Where Does the Money Go?

Report on Proactive Disclosure of Grants and Contributions for Aboriginal Peoples, 2006 – 2007

(Former) National Chief's Message
Introduction
Methodology

Part I: What We Learned About the Proactive Disclosure System

Part I Summary: What We Learned About the Proactive Disclosure System - Our Conclusions

Part II: What We Learned About the Distribution of Federal Grants and Contributions for Aboriginal People - Where Does the Money Go?

Part II Summary: What We Learned About the Distribution of Federal Grants and Contributions for Aboriginal People - Our Conclusions

Part III: CAP's Concerns and Conclusions About the Management of Grants and Contribution Funding by the Federal Government

Appendix A: Identified Aboriginal Grants and Contributions in Departmental Proactive Disclosure Listings, 2006 - 2007

Appendix B: Residency of Registered Indians as of December 2006

Appendix C: Statistics Canada 2001 Census Data regarding Aboriginal Populations in Canada

Appendix D: Federal Aboriginal Grant and Contributions, 2006 - 2007

Endnotes

Methodology

Our approach was simple.  Information contained within the various Proactive Disclosure websites was reviewed to identify “Aboriginal” expenditures.  Once a grant or contribution had been determined to be “Aboriginal” – either because the recipient or the program was identifiable as Aboriginal – it was entered into a database that would allow for sorting by type of recipient, region, or department.
In order to categorize expenditures, each recipient was assigned an organizational “type” as it was entered.   This was occasionally a difficult exercise, because information on the organization was not always available.  Where possible, we accessed information from the Internet, often using the organization’s own information to identify its affiliation and purpose. 

Our review identified 6,199 grants and contributions to 2,054 recipients from 30 federal government departments for a total value of $5,606,665,491.  A listing of the identified recipients is attached to this report as Appendix D.

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Part I: What We Learned About the Proactive Disclosure System

The enormous volume of grants and contributions and the amount of effort required to develop a “big picture” view of Aboriginal specific programming is substantial.  Treasury Board has acknowledged that, for 2004 – 2005, thirty-four separate agencies and departments reported program expenditures targeted to Aboriginal people. 7 For the year that we reviewed, 2006 – 2007, Indian and Northern Affairs Canada was the largest program provider, reporting 4,032 grants or contributions, for a total of $4,634,000,049.  Health Canada is second, with 987 reported transfers, for a total of $624,001,570.  A table summarizing the 2006 – 2007 reported and identified grants and contributions by department is attached as Appendix A.

In the process of compiling the database, we observed several limitations to the existing Proactive Disclosure process.  Recognizing that the release of this type of information is relatively new, the Congress urges the Government of Canada to review our concerns and consider the following recommendations.

Non-Disclosed Amounts

The non-disclosure of amounts under $25,000 means that the total grants and contributions reported by a specific department cannot be matched against their corresponding Parliamentary appropriation for a particular year.  It is impossible to tell, for example, what percentage of G&Cs for a particular department has actually been reported through the disclosure process.    Furthermore, the disclosure requirements do not appear to apply to all federal operations: Canada Mortgage and Housing Corporation, which provides significant funding through a subsidy program for Aboriginal housing, is not included in Proactive Disclosure.

Recommendation(s):
Departments, minimally, should provide a summary statement with their disclosure that indicates the number of unspecified (less than $25,000) grants and contributions and the total amount that is not included in their proactive disclosure listings.

All Agencies and Crown Corporations should be included in the Proactive Disclosure process.

Clarification of Fiscal Year

Even though amounts are posted in the proactive disclosure listing as relating to a specific quarter, the actual date assigned to the transfer, particularly for the 4th Quarter disclosures, are often outside of the 2006 – 2007 fiscal year.  This makes it impossible to determine if the contribution is for the past, current, or subsequent fiscal year.

Recommendation:

Proactive disclosure information should specify the fiscal year to which the transfer relates.

Multi-Year Reporting

Many transfers were reported as multi-year contributions.  While multi-year agreements allow for more effective planning by recipients (and should generally be encouraged), the reporting of these amounts as a single entry make it difficult for users of the information to analyze or compare contributions on an annual basis.  Multi-year reporting also creates the impression of non-spending or non-reporting of significant investments in subsequent years.  One example of this within the 2006-2007 fiscal year is the training and employment funding provided by Service Canada under the Aboriginal Human Resources Development Strategy.  Significant investments appear in the department’s Main Estimates but these not disclosed in the proactive disclosure reporting system. 

Recommendation:
Proactive disclosure should report only single current fiscal year cash flow. 

Batched Reporting

INAC and Health Canada, who process many programs through single agreements, disclose multiple contributions in “batches”.  This prevents users from being able to determine, for example, how much money is provided to a particular organization for services such as economic development, housing, education, social programs, or home care.  These are important issues for community members, both on and off reserve, and the current disclosure methodology is less than adequate.

An additional problem is the further reduction in transparency that occurs as a consequence of INAC’s use of a flexible funding arrangement, known as the DIAND/First Nations Funding Agreement.    Funds flowed through these agreements are not publicly reported as separate program allocations.

Recommendation:
Each program area should be disclosed as a separate entry.

Numbered Companies

Several economic development contributions to companies are posted as numbered companies, which provides no useful information to users about the recipient.

Recommendation:

Proactive disclosure should include the company’s operating or trade name, if there is one, and the provision of a bona fide operating or trade name should be a matter or standard disclosure for all grants and contributions.

Presentation of Information

The current method of reporting, department-by-department, and quarter-by-quarter, is extremely cumbersome for users.  If an individual wants to know the total G&C profile for a particular organization for the year, more than 120 separate searches are required.  This may frustrate all but the most determined citizen in their efforts to understand an organization’s G&C profile.

Recommendation:
Reporting of grants and contributions, rather than being split across departments, should be centralized into one reporting site with standardized reporting criteria for all departments.

Capacity to Follow Up on Reported Transfers

Users of the website information may wish to learn more about a specific transfer that appears on a proactive disclosure listing.  There is virtually no information on these sites that directs users how to make further inquiries.  The complexity of government departments is such that transfers might be approved at either the national or regional level, and across multiple program areas.  Users of information would have a difficult time identifying an appropriate contact person.  Furthermore, program officers are bound to follow the provisions of both the Privacy Act and the Access to Information Act, and may find follow-up inquiries difficult to manage.

Recommendation:
Proactive disclosure websites should provide the contact information for follow up inquiries, and departments should develop processes to ensure that further inquiries are responded to in a consistent and timely way.

Third Party Distribution

A number of sizeable transfers are reported as “third party distribution”.  This means that the recipient of record redistributes the funds to eligible organizations or clients on behalf of the Government.  It is impossible to tell from the government disclosure websites who and how many final recipients there are, and how much they may have received.

Recommendation:
That the recipients of “third party distribution” funding be required to comply with the proactive disclosure of final recipients, provided that the disclosure does not violate the provisions of the Privacy Act.

Insufficient Program Information

Several departments provide information using acronyms, which are not defined on the disclosure site.  A further problem is that the actual program may not be identified. For example, the information we entered for Industry Canada did not identify specific contributions related to the Aboriginal Business Canada (ABC) program.  For this reason, we were unable to identify much of what we believe may have been contributions to Aboriginal businesses, based on the information provided.  In some cases, the address of the recipient or their inclusion on the Procurement Strategy for Aboriginal Business directory was used to verify the Aboriginal nature of the contribution – otherwise they were not included in our database.

Recommendation:

The name of the funding program should be included as a mandatory requirement for routine disclosure.

Additional Issues

Treasury Board requires government departments and grant and contribution recipients to avoid “stacking” program funds.  Stacking refers to the potential for multiple government contributions for a single project or initiative.  In light of the number of departments and third party distribution recipients who are involved in funding Aboriginal programs, what mechanisms exist across departments to prevent stacking of contributions?

In addition, many Aboriginal organizations are affiliated with each other.  For example, Band Council may participate in initiatives managed by its Tribal Council, a Provincial/Territorial Organization (PTO), or one of the National Aboriginal Organizations.  What mechanisms exist within government to ensure that each organization is not being provided with separate contributions to work on the same or similar initiatives?

It should be noted that the Government of Canada, through the Canada First Nation Funding Agreement, which was developed in the 1990s, intended to provide a funding instrument that would have consolidated federal funding across multiple departments into a single agreement.  To date, however, most federal government departments have not embraced the potential provided by this type of agreement. 

The consolidation of funding for single recipients into one agreement would assist the Government of Canada in preventing “stacking” of transfers within a single organization and the duplication of transfers for similar activities across related organizations.

The Congress of Aboriginal Peoples believes that the processing of all Grants and Contributions for Aboriginal organizations should be centralized into one contribution agreement per organization, administered by a central department or agency.

The Royal Commission on Aboriginal Peoples contemplated this approach when it reported in 1991, in its recommendation that the Government of Canada create a new Department of Aboriginal Relations.  One of that new Department’s responsibilities would be to allocate funds from the federal government's total Aboriginal expenditures across the government.

7. Treasury Board Secretariat of Canada, Aboriginal Affairs:  Programs and Spending.   http://www.tbs-sct.gc.ca/aaps-aapd/faq.aspx?Language=EN

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Part I Summary: What We Learned About the Proactive Disclosure System - Our Conclusions

Presumably, the purpose of all reporting of government expenditures is to increase transparency and permit the public to better understand government priorities and operations. 

The proactive disclosure system, as it presently exists, is inadequate to provide Aboriginal people with sufficient and accurate information about how program funds are being allocated.  The current system should be regarded as a minimal effort at disclosure relative to the transfer of significant public funds for Aboriginal programs and services.

In addition, approximately $4 billion of the estimated $10 billion in Aboriginal program spending could not be identified through the public reporting of Grants and Contributions.  In the spirit of transparency and accountability, the federal government should provide Aboriginal people with standardized, annual, and consolidated reporting on these funds, in addition to the relatively new system of reporting Grants and Contributions.

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Part II: What We Learned About the Distribution of Federal Grants and Contributions for Aboriginal People - Where Does the Money Go?

The largest portion of the 2006 – 2007 transfers are to Band Councils.

Of the $5.6 billion identified Grants and Contributions, $3,748,881,596 (67%) is transferred directly to Band Councils.

Organizations created or mandated by Band Councils to serve reserve-based populations are the second largest group of recipients.

This group of recipients includes tribal councils, First Nation health, education and social service agencies, the Assembly of First Nations and its affiliated Provincial/Territorial Organizations (PTOs). This group of recipients received approximately $1.3 billion (23%) of the total identified Grants and Contribution funding.

An additional 1.6% of federal Grants and Contributions were transferred directly by the Federal Government to Provincial and Municipal Governments to provide services to reserve based populations

The distribution of federal grants and contribution funding between on and off reserve Aboriginal people appears to be disproportionate to the residency of the Aboriginal population.

Based on the information contained in the Proactive Disclosure system, it appears that (minimally) 92% of the identified Grants and Contributions were allocated to support reserve-based recipients.  Statistical information about the composition and residency of Aboriginal populations is included in Appendix B and Appendix C.

The balance of the identified grants and contributions include programs and services that are delivered in urban and rural communities and are generally available to all Aboriginal people, regardless of their status under the Indian Act.  The exception to this would be programs provided by organizations affiliated with the Metis National Council, which tend to provide services to members of those Metis organizations only.

*Amount does not total 100 % due to rounding.

Our analysis concluded that approximately 5% of the 2006 – 2007 reported Grants and Contributions were allocated to organizations that supported off reserve Aboriginal people, or were of benefit to all Aboriginal people, regardless of residency.

Of the Grants and Contributions we analyzed, approximately 4% could not be categorized as either on or off reserve expenditures, due to a lack of information about the program or recipient.  However, the trend is clear:  92% of federal Aboriginal Grants and Contributions we identified are directed towards the 30% of the Aboriginal population who live on reserve.

There is some justification for what appears to be a significant disparity.  Funding that directly relates to service delivery (education, health and social services, infrastructure) is provided to Band Councils and their specialized or delegated service delivery organizations to provide these services on reserve, while off reserve people access these services primarily through provincial and municipal governments.

However, there is no similar justification for the disparity between funding for the National Aboriginal and Regional (Provincial/Territorial) organizations, who (for the most part) do not provide services.  These organizations, typically referred to as “representative organizations”, exist as political bodies to coordinate policy, consultation, and negotiation activities on behalf of their member organizations, and ultimately, their Constituencies.

The distribution of funds between representative organizations is inequitable.

*Amount does not total 100% due to rounding.

Readers are cautioned that some of the above organizations have significant amounts reported in the 2006 – 2007 fiscal year that are in fact multi-year contributions.  This is particularly true for the Metis National Council and the Native Women’s Association of Canada.  If adjusted to reflect the actual 2006 – 2007 cash flow for those multi-year contributions, the disparity between the representative organization funding increases.

Aboriginal programming is delivered in departmentalized silos that do not support broader, strategic objectives. 
There is general agreement that economic development will reduce Aboriginal dependency and increase individual and community well being.  We identified federal contributions for economic development activities scattered across 14 different federal departments.

The information available to us on economic development funding is incomplete, but entirely instructive about the nature of Aboriginal program funding in Canada today.  The information in the following table is incomplete because it includes only those recipients who were not classified as band or tribal councils, or PTOs.  Accordingly, the data in the table below is limited to recipients who were uniquely funded to undertake economic development activities or projects.   The Department of Indian Affairs and Northern Development provides (within the “batched” grants and contributions to bands and tribal councils) funds for economic development activities such as advisory services.   It is currently not possible to determine from the G&C disclosure what portion of transfers to these organizations relates to economic development.  Readers should be aware, therefore, that the actual federal expenditures for Aboriginal economic development is significantly higher than the table below indicates.

Furthermore, our data is incomplete because Industry Canada reported Aboriginal Business Canada contributions without specifying the program, and Service Canada’s Aboriginal Human Resources Development Strategy 2006 – 2007 funding was reported in a previous year (multi year contribution) and is therefore not included in 2006-2007 database. 

According to the Department of Indian and Northern Development’s Report on Plans and Priorities for 2006 – 2007, the anticipated economic development program spending for that year (excluding capital infrastructure) was $630 million.    Existing Proactive Disclosure reporting makes it impossible to distinguish how much of that planned spending was allocated to band or tribal councils, both of whom are funded for economic development services by the Department of Indian Affairs and Northern Development.

The amount of money and the number of agencies involved in Aboriginal economic development attests to the fact that the federal government recognizes its importance as a strategic objective.  However, any attempt to analyze this single “priority” within the big picture of federal grants and contributions for Aboriginal programs quickly demonstrates the “fatal flaw” in existing Aboriginal program funding.   An Aboriginal person interested in pursuing self employment or developing a small business must identify appropriate business advisory services and funding support, but it becomes an exercise of “running madly off in all directions”.  The potential entrepreneur’s plans may be restricted by his/her “status”, residency, affiliation with a specific band or organization, or a lack of clarity over permitting and licensing for his project.   The situation is further exacerbated by the availability of provincial, territorial, municipal or regional program availability, which may or may not complement the federal funding.

We are not suggesting that any federal department, provincial, territorial or municipal government withdraw funding to reduce complexity.  Rather, that before additional investment is made in economic development, that all parties work together to ensure that the program delivery infrastructure is re-designed to reduce overall administration costs for providing these services and maximize their accessibility and effectiveness for potential clients.

Part II Summary: What We Learned About the Distribution of Federal Grants and Contributions for Aboriginal People - Our Conclusions

As previously noted, Treasury Board attempted in 2004 – 2005 to map out Aboriginal expenditures.   That effort generated an “Aboriginal Horizontal Framework” in 2005, which laid out spending for Indian, Metis and Inuit people. 8 Our analysis attempted to add a further break down of grants and contributions by recipient type in order to assess the distribution of Aboriginal program funds across reserve boundaries. 

The results of our review suggest there is a disproportionate allocation of resources between on and off reserve recipients.  However, we believe that there is an urgent need to further both approaches.   Allocation and tracking of federal program funds on the basis of existing distinctions between Indian, Metis, and Inuit people is quickly becoming an anachronism that may not be sustainable in light of court cases such as Corbiere, 9 Powley,10 McIvor,11 or Lavigne. 12 Additionally, the mobility of the Aboriginal population and the increasing number of families with multiple Aboriginal identities suggest that grant and contribution programs which limit eligibility on the basis of residency or status may in fact be discriminatory.

Funding formulas that are structured on the basis of entitlement for “Registered” Indians, without an adjustment process to account for actual residency, create service gaps that ultimately lead to the disturbing statistics which plague both Governments and Aboriginal people in Canada.

To put this in context, one needs to consider the implications of the federal government providing funding to the Province of Newfoundland in order to provide specific programs and services to Newfoundlanders who live in Alberta.    The on/off reserve question needs to be answered, so that appropriate distribution of program funds can be achieved, and the opportunity for different results created.  Our analysis attempted to clarify the on/off reserve distribution of funds but the inconsistencies in the current Proactive Disclosure system are a barrier to the completion of this effort.

Data relating to off reserve expenditures and program availability (in actual as well as theoretical terms) is necessary to proceed with informed and evidence-based discussions with Provinces, Territories, Municipal Governments and Band Councils.

Finally, the Congress believes that more accurate information is required about the nature, type and number of recipients.    Many recipients receive federal funding from a single source.  At the other end of the funding spectrum, one Provincial/Territorial Organization had fourteen contributions reported from five different departments.   This suggests that different types of funding instruments may be appropriate to different types of organizations.

8. Treasury Board Secretariat of Canada, Aboriginal Horizontal Framework, November, 2005.  http://www.tbs-sct.gc.ca/aaps-aapd/pdf/poverview_e.pdf

9. Corbiere v. Canada (Minister of Indian and Northern Affairs), [1999] 2 S.C.R. 203

10. R. v. Powley, [2003] 2 S.C.R. 207

11. McIvor v. The Registrar, Indian and Northern Affairs Canada, [2007] BCSC 827

12. R. v. Lavigne, [2005] NBPC 8

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Part III: CAP's Concerns and Conclusions about the Management of Grant and Contribution Funding by the Federal Government

Modern government accountability is not just about whether every dollar that has been spent has been fully accounted for.  It is about whether that dollar has been used in the most effective way possible to produce the desired results.     Aboriginal grants and contributions have been the subject of allegations and complaints, audits, investigations, and in some cases, criminal and civil court proceedings.  It remains absolutely necessary to address malfeasance, corruption, and fraud when it exists, but disproportionate focus on these issues diverts time and effort from an important and potentially more challenging national debate.  Canada and Aboriginal people can no longer afford a system that supports Aboriginal programs and services, intended to meet desperate need, but delivered without clear objectives or strategies to ensure those services are universally accessible, adequate, appropriate, and administered to maximize resources.  

Our analysis, based solely on the limited information contained in the Grant and Contribution disclosure system, cannot consider significant questions that need to be asked and answered about funding for Aboriginal people.  This is because the existing reporting of federal grants and contributions provides no information on the following:

1. How much federal funding is transferred to Provinces and Territories for Aboriginal people (using instruments other than Grants and Contributions) and is it being directed to Aboriginal programs?
2. Are Provinces and Territories typically spending more or less than they receive in federal transfers related to Aboriginal populations? 
3. Which level of government ultimately bears primary responsibility for Aboriginal program expenditures that are the focus of “jurisdictional” disputes?  What mechanisms are needed to begin resolving these disputes in a productive and timely way?
4. Is it appropriate for governments to provide varying entitlements and inequitable program access to Aboriginal people because of status or residency?
5. Noting that the Aboriginal population is highly mobile, including frequent movements between federal and provincial jurisdictions, are there federal/provincial agreements in place to ensure program access is not compromised by mobility?
6. If “reasonable provincial comparability” is the program test for on-reserve program and service delivery standards, what mechanisms are used to ensure that funding is adequate to meet that test?  Furthermore, how do federal and provincial governments ensure that provincial program changes, including enhancements, are supported for on-reserve delivery?
7. Are on-reserve regulatory regimes sufficient to ensure that program quality and service delivery standards are being maintained? 
8. If urban and rural Aboriginal people are expected to access programs that are available to the general population, are there mechanisms in place to ensure that provincial, territorial, and municipal government program design and delivery actually provides adequate, accessible, and appropriate services to their Aboriginal citizens?
9. For programs and services being delivered by Aboriginal organizations, what economies of scale and strengthening of capacity can be achieved through appropriate delegation and aggregation of service delivery?
10. For all programs, what is the final distribution of resources between actual program spending and administration costs?

The distribution of Grants and Contributions occurs near the “end” of the federal program funding cycle.  Before program funds can be allocated as a Grant or Contribution, there is a great deal of political and bureaucratic effort required to authorize those expenditures.  These include Cabinet approvals, the development of Treasury Board program terms and conditions, appropriation of funds by Parliament, Departmental priorization of program resources, and creation of funding formulas, allocation methodologies, and so on. 

Financial accountability focuses on recipient financial reporting, including annual audits.

Program accountability has typically been left to the Auditor General, who may only review a program every ten years, and Treasury Board, who renew program authorities for each program every five years.  Consistently, the Office of the Auditor General has raised concerns about the lack of clarity around roles and responsibilities for Aboriginal programs.   Treasury Board continues to carve out silos for program delivery between departments, resulting in gaps, duplication, and Aboriginal people’s real needs becoming “jurisdictional disputes”.  This includes education, housing, municipal services such as water and sewer, and child and family services – significantly, the very programs that are necessary to improve the quality of life and opportunities for Aboriginal people.  

The Congress believes that it is time to move the national debate from “financial accountability” to “program accountability”, including clear assignment of roles, responsibility, and accountability for results by federal departments, provincial and territorial governments, Band Councils and Aboriginal organizations.   We note that water related deaths in Walkerton and ensuing political crisis forced this exercise for on-reserve water quality.  A horizontal “First Nations Water Management Strategy” eventually evolved as a coordinated federal response.13 This exercise needs to be repeated for every program area as a matter of some urgency (economic development, education, social services, housing, and health care).   And, it must also include a realistic analysis of “on/off” program availability and accessibility in order to stop the legacy of personal and community tragedies that seem endemic to the lives of Aboriginal people in Canada today.

It is time for everyone to insist on results, in addition to audits.  And, it is time to stop funding programs, processes, and organizations that cannot demonstrate results for Aboriginal people so that valuable resources can be directed to programs and services that actually have a positive impact on Aboriginal peoples’ lives and well-being.

Accountability that only asks the question “Where did the money go?” cannot begin to address the real issues and challenges that Aboriginal people and all governments in Canada must confront.  Public reporting of Grants and Contributions through the Proactive Disclosure system only nominally begins to address the question of transparency, and raises far more questions – legitimate and important questions -- than it answers.

More work - courageous, forthright, and honest work - needs to be done. 

13. Indian and Northern Affairs Canada, First Nations Water Management Strategy http://www.ainc-inac.gc.ca/H2O/bkg_e.html

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Appendix A:

Identified Aboriginal Grants and Contributions in Departmental Proactive Disclosure Listings, 2006 - 2007

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Appendix B:

Residency of Registered Indians as of December 2006

Registered Indian Population by Sex and Residence, 2006
Department of Indian Affairs and Northern Development

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Appendix C:

Statistics Canada 2001 Census Data regarding Aboriginal Populations in Canada

Total Aboriginal Identity Population

• 976,305  (3.29 % of Canadian population)

On/Off Reserve Aboriginal Identity Population

• On Reserve, 286,080 (29% of Aboriginal population)
• Off Reserve, 690,225 (71% of Aboriginal population

Off Reserve Aboriginal Population

• North American Indian, 336,435  (49%)
• Metis, 284,995  (41%)
• Inuit, 43,260 (6%)
• Multiple Aboriginal Identity, 6,145  (1%)
• Other, 19,390            (3%)

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Appendix D:

Federal Aboriginal Grant and Contributions, 2006 - 2007

(Available in PDF Here)

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Endnotes:

• Martin Cooke, Daniel Beavon, and Mindy McHardy, Measuring the Well-Being of     Aboriginal People:  An Application of the United Nations’ Human Development Index to Registered Indians in Canada, 1981 – 2001.   October, 2004;
• Statistics Canada, Aboriginal Identity Population, 2001;
• Treasury Board Secretariat of Canada, Disclosure of Grant and Contribution Awards over $25,000.  http://www.tbs-sct.gc.ca/pd-dp/dgc-dsc/index_e.asp ;
• Treasury Board Secretariat of Canada, Policy on Transfer Payments, Appendix A:  Definitions.http://www.tbs-sct.gc.ca/pubs_pol/dcgpubs/TBM_142/ptp1_e.asp#_Toc482671180 ;
• Treasury Board Secretariat of Canada, Policy on Transfer Payments, Appendix A:  Definitions.http://www.tbs-sct.gc.ca/pubs_pol/dcgpubs/TBM_142/ptp1_e.asp#_Toc482671180
• Treasury Board Secretariat of Canada, Values and Ethics Code for the Public Servicehttp://www.tbs-sct.gc.ca/pubs_pol/hrpubs/TB_851/vec-cve1_e.asp#_Toc46202803
• Treasury Board Secretariat of Canada, Aboriginal Affairs:  Programs and Spending.   http://www.tbs-sct.gc.ca/aaps-aapd/faq.aspx?Language=EN
• Treasury Board Secretariat of Canada, Aboriginal Horizontal Framework, November, 2005.  http://www.tbs-sct.gc.ca/aaps-aapd/pdf/poverview_e.pdf
• Corbiere v. Canada (Minister of Indian and Northern Affairs), [1999] 2 S.C.R. 203
• R. v. Powley, [2003] 2 S.C.R. 207
• McIvor v. The Registrar, Indian and Northern Affairs Canada, [2007] BCSC 827
• R. v. Lavigne, [2005] NBPC 8
• Indian and Northern Affairs Canada, First Nations Water Management Strategy http://www.ainc-inac.gc.ca/H2O/bkg_e.html