Ministry of Environment: sensible reorganization or shuffling chairs?

We’ve just received word that the BC Ministry of Environment is reorganizing itself.  In addition to a brief official announcement, we also obtained an internal government email from Doug Konkin, Deputy Minister of the Ministry of Environment, which describes the Ministry’s new structure.

Our Realigned Organizational Structure

1.       Environmental Protection Division, Environmental Stewardship Division, Water Stewardship Division, Parks and Protected Areas Division and part of Strategic Policy Division are realigned to create two new divisions.

The Environmental Protection and Assurance Division (EPAD) will be focused on providing environmental leadership for the future through an emphasis on environmental goals and policy development.

The Resource Stewardship and Parks Division (RSPD) will be focused on the decisions of today, striving for excellence in resource management in the areas of fish, wildlife, habitat and water. This will put a greater emphasis on the integration of services “on the ground” on one hand and environmental leadership for the future on the other. 

2.       Given the significance of our transformation projects, RMCP [Resource Management Coordination Project] initiatives, key strategies (e.g., Oceans Strategy) and integrated business planning needs in the ministry, I am establishing an Executive Lead, Resource Integration to help provide the necessary leadership capacity to support these. 

3.       The ministry will continue to be supported by the Conservation Officer Service, Strategic Policy Division, Climate Action Secretariat, and Corporate Services Division.  

MoEReorg.jpgDeputy Minister Konkin's email was accompanied by diagrams showing how the new structure is supposed to fit together, which we've uploaded at the end of this post. 

A few observations about the reorganization. 

It’s not about the budget – no really

Although the Deputy Minister is generally upbeat about the new structure and is clear that “these changes are not driven by budget,” reading between the lines one has the impression of a Ministry that is struggling to deliver its mandate while dealing with lack of funding:

Many staff tell me they are sometimes overwhelmed with workloads and cannot react fast enough to the demands placed on them.  Staff have told me they are worried about the growing environmental pressures we are facing.  It is clear we can no longer spend so much of our time responding to specific projects and trying to mitigate negative impacts.

The answer, according to Deputy Minister Konkin, is to make better use of social media and to rely even more on industry and society to protect the environment:

Future success depends on accelerating the shift to proactive environmental management; on using social media and finding more ways to get manufacturers, proponents and society to protect the environment.  This includes product life cycle thinking, use of market based instruments, polluter pay approaches and improved professional reliance, among other strategies.

While I’m all in favour of using social media, it’s not a panacea that removes the need for a government agency capable of “responding” to the environmental impacts of “specific projects.”  And let’s keep in mind that the Ministry’s 2010 Service Plan didn’t use the word “social media” once. 

Nor am I fond of the idea that the Ministry needs to focus on finding more ways to get industry to protect the environment, rather than on mitigating the negative impacts of industry-led projects. 

The Ministry of Environment, more than just about any other, has been cut to the bone.  Although changes in government organization and accounting practices makes it hard to calculate cuts to what is now the Ministry of Environment over the past several years, there is little doubt that they are substantial.  It’s not uncommon for organizations that are under stress to try to deal with the situation through a reorganization.  In some cases where the structure was really a fundamental problem, such reorganizations can be good.  But in other cases they don’t accomplish much, divert badly needed resources and create new costs and stresses of their own.  

On the ground vs. environmental goals

There’s not a lot to suggest that the Ministry’s reorganization is being driven by fundamental problems with the old structure, or by a clearly articulated vision of how the Ministry can be more effective within the new structure.  So we’re predisposed to be sceptical of this reorganization. 

But in addition to natural scepticism about the need for a reorganization, there are a number of specific comments and questions arising from the reorganization, many of them related to the clear division between the RSPD  – which focuses on “on the ground” “resource management” and the EPAD – which works on “environmental goals and policy development.”  Seems like an artificial distinction that will discourage communication between two groups that should be working closely together. 

In addition, it looks to me as if the reorganization contemplates an expanded administrative role for the Regional Offices, with the Regional Offices taking on a wide range of licensing/approval functions, habitat restoration functions, compliance roles, etc.  If this is the case, will Ministry staff be redeployed to increase the numbers of staff in regional offices?  If not, how will regional staff – already thin on the ground – meet their new mandates?

Some areas of responsibility seem to have been divided between the EPAD and the RSPD and regional offices.  One example would be Water Stewardship, which will see responsibility for licensing occurring at the regional office level, oversight of the licensing regime (Comptroller) taking place in RSPD, and the scientific expertise surrounding water management and use housed in the EPAD.  How’s that going to work in practice?

This seems like a fairly sudden announcement.  There was certainly no mention of a reorganization in the 2010 Ministry of Environment service plan, and all indications from the email is that the announcement was a surprise for most Ministry staff.   It will be interesting to see how the re-org plays out on the ground and whether any revisions will need to be made to address concerns from Ministry staff. 

Andrewblogphoto.jpgBy Andrew Gage