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Mr. John Williams, M.P.
Chair, Standing Committee on Public Accounts
Room 510, Justice Building
House of Commons
Ottawa, Ontario K1A 0A6

Dear Mr. Williams:

I am pleased to table the Government's response to the twenty-fourth report of the Standing Committee on Public Accounts on Chapter 10 of the December 2002 Report of the Auditor General of Canada (Department of Justice - costs of implementing the Canadian Firearms Program) as per the House of Commons Standing Order 109.

The Government agrees with the broad direction of the Public Account Committee's recommendations directed to the Canadian Firearms Program and the Treasury Board Secretariat. As this response confirms, the Government has already implemented a number of measures that will respond to the Committee's recommendations. A ministerial review of the Canadian Firearms Program is currently underway to determine what additional or alternative measures may be necessary to deliver effective gun control at a predictable and reasonable cost to Canadians.

With regard to the Committee's Recommendation 10, the Auditor General will respond to this recommendation independently in her capacity as an agent of Parliament.

I would like to take this opportunity to thank the Committee for its work in developing recommendations to improve the Canadian Firearms Program.

Yours sincerely,

A. Anne McLellan


On October 30, 2003, the House of Commons Standing Committee on Public Accounts tabled to Parliament its Twenty-Fourth Report. The focus of the Committee's report was Chapter 10 of the December 2002 Report of the Auditor General of Canada (Department of Justice - Costs of Implementing the Canadian Firearms Program). The Government of Canada was asked to respond to the fourteen recommendations made by the Standing Committee in its report. The following is the comprehensive Government Response.


That the Department of the Solicitor General prepare, in cooperation with its federal partners in the gun control program, a special report to be filed with the Clerk of the House of Commons no later that 31 December 2003 that provides the full costs of the Canadian Firearms Program across government together with data on the revenues collected and refunds made on a retroactive basis using an activity-based framework in accordance with the government's regulatory policy.


On October 30, 2003 the Minister of Justice tabled in Parliament the Department of Justice's Performance Report for the year ended March 31, 2003. This report included expanded information on the Canadian Firearms Program including: a fulsome discussion of the year's activity, disclosure of a full federal government cost history, net revenues and refunds, as well as a summary of program results, challenges and lessons learned. This expanded disclosure responded to the recommendations of the Auditor General and is consistent with the special report information requested by the committee. This reporting was also supported in the Gun Control Program Action Plan.


That in those instances in which retroactive data on costs, revenues, and refunds are not available, the Department of the Solicitor General provide a full explanation in the special report.


The Departmental Performance Report referenced above contained all cost, revenue and refund information since the inception of the program in 1995-96. Limitations on the availability of information or the assumptions made to arrive at reasonable allocations are disclosed in the notes to the schedule. None of the limitations or assumptions has a significant negative effect on the usefulness of the information. For example, amounts were rounded to the nearest one hundred thousand dollars.


That the Department of the Solicitor General include, in its special report, forecasts of costs and revenues to the point at which the Department expects the Program to become fully operational, including details on outsourcing major components of the Canadian Firearms Registration System and moving certain headquarters functions to Edmonton.


Effective in April 2003, the Canada Firearms Centre was established as a stand-alone department for the purposes of the Financial Administration Act. It is now a department within the Portfolio of the Minister of Public Safety and Emergency Preparedness (formerly the Solicitor General). As such, it will now report directly to Parliament, through the Minister of Public Safety and Emergency Preparedness, on its plans and priorities on an annual basis. Its first Report on Plans and Priorities is to be tabled in Parliament in 2004. This report will reflect the Program's strategic directions, major outcomes and a forecast of costs and revenues over the planning horizon.

The Gun Control Program Action Plan also recommended streamlining Headquarters function. The CAFC Headquarters has been consolidated and is now located in Ottawa.


That the Department of the Solicitor General include, in the special report, complete explanations for changes in costs and revenues, and changes to the overall program.


As discussed in the response to Recommendation 1, full disclosure of federal government costs and revenues for the overall program since its inception was provided to Parliament as part of the Department of Justice's 2002-03 Performance Report. Ministers are accountable to Parliament on costs outlined in the reports, and opportunities exist to seek further explanations of costs when reports are tabled.


That the Government of Canada issue a timetable for consultations with parliamentarians, stakeholders, and the public on improving the design and delivery of the Canadian Firearms Program.


On June 16, 2003, a package of proposed changes to the Firearms Act regulations was tabled in Parliament by the Solicitor General of Canada. The proposed regulations were pre-published in the Canada Gazette on June 21, 2003. The Standing Committee on Justice and Human Rights and the Senate Legal and Constitutional Affairs Committee studied the proposed regulations. The Senate Committee made two recommendations: to make fees more affordable and reasonable and to provide feedback to those who participated in the fall consultations.

An online consultation, inviting the public to provide comments on the proposed regulations and the Firearms Program through the CAFC Consultation web site, was launched in early August 2003 and ended on September 30, 2003.

In addition, last fall (between September 11 and October 30, 2003) Canada Firearms Centre officials held eight consultation sessions with groups representing firearm owners, firearms-related businesses and organizations, and professional groups with interests and responsibilities for public health and safety.

Details on specific consultation activities will be included in a summary report to be published on the CAFC website (see Recommendation 7).


That the Government of Canada include, in the consultation timetable, a target completion date.


Consultation with parliamentarians, stakeholders and the public on the design and delivery of the Firearms Program was one element of the Action Plan announced on February 21, 2003.

In addition, proposed changes to Firearms Act regulations were tabled in June 2003, for the purpose of public and parliamentary consultation. The consultations undertaken by the Canada Firearm Centre through the summer and fall 2003 therefore dealt with both the delivery of the Firearms Program and the proposed changes to the regulations.

On-line public consultations were initiated in the summer and concluded on September 30, 2003. In person consultations with individuals representing firearms owners, firearms-related businesses, and groups and professionals with interests in, and responsibilities for, public safety were carried out during the fall, through to the end of October 2003. Committees of the House and the Senate also considered the proposed changes to the regulations in October.

These consultations were completed well within the 12-month timeframe identified in the February 2003 Action Plan.


That upon the completion of consultations, the Government of Canada table a report containing the resulting findings, conclusions, and recommendations in the House of Commons.


Obtaining views from parliamentarians, stakeholders and the public on service delivery and proposed regulations is a vital part of the Government's efforts to deliver a program that continues to meet public safety objectives in the most effective and efficient manner possible. The CAFC held on-line public consultations, and regional and national stakeholder consultations over the summer and fall of 2003, as part of the Action Plan for the Firearms Program. The CAFC plans to post a summary of the consultations on its website.


That the Government of Canada implement the 1997 Project Charter, making the Canada Firearms Centre at the Department of the Solicitor General of Canada the single point of responsibility and accountability for the Canadian Firearms Program.


Effective in April 2003, the Canada Firearms Centre was created as a stand alone Department reporting to the Solicitor General, now the Minister of Public Safety and Emergency Preparedness. In this capacity, it is the central point of contact for all aspects of the Canadian Firearms Program. All federal government program costs, whether incurred directly by the CAFC or by federal or provincial partners, will be reported to Parliament in the CAFC's accountability reports (Report on Plans and Priorities, Performance Report and Commissioner's Report). The CAFC'S first Report on Plans and Priorities is expected to be tabled in Parliament in 2004.


That all federal participants in the delivery of the Canadian Firearms Program clearly set out their roles and responsibilities in a formal accountability framework signed by senior officials, and include this framework in the first report on the full costs of the Program.


The roles and responsibilities of federal participants are laid out in the legislative and regulatory framework of the program. Some departments and agencies carry out these responsibilities in their own right with funding provided directly by Parliament (i.e.: RCMP - NWEST and Public Works and Government Services Canada - Accommodation). Others carry out their program responsibilities on a fee for service basis (i.e.: RCMP - Canadian Police Information Centre system, Canada Customs and Revenue Agency - Import of firearms). This multi-faceted and complex program delivery structure is managed in such a way that the participants must respond in a flexible fashion to day-to-day changes in priorities. As such, it is managed on a bilateral basis rather than through one comprehensive formal accountability framework. The Centre has developed a Management Accountability Framework to guide its operations. This framework will provide the basis for the Centre's first Report on Plans and Priorities (RPPs). The affected Departments are required by Parliament to report on their activities through regular reporting procedures such as Departmental Performance Reports and RPPs.


That the Office of the Auditor General of Canada proceed with its plans to conduct an audit of the government of Canada's expenditure management system that includes an examination of the Supplementary Estimates process.


The Office of the Auditor General is an independent audit office serving Parliament and Canadians. Because of its independence, the Office of the Auditor General will respond to Recommendation 10 in an independent manner that it determines is required.


That Treasury Board Secretariat begin immediately to monitor departmental performance reports actively and work with departments and agencies to ensure adherence to its guidance, paying particular attention to the need to present balanced, complete, accurate reports, and to integrate financial with non-financial performance information.


The Treasury Board Secretariat agrees that Departmental Performance Reports (DPRs) to Parliament should be actively monitored. Over the last several years, TBS has undertaken a number of initiatives aimed at monitoring and supporting overall improvements to DPRs. These efforts included the introduction of reporting principles in its guidance in 2001, which are available on the TBS website, followed by reviews of DPRs to assess adherence to principles and feedback to departments and agencies on how to strengthen their DPRs.

As part of its continued efforts to improve the quality of reports to Parliament, this year, the Treasury Board Secretariat is taking an integrated approach to reviewing both Departmental Performance Reports (DPRs) and Reports on Plans and Priorities (RPPs) to ensure greater consistency between planning and performance reporting. These reviews will also assess adherence to TBS guidelines and help provide advice and support to departments and agencies to improve linkages between planning and performance, resources invested and results achieved, as well as help strengthen the relevance and accuracy of information provided to Parliamentarians.

There are some 87 departments and agencies currently producing RPPs and DPRs; however, a majority of these are characterized by steady state, on-going operations with little fundamental change in their primary plans, priorities and program performance on a yearly basis. A comprehensive yearly review of all these documents would be very resource intensive and would not be cost-effective in terms of identifying significant opportunities for change or improvement. Instead, TBS will target approximately 15 to 20 departments per year and review both their DPRs and RPPs, thus allowing for an integrated review throughout the reporting cycle. All DPRs would be reviewed over a 3 to 5 year cycle. TBS will also work closely with these selected departments throughout the fiscal year to ensure improvements to their reports are made, more informed feedback to departments and agencies is provided, and better performance reports that influence planning are produced and tabled in Parliament. TBS has begun to implement such an integrated approach, which can be managed within existing TBS resource and capacity levels.


That in its monitoring activity, Treasury Board Secretariat devote particular attention to performance reporting on horizontal issues, areas of high risk and programs and activities involving significant levels of expenditure.


The Treasury Board Secretariat agrees with this recommendation. Horizontal initiatives and programs of high risk and significant levels of expenditure are an important component of the government's agenda and should be monitored.

Through the targeted reviews of DPRs and RPPs described in the response to Recommendation 11, TBS will be monitoring closely performance reporting on horizontal issues and programs that are of high risk and high materiality.

In addition to monitoring these key initiatives at the reporting stage, TBS is also ensuring that the structures necessary to facilitate this reporting are in place at the front end. For instance, as part of its continued efforts to improve monitoring of horizontal initiatives, TBS will work with PCO to strengthen governance and accountability frameworks for horizontal initiatives at an early stage in their development. For example, TBS is currently supporting the Climate Change Secretariat in the development of a Results-Based Management and Accountability Framework.

TBS provides guidelines, advice and tools to assist departments and agencies in reporting on major horizontal initiatives, including plans and priorities, expenditures, activities and results achieved. This year departments and agencies reported on over 30 horizontal initiatives in their Departmental Performance Reports. Information on these initiatives is available on the TBS Horizontal Results Database, which can be accessed via the TBS website.

TBS is also improving reporting on horizontal issues through the President's annual report to Parliament, Canada's Performance, which clusters departments and agencies into 26 horizontal areas. For example, thirteen federal organizations contribute to the horizontal area entitled "An innovative, knowledge-based economy".


That Treasury Board Secretariat begin to provide information on its monitoring of performance reports and its review and approval of departmental and agency spending proposals. This information should reference: the human and financial resources devoted by the Secretariat to these activities; the number of reports monitored and corrective interventions made; and, the number funding requests reviewed, amounts involved, changes requested, and final approvals given.


The Treasury Board Secretariat agrees in general with the need to improve its accountability and reporting to Parliament on the performance of its oversight role. It is committed to improving its response in this regard, and will give careful consideration to the areas recommended by the Committee. The Secretariat will need to respect the confidentiality requirements associated with Treasury Board decisions.


That Treasury Board ensure that its policy on major Crown projects is clear and that it be consistently applied to all projects that meet its criteria.


Treasury Board Secretariat fully supports the Committee's recommendation that the Management of Major Crown Projects Policy be consistently applied to all projects meeting the established criteria. This policy is being reviewed as part of a broadbase review of all Treasury Board Secretariat policies.