Introduction

Heritage buildings and national historic sites are important parts of Canada’s heritage; as such, they “promote and reinforce the country’s cultural identity. They are assets to maintain, value, and conserve for present and future generations of Canadians.”[1]

According to the Office of the Auditor General of Canada (OAG), “Canada recognizes the importance of conserving its heritage properties in legislation, policies, and guidelines. In addition, Canada committed to the United Nations sustainable development goal that includes efforts to protect and safeguard the world’s cultural and natural heritage.”[2] In fact, as of 2017, “the federal government owned 1,272 designated buildings and at least 223 national historic sites across Canada.”[3]

In December 2017, the House of Commons Standing Committee on Environment and Sustainable Development presented a report entitled Preserving Canada’s Heritage: The Foundation for Tomorrow, which recommended “taking stronger actions to preserve Canada’s heritage properties.”[4]

Additionally, past OAG reports pertaining to federal heritage properties found the following:

• 2003 (Chapter 6–Protection of Cultural Heritage in the Federal Government): The OAG found that heritage properties were in poor condition, and the government could not conserve them. Canadian Heritage and Parks Canada agreed to strengthen the legal framework to conserve heritage properties; the Department also agreed to work with the Treasury Board of Canada Secretariat to define what type of information to collect and how to appropriately assess and report on the condition of heritage properties.[5]
• 2007 (Chapter 2–The Conservation of Federal Built Heritage): The OAG reported that “Parks Canada had not strengthened the legal framework to conserve heritage properties, leaving them still at risk.”[6] And although it found that the Agency acted to conserve sites in poor condition in 2003, other federal organizations were only conserving them sporadically; also the Treasury Board Heritage Buildings Policy covered only heritage buildings, not national historic sites.[7] This audit also concluded that “Parks Canada’s conservation efforts since 2003 were not enough to ensure federal organizations conserved heritage properties. (…) The government agreed that the conservation regime should be strengthened, and National Defence, Parks Canada, and Public Works and Government Services Canada agreed to establish conservation objectives to conserve their federal heritage properties.”[8]

In the fall of 2018, the OAG released a performance audit whose purpose was to determine “whether Parks Canada, Fisheries and Oceans Canada, and National Defence worked to conserve the heritage value and extend the life of federal heritage properties for present and future generations of Canadians to enjoy. (Together, these three organizations own over 70% of all federal heritage buildings.)[9] The audit focused on national historic sites and heritage buildings, including heritage lighthouses.”[10]

Parks Canada manages 171 national historic sites and 504 heritage buildings, and as the lead federal organization for programs to conserve federal heritage properties, is also “responsible for implementing Government of Canada policies on

• national parks,
• national historic sites,
• national marine conservation areas,
• other federally protected heritage areas, and
• heritage protection programs.[11]

Additionally, the Agency administers the Heritage Lighthouse Protection Act and per the Treasury Board Policy on Management of Real Property, evaluates “all federal buildings over 40 years old for their heritage character” and recommends to the Minister of the Environment and Climate Change whether these buildings should be designated as such.[12]

Fisheries and Oceans Canada has 267 heritage buildings, including 32 heritage lighthouses, and seven national historic sites.[13] National Defence owns 292 heritage buildings and 22 national historic sites across the country, including armouries and airplane hangars.[14]

On 2 May 2019, the House of Commons Standing Committee on Public Accounts (the Committee) held hearings on this audit. In attendance from the OAG were Jerome Berthelette, Assistant Auditor General, and Susan Gomez, Director. From Parks Canada were Michael Nadler, Acting Chief Executive Officer; Joëlle Montminy, Vice-President, Indigenous Affairs and Cultural Heritage Directorate; and Genevieve Charrois, Director, Cultural Heritage Policies. From the Department of National Defence, Jody Thomas, Deputy Minister, and Rob Chambers, Acting Assistant Deputy Minister, Infrastructure and Environment. Lastly, from Fisheries and Oceans Canada, Kevin Stringer, Associate Deputy Minister, and Bill Varvaris, Director General, Real Property and Environmental Management.[15]

Findings and Recommendations

A. Management of Heritage Properties

1.   Number of Heritage Buildings

The OAG found that despite its lead role for federal heritage conservation programs, Parks Canada had an incomplete asset management database that identified only 186 of its 504 heritage buildings.[16] It also found that “Fisheries and Oceans Canada’s database did not have accurate information on which lighthouses were designated under the Heritage Lighthouse Protection Act. For example, the database contained lighthouses that the Department no longer owned, as well as those that were not designated as heritage under the Act but were shown as being so in the database.”[17]

In contrast, the OAG noted that National Defence had complete data on the number of heritage buildings.[18]

2.   Condition of Heritage Buildings

As part of this audit, the OAG visited several heritage properties; some were found to be in good condition, but an equal number had “crumbling bricks, no roofs, and graffiti, and some were in danger of collapse.”[19] Because of the deficiencies regarding data quality, the OAG concluded that “none of the three organizations could know the overall condition of their heritage properties.”[20]

3.   Reporting to the Treasury Board of Canada Secretariat

The Financial Administration Act requires federal organizations to “maintain current, complete, and accurate records of their inventories in the Treasury Board of Canada Secretariat’s [TBS] Directory of Federal Real Property. Annually, each organization must certify the completeness and accuracy of its records in the directory.”[21] The OAG found that “some of the directory information provided by the organizations that we audited was inaccurate, despite their certifications. Condition information was not up to date for some National Defence and Parks Canada properties, and Fisheries and Oceans Canada reported continued ownership of lighthouses that it no longer owned.”[22]

Therefore, the OAG recommended that “Parks Canada, Fisheries and Oceans Canada, and National Defence should update their asset management databases to reflect complete information on the number and current condition of their heritage properties.”[23]

In response, Parks Canada stated in its action plan that it “will complete the identification of the federal heritage properties under its responsibility and will indicate the condition of these properties in the appropriate asset/land management system. This will allow for the up-to-date accounting of the heritage assets under Parks Canada responsibility,” and will be completed by the fall of 2019.[24]

At the hearing, Joëlle Montminy, Vice-President, Indigenous Affairs and Cultural Heritage Directorate, Parks Canada, added the following:

[We] had a complete list of heritage properties and their condition, but it was divided among various regional sites in the country. The list existed, I assure you, and it was complete. People who administer those properties were aware of the list's existence.

The issue was at the national level. That list included all the properties administered by Parks Canada—there are more than 17,000 of them—and not only heritage properties. However, the list did not include the most recent details on heritage properties. So we are currently updating it.[25]

Similarly, Fisheries and Oceans Canada stated in its action plan that due to the complexity of the portfolio and resource constraints, the Department was previously unable to update the background and heritage-related information in the required time; however, it is currently updating its real property databases in a systematic manner, prioritizing sites that support program requirements, to be completed by 31 March 2021.[26]

Kevin Stringer, Associate Deputy Minister, Fisheries and Oceans Canada, further provided the following:

For Fisheries and Oceans, the issue of basic tracking is an issue, and we get the concern of the committee.

For us, there were really three things. We want to give the committee assurance. We know what heritage buildings we have and what heritage sites we have.

[We] are serious about improving the situation. It is basic stuff, and we get that. We've had, as part of our comprehensive review process, about a doubling of the investment in our real property programming and a doubling of the [full-time equivalents] that are on this, so we're confident we're going to get it right. We've already cleaned up that part of the database, and we have a broader effort for our 6,600 sites across the country.[27]

Lastly, National Defence, in its action plan, stated that the Department planned to load the new condition assessment data for 214 of 292 heritage buildings by December 2018, to be part of the TBS Directory of Federal Real Property submission for certification; going forward, it “will continue to gather data on the condition of its heritage assets with the objective of assessing the condition of 20% of the real property heritage portfolio each year.”[28]

When questioned about this matter, Jody Thomas, Deputy Minister, Department of National Defence, noted the following:

At Defence we knew the number of buildings we had: 292. They weren't all appropriately listed in our database, and that's now been updated, and we have 78 to assess this coming year.[29]

Therefore, the Committee recommends:

Recommendation 1—on asset data management

That, by 30 September 2019, Parks Canada, Fisheries and Oceans Canada, and National Defence provide the House of Commons Standing Committee on Public Accounts with reports outlining what progress has been made with regard to updating their asset management databases to accurately reflect complete information on the number and current condition of their heritage properties.

B.  Conservation of Heritage Properties

1.   Parks Canada’s Properties

Parks Canada’s mandate includes conserving its cultural resources for present and future generations, while considering available financial and human resources when making conservation decisions. The OAG noted that the Agency established priorities based upon available resources to determine which properties were to be regularly maintained, conserved, and monitored.[30]

Parks Canada invested $50.5 million between 2015 and 2018 to maintain and conserve heritage properties, including “one-time funding to reduce the backlog of deferred conservation work required. However, the Agency acknowledged that it could not conserve all its heritage properties and reported that its deferred maintenance backlog on federal heritage properties was $1.2 billion in 2017.”[31]

Additionally, although the Agency is the federal government’s lead for programs to conserve heritage properties, the OAG found that “its role was primarily limited to recommending heritage property designation for approval by the Minister of the Environment and Climate Change and giving conservation guidance when consulted, including to other federal organizations,” and once this was done, “there was no additional regular funding for departments and agencies to conserve the buildings. Parks Canada could provide conservation advice, but could not compel departments and agencies to follow its advice or to do any conservation or maintenance work in order to protect designated buildings.”[32]

The OAG also observed that “when federal lighthouses were designated as heritage under the Heritage Lighthouse Protection Act, there was no additional regular funding for lighthouse owners to conserve them,” even though the Act “gave the federal government authority to impose conservation requirements on the owners of designated lighthouses, whether the owners were federal departments or other third parties.”[33]

Lastly, the OAG found that “Parks Canada encouraged other federal organizations to prioritize conservation of their heritage properties on the basis of their available resources, thereby acknowledging that not all heritage properties could be conserved.”[34]

2.   Motivation for Departments to Conserve Heritage Properties

According to the OAG, “National Defence and Fisheries and Oceans Canada did not earmark money specifically for conserving heritage properties. The departments did not differentiate between their heritage properties and their other properties. Therefore, they made maintenance decisions on the basis of program requirements, rather than heritage value.”[35]

Under the Financial Administration Act, federal organizations must follow the Treasury Board Policy on Management of Real Property; that is, they must submit buildings 40 years or older to be evaluated and considered for heritage designation.[36] However, the policy only requires them to keep those heritage properties needed for program requirements. The OAG found that once properties were designated, these organizations were not given funds to conserve them; consequently, heritage properties risked continual deterioration. That is, federal organizations had little motivation to conserve all their heritage properties.[37]

Therefore, the OAG recommended that “Parks Canada should lead an assessment of the approach to designate and conserve federal heritage properties. Working with organizations that own properties, it should implement changes to better conserve heritage properties.”[38]

In its action plan, the Agency committed to assessing, “in consultation with custodian departments, the current approach to designate federal heritage buildings,” to be completed by the fall of 2019.[39] Moreover, it “will review, in consultation with custodian departments, the implementation of changes to better conserve federal heritage buildings,” to be completed by the fall of 2020.[40]

When questioned, Michael Nadler, Acting Chief Executive Officer, Parks Canada, stated the following:

Parks Canada is now working with other federal departments to review the approach for designation, considering some of what you've observed here. That includes the ability to maintain and continue to support the heritage value of these buildings. That's across federal departments and multiple federal custodians.[41]

Additionally, Joëlle Montminy provided the following information:

A review of the directive on real property is under way right now led by Treasury Board, so changes could come to the designation process. You're flagging that these designations do not come with legal protection for the place. As my colleague mentioned, it is an honorific designation as it stands currently. In previous reports and audits, there's been a desire to have legal protection attached to the designation process. We've been looking into that and we continue to improve, whether it's through policy tools or exploring what would be involved in legal protection.[42]

Therefore, the Committee recommends:

Recommendation 2—on an approach to designate and conserve heritage properties

That, by 30 September 2019, Parks Canada provide the House of Commons Standing Committee on Public Accounts with reports outlining what progress has been made with regard to A) leading an assessment of its approach to designate and conserve federal heritage properties; and B) collaborating with organizations that own such properties to develop better practices to conserve them.

C.  Information to Canadians and Parliamentarians

The OAG examined “whether Canadians and parliamentarians received up-to-date and accurate information about federal heritage properties” by reviewing “two Parks Canada databases that the public can access for information on federal heritage buildings.”[43] The following are some of the problems it found when comparing the information across these two databases:

• Text describing the same building did not always match in both databases;
• Building descriptions were sometimes incomplete;
• Buildings listed in one database were not always listed in the other;
• The same photograph was used for two different buildings in two different locations;
• Some photographs were historic and did not show the current condition of buildings; and
• Some entries had blank pages or were missing content.[44]

According to the Parks Canada Agency Act, the Agency “must report to Parliament at least every five years, including on the condition of national historic sites and heritage conservation programs.”[45] The OAG noted that although the Agency reported to Parliament in 2011 and in 2016 on the condition of its national historic sites, these reports were incomplete.[46]

Additionally, the Agency is required to “submit a management plan for each national historic site to the House of Commons at least every 10 years.”[47] The OAG found “that these plans were available on the Parks Canada website and included information on the condition of the historic site,” but also found that “39 plans were older than 10 years, and that 87 historic sites did not have a management plan at all.”[48]

Consequently, the OAG recommended that “Parks Canada should provide accurate and up-to-date information to Canadians and parliamentarians through public databases and reports to Parliament.”[49]

In response, the Agency stated in its action plan that upon completion of the actions pertaining to Recommendation 1, the Agency will review how to make this information available to the public; it will also be used in reports to Parliament. This is to be completed by the fall of 2020.[50] In fact, when questioned about this issue, Joëlle Montminy confirmed this by stating the following:

This is part of our response, in terms of making our national database up to date. Based on that, we will then be able to provide that information through Treasury Board where the reporting is mostly done. We will be in a better position to provide that information to Parliament and parliamentarians, and Canadians.[51]

Given the paramount importance of federal organizations providing accurate and timely information to Canadians and Parliament, the Committee takes this matter very seriously and therefore recommends:

Recommendation 3—on providing accurate information to Parliament and Canadians

That, by 30 September 2019, Parks Canada provide the House of Commons Standing Committee on Public Accounts with a report outlining how it has corrected and updated its central asset management system, in order to provide accurate and up-to-date information to Canadians and parliamentarians.

Conclusion

The Committee concludes that Parks Canada, Fisheries and Oceans Canada, and National Defence did not work sufficiently to conserve the heritage value and extend the physical life of federal heritage properties, nor did they have complete and current information about their heritage properties. Additionally, heritage property designation included no additional funding to conserve buildings. Lastly, information for the public and parliamentarians was also inadequate.

To address these concerns, the Committee has made three recommendations to help these federal organizations better manage their responsibilities regarding heritage properties. Such properties are an important part of Canada’s collective cultural history; thus, they must be dutifully conserved to ensure their future.

Summary of Recommended Actions and Associated Deadlines

Tableau 1—Summary of Recommended Actions and Associated Deadlines

Recommendation	Recommended Action	Deadline
Recommendation 1	Parks Canada, Fisheries and Oceans Canada, and National Defence should provide the House of Commons Standing Committee on Public Accounts with reports outlining what progress has been made with regard to updating their asset management databases to accurately reflect complete information on the number and current condition of their heritage properties.	30 September 2019
Recommendation 2	Parks Canada should provide the Committee with reports outlining what progress has been made with regard to A) leading an assessment of its approach to designate and conserve federal heritage properties; and B) collaborating with organizations that own such properties to develop better practices to conserve them.	30 September 2019
Recommendation 3	Parks Canada should provide the Committee with a report outlining how it has corrected and updated its central asset management system, in order to provide accurate and up-to-date information to Canadians and parliamentarians.	30 September 2019