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Regulatory Impact Analysis in Canada


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Regulatory Impact Analysis in Canada

Axel Volkery (volkery@zedat.fu-berlin.de)

Environmental Policy Research Centre, Freie Universitaet Berlin, Germany 05/11/2004

Regulatory Impact Analysis in Canada

____________________________________ 1 1 Introduction ___________________________________________________________ 2 2 History and Background _________________________________________________ 2 3 Institutional Aspects _____________________________________________________ 3

3.1 RIA and the Regulatory Process: Responsibilities, Coordination and Quality Control _________________________________________________________________ 3 3.2 Policies, Impacts and Tools: Substantial Requirements ___________________ 5 4 RIAS in practice: Strengths _______________________________________________ 7 5 RIAS in Practice: Weaknesses_____________________________________________ 8 6 Conclusions __________________________________________________________ 10

6.1 Canada’s approach to RIA scores well on important criteria of RIA (OECD 2002c): ________________________________________________________________ 10 6.2 Key lessons to be learned from Canada are: ___________________________ 10 7 Acronyms ____________________________________________________________ 12 8 Bibliography _______________________________________________________ 13


1 Introduction

In a recent review, the OECD has called Canada a pioneer and consistent leader in the area of regulatory reform over the last 25 years (OECD 2002a). As early as of 1977, agencies were required to undertake an periodic evaluation of programs. 13 departments also were obliged to execute an ex-ante Socio-Economic Impact Analysis for new major regulations in the areas of health, safety and fairness. Canada adopted a comprehensive Regulatory Reform Strategy in 1986 and since then has continuously worked to improve what is now a mature and well-functioning system of regulatory governance (OECD 2002b).

This regulatory system is based on well-established regulatory quality principles and strong institutions. The Treasury Board (TS) reviews and coordinates overall governmental

regulation making. It is supported by the Regulatory Affairs and Orders in Council

Secretariat (RAOIC) of the Privy Council Office (PCO). Regulatory Impact Analysis (RIA) is an obligatory feature of the policy-making process (Government of Canada 2004a). The regulatory system is quite transparent and RIA is fully integrated into public consultation. Central quality control is provided by the RAOIC. Additionally, an independent audit of all governmental operations is performed by the Auditor General. Enforcement and compliance, the OECD states, are handled exceptionally well (OECD 2002a: 12).

Regulatory reform has spurred economic performance and raised living standards. Greater competition has led to improved efficiency and service in many economic sectors, in particular telecommunication and trucking. But despite the significant progress, challenges remain on the agenda, such as the need for capacity-building or the problem of consultation fatigue. The system is not really integrated - sustainability concerns have only started to become integrated into RIA. So far, a Strategic Environmental Assessment of Policies, Plans and Programs (SEA) is operated independently in the subset of the RIA and RIA itself addresses largely economic issues. The performance of RIA at the federal level needs to be improved and there is an obvious lack of cooperation between the federal and provincial level. This report is based on the study of guidance and review documents issued by federal state and regulatory reform bodies, on the review of recent evaluation studies done by the OECD and other organizations as well as two interviews carried out with a senior official at the Canadian Environmental Assessment Agency and a senior policy advisor at the Canadian Parks and Wilderness Society.

2 History and Background

The agenda for regulatory reform arose in the late 1970s after a longer period of economic stagnation. In 1977, order of the Treasury Board Secretariat (TBS) obliged regulatory agencies to undertake periodic evaluation of regulatory programs. In 1978, the Government commissioned a study on the economic impacts of regulation from the Economic Council, an independent advisory council. Over the next three years, the Council issues several influential reports, that drew attention to the need for reforming the overall process of regulatory policy. As a consequence, the Office of the Coordinator of Regulatory Reform was installed within the TB in 1979. This was the first government entity to have regulatory reform as its central objective. At the same time, the president of the TB was assigned responsibility to review Government’s regulatory activities and the Parliament became involved (OECD 2002c).


The next reform was in 1986, when the Government adopted the Regulatory Reform Strategy that aimed at a centrally managed review of new regulation. The strategy nailed down

important principles: growth of regulation should be restricted, benefits should exceed costs, regulation should be subject to early public consultation and the administrative burden should be reduced. Principles were laid down in the Guiding Principles of Federal Regulatory Policy, that introduced the principle of “smarter regulation” and in the Citizens Code of Regulatory Fairness, that entrenches the right to be consulted (Privy Council Office 2000). In 1992, the Government adopted the overarching goal of “maximizing net benefit to

Canadians”, which became the overarching goal for regulatory reform over the next decade. A central focus was on increasing international competitiveness and removing barriers to

internal trade. For this reason, formal cost-benefit- and cost-effectiveness-analysis was introduced. Under the 1994 Jobs and Growth Agenda: Building a More Innovative Economy, the

the Government started to reassess every regulation on the books. This process led to the Government modifying or revoking 835 out of 2800 regulations. In 1995, the Government shifted the focus to enforcement and compliance measures and incorporated the Regulatory Policy Management Standards (RPMS, see annex 1). The Government obliged departments to adopt and to report on their compliance with these standards.

Since 1997, the Improved Reporting to Parliament Project demands two annual reports to be tabled in Parliament: 1) Plans and Priorities and 2) Performance Reports. In 1998/1999, overall coordination became strengthened: Cabinet Committee responsibility was transferred to a new Cabinet Committee - the Special Committee of Council (SCC) - oversees and the RAOIC was established at the PCO to assist the SCC. Reform in 2000 led to the Results for Canadians - A Management Framework for the Government of Canada, a management framework that entails four commitments for governmental action: citizen focus, value-driven management, result orientation and responsible public spending. In 2003, the role of the TB was expanded on behalf of the SCC to include approving regulation and most Orders in Council1 requiring Governor in Council (i.e. the Cabinet) approval (Government of Canada

2004a, OECD 2002a: 33). 3 Institutional Aspects

3.1 RIA and the Regulatory Process: Responsibilities, Coordination and Quality Control Requirements for RIA have not been adopted in form of legislation, but in the form of Cabinet Directives. The central document is the Cabinet Directive on Canada Regulatory Policy from 1999. This offers the possibility of quick adjustments and changes, but also bears the

disadvantage of watering-down or neglecting commitments. The Directive sets out seven basic requirements that need to be ensured by regulators when issuing new legislation (Government of Canada 1999):

1) broad consultation, including the option for modifying policies,

2) demonstration, that there is a problem that needs to be tackled by governmental intervention and that there is no alternative to the proposed legislation,

3) demonstration, that the benefits outweigh the costs,

4) minimization of adverse impacts on the economy and the administrative burden, 5) consideration of international and intergovernmental agreements,

6) effective management of regulatory resources, i.e. following RPMS, articulation of compliance and enforcement policies and adequate approval of resources and


7) demonstration of compliance with other Cabinet Directives concerning policy and law-making such as the Cabinet Directive on Law Making, the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals and the Cost and Recovery Charging Policy.

Requirements cover all form of legislation, including primary legislation and sub-ordinate legislation such as Orders in Council, but not quasi-regulations. RIA is directly integrated in the public consultation process (see Figure 1). Despite the central coordination provided by the RAOIC, the process is rather driven bottom-up. It is up to the departments to design and conduct the assessment, i.e. to choose the impact and indicators and select the information to be tabled for the Council in Governor and the TBS. However, RIA need approval both by the RAOIC and the TBS, and all departments fulfill watchdog functions with regard to their interest and intervente if proposals or RIA of proposals are seriously flawed (Wilbourn 2004). The Canadian RIA is an ex-ante assessment. In the beginning of the decision-making process, the department has to undertake an initial policy analysis to determine, whether decision-making is warranted or not. It has to estimate and quantify potential costs and benefits, health and safety impacts as well as environmental impacts and impacts on specific sectoral groups and has to undertake, if necessary, special assessments. Departments are obliged to verify possible alternative solutions and to undertake public consultations as soon as possible.

The department is obliged to early notify its intention to regulate in order to allow for an early public consultation. If the departments decides to regulate, a Regulatory Impact Assessment Statement (RIAS, see for more details section 3.2) must be published together with the draft legislation and other documents, most notably the Communication Assessment and Plan (CAP) and the Supplementary Note (SN). The CAP has to inform about the progress of consultation, but also to list the target audiences and measures to reach them. The SN has to inform ministers about sensitive or confident issues that are not part of the public RIAS. After the standard legal administration, the draft legislation and the RIAS needs a personal approval by the minister. Afterwards, it is sent for a pre-publication review by the RAOIC and the TBS. Both institutions have the power to refuse the submittal of the proposal to Cabinet, if documents are missing or if the RIAS is seriously flawed. If the proposal is approved, it will

Fig. 1: The regulatory process in Canada


undergo a “pre-publishing” in the Canada Gazette for receiving public comments within a period of 30 days (proposals affecting international trade are published for 70 days).

For final submission to the TB, the department must amend the RIAS reflecting the received information, the token action and the rationale behind it. When the final proposal has been approved by the minister, the RAOIC will again verify all documents. The TB will again verify the substance of the proposal and the changes before final approval or rejecting. After the entering into force and publication in the Canada Gazette Part II, a parliamentary review is to be undertaken by the Standing Joint Committee for the Scrutiny of Regulations

RAOIC and TBS: Role and powers

The RAOIC is responsible for monitoring, coordinating and advising on regulatory and Orders in Council issues and policies. It has to ensure consistency with economic, social and federal provincial policies and thus reviews every proposal form an overall policy perspective. It also in constant exchange with the departments and gives advice. The Secretariat, with a staff of 25 employees, supports the Prime Minister and Cabinet with appointment Orders and the TB with regulations and Orders in Council. It is divided into the Regulatory Affairs Division (PCO-RAD, 11 staff) and the

Orders in Council Division (PCO-OiC, 14 staff). The PCDO-RAD may request additional information or analyses from the sponsoring department prior to the proposal being submitted to the TB for consideration. The PCO-OiC might demand the same for Orders in Council.

The TBis a statutory Cabinet committee. The TBS examines draft regulations that require TB approval or recommendation in its capacity as the central agency responsible for the management of the government's financial, personnel and administrative affairs. Its powers were extended in 2003, making it the central coordinating institution for regulatory affairs and management within the Canadian Government. RAOIC and TB thus function as a gatekeeper, or as a threshold, that new regulatory proposals have to pass.

Source: Government of Canada 2004, The Auditor General of Canada 2004

3.2 Policies, Impacts and Tools: Substantial Requirements

There is no threshold to RIA – a RIAS has to accompany each proposed regulation. According to the proportionality rule, regulation with larger impact should be subject to a more detailed analysis. The proportionality rule ensures a substantial degree of targeting of efforts. Also, there is no fixed inventory of impacts that need to be analyzed regularly. The Canadian RIA approach is broad in its scope and its concrete design is in many ways dependent on the decisions taken by the single departments. RIA aims both at summarizing the information ministers require to decide on proposed regulation and to sketch what the government will deliver, how consultation proceeded, what diverging opinions and interests have been expressed and what the estimated costs and benefits of the proposal are.

A RIAS features both quantitative and qualitative approaches. Since 1992, Cost-Benefit-Analysis has been strengthened and has become an obligatory feature of the Regulatory Process. There exists an extensive amount of guidelines and manuals that give concrete advice, both on the process but also on tools. The RAOIC has developed mainly procedural advice, whereas it is up to the single departments to support desk officers with substantial advice (Government of Canada 2004 a, b, c).


Responsibility for the RIAS lies with the department or agency that sponsors the proposal. Ultimate responsibility lies with the minister or head of agency, who has to sign the RIAS. A RIAS is made up of six required sections (Government of Canada 2004a and b):

Description Alternatives Benefits and Costs Consultation

Compliance and Enforcement Contact

This first two sections of the RIAS outline the context and purpose of the proposed regulation and possible alternative options. It must be proven that the chosen approach is the superior approach and what major impacts are to be expected. Alternative options to be considered include: doing nothing (Status Quo), taxation, direct expenditure, consensus standards,

voluntary standards, marketable permits or a lighter/more stringent form of regulatory control. All proposals have to undergo a CBA. A RIAS has to demonstrate that

the benefits outweigh the costs,

the difference between benefits and costs is the greatest possible and

that the net benefits of the chosen regulation are greater than the net benefits of any other alternative regulatory option.

CBA does not aim at “quantification of everything” in order to arrive at a single number. Rather, it is understood as a means to present all relevant information to ministers and the public. A professional, comprehensive cost-benefit analysis shall be undertaken for all

proposals whose estimated direct cost will be $10 million or more, in present value terms. For proposals of moderate impact, CBA shall be undertaken to the extent possible. A more

qualitative, but systematic, analysis might be sufficient.

The RIAS shall comprise the analysis of direct and indirect economic, social and

environmental impacts, but also impacts on the overall administrative burden. Economic impacts are impacts such as effects on employment, operating costs, international trade, global competitiveness or distribution of income. Social impacts are impacts such as effects on mortality, morbidity reductions, reductions in property loss due to accidents, or measures of effects on wildlife populations.

Environmental Impact are covered separately under the Cabinet Directive on the

Environmental Assessment of Policy, Plan and Program Proposals (see next section). There are, however, no guidelines regarding concrete impacts and indicators that have to be

regularly checked. It is within the responsibility of the department to determine a list of impact areas and indicators but also of tools for the assessment.


Tools for Business Impact Analysis

There are two cost-estimating aids for desk officers: the interactive software based “Business Impact Test (BIT)” and the “Business Impact Cost Analysis Protocol (BICAP)”.

1. BIT: The BIT is a survey tool that is used to identify business expectations of the impacts of proposed regulation. The tool provides also a consistent, framework within which businesses can contribute to regulatory discussions. It thus structures discussion between agencies and companies and allows insofar for a better informed comparison of various regulatory options. A software package can be used for designing electronic surveys.

2. BICAP: The BICAP is an interview-based approach to verifying cost data combined with an accounting methodology for costing regulatory impacts. Interviews are held with business managers. BICAP includes two accounting protocols. These are focused on estimating a firm’s cost of complying with current regulations and proposed new regulation. The BICAP methodology is based on business function analysis, cost reduction and cost accounting methodologies.

Source: Adapted from Argy and Johnson 2003

Furthermore, the RIAS has to summarize the consultation undertaken. Officers have to describe whom they have contacted and which tools they have used (for example the BIT). They have to outline the amendments they undertook and they have to indicate the degree of support for the proposal as well as the actors who still oppose it.

A quite innovative feature of the Canadian approach is the separate section on compliance and enforcement measures, that has to explain in detail the procedures and resources that will be used for compliance and enforcement, like for example criminal law sanctions, ticketing or licensing. The departments or agencies have also to explain how monitoring should be implemented.

4 RIAS in practice: Strengths

Departmental capacities for RIA have been developed over time. RIA is carried out mainly by the desk officers responsible for the development of the proposal. All departments have at least appointed regulatory managers, that are responsible for coordinating RIA efforts. Several departments have also created enhanced regulatory affairs units or internal regulatory affairs committees. There is a high political commitment to the RIAS: A RIAS is a Cabinet

document, that has to get the approval of the minister. It is a precondition for submission to the Governor in Council (i.e. the Cabinet).

In the case of cross-cutting policies, the leading department or agency is obliged to consult other relevant departments when preparing the RIS. An officer of the Canadian

Environmental Assessment Agency states, that departments often to consult other departments in order to get help with data, indicators or methodological tools (Wilburn 2004). The RIA approach is broad and flexible, with the responsibility for the design of the assessment

dedicated to the department or agency. This allows for a broad looking-around, but bears also the danger of failure to recognize and analyze possible impacts. The detail of the RIAS varies according to the importance and complexity of the proposal. A RIAS thus can be a few pages, but also hundred and more pages long. Also, the time for preparing RIAS vary quite

significantly. There is no information available on average length.

Due to the refusal powers of the RAOIC and the TB, departments show a good compliance rate with the RIA requirements. There is constant coordination between the proposing department and the RAOIC that ensures a quality control from the beginning. Another key strength is the integration of RIA into the overall policy process and the focus on compliance


from the very beginning. This has changed the way of planning regulation: Capacity requirements for implementation are taken more frequently into account (OECD 2002c). Additionally, the intensive process of consultation, with early consultation, consultation during pre-publishing and consultation during publishing creates a good transparency and thus confidence of the regulatory process. The Canadian regulatory system is probably one of the most transparent worldwide. Annually, the General Auditors Office undertakes an

independent evaluation of the RIAS process and highlights certain difficulties and deficits that need to be addressed (see for the latest General Auditors Office 2003).

The regulatory culture is quite open and new ideas, grown internally or adopted externally, are incorporated quickly. Throughout the 1990s, the Government fine-tuned the institutional setting of the RIA-process in Canada several times, adjusting the allocation of power and competence at the central (i.e. Cabinet) and decentral (i.e. departments) level. In 2000, a review of the compliance with the RPMS and compliance with RIA requirements was published (The Regulatory Consulting Group 2000, cited in OECD 2002b: 12). The report indicated good progress with RIA, but identified 13 areas where improvements could be made. This included better prioritising of regulatory proposals, improved capabilities to assess regulatory and non-regulatory alternatives and increased activities to promote the sound use of cost-benefit analysis, but also more training. Also, a better targeting of efforts and an improvement of the understanding of RIA requirements were stated as being necessary. Furthermore, it was recommended to deliver guidelines on analytical and methodological techniques, improve in RIA transparency and start training for authors.

The Government responded to these recommendations. Today, Canada possibly has one of the most extensive ranges of manuals and guidance material (Argy and Johnson 2003). Many of them are available via the website of the Privy Council Office (http://www.pco-gov.ca). They cover a broad spectrum of issues: assessment of regulatory alternatives, cost-benefit analysis, writing a RIAS, developing compliance policies, managing regulatory programs, managing international regulatory collaboration or handling of federal regulatory process. As early as of 1992, the Government published the RIAS Writers Guide, that contained detailed instruction and best-practice examples (Government of Canada 1992). Today’s manuals are written in an understandable language and focus on practical problems of officers. In 2001, an innovative web-based, interactive learning tool on the Government and a simplified

Government Process Guide were developed, that allow for on-line, on-demand access to policies, guidance and best-practice in undertaking appropriate analysis (Government of Canada 2004a, b).

Training is the other dimension where Canada scores very good in Inter-OECD-comparison (Argy and Johnson 2003, OECD 2002b). On the one hand, training for all departments and agencies is provided by Consulting and Audit Canada. Also, the RAOIC provides regulatory best-practice seminars. On the other hand, the departments and agencies themselves offer a wide range of in-house training programs that are tailored to the specific needs of their regulatory programs. This includes departmental process manuals. Also it has become usual to hire external cost-benefit specialists for improving RIA (Wilburn 2004).

5 RIAS in Practice: Weaknesses

Despite the overall progress, there are still deficits, mainly with regard to:


the lack of integration of sustainability concerns into RIA,

the coordination deficits regarding federal and provincial regulation and the problem of capacity-constraints and consultation fatigue.

The quality of individual RIA and their compliance with the RPMS still vary across

departments and agencies. Especially, communication of results and the use of CBA needs to be strengthened. Additionally, there are complaints, that RIA are not always carefully

prepared and major information is not disclosed for major policy regulation. Quite often, departments use RIA not as a means to inform ministers neutrally, but as a means to advocate for their regulatory intentions (OECD 2002b).

Other critics have pointed to the fact that the RIA process so far has mainly served the deregulation and liberalization agenda, but has neglected the challenge of integrating Sustainability Concerns into RIA (CSED 2004). All proposals that are likely to have

important environmental impacts have to undergo a separate SEA. The assessment has to be done by the departments or agencies; that all have appointed a coordination officer for SEA. These officers keep contact with the Canadian Environmental Assessment Agency, that oversees and coordinates the SEA process. Staff is limited – there is only one officer to coordinate activities in all 26 departments and agencies on the federal level within the Environmental Assessment Agency.

The Commissioner on the Environment and Sustainable Development (located at the General Auditors Office) has recently criticized departments and agencies sharply for insufficient action regarding the integration of Sustainability concerns into RIAS: Existing tools would be poorly used and the use of strategic environmental assessment would be far from adequate to meet its promise in guiding policy and program development (CESD 2004). NGOs have reiterated these critics: All major areas of governmental action, especially the budget, would remain out of the focus of a true sustainability appraisal (Hazell 2004).

The Environmental Assessment Agency, however, notes, that progress has been made throughout the last years. Networking among departments has been strengthened. Also, it defends, that there are no clear impact guidance documents. A separate broad SEA would allow for deeper examination of environmental effects according to the needs of the special case. For example, environmental crime is one of the most pressing problems in Canada, but could not easily covered with impact inventories (Wilburn 2004).

Regulatory duplication and overlap between federal and regional regulations are another problem of regulatory management. As early as in 1986, the Government made provincial consultation an obligatory feature of the RIAS (OECD 2002b). However, progress has been slow over the years. A 2000 evaluation report stated, that there is urgent need to promote co-operation and collaboration between levels of government with jurisdiction over the same industries (Nancy and Coe 2000). In this context, harmonization efforts should be focused on applying RIA on existing regulation. But interviews indicate, that there is greater resistance at the provincial level to do so, due to fears of loosing competencies (Hazell 2004).

The Canadian approach is capacity-demanding, due to the extensive coordination and consultation requirements. In the past, the RAOIC has had often not enough capacities to maintain a thoroughly management and quality control of the regulatory management process. Also, departments missed capacities to organize and absorb stakeholder contributions

properly. In some cases, forms of “consultation fatigue” has been the result. So far, the Government has reacted to this problem with an intensification of efforts to push forward


E-Government and targeted Internet Consultation. In a comparative study of 20 countries, Canada was attributed the leadership in E-government (Accenture 2001).

6 Conclusions

6.1 Canada’s approach to RIA scores well on important criteria of RIA (OECD 2002c): there is a strong political commitment and a clear allocation of responsibilities

there is an open regulatory culture that allows for flexible and adaptive learning there is a strong degree of integration into the overall policy-making process there is a strong obligation to analyze alternative policy options

there is a serious commitment to public consultation and transparency there is a serious commitment to compliance and enforcement

there is a great amount of written guidance material and training opportunities. RIA has permeated the overall departmental policy-making culture and requirements go beyond the OECD-principles in many areas. Maybe one of the greatest assets is the transparency and confidentiality of the RIA approach, that underpins the credibility of the RIA system in Canada.

On the other hand, potentials for improvements can be observed, such as the inconsistency of criteria and indicators, the lacking integration of Sustainability concerns, the problems with the coordination of federal and provincial rule-making and the problem of overstretching capacities. So far, RIA has only started to leave behind the concentration on business

compliance cost, competitiveness concerns and impacts on the overall administrative burden and become the central tool for integrating Sustainability concerns into overall governmental decision-making.

6.2 Key lessons to be learned from Canada are:

Enhance the transparency of the process, but keep consultation tailored and clarify the objectives of the process for stakeholders.

Increase political commitment by requiring personal signature of Ministers

Increase the power and capacities for central steering, but keep the system flexible and open – there is a need for constant fine-tuning for finding the right balance between departmental autonomy and central steering.

Increase the power and capacities for RIA at departmental level - install a regulatory affairs unit in each department or at least designate responsible RIA officers.

Couple RIA with negative sanctions such as refusal to submit draft legislation to Cabinet in order to increases incentives for compliance.

Make reporting on compliance and enforcement measures an obligatory feature of RIA, but install also mechanisms to address practical failure.

Develop a stronger advocacy role for RIA independent from the administration, i.e. strengthen the role and capacities of independent review bodies.

Implement systematic and regular ex-post evaluation of important regulatory policies. Train the regulators – make use of web-based, interactive learning tools on the

Government to provide on-line, on-demand access to policies, guidance and best-practice in undertaking appropriate analysis.

Update and rationalize guidelines and manuals for officers - avoid, that material accumulates over time and becomes cumbersome and difficult to work with.


7 Acronyms

BICAP Business Impact Cost Analysis Protocol

BIT Business Impact Test

G i C Governor in Council

PCO Privy Council Office

PCO-OiC Privy Council Office Order in Council Division PCO-RAD Privy Council Office Regulatory Affairs Division RAOIC Regulatory Affairs and Orders in Council Secretariat

RIA Regulatory Impact Analysis

RIAS Regulatory Impact Analysis Statement RPMS Regulatory Process Management Standards SCC Special Committee of the Council

SEA Strategic Environmental Assessment

TB Treasury Board


8 Bibliography

Accenture. (2001). E-Government leadership: Rhetoric versus Reality – Closing the Gap. Accenture: Paris.

Argy, Stephen and Matthew Johnson. (2003). Mechanisms for Improving the Quality of Regulations: Australia in an International Context. Productivity Commission Staff Working Paper, July 2003. Melbourne.

Auditor General of Canada. (2004). Report of the Auditor General of Canada to the House of Commons. Ottawa: The Office of the Auditor General of Canada (Reference is made to chapter 7: Managing Government: A Study on the Role of the Treasury Board and its Secretariat).

CESD - The Commissioner on the Environment and Sustainable Development in Canada. (2004). 2004 Report of the Commissioner on the Environment and Sustainable Development in Canada. Download at:

Government of Canada. (2004). Regulatory Process Guide. Developing a Proposal and Seeking its Approval. Regulatory Affairs Division, Operations Branch, Privy Council Office, Government of Canada: Ottawa.

______(2004). Governor in Councils Guide. Developing a Proposal and Seeking the Approval of an Order by the Governor in Council. Privy Council Office, Government of

Canada: Ottawa.

______(1999). Government of Canada Regulatory Policy. Privy Council Office, Government of Canada: Ottawa.

______(1992): A Writer’s Guide to Regulatory Impact Analysis. The Treasury Board Secreta-riat, Government of Canada: Ottawa.

Nancy, Averill Nancy and Amanda Coe. (2000). Managing Regulation: Policy, Practice and Prognosis. Report prepared by the Public Policy Forum. Download of the executive summary at: www.ppforum.com/english/publications/publications/exsummary.html OECD – Organisation for Economic Cooperation and Development. (2002a). Canada:

Maintaining Leadership through Innovation. OECD Public Performance Reviews. Pa-ris: OECD.

______(2002b). Regulatory Reform in Canada: Government Capacity to Assure High Quality Action. OECD Reviews of Regulatory Reform. Paris: OECD.

_____(2002c). Regulatory Policies in OECD-Countries: From Interventionism to

Regulatory Governance. OECD Review of Regulatory Reform. OECD: Paris.


Interview with Greg Wilburn, Senior Policy Officer at the Canadian Environmental Assessment Agency (12/10/2004).

Interview with Stephen Hazell, National Executive Director, Canadian Parks and Wilderness Society and the Green Budget Coalition (4/10/2004).


Web Links Institutions

Privy Council Office http://www.pco-bcp.gc.ca Treasury Board Secretariat

http://www.tbs-sct.gc.ca/index_e.asp RAOIC Secretariat


Standing Joint Committee for the Scrutiny of Regulations http://www.parl.gc.ca

Canadian Environmental Assessment Agency http://www.ceaa.gc.ca

Relevant Directives

Government of Canada Regulatory Policy


Cabinet Directive on Law-making

http://www.pco-bcp.gc.ca/legislation/directive_e.htm Cabinet Directive on Environmental Assessment http://www.ceaa.gc.ca/act/dir_e.htm

Cost Recovery and Charging Policy


Manuals and Guidance Material(selection) ROICS Publication (general oversight)

http://www.pco-bcp.gc.ca/raoics-srdc/default.asp?Language=E&Page=Publications RIAS Writer’s guide

http://www.pco-bcp.gc.ca/raoics-srdc/docs/publications/rias_e.pdf RPMS Compliance Guide


Benefit-Cost Analysis Guide for Regulatory Program

http://ww.pco-bcp.gc.ca/raoics-srdc/procguides/cbgcntents_e.htm Assessing Regulatory Alternatives

http://www.pco-bcp.gc.ca/raoics-srdc/publications/PolGuides/assregalt_e.pdf Business Impact Test


Fig. 1: The regulatory process in Canada


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