Audit, Evaluation and Risk Oversight
Canadian Food Inspection Agency
Final Report
November 2008
Approved by the CFIA
Evaluation Committee, February 4, 2009
The objective of this evaluation is to evaluate the design and delivery, and the success of the Canadian Food Inspection Agency (CFIA) Invasive Alien Species Program (IAS Program) in implementing the Action Plan for Invasive Alien Terrestrial Plants and Plant Pests, which was a result of the National Invasive Alien Species Strategy for Canada (NIAS Strategy). The evaluation is formative in nature and process-based, and is founded on the CFIA IAS Program Results-based Management and Accountability Framework (RMAF). The recommendations are intended to guide any required adjustments to the program going forward. The main objectives were to determine the effectiveness of the IAS Program design, governance structure, and allocation of resources; determine the success of the program’s activities in achieving their objectives; and propose improvements to the program’s design, governance structure, and allocation of resources.
Under the existing Plant Health Program, CFIA’s focus was primarily on invasive alien plant pests, with only a small investment to address invasive alien plants. The $50M in new resources from Budget 2005 have been invested in the IAS Program; with approximately two-thirds of the funding directed towards invasive alien plant pests, and the remainder to increase activities related to invasive alien plants.
The CFIA IAS Program focuses on measures to prevent and control the spread of invasive alien plants or plant pests that could negatively impact wild or domestic plants in Canada. The program is aligned with An Invasive Alien Species Strategy for Canada (NIAS Strategy), and is a collaborative effort with other federal partners.
The evaluation was conducted during the spring and summer of 2008, and covered the four-year period from 2004-2005 to 2008-2009. Historically, under the Plant Health Program, invasive alien species-related activities had relatively low visibility with a limited number of resources. In 2005, CFIA received $50M over five years for the IAS Program. This evaluation is the first assessment of the IAS Program and is based on the May 2006 CFIA Results-based Management and Accountability Framework (RMAF) for the IAS Program.
The evaluation was conducted using multiple lines of evidence, including:
The evaluation has generated a number of conclusions on two areas of interest: program design and delivery, and success. Four recommendations are presented to address the most significant issues found.
As a general observation, the IAS Program is only now hitting full stride and producing significant and evident outputs and results. The following are some of the major challenges the program faces as it continues to move forward.
1. Lack of Integrated Program Management
It is difficult to establish a clear picture of the overall program plan because planning and reporting are conducted branch-by-branch, not on an integrated basis. A lack of integration in data collection systems also makes it difficult to glean a true sense of program performance. In addition, there is no clear reporting against branch work plans. Coordinating mechanisms exist such as the IAS Steering Committee and the IAS Coordinating Committee, but these are largely informational in nature.
The end result is the potential for misunderstanding or miscommunication regarding what is planned and what is actually delivered for the program. In the absence of an integrated database for program management and information collection, the opportunities for misunderstanding are compounded and have been noted by this evaluation.
2. Disconnect between the stated corporate priorities and the program’s profile with senior management decision makers
The IAS Program has certain new areas of responsibility upon which it must deliver - two of these are the Plant Health Control and Tracking System (PHCTS) and the national Plant Protection Network (PlantProNet). Both are building blocks necessary to achieve the stated outcomes of the IAS Program. PHCTS is currently on hold. Development of a plant protection network focused on targeted diagnostic lab partnerships is proceeding. Given its resourcing, the program itself has undertaken as much action as it can in designing and developing these initiatives. Continued development of these initiatives would benefit from further funding.
3. Unclear decision-making process and criteria with respect to reallocation of program resources
There is a lack of clarity concerning budget reallocation. The Finance, Administration, and Information Technology Branch (FAIT) has confirmed that IAS funding was fully allocated as per the program’s financial plan. At the same time, however, there appear to be some challenges associated with resources at the program level. For example, two key initiatives - PHCTS and PlantProNet - would benefit from additional program funding. Interestingly, over the first three years of the program more than $6M or approximately 23% of the funding was lapsed.
4. Lack of a robust data collection and performance monitoring system
The lack of solid performance management information is hampering the assessment of overall program performance, and hindering the reporting against stated outcomes and results described in the RMAF and the development of a more proactive risk-based approach to invasive alien species and plant health in general.
The key recommendations are:
1. Strengthen program management by the IAS Steering Committee and improve the integration of work planning and priority setting across the branches.
2. Engage and leverage executive support for critical IAS Program activities and priorities, including PHCTS, PlantProNet and the Invasive Plant Policy.
3. Improve the transparency of budget reallocation exercises at the branch level to ensure effective use of all program resources.
4. Strengthen data collection and performance monitoring systems, including a review of RMAF performance indicators at the outcome levels.
In September 2001, federal, provincial and territorial Ministers of the Environment, Wildlife, Forests and Fisheries and Aquaculture committed to develop a national plan to address the threat of invasive alien species in Canada. Under the leadership of Environment Canada (EC), four working groups developed a national invasive alien species strategy for Canada, and corresponding draft action plans were developed that address issues related to i) terrestrial plants, ii) terrestrial animals, and iii) aquatic organisms. The resulting document, An Invasive Alien Species Strategy for Canada (NIAS Strategy), was approved by the Ministers in September 2004. Following approval of the strategy, the draft action plans were finalized by the working groups.
The NIAS Strategy is co-delivered by federal, provincial and territorial governments, with CFIA providing overall program direction for actions pertaining to the prevention or mitigation of invasive alien plants and plant pests. The CFIA and the Ontario Ministry of Agriculture, Food, and Rural Affairs co-chaired the Terrestrial Plant and Plant Pests Working Group on Invasive Alien Species (TPPWG). This working group built upon the draft action plans described above and produced two planning documents: Phase 1 Key Initiatives, and Phase 2 Implementation Plan.
CFIA, under the existing Plant Health Program, was focusing primarily on invasive alien plant pests with only a small investment addressing invasive alien plants. The CFIA has invested approximately two-thirds of the new resources from Budget 2005 to augment activities related to invasive alien plant pests, and one-third into new activities relating to invasive alien plants.
The IAS Program includes:
The objective of the NIAS Strategy is to commence implementation of the priority initiatives, namely prevention, early detection and rapid response to new invaders, as well as management of established and spreading invaders. The IAS Program will contribute to the achievement of this objective through the following intermediate outcomes as described in the RMAF logic model:
The IAS Program activities fall into the following five categories:
Please refer to Annex A for the IAS Program Logic Model.
This report includes the following sections:
The evaluation framework is based on the RMAF for the IAS Program. Modifications were made to the evaluation framework identified within the RMAF, based in part on consultations with the CFIA Evaluation Directorate and on six strategic interviews held with CFIA management. Please see Annex B for a list of interviewees and Annex C for the evaluation framework.
The objective of the evaluation was to evaluate the design and delivery and the success of the CFIA IAS Program in implementing the Action Plan for Invasive Alien Terrestrial Plants and Plant Pests and alignment with the NIAS. The evaluation was formative in nature, process-based, and based on the IAS RMAF. The recommendations are intended to guide any required adjustments to the program going forward. The main objectives were to determine the effectiveness of the IAS Program design, governance structure, and allocation of resources; determine the success of the program’s activities in achieving their objectives; and propose improvements to the program’s design, governance structure, and allocation of resources.
The following is the list of the evaluation questions based on the 2001 Treasury Board Evaluation Policy, document review, IAS RMAF and the priorities of CFIA management.
Design and Delivery
Q1: Are there appropriate governance structures in place to deliver the program activities and outputs and meet the objectives?
Q2: To what extent does CFIA understand its roles and responsibilities in the overall NIAS Strategy?
Q3: Has the IAS Program been effective in contributing to the plant protection activities? What have been the impacts?
Q4: Do the resource levels appropriately reflect the scope of the activities?
Q5: Has the program cooperated effectively with its partners?
Q6: Are the roles and responsibilities of CFIA clearly documented and understood?
Q7: Has a performance and financial monitoring system been implemented? How effective is the ongoing monitoring framework in providing a complete picture of the IAS Program performance and allocation of resources?
Success
Q8: Are planned activities actually being implemented and producing the expected outputs?
Risk Analysis
8.1 To what extent is there information gathering?
8.2 To what extent are programs, policies and procedures developed?
8.3 To what extent is emergency planning and preparedness being
undertaken?
8.4 To what extent is there a PHCTS?
8.5 To what extent are there verification products?
8.6 To what extent are there compliance verification and import results?
Science and Technology
8.7 To what extent is there information gathering?
8.8 To what extent are there verification results?
8.9 To what extent are there laboratory test results and reports?
8.10 To what extent are there diagnostic, surveillance and inspection methods
and procedures in place?
8.11 To what extent is the national PlantProNet established and
functioning?
Legislation, Regulations and Policy Framework
8.12 To what extent is there an Invasive Plant Policy?
8.13 To what extent are there Memorandums of Understanding (MoUs), agreements
and joint initiatives with federal/provincial/territorial (FPT) partners?
8.14 To what extent are there updated legislation, regulations and
policies?
8.15 To what extent are there consultations on the legislation, regulations
and policy framework?
Education, Awareness and Outreach
8.16 To what extent is there a NIAS Communication
Strategy?
8.17 To what extent is there an IAS Outreach Strategy?
International Cooperation
8.18 To what extent are there international training workshops?
8.19 To what extent are there incoming missions and delegations on invasive
alien species?
Q9: Are complete and planned activities meeting, or likely to meet, articulated objectives (immediate outcomes)?
9.1 To what extent is entry of new invasive plants and plant pests managed
in a risk-based manner?
9.2 To what extent are new invasive plants and plant pests, and the spread of
existing alien plants and plant pests, detected within Canada?
9.3 To what extent are responses to new plants and plant pests planned?
9.4 To what extent is there increased stakeholder awareness and access to
information on plant pests/diseases and prevention control strategies?
Q10: Has the program been implemented as planned? Have there been unforeseen barriers/challenges to implementing the program as planned?
The evaluation utilized the following methods in the collection and analysis of information:
A list of interviewees can be found in Annex B. A list of documents reviewed can be found in Annex D and the interview guides in Annex E. The case study can be found in Annex F.
There is a lack of performance information related to the IAS Program. No commonly accepted definitions exist to clarify what an IAS Program-attributable activity is; therefore IAS activities are not always captured in the current data systems, and data capture lacks consistency over the period covered by the evaluation. The end result is that the data contained in the various systems used by the different branches is of limited use - it is incomplete and difficult to analyze. Consequently, we have placed a greater reliance on qualitative data sources.
Due to time and budget limitations site visits were not possible; telephone interviews were conducted instead. A limited number of external stakeholders were also interviewed.
While not initially included as an evaluation issue in the evaluation framework, program relevance in terms of consistency with departmental and government-wide priorities is worth noting. It is easily determined that the IAS Program remains very relevant. Maintaining a safe and sustainable plant and animal resource base continues to be a strategic outcome for CFIA as outlined in its Program Activity Architecture (PAA), and invasive alien species have been highlighted as priorities in the CFIA Corporate Risk Profile.
From a government-wide perspective, the IAS Program itself is a response to the NIAS, which seeks to protect Canada’s ecosystem and biodiversity. Invasive alien species are considered the second most significant threat to biodiversity in the world after habitat loss.1 Research continues into the social, economic and environmental impacts of invasive alien species and all indications show they have a strong negative impact in all areas. The IAS Program therefore addresses a very real need.
1 International Union for the Conservation of Nature.
This section of the report presents an assessment of the design and delivery of the IAS Program. It examines the management processes, coordination across other areas of CFIA and other stakeholders, the regulatory base, and the approach to inspection. Findings are derived primarily from document review and key staff and management interviews.
Q1: Are there appropriate governance structures in place to deliver the program activities and outputs and meet the objectives?
For the purposes of the evaluation, the term governance structure has been defined as a senior management decision-making structure with direct accountability for program results. This is distinguishable from coordinating structures which are primarily used for inter-branch coordination and information sharing but lack the ability to set priorities and make decisions for the program as a whole.
Coordinating structures are already in place - for example, the IAS Steering Committee and the IAS Coordinating Committee. These committees are primarily information-sharing in nature; they do not have the authority to address financial, performance, or accountability issues within the IAS Program.
At the executive level, there is no IAS Program-specific governance body. This is evident by the lack of decision making or priority setting with regards to the Invasive Plant Policy, the delays in the implementation of the PHCTS, and the lapsing of 23% of program funds in the first three years of the program. Finally, there is no evidence of IAS Program-specific metrics at the corporate level. The IAS Program is not reported on as a separate and specific line item in the PAA, but rather is rolled up into the overall Plant Health Program activities as outlined in the RMAF.
Q2: To what extent does CFIA understand its roles and responsibilities in the overall NIAS Strategy?
Interviews with various CFIA personnel reveal a clear understanding of the roles and responsibilities at the working level within the IAS Program across the branches. Other government departments (OGDs) have also confirmed CFIA’s commitment to and understanding of the NIAS priorities and participation in established federal and FPT coordinating structures and initiatives, such as the DG Interdepartmental Committee on Invasive Alien Species, the regional councils, and the Invasive Alien Species Partnership Program.
Of note, however, is that the stated priority afforded to the IAS Program in corporate documents is not reflected in the level of senior management attention to the program, as elaborated in the findings for Section 3.1, Question 1.
Q3: Has the IAS Program been effective in contributing to the plant protection activities? What have been the impacts?
The IAS Program has contributed to plant protection activities as evidenced by the invasive alien species plant and plant pest risk assessments and surveys; the new policies and procedures such as the new Plant Import Inspection Manual, Plant Emergency Response Plan (draft), and the Canadian Invasive Plant Framework; the establishment of communication and outreach products and plans; and the undertaking of national and international training activities.
Evidence of the impacts of the IAS Program, however, remains inconclusive due to a lack of performance data. In the absence of the PHCTS, the IAS Program data lacks integration and is difficult to consolidate. Some information remains in paper format and can be difficult to access in a timely fashion (e.g., information at the Import Service Centres). At the operational level, some confusion exists about what to capture as an IAS Program activity, and what to capture as the Plant Health Program - possibly leading to under- or mis-reporting of activities attributable to the IAS Program.
Q4: Do the resource levels appropriately reflect the scope of the activities?
The activities and outputs achieved to date are, for the most part, consistent with the level of resourcing received by the various program leads, except in the case of the Operations Branch, where it appears resources were under-utilized. This funding has allowed the Agency to initiate activities in areas that were previously under-prioritized and/or underfunded. However, the activities and outputs of the program have not necessarily been maximized as witnessed by approximately $6M in lapsed funding over three years.
As an example, the PlantProNet has not yet been fully implemented, but a Secretariat has been established and design and development work has been undertaken. Financial requirements to implement and maintain a network appear to be beyond the funding that was awarded.
Another example concerns the resource allocations within the Operations Branch, which are not reflective of IAS Program-specific funding. Work plans have projected full tasking of the 25 full-time equivalents (FTEs) allocated to the Operations Branch; however, the actual reported tasking in 2007-2008 was less than 13 FTEs.
Finally, the development of PHCTS was not specified in the request of funds from Treasury Board and therefore did not receive any directed funding. A business case and design work has been completed and a reasonable budget generated, but a funding source has not yet been identified. Therefore, the project remains on hold pending identification of funding sources.
Q5: Has the program cooperated effectively with its partners?
Clear evidence can be found that the IAS Program has cooperated effectively with its partners. From an FPT perspective, there has been participation in the DG Interdepartmental Committee on Invasive Alien Species and the FPT Coordinating Committee, co-chairing of the TPPWG, and participation in Regional Councils. Finally, there has been cooperation and collaboration with provincial counterparts (e.g., regional surveillance and provincial diagnostic laboratories).
From the OGD perspective there is solid evidence of good cooperation with CBSA, CFS, and EC. However, there is a perceived need by some departments to bring OGDs into a consultation process earlier in the development of CFIA-led IAS communications products. Areas that have been identified as requiring improvement with CBSA include communication and clarity around the organization of inspection blitzes, the limitations of World Customs Organization codes, and the challenges associated with inland inspections versus point-of-entry inspections.
Q6: Are the roles and responsibilities of CFIA clearly documented and understood?
The roles and responsibilities of CFIA are clearly documented, as evidenced by the NIAS Strategy, and the TPPWG Action Plans.
The CFIA’s understanding of the program has translated into an RMAF for the IAS Program, branch-level work plans, a revised Plant Import Inspection Manual, and training of CFIA personnel consistent with their roles and responsibilities as outlined in the documents mentioned above.
However, CFIA senior executives’ understanding of the roles and responsibilities of CFIA regarding the IAS Program could be improved, as discussed previously in Section 3.1, Question 1.
Q7: Has a performance and financial monitoring system been implemented? How effective is the ongoing monitoring framework in providing a complete picture of the IAS Program performance and allocation of resources?
There is no evidence of an integrated IAS Program performance monitoring system, although a program financial monitoring system is in place. The PHCTS has not been implemented due to the lack of an identified funding source. Currently, work plans and reports are done separately by branch (with some input from other branches) and are not consolidated nor reported against.
MRRS operational information only began flagging IAS Program activities in 2007-2008, but roll-up is unclear as to the different IAS Program activities. Further, MRRS does not reference work plans, and at the operational level some confusion still exists as to what to code is an IAS Program activity. In the case of the Seed Program, samples have always been viewed as shared IAS and seed samples since both programs benefit from the information gathered. As such, no distinction has ever been made as to the samples taken.
From a financial perspective, financial tracking is possible through the use of fund codes, cost centres and general ledger codes. National internal orders, which would allow for tracking of expenses by the various IAS Program activities (e.g., risk analysis) are not mandatory and were not established. Various branches did set up a variety of their own internal orders; however, these were not communicated across all branches nor were all branches requested to use them. Please see Annex G for a summary of financial information.
The current monitoring systems therefore provide only a limited and fragmented picture of IAS Program performance and allocation of resources. In addition, the financial and non-financial performance information is not easily comparable - e.g., the IAS Program is not specifically reflected in the PAA as a sub-activity, which would bring both the financial and non-financial performance information to the fore in corporate plans and reporting. Merely a narrative mention is made of the IAS Program in the Departmental Performance Report (DPR) and the Report on Plans and Priorities (RPP) (no IAS Program-specific metrics). Work plans are done separately by each branch (with some degree of input from others) but not integrated and not reported against systematically.
There are many positives about the design and delivery of the program. Coordinating mechanisms are in place, the roles and responsibilities within CFIA and among its partners are well understood and documented, and overall the IAS Program is being implemented. However, challenges still exist that need to be addressed. The following conclusions are drawn from the above findings:
Recommendations:
This portion of the evaluation contains an assessment of the success of the IAS Program in meeting its stated objectives. It examines activities performed against the plans, the outcomes of those activities and the overall impact of the program. Findings are derived primarily from document reviews and key staff and management interviews.
Q8: Are planned activities actually being implemented and producing the expected outputs?
Table 2 lists the activities and outputs of the IAS Program components as listed in the RMAF logic model, which is included in Annex A. The right-hand final column summarizes our findings on the implementation of these activities and outputs.
Table 2: Logic Model Activities and Outputs
Component: Risk Analysis
Activities/Outputs | Are they being implemented? |
---|---|
Examples of risk assessments, plant and pest risk assessments (PRAs) |
|
Import policies and enforcement procedures |
|
Emergency planning and preparedness being undertaken |
|
PHCTS |
|
Verification products (site inspection results) |
|
Compliance verification and import results (certificates, import documentation count, import permits) |
|
Component: Science and Technology
Activities/Outputs | Are they being implemented? |
---|---|
Information gathering reports, science advice, etc. |
|
Verification results such as surveys, audit and monitoring |
|
Laboratory test results and reports |
|
New diagnostic, surveillance and inspection methods and procedures |
|
PlantProNet established |
|
Component: Legislation, Regulations and Policy Framework
Activities/Outputs | Are they being implemented? |
---|---|
Invasive Plant Policy |
|
MoUs, Agreements, joint actions with FPT Partners |
|
Updated legislation and regulations and policies |
|
Consultations on the legislation, regulations and policy framework |
|
Component: Education, Awareness and Outreach
Activities/Outputs | Are they being implemented? |
---|---|
NIAS Communication Strategy |
|
IAS Outreach Strategy |
|
Component: International Cooperation
Activities/Outputs | Are they being implemented? |
---|---|
Workshops, expert panels, standards development |
|
International missions and delegations |
|
PHCTS
The IAS Program has completed a project charter, design work and developed business cases in support of the implementation of the PHCTS. However, the PHCTS has not been implemented due to the fact that there were no resources specifically dedicated for this purpose. The absence of an integrated database for performance management puts into question the ability of the Agency to play its role in the development and implementation of PlantProNet and a national surveillance system.
Verification Products
An augmentation in the actual number of product inspections was not expected; instead, better targeting of inspections related to invasive alien species became the focus. Information related to inspection results is being collected at the local level, and the MRRS system is used to capture and roll up this information at the national level. However, the information provided to the evaluators by the Operations Branch did not clearly define inspection activities as related to the IAS Program, but rather to the Plant Health Program as a whole.
The quality of the data is also questionable based on two observations. First, the MRRS system only started to incorporate fields for coding IAS Program activities in the 2007-2008 period - thus making baseline comparisons impossible. Second, the need still remains to improve the understanding of inspection officers on what should be coded as an IAS Program-related activity as opposed to a regular Plant Health Program activity. It would seem that the current confusion might be leading to inconsistent and therefore inaccurate reporting.
Compliance, Verification and Import Results
The data collected in respect to this area, namely the number of plant import permits, provides no context or relation to the IAS Program. The number of plant import permits has increased steadily since 2004 but the reasons for the increase are not clear.
PlantProNet
There has been a considerable amount of development and design activities, but the actual PlantProNet is not yet fully established. Activities include establishment of a Secretariat, identification of FPT contacts, analysis of provincial plant health laboratory capacity, review and analysis of other national networks and international plant health networks, and capacity analysis of plants and pests of special interest. It appears that the actual costs of implementing and maintaining the PlantProNet were not adequately contemplated nor reflected in the funding received. The focus has been on establishing the Secretariat, and undertaking capacity analysis and gap analysis studies.
Q9: Are complete and planned activities meeting, or likely to meet, articulated outcomes (immediate)?
The comments that follow are qualified by the fact that there is a lack of statistical data on activities and outputs currently being generated for the IAS Program, for reasons already highlighted. It is also worth noting that during the period of this evaluation; the IAS Program was two and a half years into implementation, and, by all indications, is only now hitting full stride and producing significant and evident outputs and results. Further progress is challenged by the lack of clarity surrounding funding allocations and reallocations at the branch level.
While there appear to be some challenges associated with resources at the program level, FAIT has confirmed that IAS funding was fully allocated as per the program’s financial plan and that, in fact, over the first three years of the program more than $6M or approximately 23% of the funding was lapsed.
Immediate Outcome 1 - Entry of new invasive plants and plant pests is managed in a risk-based manner.
Overall, invasive plants and plant pests are managed in a risk-based manner but areas for improvement still exist. A risk-based framework for managing the entry of new invasive plants and plant pests is under development. The Invasive Plant Policy is the main initiative to put this in place. To date, the development of this policy is delayed pending the finalization of a screening decision-making tool that will become a component of the policy. This policy will also cover biosafety and seeds aspects in respect to IAS, and this has also increased the time necessary to conduct appropriate internal consultation. In the interim, the Plant Import Inspection Manual has been revised and updated, plant pest, plant and weed risk assessment methodologies have been developed, and training has been provided to inspection officers.
Progress in the development of a pathway analysis methodology has been slower than anticipated. This work was initially integrated into the NAPPO IAS Committee work plan, based on the relatively advanced work of the U.S. on pathway analysis. As of August 2008, however, a draft of the Regional Standards for Phytosanitary Measures (RSPM No. 31) has been posted on the NAPPO Web site for country consultation.
The importance of completing the risk-based framework for new invasive plants and plant pests cannot be overstated. The finalization of the decision-making screening tool, and approval of the Invasive Plant Policy, and finalization of a pathway analysis methodology are inter-related. There is clear evidence of progress on all these items, but delays in finalization may impact on the program as a whole.
Immediate Outcome 2 - New invasive plants and plant pests and the spread of domestic alien plants and plant pests are detected within Canada.
There has been only one new invasive plant pest detected since the start of the IAS Program - namely the potato cyst nematode (PCN). Surveys and monitoring of the PCN threat are ongoing, but these currently fall outside the IAS Program. Examples of some areas of direct IAS Program involvement include: the woolly cup grass incursion (Annex F), collaborative programs with NRCan such as the Exotic Forest Pest Survey, the Exotic Forest Pest Guidebook, and agreements with provinces on critical pest management - e.g., in Ontario, agreements in relation to the Emerald ash borer (EAB) and Asian long-horned beetle (ALHB). All these activities will greatly assist in early detection of invasive plant and plant pests.
From the sum of these activities and outputs there are indications that planned activities will meet the articulated outcome, although areas for improvement remain. For example, the CFIA Web site offers survey information up to 2006, although surveys have continued to the present. This delay in posting survey results is counterproductive to the goals and objectives of the program.
Immediate Outcome 3 - Responses to new invasive plants and plant pests are planned.
There are indications that the program will realize this outcome. A new Plant Emergency Response Plan has been drafted and is currently undergoing internal consultation within CFIA. This is the first time such a plan has been drafted, and it falls under CFIA’s overall Emergency Response Plan. As part of the Plant Emergency Response Plan, management plans for particular plants or plant pests of interest are defined. Various plant and pest management plans exist that were developed outside of the IAS Program, but the Woolly Cup Grass management plan has been directly related to the IAS Program. In addition, the work on the firewood campaign can be considered evidence of a planned response. The important milestone here will be to have the overall Plant Emergency Response Plan in place. The overall status in this area is considered to be progressing but behind schedule.
The CFIA-Ontario MoU on Critical Pest Management is another excellent example of how the program has moved to work with partners to effectively address the need for planned responses to invasive plants and plant pests. This agreement related mainly to the Emerald ash borer and the Asian long-horned beetle. Such agreements are also under discussion with British Columbia, Quebec and New Brunswick. IAS Regional Councils are also an effective platform to plan responses around critical plants and plant pests, and have played a role in initiating and supporting discussion on critical pest management. One very positive result of the IAS Program, as noted by an official from another government department, has been the breaking down of jurisdictional boundaries and forming new working relationships so “organizations are ready when something does arrive.”
Immediate Outcome 4 - Increased stakeholder awareness and access to information on plant pests and diseases and prevention and control strategies.
Indications suggest that the program will achieve this outcome. The IAS Program has developed various coordination and consultation mechanisms at the federal, FPT and provincial/territorial (PT) levels and internal to CFIA. All of these have increased stakeholder awareness of the importance of addressing invasive alien species.
Table 3: Coordination and Consultation Mechanisms
Level | Mechanism |
---|---|
Federal |
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FPT |
|
PT |
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CFIA |
|
The CFIA has developed a draft IAS Communication Strategy and communication products have been developed and distributed, including information products on the Invasive Alien Species Strategy for Canada, the Action Plan for Terrestrial Plant and Plant Pests, the Exotic Forest Insect Guidebook, and Invasive Alien Plants in Canada. There have also been targeted campaigns, as in the case of firewood.
As a result of IAS funding, the augmentation and introduction of new activities in the area of invasive plants has also drawn in new stakeholders, as in the case of the cut flower industry and nurseries. Consultation and collaboration is growing between the various stakeholders involved in the cut flower industry that has led to reportedly increased awareness of regulations and protocols in the industry.
Q10: Has the program been implemented as planned? Have there been unforeseen barriers/challenges to implementing the program as planned?
Table 4 attempts to align TPPWG Action Plan items (developed before the final funding decision) with the CFIA RMAF (based on the funding decision) and progress to date. The activities as highlighted in the RMAF do not necessarily directly link to the TPPWG Action Plan, so the following is an approximation.
Table 4: Action Plan Comparison
Leadership and Coordination
TPPWG Action Plan | RMAF | Actual |
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Legislative and Regulatory
Action Plan | RMAF | Actual |
---|---|---|
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Science - Research
Action Plan | RMAF | Actual |
---|---|---|
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Science - Surveillance and Diagnostics
Action Plan | RMAF | Actual |
---|---|---|
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Risk Analysis
Action Plan | RMAF | Actual |
---|---|---|
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Education and Public Awareness
Action Plan | RMAF | Actual |
---|---|---|
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International Cooperation
Action Plan | RMAF | Actual |
---|---|---|
|
|
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There are three areas where the program has not fully produced the desired outputs. The enhanced data collection through the PHCTS has not progressed beyond basic design. The actual funding for implementation of PHCTS has not yet been identified. In the case of PlantProNet, design work has been undertaken, a Secretariat established, and steps taken towards the implementation of a plant protection diagnostic laboratory network is proceeding. Continued development of both PlantProNet and PHCTS would benefit from further funding. Finally, the Invasive Plant Policy remains a draft document.
1. Lack of clear reporting on IAS Program-specific operational activities and resource usage.
The Operations Branch utilizes the MRRS system to collect information and report on it at the national level. While Operations Branch IAS Program work plans clearly reflect the activities to be conducted and the allocation of human resources, the information provided by the MRRS system is not traceable to the work plan as IAS Program-related activities are often rolled up with ongoing plant health activities. In addition, confusion exists at the inspector level as to how to code certain activities as either related to the IAS Program versus the Plant Health Program. In the absence of an integrated database, such as the PHCTS, there is significant reliance on the MRRS for quality data which, as mentioned above, is associated with its own challenges. Finally, there is evidence that the actual allocation of FTE time reported is well below the resources allocated to the Operations Branch for the IAS Program.
2. Funding for the implementation of the PHCTS and PlantProNet.
The importance of an integrated information system has been stressed throughout this report. It is essential to perform risk identification and assessment and to monitor the activities and results achieved by the program. The IAS Program and the PHCTS itself have been clearly highlighted as priorities for the Agency in various corporate documents such as the RPP (2007-2008) and the Corporate Risk Profile (May 2008).
Design work for a national PlantProNet has been undertaken, a Secretariat established, and steps have been taken towards the implementation of a plant protection diagnostic laboratory network. Continued development of PlantProNet would benefit from further funding.
3. Delay in the completion of the Invasive Plant Policy.
For reasons already highlighted in this report, development of the Invasive Plant Policy has been delayed. This will be a significant piece of the IAS Program and will put in place the overall risk-based framework for preventing and detecting invasive alien plants and plant pests; it is critical that this policy be finalized as soon as possible.
4. Role clarity with the CBSA.
The second area of improvement directly impacts the efficacy of the IAS Program. The CBSA retains authority over points of entry; the CFIA is often dispatched to inspect products only after they have been moved inland to their destination. This has two effects: first, the number of inspections that can be conducted is greatly reduced given the dispersed and longer distances that inspectors need to travel; and second, the transportation of products that are potential pathways for invasive plants or plant pests, from point-of-entry to inland destinations, provide opportunities for the spread of invasive alien species before the product can even be inspected.
Recommendations:
As a general observation, by all indications, the IAS Program is just now reaching its full stride and producing significant and evident outputs and results. The following are some of the major challenges facing the program as it continues to move forward.
1. Lack of Integrated Program Management
It is difficult to establish a clear picture of the overall program plan because planning and reporting are conducted branch-by-branch, not on an integrated basis. A lack of integration in data collection systems also makes it difficult to get a clear picture of program performance. In addition, there is no clear reporting against branch work plans. Coordinating mechanisms exist such as the IAS Steering Committee and the IAS Coordinating Committee, but these are largely informational in nature.
The end result is the potential for misunderstanding or miscommunication regarding what is planned and what is actually delivered for the program. In the absence of an integrated database for program management and information collection, the opportunities for misunderstanding are compounded and have been noted by this evaluation.
2. Disconnect between the stated corporate priorities and the program’s profile with senior management decision makers
The IAS Program has certain new areas of responsibility upon which it must deliver - two of these are the Plant Health Control and Tracking System (PHCTS) and the national Plant Protection Network (PlantProNet). Both are building blocks necessary to achieve the stated outcomes of the IAS Program. PHCTS is currently on hold. Development of a plant protection network focused on targeted diagnostic lab partnerships is proceeding. Given its resourcing, the program itself has undertaken as much action as it can in designing and developing these initiatives. Continued development of these initiatives would benefit from further funding.
3. Unclear decision-making process and criteria with respect to reallocation of program resources
There is a lack of clarity concerning budget reallocation. Finance, Administration, and Information Technology Branch (FAIT) has confirmed that IAS funding was fully allocated as per the program’s financial plan. At the same time, however, there appear to be some challenges associated with resources at the program level. For example, two key initiatives - PHCTS and PlantProNet -would benefit from more program funding. Interestingly, over the first three years of the program more than $6M or approximately 23% of the funding was lapsed.
4. Lack of a robust data collection and performance monitoring system
The lack of solid performance management information is hampering the assessment of the overall performance of the program, and hindering the reporting against stated outcomes and results described in the RMAF, and the development of a more proactive risk-based approach to invasive alien species and plant health in general.
Recommendations
1. Strengthen program management by the IAS Steering Committee and improve the integration of work planning and priority setting across the branches.
2. Engage and leverage executive support for critical IAS Program activities and priorities, including PHCTS, PlantProNet and the Invasive Plant Policy
3. Improve the transparency of the budget reallocation exercises at the branch level in order to ensure effective use of all program resources.
4. Strengthen data collection and performance monitoring systems, including a review of RMAF performance indicators at the outcome levels.
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Strategic Interviews to Set the Evaluation Framework
Evaluation Interviewees
Q1: Are there appropriate governance structures in place to deliver the program activities and outputs and meet the objectives?
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Q2: To what extent does CFIA understand its roles and responsibilities in the overall National Invasive Alien Species (NIAS) Strategy?
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Q3: Has the IAS Program been effective in contributing to the plant protection activities? What have been the impacts?
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Q4: Do the resource levels appropriately reflect the scope of the activities?
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Q5: Has the program cooperated effectively with its partners?
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Q6: Are the roles and responsibilities of CFIA clearly documented and understood?
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Q7: Has a performance and financial monitoring system been implemented? How effective is the ongoing monitoring framework in providing a complete picture of the IAS Program performance and allocation of resources?
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Q8: Are planned activities actually being implemented and producing the expected outputs?
Risk Analysis - 8.1 To what extent is there information gathering?
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Risk Analysis - 8.2 To what extent are programs, policies and procedures developed?
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Risk Analysis - 8.3 To what extent is emergency planning and preparedness being undertaken?
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Risk Analysis - 8.4 To what extent is there a PHCTS?
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Risk Analysis - 8.5 To what extent are there verification products?
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Risk Analysis - 8.6 To what extent are there compliance, verification and import results?
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Science and Technology - 8.7 To what extent is there information gathering?
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Science and Technology - 8.8 To what extent are there verification results?
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Science and Technology - 8.9 To what extent are there laboratory test results and reports?
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Science and Technology - 8.10 To what extent are there diagnostic, surveillance, and inspection methods and procedures in place?
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Science and Technology - 8.11 To what extent is the national PlantProNet established and functioning?
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Legislation, Regulations and Policy Framework - 8.12 To what extent is there an Invasive Plant Policy?
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Legislation, Regulations and Policy Framework - 8.13 To what extent are there MoUs, agreements or joint initiatives with Federal/Provincial/Territorial (FPT) partners?
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Legislation, Regulations and Policy Framework - 8.14 To what extent are there updated legislation, regulations and policies?
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Legislation, Regulations and Policy Framework - 8.15 To what extent are there consultations on the legislation, regulations and policy framework?
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Education, Awareness and Outreach - 8.16 To what extent is there a NIAS Communication Strategy?
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Education, Awareness and Outreach - 8.17 To what extent is there an IAS Outreach Strategy?
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International Cooperation - 8.18 To what extent are there international training workshops?
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International Cooperation - 8.19 To what extent are there incoming missions and delegations on invasive alien species?
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Q9: Are complete and planned activities meeting, or likely to meet, articulated objectives (immediate outcomes)?
9.1 To what extent is entry of new invasive plants and plant pests managed in a risk-based manner?
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9.2 To what extent are new invasive plants and plant pests and the spread of domestic alien plants and plant pests detected within Canada?
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9.3 To what extent are responses to new plants and plant pests planned?
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9.4 To what extent is there increased stakeholder awareness and access to information on plant pests/diseases and prevention control strategies?
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Q10: Has the program been implemented as planned? Have there been unforeseen barriers/challenges to implementing the program as planned?
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Program Documents
CFIA Corporate Documents
Programs Branch
Emergency Response
Seed Program
Science Branch
Operations Branch
Communications Branch
Web sites
INTERVIEW GUIDE
FORMATIVE EVALUATION
INVASIVE ALIEN SPECIES PROGRAM
INTERNAL
TDV Global, a management-consulting firm, has been engaged by Audit, Evaluation and Risk Oversight (AERO) Branch of the Canadian Food Inspection Agency (CFIA) to conduct an evaluation of the Invasive Alien Species (IAS) Program. The objective of the evaluation is to evaluate the success and design and delivery of the CFIA IAS Program in implementing the Action Plan for Invasive Alien Terrestrial Plants and Plant Pests (Action Plan). The evaluation is formative in nature and process-based, and the recommendations will guide any required adjustments to the program going forward.
We would like to discuss the program with you, based on the areas outlined below that you are involved in. We anticipate requiring approximately 60 to 90 minutes.
Opening
1. Please describe your involvement with the IAS Program.
Success
2. Do the program’s activities result in improved prevention, early detection, response to invasive alien species? How do you know?
3. Is there an increase in stakeholder awareness and access to information on invasive alien species?
4. How successful has the implementation of the program been in comparison to the Action Plan? How do you know?
5. Are you aware of any unintended outcomes or outputs from the program?
Program Design and Delivery
6. Describe the major decisions faced in the operation of the program. How are those decisions made? Are they effective?
7. How do you work with the following groups? What activities are coordinated and how? Are there any problems?
8. How do you know the roles, responsibilities and the procedures for your activities for the IAS Program? Do you have manuals or other documentation that you use? When did you last receive formal training on procedures?
9. Are documented procedures appropriate? Do you ever have to deviate from them?
10. Are the regulations in place sufficient for you to carry out your mandate?
11. What activities, if any, are not performed due to lack of financial or executive support?
12. Are ways to improve program delivery being considered and implemented?
13. How do you assess programmatic risk in considering your activities? Have programmatic risks been identified and is there a risk management plan?
INTERVIEW GUIDE
FORMATIVE EVALUATION
INVASIVE ALIEN SPECIES PROGRAM
EXTERNAL
TDV Global, a management-consulting firm, has been engaged by Audit, Evaluation and Risk Oversight (AERO) Branch of the Canadian Food Inspection Agency (CFIA) to conduct an evaluation of the Invasive Alien Species (IAS) Program. The objective of the evaluation is to evaluate the success and the design and delivery of the CFIA IAS Program in implementing the Action Plan for Invasive Alien Terrestrial Plants and Plant Pests (Action Plan). The evaluation is formative in nature and process-based, and the recommendations will guide any required adjustments to the program going forward.
We would like to discuss the program with you, based on the areas outlined below and your collaboration with CFIA. We anticipate requiring approximately 60 minutes.
Opening
1. Please describe your involvement with the CFIA and the IAS Program.
Success
2. Do the program’s activities result in improved prevention, early detection, response to invasive alien species? How do you know?
3. Is there an increase in stakeholder awareness and access to information on invasive alien species?
4. How successful has the implementation of the program been in comparison to the Action Plan? How do you know?
5. Are you aware of any unintended outcomes or outputs from the program?
Program Design and Delivery
6. Describe the major decisions faced in the operation of the program. How are those decisions made? Are they effective?
7. How are your activities coordinated with CFIA? Are roles and responsibilities communicated effectively and consistently?
8. Are the regulations in place sufficient for you to carry out your mandate?
9. Are ways to improve program delivery being considered and implemented? How are those identified and communicated?
Executive Summary
Three incidents of woolly cup grass entrance into Canada were identified. In one case, the plant was found to be growing on an experimental field owned by a seed company in Quebec. In two other cases, seeds were detected in shipments of crop seeds (millet).
The Canadian Food Inspection Agency (CFIA) conducted a pest risk assessment and formed a partnership with Quebec and the seed company to survey nearby fields, test control options and eradicate the infestation. The eradication was successful and an ongoing survey continues. The plant was added to the “Prohibited Noxious Weed Seeds” list.
The overall effort of CFIA in response to this situation was planned in collaboration with partners, executed and followed up on. It demonstrated that the activities on the IAS program are occurring and having the desired/planned outcomes for this case.
Case Study Description
Detection
Woolly cup grass (Eriochloa villosa) is an annual plant native to Asia. It is known to occur in several U.S. states, starting in the 1940s. It is considered a noxious weed in more than 10 U.S. states. The weed is difficult to control and eradicate; it is very prolific and tolerant to a number of herbicides. It is well adapted to corn-corn and corn-soybean rotations. Woolly cup grass seeds can survive for several years in the soil. Woolly cup grass was first detected in Canada in the summer of 2000 in experimental barley plots. Two later incidents of seed presence in Japanese millet seed were detected in 2003 and 2004. The weed is not known to occur in Canada outside of three locations in the province of Quebec.
CFIA Response
Two years after the initial detection in the experimental plot, CFIA partnered with the Ministère de l’Agriculture, des Pêcheries et de l’Alimentation du Québec (MAPAQ) and the landowner to eradicate the woolly cup grass on the contaminated site. MAPAQ has been carrying out a systematic program aimed at eliminating the weed since 2002. In 2006, CFIA funded ongoing costs to scout the land and to leave the contaminated plot to fallow.
The CFIA Plant Production teams from the Saint-Hyacinthe and Sainte-Foy offices scouted several soybean fields in various regions of Quebec. Visual scouting was also carried out in research centres where cultivar trials are being conducted, sites along the perimeter of the Port of Sorel and some grain elevators in the Saint Hyacinthe area. On July 1, 2005, CFIA added woolly cup grass to the “Prohibited Noxious Weed Seeds” list of the Weed Seeds Order.
Relevance
Does the program continue to be consistent with departmental and government-wide priorities, and does it realistically address an actual need?
Woolly cup grass has the capacity to impact production of corn and soybean crops by reducing yields. It represents a legitimate threat to Canadian agricultural production and as such is appropriate to the mission of CFIA. As a result of the infestation, and subsequent efforts of CFIA, woolly cup grass has been added to the Class 1 Prohibited - Noxious of the Weed Seeds Order and it is now prohibited to import woolly cup grass into or sell it within Canada.
Design and Delivery
Governance
Are there appropriate governance structures in place to deliver the program activities and outputs, and meet the objectives?
In this instance, a partnership was established between MAPAQ, the landowner and CFIA. All indications are that the partnership was supported by CFIA management and was successful. Within CFIA, a project manager from within the Programs Branch was assigned to the project. That manager established good working relationships with the Operations Branch and the project was considered to be well coordinated. The IAS Coordinating Committee was effective in ensuring that all appropriate program and support areas were aware of the activities.
Understanding of Roles and Responsibilities
To what extent does CFIA understand its roles and responsibilities in the overall National IAS Strategy?
The CFIA’s actions were consistent with its mandate. The CFIA took a lead role during the evaluation and kept well informed on progress. Quebec was receptive to CFIA involvement. At the conclusion of the investigation, CFIA took it upon itself to introduce the regulatory change to declare woolly cup grass a prohibited noxious weed. The CFIA also conducted a pest risk assessment which classified the weed as a moderate risk: high likelihood of introduction, high likelihood of establishment, medium spread potential, medium economic impact and low environmental impact.
Effectiveness
Has the IAS program been effective in contributing to the plant protection activities? What have been the impacts?
Eradication efforts were successful and the weed has not re-emerged. Regulatory actions were also effective in that the weed has been identified and added to the regulations.
Resource levels
Do the resource levels appropriately reflect the scope of the activities?
The Operations Branch was able to allocate sufficient resources to manage the survey and validate eradication efforts. Staff from two district offices in the Quebec area were able to assist in the survey work at an appropriate and sufficient level of involvement, conducting visual surveys. The Agency was able to contribute financially to the three-party eradication plan. There were no indications that resources were wasted or needlessly expended.
Partnerships
Has the program cooperated effectively with its partners?
The Agency established a good working relationship with Quebec and the private sector. One observation made in an interview was that the emergency situation established a good working relationship and promoted ongoing dialogue for future events.
Role Documentation
Are the roles and responsibilities of CFIA clearly documented and understood?
There were no indications of hesitancy on the part of CFIA staff in any of Science, Operations or Programs Branches. From that, we deduce that the documentation of roles and responsibilities was adequate.
Performance Monitoring
Has a performance and financial monitoring system been implemented? How effective is the ongoing monitoring framework in providing a complete picture of the IAS performance and allocation of resources?
The event was of a sufficiently short duration and involved limited activity, therefore performance monitoring was not necessary. There was no evidence of any post-event evaluation activity to consider value for money, but there was also no indication that the small expenditures were deemed inappropriate.
Success
Activities Happening
Are planned activities actually being implemented and producing the expected outputs?
Risk assessments, surveys, inter-government partnership and private public collaboration activities were all part of the Agency’s response to the incidents. As expected, surveys that were conducted established infestation- free areas and also identified weeds and the degree of infestation.
Activities Meeting Objectives
Are complete and planned activities meeting, or likely to meet, articulated objectives (immediate outcomes)?
Activities currently in place - for example, ongoing survey, weed classification, and established partnerships - are meeting program objectives. The activities had the desired result. The risk was assessed and communicated, surveys identified infested fields and also fields free from infestation. The weed has not re-emerged. Collaboration activities succeeded in creating an effective multi-jurisdictional response.
Implementation According to Plan
Has the program been implemented as planned? Have there been unforeseen barriers/challenges to implementing the program as planned?
The response was implemented as planned. The one barrier identified was the timing required to effect the regulatory change. Program Branch staff felt that this activity took a lot longer than was desirable.
INVASIVE ALIEN SPECIES PROGRAM EXPENDITURE (000’s)
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Annex G - INVASIVE ALIEN SPECIES PROGRAM EXPENDITURE
(000’s)
ALLOCATION OF INVASIVE ALIEN SPECIES PROGRAM FUNDING (000’s)
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Annex G - ALLOCATION OF INVASIVE ALIEN SPECIES PROGRAM
FUNDING (000’s)
Tables provided by the Finance, Administration, and Information Technology Branch of the Canadian Food Inspection Agency