Evaluation of the Emergency Management Assistance Program and Indigenous Community Support Fund

Evaluation context

The Emergency Management Assistance Program (EMAP) is designed to support emergency management activities exclusively for on reserve and other eligible First Nations^{Footnote 1}, as defined by its Terms and Conditions. The evaluation also recognizes that over the evaluated period, EMAP was working to respond to the Office of the Auditor General (OAG) of Canada's recent report on Emergency Management in First Nations Communities—Indigenous Services Canada, and that there is ongoing and complementary work that ties in to this evaluation's findings and recommendations.

Self-determination

The evaluation heard that EMAP's approach to funding and service delivery could better align with First Nations' visions for self-determination and enable culturally relevant services, in line with Canada's commitment to reconciliation. In particular, EMAP's funding mechanisms and reporting requirements for response and recovery reimbursements were seen by some partners as misaligned with a Nation-to-Nation relationship. The evaluation found promising practices in the Atlantic and Saskatchewan that could be replicated across the country with regards to allocating resources transparently, predictably, and equitably across a region.

Effectiveness

The evaluation examined the extent to which EMAP contributed towards its ultimate outcome: "First Nation communities have increased their response and recovery capabilities." The evaluation found that EMAP funding, combined with the efforts of ISC staff at headquarters and regional offices, supported emergency management capacity in communities through funding for Emergency Management Coordinators, Non-Structural Mitigation and Preparedness (NSMP) and FireSmart projects, response and recovery expenses, and funding allocated for service agreements. EMAP funding and efforts of staff have also supported progress towards the establishment of multilateral emergency management agreements. Together, these supports have contributed towards increased response and recovery capabilities of First Nations. However, the evaluation also found that the need for additional resources to support First Nation capacity, combined with the long amount of time needed to establish multilateral agreements, limited the full achievement of EMAP's ultimate outcome.

Relevance

The impacts of EMAP on evacuees, priority groups, and response and recovery capabilities need to be better measured to comprehensively assess their effectiveness. At the same time, the evaluation found that culturally relevant services were being provided using EMAP funding, where First Nations were able to control their choice of service providers. First Nations also reported that EMAP staff support their plans to prioritize the most vulnerable populations in their communities.

While ISC staff and First Nations representatives understand the importance of climate change adaptation and resiliency, the evaluation found that EMAP's budget does not enable the program to sufficiently prioritize proactive support for First Nations to prepare for and mitigate against the increasing risk and magnitude of disasters caused by natural hazards.

Efficiency

The evaluation found that the reporting requirements for EMAP's response and recovery reimbursements places a high administrative burden on First Nations and ISC staff, and sometimes results in payment delays that threaten the financial well-being of First Nations and their partners.

The evaluation also found that the proposal-based nature of funding and its eligibility criteria limited the ability of First Nations to fully address their emergency management priorities. Finally, ISC regional staff experienced some challenges in providing timely services to First Nations, particularly during times when multiple emergencies created surges in demand. EMAP staff were characterized by First Nations as integral supports to their emergency management capabilities. These staff supported communities both by being responsive and available during emergency situations, and by providing advice to First Nations seeking to access EMAP funding for mitigation, preparedness and recovery activities.

Indigenous Community Support Fund (ICSF)

First Nations generally reported that ISC's response to the COVID-19 pandemic through ICSF was helpful for their communities. The evaluation found that the direct allocations of ICSF funds to First Nations supported communities to manage their funding, address their priorities, and develop community-based solutions to mitigate the effects of the COVID-19 pandemic and the spread of COVID-19. These positive experiences, however, also created new expectations around existing unmet needs for food security, mental health supports, and perimeter security. At the same time, the evaluation also heard that not all activities were eligible for ICSF funding, and proposal-based funding may not have been accessible to all First Nations. In addition, the effects of ICSF funding on individuals were also not well understood due to a lack of data. Moreover, the reintroduction of reporting requirements partway through ICSF's implementation increased the administrative burden on First Nations.

At the regional level, the evaluation heard that ISC regional staff faced challenges allocating ICSF equitably across and within regions. ICSF's 'no wrong door' approach was found to have successfully streamlined the application process, but also required an agile response from ISC, which created an additional burden for regional staff.

Overview

• This Management Response and Action Plan was developed to address recommendations presented in the Evaluation of EMAP and the EMAP component of ICSF. It was developed by ISC's Emergency Management Directorate in collaboration with the Evaluation Directorate.
• Indigenous Services Canada (ISC) acknowledges and concurs with the recommendations outlined in the report of the evaluation of the Emergency Management Assistance Program and Indigenous Community Support Fund.
• For all recommendations ISC recognizes the importance of committed and dedicated action towards self-determination and service transfer.
• ISC is committed to supporting First Nations in their efforts to enhance their resiliency in response to the increasing frequency and intensity of emergency events.
• This evaluation covers the period from April 2017 to September 2023.
• In 2022, EMAP also underwent an Office of the Auditor General of Canada (OAG) audit, the resulting report entitled, Emergency Management in First Nations Communities, covering a similar period of Fiscal Year 2018-19 to 2021-22.
  • The audit produced six EMAP related recommendations, four of which directly overlap with this evaluation's findings.
  • ISC responded with a Management Response and Action Plan, in response to the 2022 audit, with the majority of actions completed or underway as of April 1, 2024.
  • All of ISC's responses were reviewed by a co-led Assembly of First Nations/ISC First Nation Steering Committee comprised of 12 emergency management practitioners from across Canada. The Committee provided feedback and guidance on development and implementation of ISC's responses. The Committee met on 13 separate occasions between October 2023 and June 2024.
  • The Committee was reconvened in Fall 2024 as the First Nations Advisory Committee on Emergency Management. This Committee examines both the continued ISC responses to the OAG audit and other changes being proposed to the EMAP program.
  • This Committee will play a key role in reviewing and providing feedback on all 4 of this evaluation's MRAP responses.

The OAG's five MRAP related recommendations, ISC responses and the Evaluation corresponding Finding (s) are as follows:

• In addition to the audit response, EMAP explored ways to expedite the reimbursement process and render EMAP eligibility clearer for First Nations partners directly related to the Evaluation's Finding #15.
• A new, more efficient invoice review process has been implemented as part of the process to reimburse First Nations.
• The Emergency Management Directorate is also developing tools, templates, and guidelines to help First Nations navigate EMAP more easily. These will clarify eligibility criteria, streamline the claim package submission, and reduce back-and-forth communication with the department, thereby enhancing transparency and reducing administrative burdens.
• ISC intends to initiate implementation of the recommendations immediately. A quarterly review of the Management Response and Action Plan will be conducted by ISC Evaluation and shared with the ISC Performance Management and Evaluation Committee (PMEC) to monitor progress and activities.

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.

Recommendation 1:

Explore options and make recommendations based on feedback from First Nations partners to shift NSMP and FireSmart funding from proposal-based to long-term, flexible, and multi-year preparedness and mitigation funding.

Actions: We do concur.

EMAP agrees that exploring options and making recommendations, based on feedback from First Nation partners, around NSMP and FireSmart funding is a component of supporting First Nations' effort to enhance their capacity. The recommendation will explore options in dialogue with First Nation partners to reduce the administrative burden in accessing funding while ensuring those with the greatest need are prioritized using a risk-informed approach developed during the OAG MRAP process.

To address this recommendation, EMAP will:

• Action 1.1. Develop options drawing on findings from existing internal research and First Nations engagement on the issue of preparedness and mitigation funding, conducted through existing channels such as the ISC-Assembly of First Nations Advisory Committee on Emergency Management, Multilateral discussion tables, as well as First Nations EM Regional mechanisms (e.g. Atlantic region Emergency Management Coordinators Network). (Q1-4, 25/26)
• Action 1.2. Share developed options within ISC and with First Nation partners for feedback resulting in recommendations for improvements. Recommendations will be integrated into the program's continuous improvement efforts around proposal based funding.(Q1-2-26/27)

Responsible Manager:
Director General, Sector Operations Branch (SOB)

Planned Start and Completion Dates:
Start Date: April 2025
Completion Date: September 2026

Action Item Context / Rationale
Status: Partially implemented

In 2023 and early 2024, EMAP undertook regional engagement on potential improvements to the program, including proposal based funding, resulting in a What We Heard report. Select recommendations from this report will inform the development of options.

Recommendation 2:

Leverage ongoing multilateral discussions to strengthen ISC's coordination with federal, provincial, and territorial partners directly involved in emergency management, in order to better support First Nations and Tribal Councils in accessing the full range of available funding and services.

Actions: We do concur.

EMAP agrees that the development of recommendations to explore the potential enhancement of coordination across the federal government and with provincial and territorial partners is important to support First Nations' efforts to access funding for emergency management services. It is important to note that these recommendations will touch upon elements that are currently outside of the EMAP program's authorities.

To address this recommendation, EMAP will:

• Action 2.1. Produce findings from the results of research into the available EM related supports to First Nation partners across the federal, provincial and territorial landscape and explore options for enhanced coordination. (Q1-2, 25/26)
• Action 2.2. Engage implicated federal, provincial, and territorial partners, through Multilateral Tables, to examine options and recommendations to enhance coordination across the federal government and with provincial and territorial partners. (Q3-4, 25/26)

Responsible Manager:
Director General, Sector Operations Branch (SOB)

Planned Start and Completion Dates:
Start Date: April 2025
Completion Date: September 2026

Action Item Context / Rationale
Status: Partially implemented

EMAP expects that this recommendation will be addressed in the context of ongoing continued multilateral service agreement discussions which encompass province, territorial and other relevant federal partners aligned to the OAG MRAP work.

Recommendation 3:

Support First Nations Emergency Management Coordinators to be as effective and efficient as possible by enhancing their capacity in Emergency Management in communities and tribal councils.

Actions: We do concur.

EMAP agrees that it is important to continue work started in the OAG MRAP to further refine and implement plans to enhance the delivery of Emergency Management Coordinators (EMC) supports. EMCs occupy a pivotal role in assuring their community(ies) are prepared and are able to respond to emergencies. EMC positions are supported based on a risk-informed approach striving to prioritize Frist Nation communities with the greatest need. Recent EMC expansion has leveraged partnerships in multilateral discussions as part of an overall strategy to enhance First Nations self-determination.

To address this recommendation, EMAP will:

• Action 3.1. Work with relevant officials within ISC headquarters and regional staff to support capacity development research and strengthen the EMC program. (Q1, 25/26)
• Action 3.2. Develop options supporting the role of EMCs, based on feedback from engagements with ISC regional offices, EMCs across Canada, previous OAG work, data from existing pilot initiatives (e.g., Alberta EMCs). (Q2-4, 25/26)
• Action 3.3. Collaborate with First Nation partners, finalize implementation plans and begin a rolling implementation of new measures with First Nation partners while actively continuing to leverage multilateral discussions on emergency management agreements to expand support for EMCs. (Q1-2, 26/27)

Responsible Manager:
Director General, Sector Operations Branch (SOB)

Planned Start and Completion Dates:
Start Date: April 2025
Completion Date: September 2026

Action Item Context / Rationale
Status: Partially implemented

Recommendation 4:

Strengthen overall efficiency across all of EMAP's funding streams by: improving clarity and awareness around eligible and ineligible expenses; assessing and putting in place measures to streamline and simplify the reimbursement process; and build on existing progress in the use of advance payments for response and recovery funding.

Actions: We do concur.

EMAP agrees that there is an opportunity to improve clarity around the program's eligibility based on its Terms and Conditions as well as assessing and putting in place measures to streamline and simplify the reimbursement process; and build on the existing use of advance payments for response and recovery funding.

To address this recommendation EMAP will:

• Action 4.1. Develop and finalize, with ISC Communication officials, public-facing guidelines for Advance Payments, which clearly outline criteria and process for Frist Nations in accessing advanced funding for response and recovery activities (Q1-4 25/26
• Action 4.2. Develop comprehensive eligibility guidelines with First Nation partner feedback. (Q3-4, 25/26)
• Action 4.3. Disseminate developed products, leveraging ISC Communication and partner channels, to First Nation communities and partners (e.g. First Nations Advisory Committee on Emergency Management). (Q1-2, 26/27)
• Action 4.4. Review and adjust, if required, EMAP's new invoice review process in 2026 to further expedite and streamline reimbursement for Response and Recovery claims for First Nation partners. (Q1-4 26/27)
• Action 4.5. Develop and finalize, with ISC Communication officials, public-facing eligibility guidelines, which clearly outline the eligibility criteria and processes to support First Nation partners in understanding and accessing timely response and recovery funding. (Q4, 26/27)

Responsible Manager:
Director General, Sector Operations Branch (SOB)

Planned Start and Completion Dates:
Start Date: April 2025
Completion Date: September 2026

Action Item Context / Rationale
Status: Partially implemented

Actions already taken since the Evaluation in response to this recommendation:

EMAP Invoice Review Process
As of January 1st, 2025, a new EMAP Invoice Review Process has been approved by our Senior Assistant Deputy Minister with the full support of the Deputy Minister and is being implemented. The updated process is designed to enhance efficiency in the Response and Recovery reimbursement process, with a specific focus on reducing wait times for First Nation partners. Highlights of the process include:

1. Risk-Based Sampling: A streamlined approach for large claims, focusing on accuracy and efficiency;
2. Standardized Reviews: Efficiency and standardization checks for all other claims to improve timelines and reduce administrative burden;
3. Alignment with the Financial Administration Act requirements to support compliance while addressing unique needs of First Nation communities.

EMAP 101 Toolkit
While the eligibility guidelines are being developed, EMAP has shared this toolkit for First Nations to support in navigating of the program – this toolkit includes:

1. EMAP 101 Deck – An overview of the program, including details on each funding stream and what activities/expenses are covered.
2. EMAP One Pager – A concise summary of the program and eligible Response and Recovery expenses with QR codes linking directly to EMAP webpages.
3. EMAP Response Checklist and Reconciliation Sheet – An optional tool to help recipients streamline their Response claim reimbursement process.

Emergency Management in Canada

Emergency management in Canada is a shared responsibility requiring cooperation and communication among:

• federal, provincial, and territorial governments;
• government partners, including Indigenous partners; and
• individual citizens.

Each level of government has their own emergency management legislation and ways of organizing within their respective jurisdictions.^{Footnote 3} Individual citizens first have a responsibility to prepare for disasters and contribute to community resiliency.^{Footnote 4} In an emergency, provincial and territorial governments and local authorities almost always provide the first response.^{Footnote 5} If an emergency threatens to overwhelm their resources, provinces/territories can request federal assistance through Public Safety Canada,^{Footnote 6} which is the primary department that ensures the whole government works together to help in an emergency.^{Footnote 7} The joint response by all partners follows the Federal Emergency Response Plan (FERP) and An Emergency Management Framework for Canada (2017), which establishes a common approach for collaborative emergency management initiatives in support of safe and resilient communities.

First Nation's Emergency Management

First Nations' Emergency Management is a shared responsibility^{Footnote 8} among:

• the First Nation and/or Tribal Council;
• the federal government;
• the provincial/territorial government; and
• individual citizens.

First Nations, as a form of local authority, are expected to conduct risk and vulnerability assessments, create emergency management plans, conduct training, and lead their communities during emergencies. If a First Nation's capacity is overwhelmed, First Nations can request assistance from provincial/territorial governments. First Nations and provincial/territorial governments can then seek reimbursement of eligible costs under ISC's Emergency Management Assistance Program.^{Footnote 9}

The Government of Canada has a role to play in supporting emergency management on First Nation reserves consistent with the Emergency Management Act, 2007 and its legislative authority in relation to First Nations and reserves stemming from section 91(24) of the Constitution Act, 1867. The Department of Indigenous Services Act in section 6(2)(h) lays out the Minister's authority and duty to ensure that Indigenous individuals and their governing bodies are provided with the emergency management services they are eligible to receive under EMAP. ISC is responsible for ensuring access to emergency services under EMAP and works to ensure its services follow the National On-reserve All Hazards Emergency Management Plan, in addition to the emergency plans followed by Public Safety Canada.^{Footnote 10} ISC also provides funding and coordinates emergency management efforts with provinces, territories, or service providers such as non-government organizations to deliver emergency support to on reserve communities. Service agreements between ISC and provincial or territorial governments help ensure that First Nations receive emergency assistance comparable to other Canadians as a baseline.

EMAP Programming

EMAP provides support under the 4 pillars of emergency management: non-structural mitigation^{Footnote 12}, preparedness, response, and recovery. These four interdependent components may be undertaken sequentially or concurrently.

Within each of the programming areas mentioned below, the delivery of EMAP varies across Canada because ISC regional offices deliver EMAP and provincial or territorial governments play different types of roles with differing levels of involvement in EMAP.

ICSF programming

ICSF supported First Nations with both direct allocations and proposal-based funding. Its key feature included a "no wrong door approach" for funding applicants, meaning that one submission through ICSF could be funded by a number of programs within ISC. Within ICSF, eligible activities included (but were not limited to):

• Preparedness measures to prevent the spread of COVID-19.
• Mental health assistance and emergency response services.
• Support for Elders and vulnerable community members.
• Educational and other support for children.
• Measures to address food insecurity.

ICSF resources

ICSF provided resources to First Nations to mitigate the spread of COVID-19 and address the effects of the pandemic in their communities. The EMAP-ICSF funding was 62% of the $2 billion allocated through ICSF. The remaining ICSF funding was allocated through Urban Programming for Indigenous People Program and Capital Facilities and Maintenance Program. ICSF expenditures totalled $1,252,300,000. The distribution across the direct allocation and proposal-based funding mechanisms are shown in Table 2.1 and 2.2 below.

See Appendix 3 for ICSF's performance indicators.

First Nations call for core funding to address their preparedness and mitigation priorities and build their capacity

As outlined in Finding 16, the use of annual, proposal-based funding to First Nations' emergency preparedness and mitigation efforts presented challenges. The evaluation found this type of funding in EMAP created administrative burden and year-over-year uncertainty, as well as the potential for communities to miss funding opportunities if they lacked the resources to develop the proposals within prescribed annual deadlines.

In many discussions, the evaluation heard from ISC staff, service providers, and First Nation representatives that First Nations were calling for core NSMP and FireSmart funding that is predictable, flexible, and multi-year so they could better address their emergency management priorities and take on more responsibilities. Core funding could provide greater flexibility than proposal-based funding by eliminating restrictions to specific activities that were previously outlined in a proposal, and focusing on supporting the broad range of activities within EMAP's eligibility criteria.

"The budget should include training, recruitment, equipment, travel costs, and provide a vehicle. A bare-bones minimum would be $140,000."

ISC staff, service providers, and First Nations representatives shared in several discussions that with core funding provided over multiple years, First Nations would have more predictable financial resources to build their capacity in emergency management. Several discussions also indicated that core funding could encourage more sustainable community preparedness and long-term mitigation projects as First Nations can better adapt, anticipate, and allocate their EMAP resources.

In several discussions, First Nation and Tribal Council representatives also recognized that, within a fixed funding envelope, the distribution of core funding to First Nation communities should be balanced with collaborative approaches among First Nations, Tribal Councils, and regional First Nation-led organizations to avoid duplication and fill capacity gaps.

Some First Nations are seeking more direct control over who delivers emergency management services

In several discussions, First Nation and Tribal Council representatives called for EMAP funding to always go directly to them instead of service providers, the province, or other third-party organizations - even if those organizations are First Nations led. With direct funding, First Nations and Tribal Councils can decide to either deliver a service for themself or choose a service provider. Because of dissatisfaction with service providers in the past, First Nation and Tribal Council representatives in many discussions mentioned that they should be able to make decisions about how funding is allocated or used to support their emergency management priorities. They suggested that direct funding could be used as a means to adhere to their own accountability processes, within the eligibility criteria of EMAP.

"Regarding wildfire management, it has been built without us, for us. There's no space for us to be in leadership. Nothing for us without us."

To accompany direct funding, Tribal Council and First Nation-led service provider representatives in a few discussions called for measures to make sure funding is used for its intended purpose and is used strategically, for example starting with emergency management foundations (such as hazard assessments and emergency management plans) before implementing more advanced activities. To do this, First Nations and Tribal Councils suggested structures and processes that facilitate their accountability to their members or regional organizations, such as funding decision-making forums or committees that include First Nations and Tribal Councils.

EMAP's specific definition of what constitutes an emergency does not capture all of a community's emergency events, leaving First Nations challenged to find funding sources for their varied emergency management needs

In many discussions, First Nation, Tribal Council, and First Nation-led organizations expressed frustration with EMAP because its eligibility criteria did not allow them to apply their definition of an emergency. Notably, the exclusion of structural fire^{Footnote 23} and elements of community safety^{Footnote 24} were identified as problematic. To address these issues, the evaluation heard in the majority of discussions that First Nations are seeking funding from other programs at ISC, other federal departments, and provincial or territorial governments. Respondents in several discussions added that there was limited coordination or collaboration between the different programs. In several discussions, respondents shared that, due to the complexity and distributed nature of emergency management funding, it could be a challenge to identify resources to address their emergency management priorities.

To address the complexity of funding sources and streamline funding, the evaluation heard from many discussions with ISC staff and service providers that when possible, they referred applicants to the funding sources they needed. ISC staff also mentioned that they were working to support First Nations by increasing internal collaboration with other ISC programs. As an example, one ISC staff shared that a liaison position was created to support recovery efforts of a community and navigate between multiple sources of funds.

Limited funding curtailed the ability of interested First Nations, Tribal Councils, and First Nation organizations to build their capacity to deliver services, locally or as broader service providers

Through several discussions, the evaluation heard that there were First Nations, Tribal Councils, and First Nation-led service providers looking for opportunities to grow their emergency management capabilities and take on more responsibility. As mentioned in Finding 4, the evaluation heard from several discussions that the amount of NSMP funding and funding for Emergency Management Coordinator positions was not enough to support this priority. Several discussions indicated a need for additional resources if First Nations are to build a solid foundation for emergency management capacity.

Additional resources could also be used to build up the capacity of First Nations-led service providers. A few respondents reported that First Nations-led service providers could offer more services to First Nations if they had access to funding to build their capacity.

"ISC needs to support capacity at our level and at community's own pace. It's starting to impact our climb up the service ladder."

In several discussions and a few survey responses, the evaluation heard that if First Nation-led service providers are able to offer services that were previously only offered by the province, territory, or Canadian Red Cross, then First Nations would have a choice of service providers and be able to exert control over who they receive services from.

EMAP's funding models may contribute to views that the federal government does not trust First Nations

In several discussions, the evaluation heard that EMAP's approach to funding was characteristic of a colonial fiscal relationship. Specifically, respondents indicated that they felt that ISC did not trust First Nations to manage funds. In a few discussions, the evaluation heard that the proposal-based approach made First Nations feel like they needed to repeatedly ask ISC for permission to address their emergency management priorities.

The reporting requirements for reimbursement were critiqued as colonial in a few discussions with First Nation and Tribal Council representatives, and ISC staff, partly because First Nations were required to submit itemized invoices and receipts. Additionally, First Nations in a few discussions viewed the reporting requirements as colonial because some non-Indigenous service providers were not submitting the same level of documentation for reimbursement as First Nations and Tribal Councils, which ISC staff confirmed did occur on some occasions.

ISC did not always demonstrate transparency in terms of its funding amounts and processes

First Nation and First Nation-led service provider representatives in a few discussions also called for transparency, particularly regarding the amount of funding available, who it was distributed to within a region, why some proposals were rejected while others were not. They reported that increased transparency from ISC would combat mistrust, as they could verify whether funding was distributed fairly.

In several discussions, respondents reported that ISC did not provide updates for the status of a funding proposal or explain why they rejected requests for funding. They also reported that ISC did not share how program budgets were established, including the distribution across the regions. Finally, in several other discussions, First Nation and Tribal Council respondents reported that ISC did not inform them of funding available within EMAP, and what it could be used for.

EMAP may not have mechanisms for First Nations to hold their partners accountable for inadequate service provisions

In several discussions, respondents mentioned that the various partners in emergency management have different levels of responsiveness to the priorities of First Nations, and that they saw limited measures in place for First Nations to hold service providers accountable for their activities delivered during an emergency response.

"There is no mechanism for accountability [for the services delivered by service providers]. It's just outside services that are not emotionally sensitive."

For example, the evaluation heard multiple stories of neighbouring municipalities that refused to provide services to First Nation communities due to 'outstanding bills' though the Nations were not aware of the bills and they could not be produced when the Nations asked to pay them; or cases where a neighbouring municipality would agree to respond to an emergency in a First Nation but would take a very long time, resulting in greater damages to the community.

Emergency Management Coordinators were key to enabling a community's preparedness and in some cases enabled communities to manage their own emergencies

An Emergency Management Coordinator is responsible for multiple activities within a community or multiple communities if employed at Tribal Council or regional organizations. Without one, emergency management responsibilities are added to the workload of existing members of the First Nation staff, who often have many other responsibilities and priorities. The evaluation found that the work of the Emergency Management Coordinators is important for communities to respond to emergencies on their own and is essential to enable a community's preparedness in a comprehensive and sustainable way. Respondents highlighted a wide range of tasks that Emergency Management Coordinators carried out (each mentioned in at least a few discussions):

• applying for emergency management funding;
• managing preparedness and mitigation projects;
• coordinating response and recovery activities;
• strategizing an emergency management vision; and
• increasing their community or Tribal Council's responsibilities during an emergency.

In a few discussions, the evaluation also heard that when Emergency Management Coordinators took advantage of networks and forums funded through EMAP, they were able to build their capacity together and explore opportunities to support each other's emergency management preparedness.

Funding for Emergency Management Coordinators salary increased but fell short of achieving EMAP's targets

Figure 4 illustrates that EMAP's Capacity Building expenditures for the salary of Emergency Management Coordinators has been increasing, even when adjusting for inflation.

Source: Emergency Management Directorate, ISC as of February 20, 2025

Text alternative for Figure 4. EMAP's Capacity Building expenditure for the salary of Emergency Management Coordinators, 2019-20 to 2023-24

Adjusted for inflation (2023 CPI)

Unadjusted:

• 2019 – 2020: $4.7M
• 2020 – 2021: $9.8M
• 2020 – 2022: $12.4M
• 2022 – 2023: $13.3M
• 2023 – 2024: $16.5M

In addition to the Capacity Building funding presented in Figure 4, an unspecified amount of Service Agreement and Health Emergency Management funding was also used to fund Emergency Management Coordinator positions.

EMAP officials estimate that together, these 3 EMAP streams provided funding for:

• 196 positions in 2022-23.
• 213 positions in 2023-24.

Since a proportion of positions funded were at the Tribal Council or regional level, they were able to serve multiple communities. As shown in Figure 5, although funded positions covered 68% (423 out of 619) of First Nations^{Footnote 27}, this was short of EMAP's performance target of 80% for that year. As the Capacity Building funds that support Emergency Management Coordinator salaries were fully allocated each year, the 80% target was not likely to be met without an additional infusion of funds for this purpose.

Source: Emergency Management Directorate, ISC as of December 9, 2024

Text alternative for Figure 5. Percentage of First Nations served by the positions funded in 2023-24

In 2023-24, EMAP distributed funding for 213 positions. A proportion of these positions funded were at the Tribal Council or regional level, so they were able to serve multiple communities.

These positions served: 68% of First Nations (423 of 619). The target was for 80% of First Nations to be served by an Emergency Management Coordinator by 2023-24.

Shared Emergency Management Coordinators may not have always provided sufficient depth of service

The evaluation found that while Emergency Management Coordinators employed by Tribal Councils or regional organizations did have flexibility to increase community coverage, they did not necessarily provide the depth of service required. The evaluation heard in many discussions that without a dedicated coordinator in every community, essential emergency management responsibilities may have been neglected.

In one discussion, an ISC staff member indicated that the combination of increasing risks of emergencies due to climate change and the proposal-based nature of NSMP funding exacerbated risks to First Nations if they do not have a coordinator who can comprehensively develop their community's emergency management:

"So First Nations have to apply for emergency preparedness project funding on an annual basis, if they have work that's eligible under terms and conditions. But we don't have support for ongoing Emergency Management programs in First Nation community and you know as we say, climate change and the frequency and severity of natural hazards, events, forest fires and flooding continues to increase and First Nation continue to be disproportionately impacted, but they don't have the ability to have full-time program staff to support their preparedness and response."

In addition, First Nation representatives in a few discussions suggested that a dedicated coordinator can support buy-in and momentum for emergency management, for example by getting community members as well as Chief and Council to sign up for emergency management-related training. In a few discussions, community buy-in was identified as essential for developing emergency management.

First Nations and Tribal Councils faced challenges with the recruitment and retention of Emergency Management Coordinators

Even with funding to hire Emergency Management Coordinators, recruitment and retention challenges were reported in several discussions. First Nations and Tribal Councils reported a wide range of challenges recruiting experienced and trained coordinators. Each of the following challenges were mentioned in a few discussions:

• Not all First Nations or Tribal Councils were able to offer a competitive and stable salary, especially those in northern or remote communities where the cost of living can be high.
• Comprehensive emergency management training is not available in every region, meaning the supply of trained coordinators did not meet the demand.
• Lack of housing for new recruits.

In addition to recruitment challenges, several discussions indicated that there are intense and frequent levels of stress and trauma experienced by coordinators when managing emergencies. Burnout was a common theme, which threatens retention of existing staff.

"Officers go through trauma all the time. Indigenous first responders are further traumatized as they continually respond to family and friends. This trauma is also increased as they must continually drive by areas in the community that they have responded to calls."

Projects funded through NSMP and FireSmart supported First Nations' preparedness and mitigation capacities

The evaluation heard that NSMP and FireSmart projects were affecting change. Several discussions, a few survey responses, and reports from ISC regional offices indicated that with these projects, First Nations identified their vulnerabilities through risk assessments, and identified opportunities to mitigate the effects of hazards through mitigation studies and plans.^{Footnote 28} A few discussions with service providers mentioned that funding for FireSmart projects had decreased some negative effects of wildfires through prescribed burning, forest thinning, vegetation management, and the removal of surface fuels. These service providers also cited benefits of funding for training for people (including firefighters) in ground ignition, wildland suppression, and as local FireSmart representatives.

In many discussions with First Nation and Tribal Council representatives, ISC staff, and service providers, the evaluation heard that, through activities funded by NSMP, First Nations have improved their capabilities to participate in an emergency response led by service providers. The evaluation also heard in several discussions that First Nations have used NSMP funding to enhance their capacity to lead components of emergency response or evacuation. ISC regional offices' reporting^{Footnote 29} also confirmed this evidence by outlining what NSMP has supported:

• introduction to emergency management and the relevant partners in their province or territory;
• preparation of emergency management plans;
• Incident Command System training^{Footnote 30};
• running scenarios;
• community engagement;
• training and scenarios;
• preparation of evacuation plans; and
• equipment and kits (such as emergency communications equipment and Emergency Operations Centre kits).

Funding for Non-Structural Mitigation and Preparedness and FireSmart remained relatively constant

Figure 6 shows that, following a boost in funding and the introduction of FireSmart in 2018-19, the combined expenditure for NSMP and FireSmart projects was fairly consistent over the evaluated period.

Source: Emergency Management Directorate, ISC as of February 20, 2025

Text alternative for Figure 6. Expenditures for NSMP and FireSmart projects 2017-18 to 2023-24

Expenditures for NSMP and FireSmart projects 2017-18 to 2023-24

• 2017 – 2018: $16.8M
• 2018 – 2019: $31.5M
• 2019 – 2020: $25.7M
• 2020 – 2021: $25.6M
• 2021 – 2022: $27.6M
• 2022 – 2023: $28.2M
• 2023 – 2024: $7M

EMAP did not achieve its target to provide NSMP funding to 70% of First Nation communities within the previous two years

To support First Nations with their preparedness and mitigation capacity, EMAP aimed to increase program reach. As shown in Figure 7, EMAP did not achieve its 2019-20 performance target of 70% of First Nation communities receiving funding to implement emergency preparedness or non-structural mitigation within the previous two years. The actual percentage ranged from 46% to 67% over the evaluated period.

*Note: EMAP retired this indicator and stopped reporting on this in 2022-23.

Source: Emergency Management Directorate, ISC as of January 14, 2025

Text alternative for Figure 7. Percentage of First Nation communities who received funding to implement emergency preparedness or non-structural mitigation within the previous two years

The target is 70%

• 2017 – 2018: 46%
• 2018 – 2019: 63%
• 2019 – 2020: 49%
• 2020 – 2021: 56%
• 2021 – 2022: 67%
• 2022 – 2023: 58%

ISC did not maintain a consolidated dataset on which communities submit proposals for what purpose, relative to which communities ultimately receive funds. Similarly, First Nations representatives in a few discussions reported that they were generally not given a reason when their proposals were rejected. Consequently, it is difficult to unpack why this target was consistently unmet.

What is known is that the program was consistently oversubscribed, meaning there may have been too few funds available to cover the targeted number of communities. However, there are other potential explanations. For example, as is discussed later in Finding 16, perhaps not all communities had the capacity to develop proposals.

Funding for NSMP and FireSmart projects left gaps

The evaluation found that First Nations, Tribal Councils, and First Nation organizations were using NSMP and FireSmart funding as much as they could to prepare for emergencies. However, these funding sources are not increasing and were fully spent every year.

"The risk is changing, but the actions that we're taking really are largely limited by resourcing. I don't see any nuance to [FireSmart] in response to climate change."

In more than half of the discussions, First Nation or Tribal Council representatives, ISC staff, and service providers reported that they experienced challenges preparing for emergencies because funding was not always available. As identified by a few discussions, the most frequently reported priorities that First Nations were unable to address included:

• gaining the skills needed to respond to an event (through training and scenarios);
• developing hazard, risk, and vulnerability assessments and emergency management plans; and
• purchasing the equipment needed to safely and adequately respond to high-risk events (for example wildland firefighting equipment).

A further discussion on the funding gaps and First Nations' emergency management priorities appeared in Finding 1.

Increased funding for response and recovery reflected the increasing need

Expenditures by EMAP for Response and Recovery was unprecedented in 2023-24, increasing from $266.3 million in 2022-23 to $509.1 million in 2023-24. Unprecedented spending such as this is possible because EMAP is responsible to support First Nations during and after emergencies and has been able to secure the funding to fulfil the increasing needs of First Nations.

Figure 8 shows that since 2020-21, EMAP has been contributing an increasing amount to service providers for response activities.

Source: Emergency Management Directorate, ISC as of February 20, 2025

Text alternative for Figure 8. Expenditure for Response, 2017-18 to 2023-24

Adjusted for inflation (2023 CPI)

Unadjusted:

• 2017 – 2018: $7.5M
• 2018 – 2019: $58.7M
• 2019 – 2020: $108M
• 2020 – 2021: $31.1M
• 2021 – 2022: $78M
• 2022 – 2023: $189.6M
• 2023 – 2024: $369.5M

Figure 9 below shows that over the evaluation period, Recovery expenditures were much higher in 2023-24.

Source: Emergency Management Directorate, ISC as of February 20, 2025

Text alternative for Figure 9. Expenditure for Recovery, 2017-18 to 2023-24

Adjusted for inflation (2023 CPI)

Unadjusted:

• 2017 – 2018: $27.6M
• 2018 – 2019: $70.7M
• 2019 – 2020: $71.6M
• 2020 – 2021: $38.3M
• 2021 – 2022: $76.5M
• 2022 – 2023: $76.7M
• 2023 – 2024: $169.6M

It is worth noting that while ISC has successfully received the supplemental funding requested over the evaluated period, the evaluation does recognize that the annual process through which EMAP secures this response and recovery funding is administratively burdensome and may put the department at risk if the request is denied. Requests for supplementary funding is required because EMAP's base funding does not cover its expenditure. Figure 10 below shows that EMAP had to access supplemental funding each year over the evaluated scope to cover anywhere from 52% to 81% of EMAP's response and recovery funding.

*Note: From 2017-18 to 2021-22, base funding was $29 million each year and from 2022-23 to 2023-24, base funding was $128 million each year.

Source: Emergency Management Directorate, ISC as of April 17, 2025

Text alternative for Figure 10. Annual expenditure and base funding for response and recovery, April 2017 to March 2024

Years	Annual expenditure and base funding for response and recovery	Percentage of the annual expenditure not covered by base funding
2017 – 2018	$103M	72%
2018 – 2019	$129M	76%
2019 – 2020	$180M	84%
2020 – 2021	$69M	58%
2021 – 2022	$155M	81%
2022 – 2023	$266M	52%
2023 – 2024	$509M	75%

More than half of survey respondents reported that EMAP funding fully supported First Nations to respond to and recover from emergencies

Seventy-one percent (32 out of 45) of emergency management representatives surveyed agreed that EMAP supported their response strengths and priorities. 58% (26 out of 45) of survey respondents agreed that EMAP supported their recovery activities, while 27% (12 of 45) neither agreed nor disagreed.

Response and recovery funding facilitated a range of responses to emergencies

Overall, the evaluation found that the comprehensiveness and flexibility of EMAP's response funding supported numerous targeted responses that were tailored to the unique needs of the situation. The evaluation heard from service providers that they were able to procure, coordinate, or deliver services and supplies to support First Nations to shelter-in-place, temporarily move to nearby places of safety, or evacuate to another First Nation or municipality. For shelter-in-place activities, a few discussions mentioned the purchasing equipment such as air purifiers and generators. In the case of evacuations, service providers in a few discussions reported procuring or coordinating transportation from and to a community, accommodations, food, security for evacuees, and social services.

At the same time, a few First Nation representatives reported that not all of their expenses were eligible, and the lack of clarity around what constituted eligible expenses created risks for them (as well as the reimbursement delays discussed in Finding 15). ISC staff in a few discussions pointed out that the flexibility of EMAP's eligibility guidelines enabled the reimbursement of a wide variety of expenses. However, one regional ISC staff member felt that the breadth of the eligibility guidelines made it difficult for communities to know what they were entitled to through EMAP if they were evacuated. The ISC staff member mentioned that they themselves had to seek clarity from staff in headquarters to interpret the guidelines. Concerns related to unclear eligibility of expenses were also reflected in recommendation 8 of the 2018 Report of the Standing Committee on Indigenous and Northern Affairs titled: From the Ashes: Reimagining Fire Safety and Emergency Management in Indigenous Communities.

ISC officials worked with First Nations and service providers to advance discussions toward establishing multilateral agreements

According to EMAP officials, ISC was moving towards establishing multilateral emergency management service agreements in the spirit of reconciliation and towards service transfer. ISC was doing this in all jurisdictions that include First Nations on reserve. They reported that establishing these agreements involved engaging First Nations as full and equal partners in deciding what services and supports they receive from their relevant jurisdiction and other nongovernmental organizations. ISC's internal documentation^{Footnote 33} reported that efforts of ISC staff and funding for First Nation-led engagement in different provinces and territories had:

• introduced the concept of multilateral agreements;
• introduced the different emergency management partners in a province or territory;
• provided funding for First Nations to draft a vision for emergency management and a path for discussions^{Footnote 34};
• established working groups and commitments to collaborate;
• provided funding to First Nations-led service providers to expand their service offerings^{Footnote 35}; and
• established a governance model that defines roles and responsibilities.

Figure 12 below shows that during the early years of the COVID-19 pandemic, expenditure for multilateral engagement decreased to $0.^{Footnote 36} Funding resumed in 2022-23, alongside the formation of a dedicated headquarters team to advance these discussions, supported by ISC regional teams.

Source: Emergency Management Directorate, ISC as of February 20, 2025

Text alternative for Figure 12. Expenditure for engagement towards multilateral agreements, 2019-20 to 2023-24

• 2019 – 2020: $750,000
• 2020 – 2021: $40,000
• 2021 – 2022: $0
• 2022 – 2023: $1,003,000
• 2023 – 2024: $70,000

Progress towards the short-term target for developing multilateral agreements is unclear, and the longer-term target appears to be at risk of not being met

With respect to engagement towards establishing multilateral emergency management service agreements, the program's performance indicator speaks to the percentage of provinces and territories where First Nations are actively involved in discussions towards multilateral Emergency Management Service Agreements. As reported by EMAP officials, Figure 13 shows that, by the end of the evaluated period, First Nations in 75% (9 out of 12) of the implicated provinces and territories were actively involved in such discussions (note that there are no First Nations communities in Nunavut and so it is not included). Rather than being expressed in the same units as the indicator (i.e., provinces and territories), EMAP's target for this indicator was to have 83% of First Nations actively involved in discussions towards multilateral Emergency Management Services Agreements by April 2021. As the program did not collect data at the First Nation level, progress towards this target as it was originally defined is not clear.

In the longer-term, the program aimed to have 47% of communities served by multilateral Emergency Management Service Agreements by April 2025. As of the end of the evaluated period, however, none had yet been established.

Source: Emergency Management Directorate, ISC as of January 31, 2025

*Notes:

• Nunavut is not included in the graphic above because there are no First Nations communities in the territory.
• First Nations in a province or territory are considered to be "actively involved in discussions" when they have agreed to pursue formal or informal discussions.

Text alternative for Figure 13. Progress made by September 2023 in each region towards the establishment of a multilateral agreement*

Pre-engagement efforts initiated:

• Northwest Territories (CIRNAC  led)
  

Outreach efforts initiated by ISC:

• Yukon
• Quebec
  

Actively involved in discussions:

• British Columbia
• Alberta
• Saskatchewan
• Manitoba
• Ontario
• New Brunswick
• Prince Edward Island
• Nova Scotia
• Newfoundland and Labrador

It is essential that multilateral agreements are flexible and can accommodate different visions

In several discussions, the evaluation heard that multilateral agreements needed to accommodate different First Nation visions regarding the future of emergency management. As seen in Figure 12 above, ISC provided funding for First Nations, Tribal Councils, or other organizations in many jurisdictions to increase their capacity to engage in multilateral discussions and community engagement. Respondents mentioned that the differences in First Nations' goals can be shaped by factors such as their capacity and interest to do emergency management activities, their satisfaction with the services previously received, and whether they perceive service transfer more as a transfer of liability (in which case, they are not interested). In many discussions, First Nation and Tribal Council representatives reported the intent to build their self-sufficiency in emergency management, while others have established relationships with service providers to support them.

"Every First Nation or Tribal Council is going to be different in how it governs itself and how it wants to govern."

A respondent shared that one region is making sure that their multilateral agreement recognizes the different preferences of First Nations regarding the role and level of involvement of First Nations and service providers during an emergency. They mentioned that the agreement contains a 'core' component that all First Nations agree to with annexes appended to define considerations that are specific to a First Nation or group of First Nations.

The right people need to be involved in multilateral discussions

In several discussions, ISC staff noted the importance of establishing who is permitted to speak on behalf of First Nations and able to commit to the time needed to participate. In a few discussions with First Nation representatives, they emphasized the importance of involving both the people who represent First Nation leadership and those with knowledge of the emergency management context, which they noted was not consistently done.

ISC provided funding for First Nations, Tribal Councils, or other organizations before engaging in discussions to help ensure adequate capacity was available on all sides. Notably, Emergency Management Coordinators can be key players in multilateral discussions, further highlighting the importance of these positions, as outlined in Finding 4.

Discussions towards the establishment of multilateral agreements can support opportunities for collaboration among First Nations, Tribal Councils, and First Nation-led organizations

The evaluation found that, in multilateral discussions, there are opportunities to clarify and define the roles and responsibilities of different partners working in emergency management. A further discussion on the need for increased clarity of roles and responsibilities is found in Finding 17.

The evaluation heard from a few survey respondents, and several discussions with First Nation or Tribal Council representatives, that collaboration among First Nations is essential to avoid duplication and fill capacity gaps. For example, a few discussions identified that Tribal Councils and First Nations-led service providers are often able to serve multiple communities in a cost-efficient manner or provide additional emergency management support for smaller First Nations. Relatedly, several discussions and a survey respondent identified the potential benefits of using existing regional organizations or establishing new regional tables for First Nations' emergency management. They mentioned that through this regional approach, First Nations can fill capacity gaps, coordinate and share responsibilities, facilitate more appropriate funding decisions, and jointly advocate on behalf of communities.

To ensure a holistic approach to emergency management (beyond the scope of EMAP), several discussions with ISC staff also suggested the involvement of other provincial or territorial agencies, ISC programs, and federal departments in multilateral agreements. They mentioned that this would create an opportunity for the governments to commit funding to support the emergency management priorities of First Nations, including priority issues such as climate change, public health, infrastructure, and community safety.

Varying support from provincial or territorial governments may be a barrier to establishing multilateral agreements

Provinces and territories are essential service providers and should be included in multilateral agreement discussions. The evaluation heard in a few discussions with First Nation and Tribal Council representatives that some provincial or territorial governments did not support transferring their emergency management responsibilities to First Nations, First Nations-led service providers, or Tribal Councils.

First Nations prioritized support for the most vulnerable during emergencies

The evaluation survey found that over two thirds (68%, or 29 of 43) of respondents agreed that EMAP funding and services helped consider the strengths and priorities of different groups. In many discussions, the evaluation heard that community leaders prioritized support for people with disabilities, Elders, children and families, youth, members of the 2SLGBTQIA+ community, and people with addictions; and that these priorities were upheld by ISC regional staff and by service providers.

To support targeted efforts for priority groups, a few discussions mentioned that, during planning and preparedness exercises, their communities prioritized who got evacuated when, or who would get the most attention during an emergency. Often the groups that were prioritized first included Elders, families with young children, and people with health challenges. The next level of priority was other community members, lastly followed by Chief and Council and the emergency response crew.

Additional clarity on EMAP's role and impact in supporting vulnerable populations was needed

Over the evaluated period, EMAP did not have a system in place to collect disaggregated data from service providers about evacuees and their experiences during an emergency response.

While the evaluation heard from First Nation survey respondents and in discussions that ISC offices supported their priorities during emergencies, in a few discussions, the evaluation heard that First Nation and Tribal Council representatives were unable to support individuals with disabilities in preparation for emergencies. For example, one representative shared they were unable to buy a vibration alert device for a person who is deaf, or build a ramp for a person that uses a wheelchair, as ISC staff assessed these requests as ineligible for EMAP because they would support an individual rather than a community.

First Nations control over their own emergency management services helped ensure the cultural relevance and alignment with communities' priorities and needs

ISC is committed to improving emergency management services and transferring control of emergency management programs to First Nation partners.^{Footnote 37} The evaluation heard in many discussions that when First Nations have control over their emergency management, they are best positioned to address their own priorities and needs, ensuring that solutions are culturally relevant, effectively planned, and respectful of local knowledge. The evaluation found that self-determination was identified in many discussions as the key facilitator of services that prioritize and integrate cultural considerations. Respondents mentioned specific expressions of self-determination that facilitated culturally relevant services, which included:

• the influence of First Nations over the design and throughout the delivery of services by a third party
• the selection of service providers by First Nations
• the provision of services by First Nations themselves or by other First Nation organizations

"[What makes EM services culturally appropriate is] having services delivered by First Nations people, that are adapted to the experience and expertise of the officers, who take an on-the-ground approach. It is driven by experiences, both inside and outside of the classroom."

In several discussions, the evaluation heard examples of culturally relevant services that have been provided. These services included Indigenous languages and traditional or ceremonial practices such as:

• smudging
• the involvement of Elders
• opening drummers
• providing cultural foods

The evaluation heard in a few discussions that culturally relevant services require a holistic approach to emergency management that includes mental health supports, recognition of historical trauma, and the integration of First Nations' knowledge and traditional methods. Finally, ISC staff in a few discussions mentioned that evacuating members to other First Nation's territories, rather than to a major population centre, was another way to facilitate culturally relevant services and experiences.

"[When we took in evacuees], one man asked if he could smoke fish and we said 'OK, what do you need to do that?' It's not part of our traditional practices here [...]. We found what he needed on Facebook and when he came back from fishing, he taught us how to smoke fish. It was the same story when someone asked if they could dry some meat- when they came back from hunting they taught a bunch of the kids how to properly clean, prepare, and dry the meat."

Services that were not culturally relevant had a negative impact on First Nations' experiences

When First Nations are not in control of their emergency management services, this can exacerbate the trauma of emergencies. In a few discussions, First Nations identified services they had received that were not culturally relevant. These were often delivered by service providers that did not involve First Nations in their planning or while delivering a service during an emergency.

One discussion identified an example of a service that was re-traumatizing. During an evacuation, a non-Indigenous service provider loaded the highest priority evacuee group, Elders, onto a school bus. The Elders were not adequately informed of what was happening, and were not permitted a rest stop when one was requested. The respondent heard that this reminded the Elders of being forcibly removed from their community to attend a residential school. In response, a First Nations-led service provider took over service delivery to that community and secured charter busses to support community evacuations.

Limits on the value of equipment that can be purchased challenged First Nations' emergency management

The evaluation heard during several discussions that First Nations were unable to address their preparedness priorities because they could not secure high-value equipment that exceeded the EMAP maximum limit. While the limit increased from $5,000 to $10,000 after the evaluated period, First Nation and Tribal Council representatives indicated in a few discussions that essential equipment such as a high-power commercial generators or air purifiers are still over this new threshold. The evaluation heard that being unable to purchase high-value equipment hindered the ability of First Nations to build their capacity to be prepared for emergency events, and maintained their reliance on large-scale service providers such as provincial or territorial government agencies, or the Canadian Red Cross.

"Setting up Operations Centers can be a challenge, since you need things to set up these centres and can't purchase anything through EMAP that costs more than $5,000. So what about when you need a generator for a school? […] We've heard that the limit will be raised to $10,000, which is nice, but it's still not enough to cover a Generac generator. […] It's almost like you are being held back because you are First Nation. You have to call the province."

In several discussions, First Nation representatives pointed out that the high-value equipment they previously requested for their preparedness could only be purchased once an imminent threat was announced, as part of their response to an emergency. This created situations where opportunities for training or familiarity with equipment were missed and introduced the risk of unavailable or higher-cost equipment during an emergency.

"One community needed [water tank backpacks, known as] piss packs for their firefighters, but they wouldn't have gotten them reimbursed if they purchased them before a fire started. They can only afford them if they wait until there's an ongoing emergency and purchase them within the response funding parameters."

Capital infrastructure investments are vital for good emergency management but were outside the scope of EMAP's supports

The evaluation also heard in several discussions that First Nations were unable to address their mitigation priorities because they were unable to secure funding to make investments in capital infrastructure. The 2022 audit completed by the OAG on emergency management in First Nations communities reported that other sources^{Footnote 38} did not always have the funding available to support the mitigation priorities of First Nations. ISC staff and First Nation respondents in several discussions mentioned that without access to capital funding, First Nations were unable to mitigate against the risks they had identified, debilitating their mitigation capacity. One ISC staff illuminated the issue by noting that EMAP can pay for a study that says you need to build a dike (a flood barrier), the response when flooding repeatedly happens, and even a temporary dike, but it cannot fund the construction of a permanent dike.

Climate-related emergencies increased in both scale and frequency

The evaluation found that the increasing frequency and scale of climate-related emergencies may necessitate changes in the way EMAP operates. Climate change has resulted in more frequent and severe natural hazards^{Footnote 39} and regional variations in the occurrence of these hazards.^{Footnote 40} According to an analysis presented to ISC in 2020, there is a very high risk that these natural hazards will increase and change the need for emergency preparedness and response.^{Footnote 41} The Government of Canada also recognizes that the impacts of natural hazards will increase unless adaptation (including preparedness) measures are implemented.^{Footnote 42}

Climate-related emergencies posed a distinct and increasing risk to First Nations, which can be partially mitigated through proactive mitigation and preparedness

The evaluation found that preparation and mitigation are essential components of EMAP as they can help to reduce the physical, emotional, spiritual, and economic effects of increasing emergencies. First Nations are especially affected by emergencies due to their remoteness, historical lack of emergency resources, higher risk of being evacuated (compared to non-Indigenous communities), discrimination, and how an evacuation disrupts their cultural practices and relationship with their land.^{Footnote 43Footnote 44}

The priority of proactive mitigation (before an emergency takes place or is imminent) was emphasized in several discussions with First Nations and ISC staff who noted that increasing mitigation efforts can prevent both financial and social hardship for First Nations. In regards to the fiscal consideration of preparedness and mitigation, studies have estimated that for every $1.38 CAD ($1 USD)^{Footnote 45} invested in preparedness and mitigation, between $5 and $18 CAD can be saved in emergency response and recovery costs, depending on the specific measures and types of savings considered.^{Footnote 46Footnote 47Footnote 48}

ISC's mechanism for reimbursing response and recovery expenses required detailed reporting

In line with its terms and conditions, EMAP reimburses First Nations, Tribal Councils, provincial and territorial governments, and third-party emergency services organizations for their actual expenses from delivering response and recovery emergency management services on reserve.

Reimbursements are funded through a special purpose allotment^{Footnote 49}, which reserves a portion of a department's funds for a specific purpose within a fiscal year and requires detailed reporting to show the funds were used as intended.

As shown in Figure 14, the reimbursement process used for response and recovery expenses of partners has 6 interrelated steps.

*Note that this process has been simplified for illustrative purposes.

Text alternative for Figure 14. The steps to reimbursement

Step 1:

• Response: partner request pre-approval before spending (optional)
• Recovery: partner submits damage assessment

Step 2:

• After spending, partner submits itemized invoices, proof of payment, etc.

Step 3:

• ISC regional staff review every receipt and document

Step 4:

• If needed, ISC staff request clarification or additional evidence

Step 5:

• ISC headquarters staff review reimbursement request from regional offices

Step 6:

• ISC issues reimbursement

In some regions, ISC regional staff coordinate their reimbursement process with the provincial or territorial governments to make sure expenses are only being covered once. Uniquely, First Nations, Tribal Councils, and service providers in British Columbia submit their claims to the provincial government to be reimbursed. The provincial government then submits any additional uncovered expenses to ISC to reimburse.

Reimbursement processes sometimes, but not always, resulted in delayed payments to First Nations and their partners

The evaluation has found that the detailed reporting requirements for response and recovery reimbursements can have a "domino effect," where one challenge creates another, and so on. In more than half of discussions, ISC staff, service providers, and First Nation representatives reported that First Nations, Tribal Councils, and service providers experienced delays in getting reimbursement for expenses they covered during an emergency response or recovery. The evaluation heard from some respondents that they have waited over 1 year for reimbursements, with cases of over 2 years of delays. While EMAP did not have a service standard for the processing time of reimbursement requests, ISC staff respondents recognized these delays in the process.

Not all First Nations reported negative experiences with the reimbursement process. In response to the evaluation survey, 54% (22 of 41) of respondents reported that they did not experience challenges when seeking reimbursement from ISC. Similarly, First Nation and Tribal Council representatives and ISC staff in several discussions reported cases where First Nations did not experience delays because they understood the requirements, prepared their processes beforehand, and had the needed capacity. In contrast, several discussions and survey responses with First Nation and Tribal Council representatives, ISC staff, and service providers report that preparing documentation for reimbursement was difficult for partners because the reporting process and the eligibility of expenses was not clear beforehand. This lack of clarity around EMAP's processes reflects a finding from a 2018 report of a Standing Committee^{Footnote 50} and is further discussed in Finding 16.

Detailed reporting requirements created an additional burden on the time, effort, and mental wellbeing of those involved with the process

One respondent pointed out that, during an emergency, First Nation or Tribal Council staff are focused on evacuating members or keeping them safe. At the same time, they must collect and submit their invoices, proof of payment, and any supplementary evidence or details requested by ISC to receive reimbursement. The evaluation heard in a few discussions that this can be overwhelming, re-traumatizing, or distracting from their other responsibilities. Recognizing the burden put on First Nation and Tribal Council staff to comply with the special purpose allotment reporting requirements, EMAP is able to provide funding for a First Nation or Tribal Council to hire a consultant to manage and coordinate reimbursement reporting requirements; although the evaluation did not hear of any specific instances where this was done.

In several discussions, ISC staff reiterated a finding of the 2017 evaluation of EMAP and shared that the amount of time and effort needed to account for every dollar spent hindered the ability of ISC regional office staff to fulfil their other EMAP responsibilities.^{Footnote 51} The range of responsibilities expected from ISC's regional staff to support the emergency management of First Nations while administering reimbursements is discussed further in Finding 18.

The quantity of documentation and review needed for the reimbursement process caused delays

The evaluation heard there are multiple contributing factors that sometimes led to delays. ISC staff reported in several discussions that the quantity of documentation that partners needed to submit for their review was too much to manage in a reasonable timeframe. In a few discussions, First Nation representatives and ISC staff reported that processes being applied to submit a claim are not always consistent, as First Nations staff are sometimes occupied with active emergency management events.

ISC staff in a few discussions mentioned that the reimbursement process faced inefficiencies because every request was subject to mandatory review by ISC headquarters in addition to the initial review at the regional level. Although the evaluation could not confirm the processes used in other federal departments, one ISC staff at headquarters shared that they heard complaints from multiple regions that this process was not aligned with other disaster relief programs within Canada.

In one region, ISC staff also pointed to ISC's use of its Grants and Contributions Information Management System platform to process reimbursement requests as an inappropriate method of distributing humanitarian aid. These staff noted the platform was created for regular grants and contributions, and that the platform was not sufficiently agile for emergencies, when communities needed money quickly.

Reimbursement delays have threatened the financial well-being of some First Nations, Tribal Councils, and service providers

In several discussions, respondents shared the difficulties that First Nations and Tribal Councils encounter in managing debt, and the risk of going to collections while waiting for reimbursement. In one case, the evaluation heard from a service provider that they were on the brink of bankruptcy because they were waiting for reimbursement from ISC. In several discussions, First Nation and Tribal Council representatives, service providers, and ISC staff highlighted that First Nations should not be expected to have the cash required to cover emergency management response and recovery. For example, one Tribal Council representative spoke to the financial risks associated with supporting neighbouring communities given the slow pace of the ISC reimbursement process:

In a few discussions, respondents pointed out that First Nations with less access to cash were at risk of being unable to respond to emergencies. They also mentioned that unclear eligibility resulted in cases where First Nations were never reimbursed for expenses they thought were eligible, but were not.

When First Nations, Tribal Councils and service providers could not promptly pay their suppliers, this put their relationship with suppliers at risk

In a few discussions, respondents described the additional financial pressure put on First Nations, Tribal Councils, and service providers who needed to maintain good relationships with their suppliers while they waited to receive reimbursement from ISC. One respondent highlighted that this was especially the case for suppliers that are relied on for services needed outside of emergencies.

Another respondent mentioned that municipalities that previously hosted evacuees have declined to host future evacuations, because they are holding debt while waiting for ISC to reimburse them.

Advance payments could reduce the financial strain of response costs, but would not reduce administrative burden

EMAP formally introduced advance payments for response expenses in 2018. Advance payments provide funding to First Nations at the onset of an emergency. In a few discussions, ISC staff and service providers reported that advance payments can help diminish the financial strain faced by a First Nation. However, the evaluation only heard from one First Nation or Tribal Council representative who had experience using advance payments.

"Statistically, activities within the pillar of response are the most expensive. The fact that communities must pay for the activities upfront places significant stress on community finance."

The evaluation heard from a few ISC staff that the option of advance payments was not widely communicated out to First Nations partners. ISC regional staff are responsible to offer advance payments to First Nations, but the evaluation found that they did not have access to guidelines or communications products for this purpose.

Further, the evaluation recognizes that advance payments add to the administrative burden for both First Nations and for ISC. This is because, in addition to submitting detailed expense reporting after an emergency, First Nations must also submit an estimate of expected costs in order to request and secure an advance payment.^{Footnote 52}

The annual nature of proposal-based funding was not conducive to long-term results

The evaluation heard from several discussions with First Nation representatives that the short-term, annual nature of NSMP and FireSmart funding created uncertainty because they did not always know how much funding they would receive or when they would receive it. ISC staff, service providers, and First Nations representatives shared in many discussions that this uncertainty hindered the ability of First Nations and their organizations to effectively plan their future activities. This was noted as especially challenging for First Nations, Tribal Councils, or First Nation-led organizations that might have wanted to build their emergency management capacity, but did not know what goals were financially realistic.

The evaluation also heard from many discussions with First Nations and service providers that delays in both approval and disbursement of proposal-based funding sometimes resulted in a loss of momentum or community buy-in, for example, when funding for emergency management preparedness training was disbursed six months after a list of interested people was compiled. Respondents mentioned that these delays were especially problematic for weather specific activities, such as search and rescue training on ice.

The administrative burden of proposal-based funding was a barrier to accessing non-structural mitigation and preparedness funding

The evaluation heard from many discussions that the proposal-based and annual nature of funding may have inadvertently limited its access to First Nations and Tribal Councils who had the time and capacity to research and write proposals, disadvantaging communities with lower capacity. Further, in some discussions with First Nations and First Nation-led service providers, the evaluation heard that the annual proposal-based funding causes an additional reporting burden given the year-end reporting requirements.

"Proposal-based funding takes time. It's intimidating."

The evaluation heard in a few discussions with First Nation and Tribal Council representatives that some First Nations make emergency management a priority only after they have experienced one. First Nation and Tribal Council representatives in a few discussions reported that there should be a standard or routine process to support First Nations to establish and update the foundational pieces of emergency management in their community, such as an All Hazards Risk Assessment and an Emergency Plan. They requested that this process be automatic without the burden of a proposal and the possibility of the request being declined.

"There needs to be a change because EMAP is mostly reactive and the prevention is being missed."

Prioritization of proposals based on previous events may have left the most vulnerable communities at risk

While implementation was outside of the temporal scope, the evaluation heard that during the evaluated period, EMAP planned to adjust their approach to the distribution of NSMP funding in response to a recommendation from the 2022 OAG report. Specifically, EMAP planned to update their existing risk-based approach to their regional allocation of funding and also planned to adopt a new risk-based approach to proposal assessment by establishing a framework to assess the risk of each community^{Footnote 53}. The updated risk-based formula, developed in 2023-24, considers factors including communities' climate risk, history of emergencies, well-being, population, remoteness, funding for emergency management coordinators, fire capacity, and previous mitigation funding.

Again, although the implementation of this formula did not take place within the evaluated period, some conceptual considerations were noted during the evaluation. The new risk-based formula prioritizes communities who had a larger number of past emergencies.

In the context of climate change, however, the threat of natural hazards is new for some First Nations.^{Footnote 54} First Nation and Tribal Council representatives in a few discussions expressed concern that less-experienced communities may be disadvantaged by the new risk-based approach. They further cautioned that, if these less-experienced communities are the same ones that have not been accessing EMAP's preparedness funding for the reasons described above (i.e., the burden of proposal writing or competing priorities among leadership), their risk of experiencing the full impacts of an emergency event is compounded.

The evaluation undertook a basic but illustrative exercise to explore the idea that lower-capacity communities are less likely to access NSMP funding because of the administrative burden it entails. In 2023-24, before the new formula was implemented, NSMP funding covered 36% (220 of 616) of First Nation communities, with funding that went directly to communities or their Tribal Councils. Assigning the risk score retrospectively, we see that 37% (65 of 176) of communities that would become designated as 'high risk' received NSMP funding as compared to the 35% (155 of 440) of communities that would not be identified as 'high risk'. Other things being equal, it stands to reason that the coverage of 'high-risk' communities should have been significantly greater than coverage for lower-risk communities. The fact that high risk communities were not more likely to receive funding could be because they lacked capacity to develop proposals. Evidence that this is the case can be found in the risk score themselves, which include proxies (albeit imperfect ones) of their administrative capacity; i.e., higher-risk communities have lower Community Well-Being Index Scores, are more remote, and had lower coverage of Emergency Management Coordinators. This analysis aligns with concerns raised in discussions that lower-capacity communities may face barriers in developing NSMP proposals.

Inconsistent and unclear eligibility for proposal-based funding created inefficiencies in the approval process

Many discussions with First Nations and ISC staff focused on a need for more clarity on eligibility of expenses to support the efficient development of NSMP proposals. The evaluation heard from a few ISC staff that they needed to double check eligibility with headquarters as what was allowed seemed to change frequently.

In addition, the evaluation heard of instances where ISC regional and headquarters staff did not align in their interpretations of EMAP's Terms and Conditions, resulting in confusion around which expenditures are eligible. In one case, the evaluation heard that a community had duplicated a proposal from a neighbouring First Nation and submitted it to EMAP, only changing their communities' names, and only one proposal was accepted as eligible.

The roles of different parties in emergency management were not clearly defined within EMAP

Though there is a section on roles and responsibilities within the National On-reserve All Hazards Emergency Management Plan, it does not elaborate on the role of provincial and territorial governments in relation to EMAP except to note that most of them have some form of agreement to provide comparable emergency services to those living on reserves.^{Footnote 56} Similarly, it does not define the role of service providers or "other entities" apart from identifying them as part of the First Nations' emergency management planning process.^{Footnote 57}

Further, who is responsible to declare a state of emergency is not delineated in the agreements. Although EMAP can support First Nations without an official declaration of a state of an emergency, there is confusion around who should be declaring the emergency. For example, in Manitoba, a First Nation can declare an evacuation or a state of local emergency and this will trigger the 2013 service agreement between the Canadian Red Cross and ISC to provide emergency services to First Nations.^{Footnote 58} According to Manitoba's Emergency Measures Act, the provincial Minister may also declare a state of emergency.^{Footnote 59} Both of these declarations could result in EMAP being engaged, provided that the emergency situations meet its eligibility criteria. One First Nation service provider noted that it is not clear to communities who should declare first.

The roles of different parties in emergency management were not clearly communicated within EMAP

Responses to the evaluation survey indicated the need to clarify roles between parties in emergency management. Less than half (45%, or 15 of 33) of First Nation or Tribal Council emergency management representatives agreed that the roles and responsibilities of emergency management partners were appropriate, effective, and clear. In a few discussions, First Nation and Tribal Council representatives told the evaluation team they had never seen the bilateral agreements between the provincial and federal governments that outlined the roles and funding allocations for First Nations' emergency management services. The evaluation found that where these formal provincial or territorial service agreements exist , they each contained different expected activities and funding formulas. In a few discussions and survey responses, respondents specified that multilateral agreements needed to clarify the roles and responsibilities of partners so that in any emergency management scenario, there is no question about who is responsible for what aspects of emergency management services.

ISC regional offices had a broad and growing scope of emergency management responsibilities

The evaluation recognizes the support of ISC regional staff as a facilitating mechanism for various aspects of EMAP's programming. In a few discussions, First Nation and Tribal Council representatives reported good relationships with their regional ISC staff. The evaluation did hear from many discussions that ISC regional staff and third-party service providers supported First Nations to identify funding opportunities and develop proposals to access them. The evaluation heard that even with the support of staff from ISC headquarters, there might not have been enough capacity among ISC regional staff to appropriately support First Nations externally and undertake the internal processes required to administer EMAP funding, considering the scope of their responsibilities.

Regarding emergency response in particular, the evaluation heard in several discussions that ISC regional staff supported coordination among the actors involved in emergency response. They did this leading up to and during emergencies, and during recovery on an as-needed basis to ensure essential roles were filled.

ISC regional staff pointed out that the expectations on them increased along with both the COVID-19 pandemic and the increasing number and severity of emergencies, with a few discussions highlighting the risk of staff burnout. Figure 15 shows there are there were 40 full-time positions supporting emergency management across ISC's regional offices, with some funded by EMAP and a few funded through other sources.

Source: Emergency Management Directorate, ISC as of February 7, 2025

*Note: These numbers do not include staff with part-time emergency management responsibilities.

Text alternative for Figure 15. Number of full-time emergency management positions in each ISC region in 2023-24

Provinces and territories	EMAP funded	Other funding source
Alberta	10	0
Ontario	6	0
Atlantic	5	1
Quebec	0	4
Manitoba	4	0
British Columbia	4	0
Yukon	0	1
Northwest Territories	0	0

Several discussions highlighted how pressure on ISC regional staff was magnified when emergencies affected more than one First Nation at a time, and when there was more than one emergency occurring at once in a region. This meant that ISC regional staff often administered the reimbursement process for multiple First Nations simultaneously. In a few discussions, ISC staff reported that this was becoming more unmanageable as they saw the frequency and magnitude of the disasters caused by natural hazards increasing in their region. Particularly given that immediate emergency response represents only one aspect of EMAP staff responsibilities, and the administrative burdens highlighted in Finding 15, many discussions with ISC staff highlighted the need for additional human resources.

Mechanisms

The evaluation found that the administrative burden and uncertainty created by the proposal-based funding model used for NSMP and FireSmart hindered First Nations' preparedness and mitigation efforts. Furthermore, EMAP's annual funding for preparedness and mitigation did not align with the long-term capacity-building required to support First Nations' visions for the future of emergency management. Having trained staff who had enough time to apply for proposal-based funding was a common challenge for First Nations across both EMAP and ICSF. In contrast, the evaluation highlighted ICSF's success with flexible, direct allocation funding which supported communities to lead their own emergency responses.

Access

EMAP's eligibility criteria can limit First Nations' capacity to prepare for emergencies, and First Nations or Tribal Councils may face challenges accessing funding from other sources. At the same time, the evaluation highlighted the success of a simplified application process using the 'no wrong door' approach to ICSF that ISC coordinated across EMAP, the First Nations and Inuit Health Branch, and the Urban Programming for Indigenous Peoples program.

Process

EMAP's reimbursement process was found to be complex, creating delays that financially strained First Nations and their service providers. Furthermore, detailed reporting requirements were seen as burdensome and contributed to mistrust between First Nations and ISC. Though advance payments could reduce the financial burden of response and recovery, they add to the administrative burden placed on both First Nations and ISC staff.

Risk

ISC's funding streams for non-structural mitigation and preparedness were consistently oversubscribed. Although EMAP has met its obligations to reimburse eligible expenses incurred during or after an emergency, the annual process through which EMAP secures this response and recovery funding creates risk, administrative burden, and cash management challenges for the department.

Relevance

1. To what extent did EMAP and ICSF address and support the priorities and strengths of First Nations partners, including individuals with diverse and intersectional identities?
   1. 1.1 How has EMAP and ICSF design, delivery, implementation, and engagements supported or not supported First Nations partners to address their priorities and support their strengths?
   2. 1.2 What priorities or strengths of First Nations partners were not addressed or supported by the program, potentially hindering the emergency management and COVID-19 response of communities?
   3. 1.3 How has EMAP and ICSF supported or not supported First Nations to address their priorities relating to people that face increased hardship in the face of emergencies?^{Footnote 61}
2. To what extent were the services provided through EMAP culturally appropriate?
   1. 2.1 How culturally appropriate were the services received?
   2. 2.2 What makes services delivered through EMAP culturally appropriate according to First Nations?
   3. 2.3 What design elements of EMAP support or hinder the delivery of culturally-appropriate services?

Effectiveness & Efficiency

3. To what extent did EMAP and ICSF contribute to the achievement of their intended outcomes?
   1. 3.1 To what extent have the intended outcomes of EMAP and ICSF been achieved?^{Footnote 62}
   2. 3.2 What factors and influences (internal and external to the programs) inhibit or promote the achievement of intended outcomes?
   3. 3.3 To what extent did EMAP and ICSF provide sufficient support (such as human resources, training, and financial resources) to achieve their intended outcomes?
4. To what extent did EMAP and ICSF cause a meaningful change in First Nations communities, including for individuals with diverse and intersectional identities?
   1. 4.1 What desirable effects has EMAP and ICSF had in communities and for people that face increased hardship in the face of emergencies, according to First Nations?^{Footnote 63}
   2. 4.2 What factors and influences (internal and external to the programs) inhibit or promote a meaningful change?
   3. 4.3 What changes would a successful emergency management program support, according to First Nations?
5. How did the unique funding and delivery model used for the implementation of ICSF affect the outcomes achieved and efficiency of the program?^{Footnote 64}
   1. 5.1 How did the unique funding and delivery model of ICSF contribute to the COVID-19 pandemic response of communities?
   2. 5.2 What challenges did the unique funding and delivery model cause for First Nations or ISC?
   3. 5.3 To what extent did the delivery features of ICSF facilitate efficiency? Features of efficiency include, but are not limited to:
      • resources were redirected as needs changed
      • risks managed during the design and throughout implementation
      • funding available to communities when it was needed
      • resources to be allocated based on needs and engagement with populations most impacted by COVID-19
      • the cost-effective procurement of goods and services
6. What factors act as facilitators or barriers to the establishment of multilateral service arrangements under EMAP?
   1. 6.1 How has the Emergency Management Directorate responded to these barriers and supported these facilitators?
7. To what extent are the respective roles and responsibilities of EMAP partners (inside and outside of Government) appropriate, effective, and clear?
   1. 7.1 Which roles and responsibilities of EMAP partners align with their strengths and First Nations' right to self determination?
   2. 7.2 Which roles and responsibilities of EMAP partners support the achievement of the program's intended outcomes?
   3. 7.3 Which roles and responsibilities of EMAP partners are well understood?
   4. 7.4 Which roles and responsibilities of EMAP partners might need to be reconsidered?
8. How were promising practices for emergency preparedness, mitigation, response, and recovery facilitated in EMAP and ICSF?
   1. 8.1 What implementation approaches or practices promoted success?
   2. 8.2 How were these approaches or practices supported by EMAP and ICSF?
   3. 8.3 How can these approaches or practices be better supported by EMAP?

Cross-cutting Issues

9. How might the delivery of EMAP be improved to advance service transfer to First Nations communities and partners?
   1. 9.1 What does service transfer look like for First Nations partners in the context of EMAP?
   2. 9.2 How does EMAP intend to advance service transfer and support First Nations self-determination?
   3. 9.3 What factors support or hinder service transfer to First Nations communities and partners (e.g. legislative, regulatory, rigidity of Terms and Conditions [includes reporting requirements], skills and resource capacity or development, funding, etc.)?
10. How did EMAP activities and implementation processes account for and react to the impacts of climate change?
    1. 10.1 What are the impacts of climate change related to emergency management?
    2. 10.2 How did EMAP account for and react to these impacts?
    3. 10.3 What climate change effects related to emergency management are not being adequately addressed?
11. How did EMAP activities and implementation processes account for and react to the impacts of the COVID-19 pandemic?
    1. 11.1 What are the impacts of the COVID-19 pandemic related to emergency management?
    2. 11.2 How did EMAP account for and react to these impacts?
    3. 11.3 What COVID-19 pandemic effects were not adequately addressed?

Table 6. Performance indicators and targets for each outcome^{Footnote 65}

Table 7. Performance indicators and targets for each outcome