When browsing twitter last week, I came across the following post:
That’s right- DFO is seeking public consultation on (some of) the changes to the Fisheries Act. For those interested, the link to the changes (and instructions on how to comment- there’s a process, not surprisingly) is here:
Great, consultation. This is a good thing. So, I thought I’d check the DFO website to see where it was advertizing the fact that it was looking for consultation:
Hmm- nope, just Economic Action Plan ads. Okay, it must be under the news section- the notice for publication was made on April 13th, so there’s probably a news release to let people know that it’s available for comment:
Okay, nothing there for April 13th, and no earlier announcements (you can check the site yourself to verify: http://www.dfo-mpo.gc.ca/media/news-presse-eng.htm).
Maybe an oversight then. Surely, it’s on the DFO twitter feed- after all, this is what social media is for, right? Interaction and engagement with an audience. Let’s see:
Hunh. So all this news clearly overwhelmed DFO’s communication staff around the 13th of April, and besides, it’s only asking for public consultation on the Fisheries Act, which essentially guides how the department operates on a day-to-day basis. Nothing as important as talking about how to age cod.
Hold on- let’s go back to the Gazette page for a second:
“Fisheries and Oceans Canada is communicating with stakeholders to raise awareness of this regulatory proposal and to inform stakeholders of the comment period afforded through prepublication of the proposed Regulations in Part Ⅰ of the Canada Gazette. Potential revisions to the proposed Regulations will be made based on comments received during the 30-day comment period.”
Oh- I see. Publication in the Gazette IS the notification. Because everyone I know reads the Canada Gazette regularly (clearly, it’s something we should probably be doing more often). Interestingly, there’s all kinds of amendments where consultation is currently being sought, by the Department of Environment, the Canadian Environmental Assessment Agency, and Parks Canada, to name a few.
Okay, so if you’re interested in making comments, note the following (also from the Canada Gazette page):
“Interested persons may make representations concerning the proposed Regulations within 30 days after the date of publication of this notice [April 13, 2013]. All such representations must cite the Canada Gazette, Part Ⅰ, and the date of publication of this notice, and be addressed to Ray O’Flaherty, Legislation and Regulatory Affairs, Fisheries and Oceans Canada, 200 Kent Street, Ottawa, Ontario K1A 0E6 (tel.: 613-993-0982; fax: 613-993-5204; email: FPR-RPP@dfo-mpo.gc.ca).”
So, if you don’t cite the Canada Gazetter, the date of publication, AND address it to Ray, they have every right to toss your comments in the trash. Be warned.
And in case you’re not going to read all these particular posted changes, the main issue they are seeking consultation on is review times for proponents who are undergoing “development” that has the potential to be harmful to fish. The proposed timelines are 60 days to notify the proponent that their application is complete and no additional information is required, and then 90 days from the time of notification that applications are complete to either authorize or refuse the proposed work. 5 months total. That should be pretty simple, since the department just cut 130 positions from the habitat program (the folks doing these reviews) and plans to absorb another $100 million in cuts over the next 3 years. This, despite recent work showing that review times on habitat authorizations weren’t taking very long before these changes.
If you think these proposed timelines are as fishy as they sound, I would encourage you to submit your comments to Mr. O’Flaherty.
And take note- you may need to actually work really hard as a member of the public to find out you’re being consulted with by the current government.