offices to identify any regional variation in capacity and gather regional perspectives on the challenges and opportunities related to contaminated sites management (Q4, 2024–25).
Action 1.3: Work closely with the finance team to review the current budget allocated for contaminated site management and identify/explore mechanisms to secure necessary funding for staffing (Q4, 2024–25).
Action 1.4: Work collaboratively with Regional Office to develop and implement targeted training (Q4, 2025–26).
Recommendation 2
Working with First Nations partners and Regional Offices, leverage existing knowledge about First Nations' capacity for contaminated site management to develop options to maximize the sharing of their expertise and to ensure First Nation communities have ongoing access to qualified and dedicated human resources.
Action 2.1: Review existing knowledge and expertise in contaminated sites management within First Nations and First Nation Organizations by engaging with partners and Regional offices. Leverage existing knowledge to identify areas of expertise, available resources, and capacity gaps Q4, 2025–26).
Action 2.2: Develop options to partner internally or with FCSAP, to provide financial resources to enhance the technical expertise within First Nation organizations (Q4, 2026–27).
Recommendation 3
Working with First Nations partners and ISC's performance measurement and data specialists, revise the performance measurement framework to include program results around First Nation's priorities, and update associated data collection instruments to enhance ISC's responsiveness to First Nations' priorities.
Action 3.1: Collaborate with Regional offices and First Nations communities to identify specific priorities and expectations of First Nations communities regarding the CSOR Program (Q4, 2024–25).
Action 3.2: Conduct a review of the existing performance measurements metrics to identify areas where the existing framework may need adjustment or revisions to integrate program results aligned with First Nations' priorities (Q2, 2025–26).
Action 3.3: As required, update data collection instruments in alignment with the revised performance measurement framework to ensure collected data contributes to informing program success and identifying opportunities for continual improvement (Q4, 2026–2027).
Recommendation 4
Working with First Nations partners, support the ISC programs responsible to establish and resource an Indigenous business development and procurement strategy, and ensure the socio-economic opportunities from the CSOR program flowing to Indigenous communities and businesses are maximized.
Action 4.1: Proactively identify measures to enable applicable ISC Tendering Policies and guidance to maximize the ability of First Nations and Indigenous-owned organizations to deliver their contaminated sites projects. (Q4, 2025–2026)
Recommendation 5
Integrate mechanisms to provide funding or support for additional activities that are not currently funded under the CSOR Program, such as pollution prevention efforts, and assessment or remediation work on sites for which ISC does not accept liability.
Action 5.1: Conduct a strategic planning exercise to identify and prioritize activities that are not currently covered by CSOR funding or authorities (Q2, 2024–2025).
Action 5.2: Review other ISC programs to identify potential mechanisms and authorities that could be leveraged to address gaps in CSOR program authorities (Q3, 2024–25).
Action 5.3: Identify other program funding within ISC to identify funding that could be leveraged to support priority activities that are not currently funded through CSOR program (Q4, 2024–25).
Action 5.4: Seek additional authorities or funding through formal processes such as the submission of a Memorandum to Cabinet, budget proposal and Treasury Board Submission (Q1, 2026–27).
Action 5.5: As required, revise CSOR Program's Terms and Conditions to reflect the expanded authorities, based on cabinet direction (Q4, 2026–27).