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  • 标题:Organizing for mega-consultation: HRDC and the Social Security Reform.
  • 作者:Lindquist, Evert A.
  • 期刊名称:Canadian Public Administration
  • 印刷版ISSN:0008-4840
  • 出版年度:2005
  • 期号:September
  • 语种:English
  • 出版社:Institute of Public Administration of Canada
  • 摘要:"The greatest room for public involvement is with ill-structured issues. These are the most difficult issues because conflict often centers on the basic problem definition and the values inherent in the evaluation criteria. Public educational forums, including Internet chat rooms, provide a means for soliciting public comment on the problem and may be important in the discovery phase of analysis. Often, however, it is participation on a smaller scale that yields important progress on a problem." (2)
  • 关键词:Social security reform

Organizing for mega-consultation: HRDC and the Social Security Reform.


Lindquist, Evert A.


"It is important to distinguish between matters that are amenable to a consultative process and those that have to be dealt with primarily as political contests. The precise line between the two may not be clearly delineated in practice, but a failure to recognize the differences can undermine the benefits that consultation can bring. Rather than building community trust or overcoming cynicism, governments may be hamstrung by becoming trapped in political fights they cannot successfully manage." (1)

"The greatest room for public involvement is with ill-structured issues. These are the most difficult issues because conflict often centers on the basic problem definition and the values inherent in the evaluation criteria. Public educational forums, including Internet chat rooms, provide a means for soliciting public comment on the problem and may be important in the discovery phase of analysis. Often, however, it is participation on a smaller scale that yields important progress on a problem." (2)

On 31 January 1994, Lloyd Axworthy, the minister of human resources development, announced a sweeping review of federal government programs pertaining to social security including unemployment insurance, social assistance, postsecondary education and student loans programs, employment training and retraining programs, and support for children and families. The minister indicated that the standing committee of human resources development would undertake preliminary consultations, a ministerial task force on social security reform would be created and, following the release of an "action plan" later in the spring, extensive public consultations would take place.

There are many stark images associated with the Social Security Reform (SSR) process: protesters bursting into the hearings of the standing committee; the minister ducking flying objects and attempting to respond to thousands of angry students on Parliament Hill; and, on the day of the release of his long-awaited discussion paper on social security reform, the minister responding to a torrent of questions about a leaked document outlining impending cuts to social security programs in the next federal budget. The lingering impressions are of a process beginning with a big bang and high aspirations, and ending with a whimper; of a reform initiative undermined by federal-provincial considerations and deficit-reductions; and, finally, of reforms eventually delivered in a piecemeal, as opposed to a comprehensive, fashion by the government.

These impressions do not do justice to an extraordinary set of consultations which proceeded under the auspices of the Department of Human Resources Development Canada (HRDC), the standing committee on human resources development (SCHRD), and individual members of Parliament. The SCARP heard 637 groups, the MP town halls involved 20,000 citizens, and HRDC received over 43,000 workbooks, enabled close to thirty policy seminars and policy colloquia, and experimented with web-based technology. Moreover, this was a high-water mark of experimentation following the consultations for the constitutional debates and the Charlottetown Accord, as well as Paul Martin's preparations for his first budget as minister of finance.

This paper provides an account and assessment of the SSR consultations, focusing on managerial challenges and lessons. (3) It does not analyse the problems and policy options embraced by the SSR, (4) nor gauge the extent to which particular consultation instruments or specific groups influenced the minister, the Liberal government, or officials on certain issues, nor chronicle the competition between the minister of finance and the minister of human resources development. (5) The focus is administrative: on how capacities were created or aligned to design and implement a broad consultation strategy pertaining to a complex policy problem, and on how this was coordinated with consultations and decision-making associated with the other policy reviews, the Program Review and pre-budget consultations launched by the government in 1994.

The SSR must be put in context if the appropriate lessons are to be drawn. Despite the ambitions of the minister to produce what I call a "comprehensive policy innovation"--one simultaneously seeking to address several complex and interrelated problems--the Chretien government had yet to determine its priorities beyond its Red Book promises for the October 1993 election campaign. The SSR was a formative process that, like the Program Review, informed and shaped the emergent preferences of a relatively young government. Despite the public tribulations and some key deficiencies in planning, the government was able to mobilize an impressive set of consultations and, ultimately, was well served by the consultations and broader policy process: it discovered its preferences, squared high-level social policy aspirations with its fiscal and intergovernmental strategy, and decided to proceed with social policy reform on a selective and sequential basis.

The first section outlines the context for reform and introduces key concepts. The next three sections review the major phases of the SSR (see Figure 1). The first phase covers the SSR launch, the work of the Ministerial Task Force (MTF), the first hearings held by SCHRD, and the unsuccessful effort to produce the "action plan" by the promised date. The second phase includes the difficulties in drafting the discussion paper and how HRDC and SCHRD prepared for consultations. The third phase began with the release of the discussion paper on 5 October, setting in motion a bewildering array of consultation activities, and officially ending with the February 2005 budget. The fifth section reviews key lessons for managing mega-consultations on its own terms, while the next considers the decision to simultaneously proceed with a comprehensive policy innovation early in a mandate without a strong policy blueprint and with mega-consultations. The final section puts these lessons in contemporary context and proposes using mega-consultations as a backdrop to explore the value-for-money of different consultation instruments.

The Social Security Reform: Context and concepts

On 4 November 1993, Lloyd Axworthy was appointed as minister of human resources development Canada. Having served previously as minister of employment and immigration in 1980-83, one of HRDC'S predecessor departments, and with a strong political base in Western Canada, he was progressive on social policy issues and had already cultivated a network of academics and social policy experts before arriving in office and quickly began consulting about the possibilities for reform.

This appointment was timely for HRDC, which only a few months earlier had been created as part of a major restructuring of the federal public service from elements of the former departments of Employment and Immigration, Health and Welfare Canada, Labour Canada, and the Secretary of State. (6) The goal was to better position a new government to deal with a long overdue overhaul of social programs in the context of building budget pressures. Important and interconnected policy programs, such as unemployment insurance, training and re-training programs, labour standards, income security for seniors and those on welfare, child benefits and postsecondary education funding, were brought together in one department. Another rationale was to increase the capacity of the federal government to negotiate with the provinces on social policy matters. Axworthy's appointment promised to realize the potential of the department.

In early January 1994, the minister went to cabinet to seek approval for social security reform to be identified as a priority in the Throne Speech. Social policy reform had not received much attention in the Liberal Party's Red Book, but the minister was authorized to launch a review. In late January, the minister announced the Social Security Reform (SSR). He promised an "action plan" by April 1994 to inform extensive consultations, and a brief background paper was released. (7) It would be the first major policy test of the government, already grappling with fiscal and federal-provincial issues.

Planning for the SSR proceeded against the backdrop of two other significant challenges. The first involved the transition process and the typical wariness of a new minister and his advisers when working with officials who had served another government. (8) The minister was known to be demanding and intellectually curious, and had strong ideas about how to proceed. The delicate process of developing trust was complicated because all concerned were immediately thrust into a pressure-cooker of a major reform initiative and the minister had to rely more heavily on officials since the Prime Minister's Office had limited the number of executive assistants ministers could hire. Second, HRDC was coping with the aftershocks of the June 1993 restructuring of the public service. During late 1993 and 1994, Jean-Jacques Noreau, the deputy minister, and his executive team were consumed by the task of consolidating a new mega-department. With the minister committed to a major reform initiative, the deputy had to create sufficient bureaucratic capacity for policy analysis and consultation, and buffer it from the restructuring.

The literature sets out several principles for designing and managing consultations, and identifies an expanding menu of instruments for engaging citizens. (9) Generally, there is agreement that consultation objectives should be matched with appropriate instruments, lead departments should have sufficient capacity to conduct consultations, affected citizens and groups should have opportunities to express their views, and governments should report to those consulted about what was learned and why certain decisions were taken. However, the SSR case adds three important strategic considerations to the mix:
 --the scope of the consultations, which embraces the breadth
 of the programs as well as the range of consultation instruments,
 and the strategic challenge of managing them. In launching the
 SSR, the government sought to address several enormous social
 problems with significant economic and political dimensions;
 this led to a strategy of "comprehensive" problem-solving
 and a strategy of comprehensive consultation which I refer to
 as "mega-consultation."

 --the mobilization of internal capacity to manage comprehensive
 problem-solving, including working across program and
 departmental boundaries, dealing with elected officials and,
 of course, designing and managing public consultations.
 Traditional, professional bureaucracies often do not
 contain or properly mobilize the expertise and talent
 necessary to address such challenges. Departments like
 HRDC must discover pertinent latent expertise and combine
 that with new expertise to create a "temporary,
 administrative adhocracy" capable of meeting the technical
 and political challenges inherent in moving an exercise like
 the SSR forward. (10)

 --the requirement for sufficient political commitment and
 capability to not only initiate but sustain comprehensive
 policy reform and mega-consultations, because of the political
 and logistical challenges they generate. Otherwise,
 noble intentions and well-managed consultations can be
 compromised. (11)


In taking up these themes, this paper adopts a "state-centred" administrative perspective on consultation and citizen engagement, while most of the recent literature has adopted a "citizen-centred" or civil society perspective. (12) A standard for evaluating consultations should be whether a government is well-served in terms of discovering citizen and its own preferences, and developing a workable strategy over the medium to long term.

The first phase: January to May 1994

In early December 1993, the deputy minister appointed Karen Jackson, his former director general for corporate services, as his adviser and representative on the SSR, assuming a small group could prepare cabinet documents and handle transactions with central agencies. But, in early January 1994, as the SSR'S scope became clearer, it was determined that greater capacity would be needed to handle policy development and consultations. Several new appointments and structures were announced, and early consultations were immediately launched by the minister and the government.

Building an administrative adhocracy: Policy, communications and consultations

For the deputy minister, the SSR presented an opportunity to improve integration across HRDC with the remnants of former departments and elements within each (policy, operations and field structures). The strategic policy sector was a logical place to begin, since the SSR would draw on all policy capabilities from several former departments and its breadth required melding analysis across traditional domains of expertise. The HRDC had strengths in areas like unemployment insurance, children and child development, but had less depth in areas of emerging importance such as life-long learning and postsecondary education. (13) For the SSR, HRDC decided to rely on internal expertise and the sector created so-called "virtual" policy teams around "life-cycle" categories (see Figure 2), such as children and youth, in order to encourage analysts to move beyond the worldviews associated with the traditional policy shops from the former departments of Employment and Immigration, Health and Welfare, Labour, and the Secretary of State. Five teams were initially formed on unemployment insurance, training, postsecondary education, children and families, and the disabled. Each was led by a director-general and a mix of policy and program staff.
 HRDC developed a complex matrix organization and
 adhocracy to manage the SSR, across the policy, communications
 and consultation functions using internal and
 external expertise (see Figure 2). Considerable effort was
 made to ensure good horizontal coordination and communication
 with steering committees, though inevitably
 tensions arose


The senior assistant deputy minister for strategic policy, Harvey Lazar, realized that undertaking substantive policy work and drafting relevant legislation would be a significant challenge. His ability to "authoritatively advise" the minister and the deputy minister on policy matters would be compromised if he also had to manage consultations, work with central agencies and deal with communications. The deputy minister recruited Kathy O'Hara from the solicitor-general into the new position of assistant deputy minister for social security reform (ADM SSR) to coordinate all facets of the review, and Patrick Johnston, who left the Canadian Council on Social Development, was recruited to become executive director of the soon-to-be announced Ministerial Task Force (MTF) on Social Security Reform. (14) Finally, he established a steering committee of the DM adviser and two ADMS that met once a week to update the deputy minister on recent developments and to receive direction. It later expanded to include anywhere from eight to twelve members, depending on the issues at hand.

The division between overseeing policy and process was not so neat. Early on, the ADM SSR oversaw how the virtual policy teams supported the MTF, while the ADM for strategic policy managed the existing policy shops. The ADM SSR tapped into the expertise contained in the policy sector (policy staff thus reported to two superiors) and had about five staff. Although Johnston was initially recruited by the minister, he reported to the deputy minister and worked closely with the ADM SSR to manage the MTF.

The SSR also reached into the communications branch. Its research and analysis group (with at least five full-time employees) undertook "public environment analysis," including sponsoring and analysing qualitative and quantitative public opinion research as well as conducting media and stakeholder analysis. (15) Early on, this group contracted with Angus Reid to conduct three waves of polling and focus groups (February, June and December 1994). However, the unit and the larger branch were not well positioned to feed into the SSR. In January 1994, the deputy minister appointed Cathy Drummond a new director general of strategic communications, and the communications function was split into two new branches: one made up of groups responsible for routine communications (producing standard government information, news releases and related activities) for specific HRDC programs, and a new branch consisting of the research and analysis group, an existing communications operations capacity, and a new unit to handle the advertising, distribution and other contracting flowing from the SSR (this unit grew to eleven full-time employees at the peak of the consultations). The new branch was filled out by March 1994. There was a further twist in reporting: the ADM for communications, James Lahey, delegated communications issues early on to Drummond because he was overseeing HRDC'S renewal strategy after the June 1993 government restructuring. Consequently, Drummond reported to both O'Hara and Lahey.

Ideas about what consultations should be undertaken first emanated from the original strategic communications branch. (16) However, the group had little expertise in managing consultations, let alone an initiative of this scope. Anne-Marie Smart, a specialist in this area and former director of communications for the Royal Commission on Reproductive Technology, joined O'Hara's unit on contract. (17) Until then, a dedicated consultation capacity did not exist, despite the commitment of the minister and the government to launch significant consultations. A consultations and communications committee began meeting in February once or twice a week; (18) later, a representative from PCO consultation and communications attended some meetings.

The HRDC was generally not well prepared to deal with the full range of interest groups, particularly social policy groups, since most policy staff had more experience dealing with business and labour groups. Aside from developing a consultations plan, a priority was to create capacity to deal with think-tanks and other groups. Smart hired two staff for stakeholder analysis and to support the consultations and communications committee. An early concern was that, as SCHRD held hearings, it would attract representations mainly from interest groups and not fairly represent public attitudes towards reform. Accordingly, ideas were sought about how HRDC might sponsor arm's length multi-stakeholder and other citizen consultations. One option was to create an independent unit to coordinate consultations, as was done with 1992 public constitutional conferences, (19) but it was decided to handle this in-house.

Finally, the strategic communications branch retained the Earnscliffe Group, who had assisted the Department of Finance with budget consultations. Earnscliffe provided strategic advice on the challenges confronting HRDC, the politics of consultation with outside groups, how to move the minister's agenda through the cabinet system, and federal-provincial issues. They identified alternative approaches, such as town halls and more focused conferences, to encourage dialogue among citizens and groups.

In short, HRDC developed a complex matrix organization and adhocracy to manage the SSR, across the policy, communications and consultation functions using internal and external expertise (see Figure 2). Considerable effort was made to ensure good horizontal coordination and communication with steering committees, though inevitably tensions arose. (20) No function had priority over the others; each was led by competent individuals and intimately related to the others. This structure proved quite flexible, able to scale up and down as required. Later, we explore how SCHRD also expanded its capabilities.

MTF and the early round of consultations

Several consultation exercises were launched in February 1994, thus exposing HRDC officials to the politics of social security reform. The first and most significant was the Ministerial Task Force (MTF) announced on 6 February. Chaired by the minister, and supported by the executive director, it had fourteen members, appointed by the government and familiar to the minister, half of whom had strong social policy backgrounds. The MTF began weekly meetings on 15 February.

The MTF was plagued by ambiguity. First, it was unclear whether MTF was to comment on drafts of the discussion paper or get involved in drafting, and whether the discussion paper was to lay out broader possibilities for reform or an "action plan" with specific options. Second, it was unclear how a possible Quebec election and the federal government's priorities job-creation and deficit-reduction commitments would affect social policy. Third, changes to the Unemployment Insurance Program, a major element of the social security system, had been announced in the February 1994 budget along with an HRDC discussion paper before the consultations began. (21) Finally, the budget had blandly announced a "program review" of all federal programs, intended to re-allocate resources to government priorities. Initially, HRDC was exempt from the process because of the SSR; it was hoped that better, more integrated policy would produce its own savings on more extended timelines.

The MTF met in day-long plenary sessions during the first few weeks, briefed and supported by HRDC'S virtual policy teams. More detailed deliberations proceeded in working groups, including invited speakers, focused on the client groups that defined the virtual teams (children, youth, seniors, adults, etc.). Officials worked under strict deadlines to provide data and analysis, but an impression emerged that HRDC expertise was uneven in certain areas. (22) The MTF did not hold hearings; the minister and the government saw this as SCHRD'S role and, more particularly, the intent was to buffer the MTF from interest groups. The minister attended many of the early meetings or was debriefed by the executive director as were HRDC officials. Generally, the consultations and communications committee did not have much to do with the MTF, but the deputy minister received progress reports through his SSR steering committee.

During late 1993 and early 1994, the minister consulted the provinces. These meetings were significant because the federal and provincial governments had not met to discuss labour market issues, among others, for several years, and raised expectations that the Liberal government might adopt a cooperative approach to reform, but also worry since the minister was known as an activist. However, these meetings were not continued as the federal government became increasingly worried about the sovereignty movement in Quebec. Direct consultations would not restart for several months.

The third set of early consultations was held by SCHRD. On 8 February, the committee received an order of reference to initiate hearings and prepare a report by 25 March. The SCHRD immediately proceeded to organize its hearings, which had implications for HRDC. The minister and deputy minister appeared before the committee in February followed by senior policy officials a few days later. The committee held six more days of hearings with groups in late February and early March to round out what was a "scoping" exercise, since the minister's action plan was to be produced by late April. To deal with the severe time constraints, and to sample opinion across the country, the committee relied on video-conferencing technology--a "first" for a parliamentary committee. The SCHRD issued a report in late March 1994, that outlined principles for reform, indicated the range of social policy reform issues and provided a sampling of opinion. (23)

The early SCHRD hearings were harbingers of the tensions that would later resurface. First, many interest groups were upset by the short notice for giving testimony or could not be present. The promise of later consultation opportunities was thin gruel for these groups. Second, some committee members felt that they were competing with the MTF for media attention, and wondered if the minister had established it to divert attention away from the committee. The minority report of the Bloc quebecois raised questions about the HRDC'S program of intervenor-funding for interest groups (see below), and criticized the government for launching three simultaneous, uncoordinated consultation processes that, in their view, undermined SCHRD'S work. (24) After releasing the report, SCHRD began planning for the next round of consultations since the action plan, which would happen during the summer months.
 Perhaps the most innovative development in the SSR
 consultations did not arise from either HRDC officials or
 the Earnscliffe Group. Rather it came from Andy Scott,
 a former official and recently elected MP from New
 Brunswick and member of the SCHRD, who strongly
 believed in better engaging citizens at the local level on
 national issues to reduce cynicism about the role of
 elected representatives


As SCHRD prepared its report, the MTF and the minister reviewed the first attempt at crafting the action plan, which they quickly discarded: It soon became apparent that neither the minister, HRDC nor MTF would be ready to produce a draft discussion paper, so the release date was pushed back from April to mid-summer. A small group of MTF members decided to produce their own draft, which displeased HRDC officials, but this was no more successful, with the minister requesting many changes. The rolling draft inside HRDC was characterized as a "hodgepodge," as too cautious and bureaucratic, but this reflected the breadth of issues and a government unwilling to make social policy commitments until it determined its fiscal and federal-provincial strategies. Draft papers and other documents were sent to cabinet and the PMO for review, but the process was clearly flagging in April. The deputy minister attempted to reconcile the views of MTF members, the subcommittee of the Cabinet Committee on Social Policy, the PMO and HRDC staff, but to little avail. Immersed in the interactions between HRDC and the centre, the ADM SSR relinquished responsibility for policy to the ADM social policy.

The MTF process petered out by May 1994, although it was not formally disbanded until late June. There were varying degrees of relief and disappointment among its members, and the minister had valued the deliberations and advice. Nevertheless, many of the documents and ideas generated by MTF and the virtual policy teams found their way into the final discussion paper and some supplementary documents, and the minister and HRDC officials were exposed, in a relatively controlled environment, to many of the internal and external politics that they would contend with in the months to come.

The consultations and communications committee began to meet more frequently (soon every morning), and the MTF less so. The HRDC officials were asked to draft the discussion paper (with input from the centre) and to develop a consultation strategy for the fall. Even though it was understood that SCHRD would conduct hearings, and HRDC would support those initiatives, it remained unclear as to what public consultations HRDC might sponsor. With the demise of the MTF, Patrick Johnston's role evolved; he became more of an intermediary and conduit for many affected groups, compensating for HRDC officials unfamiliar with the groups in the Ottawa area and outside the National Capital region. Finally, the Earnscliffe Group was retained in April to provide strategic advice to HRDC officials on developing a consultation and communications plan.

The second phase: June to August 1994

During the summer months, the key challenge was to produce a discussion paper that would meet the demands of the minister and the political sensitivities of cabinet colleagues, which proved difficult. While countless iterations of the discussion paper swirled inside HRDC and elsewhere in the government, officials responsible for consultation and communications planning for HRDC and SCHRD developed materials on a contingency basis, since content and process were intertwined. This section draws attention to several important challenges.

The problem of intervenor funding

In early summer 1994, the SCHRD clerk began hearing from groups who were inquiring about how to obtain funds to support involvement in the consultations. Neither the clerk nor the chair were aware of an Intervenor Funding Program (IFP) administered by HRDC. Important questions loomed about what groups SCHRD could support and whether they were guaranteed an opportunity to make representations to the committee, and whether it was intended to support groups that might find it difficult to participate in the review, and enable them to conduct research and to hire consultants. (25)

The minister established a $4 million fund not long after announcing the SSR in January 1994, (26) but its existence was not actively promoted. The funds were allocated by the Intervenor Funding Steering Committee chaired by Ian Green, ADM for the Social Development and Education Sector, with representation from all program areas. The sector was chosen because it: (1) administered grants and contributions programs for the disabled, voluntary and women's groups; (2) worked with social policy groups; and (3) advanced the goal of encouraging work across departmental stovepipes. The funding sponsored 168 projects for 3,500 groups (including business and labour) and eventually supported 155 formal presentations to either SCHRD or the minister.

The SCHRD was piqued about the IFP for two reasons. First, it complicated the committee's ability to award funding for travel to many groups. Intervenor funds could be awarded either for travel or research and report-writing; any resources received from SCHRD for travel expenses would constitute double-dipping. The issue was later resolved cooperatively; it was agreed that travel expenses would not be covered. Second, if a group were to receive IFP funding from HRDC, it implied that groups could make presentations to SCHRD, but HRDC officials could not know which groups would be given that privilege. This issue of principle became a pragmatic challenge when the schedule slipped, forcing the committee to choose among groups.

The discussion paper: tag-team drafting

With MTF losing its central role in developing ideas for the paper during summer 1994, HRDC officials attempted to rise to the challenge. During May and June, a team of two advisers from the minister's office and the deputy minister's office sought to make the document engaging and informative. Finance, PMO, and PCO officials were increasingly sensitive about the unity file and fiscal targets, and about endorsing bold statements about new directions for social programs. After many iterations, the life-cycle framework was rejected as too "academic," and the new categories of working, learning and security were adopted. The virtual policy teams were adjusted accordingly. The policy and communications groups began preparing the plans and formats for the discussion paper, supplementary documents, the workbook, press releases, information sheets, Q&A sheets, etc. This proved difficult since the content of the discussion paper continued to evolve.

With the PMO demanding progress, the minister and the deputy minister decided to consolidate a sprawling process. In late July, Giles Gherson, a former national political affairs columnist for the Globe and Mail, was hired by the minister to hold the pen. He worked with the ADM communications, who coordinated HRDC'S input as the paper was refined over the next few weeks. There continued to be considerable input from PMO and Finance.

The paper underwent tremendous scrutiny that summer. A department might usually go to cabinet two or three times with a discussion paper and communications plan for a major initiative. In this case, the discussion paper was reviewed by an ad hoc cabinet committee on SSR about ten or eleven times during the summer, (27) reflecting concern over developments in Quebec and evolving views on the fiscal stance. The SSR embraced a huge swath of federal expenditures, so proposed government commitments had to be carefully balanced with other priorities. Moreover, the government and the minister could not formally engage the provinces without a strong or coherent position. The deputy minister and Patrick Johnston did conduct informal, bilateral discussions with provincial representatives, who refused to engage unless something firm was on the table.

Preparations of the standing committee

After completing its report in late March, the SCHRD chair and clerk and research officers from the Library of Parliament anticipated launching a much broader set of consultations during summer 1994. They envisioned a multi-faceted approach: town halls, roundtables, site visits, video-conferencing and traditional hearings. This would require far more capacity: Barbara Reynolds arrived from the Parliamentary Centre to handle process in May 1994, and Gordon Bechterman, an expert on labour market policy, was retained to manage a research team from the Library of Parliament. (28)

Reynolds produced the Plan "A" process for a more extensive set of consultations. These plans were informed by the Spicer Commission (the Citizens' Forum on Canada's Future), the public constitutional conferences, and the Department of Finance's budget conferences, but SCHRD settled on its own ideas and mix. However, the starting dates steadily slid: first to June, then July, August and November. The original goal was to have 403 presentations. By the end of August, SHCRD was exploring a Plan "B" process.

Marketing the town hall concept

Perhaps the most innovative development in the SSR consultations did not arise from either HRDC officials or the Earnscliffe Group. Rather it came from Andy Scott, a former official and recently elected MP from New Brunswick and member of the SCHRD, who strongly believed in better engaging citizens at the local level on national issues to reduce cynicism about the role of elected representatives. Scott believed town hall forums could engage citizens and backbenchers on policy issues, and elected representatives could play an important role in linking government and citizens.

During spring 1994, Scott held a series of meetings on topics of health, defence, social security reform and gender issues. The town halls were daylong televised events with plenary and working-group sessions, with anywhere from 100 to 200 citizens attending, and local representatives from competing political parties. However, Scott realized that such activity, no matter how innovative, would have little impact on policy discussions in Ottawa. He advocated the town hall concept to MP colleagues and developed a kit with tips on how to develop mailing lists. He invited Maurizio Bevilacqua, the parliamentary secretary to the minister of human resources development and scion member, to observe a town hall in April. Bevilacqua felt it was a success and informed the minister, who in turn encouraged Scott to approach colleagues across the country and persuade them to consider hosting their own town halls in connection with the SSR. (29)

The third phase: September 1994 to February 1995

In September, once the government had indicated that it would release a discussion paper in early October, detailed preparations began on several fronts. For HRDC officials this was the most taxing phase. They had to keep abreast of the activities of SCHRD, individual MPS, and the budget hearings of the standing committee on finance. Moreover, supplementary papers and the workbook could not be fully developed until the discussion paper was approved and released. This proceeded against the backdrop of broader debates among ministers about how to contain the burgeoning deficit, and to more explicit expectations that the SSR and HRDC contribute to the program review targets identified by the minister of finance. (30)

Creating capacity for coordinating consultations

About a month before the release of the discussion paper, HRDC established the coordination centre, which superseded the Consultation and Communications Committee. It tracked all activities related to the preparations and then the release of the discussion paper, and coordinating subsequent consultations. About ten people met every morning to discuss what had transpired the day before, and that day's agenda. When the consultations started, the group met in the late afternoon for briefings on the day's activities. Later, it also handled media analysis and monitored progress with SCHRD, the workbook, supplementary papers, the internet, telephone lines, policy seminars and policy colloquia. It worked closely with PCO'S consultations and communications group to minimize conflict with the Department of Finance pre-budget conferences and roundtables, and the SSR town halls organized by MPS.

The coordination centre--a single room filled with white boards, faxes, telephones and computers--was managed by Smart and two staff (one usually attending consultation events wherever they were held). Gherson, the ADMS and other officials met in the room, streaming in and out each day. (31) This was the place to call with questions or concerns about consultations, or to request documents or other assistance. For example, staff fielded complaints from groups that had received only a day's notice before SCHRD hearings or had been overlooked. Given the concerns about SCHRD having insufficient capacity to handle such a complicated and intense round of consultations, the centre provided assistance such as media clippings and analysis, as well as background information on groups members might encounter during their hearings. However, SCHRD typically did not directly contact the coordination centre; this was generally handled through the minister's office.

Distributing the discussion paper and fielding requests

The discussion paper, Improving Social Security in Canada, was released on 5 October, and officials met with representatives of over 120 organizations to discuss its contents. (32) The briefing was an extension of a series of rolling low-profile meetings with various experts, opinion leaders and organizations. A second press conference was held a day later by Frances Leblanc, chair of SCHRD, to announce its consultation schedule. However, the long-awaited launch was overshadowed by a leaked central agency document indicating the government planned further expenditure reductions in social programs but would not announce them until the February 1995 federal budget. (33) The unanticipated leak was difficult for the minister to handle: it undermined his credibility and fuelled angry protests at SCHRD hearings and MP town hall meetings.

Nevertheless, HRDC proceeded to distribute the discussion paper. Newspaper advertisements indicated distribution points .for the discussion paper and the 1-800 numbers interested parties could call. Fielding telephone inquiries was contracted out to the Canada Communications Group, which trained operators (after receiving preliminary briefing and training from HRDC). (34) About 6,000 calls were handled the first day. The CCG handled about ninety per cent of approximately 40,000 calls, most of which were routine. The other calls, usually requiring more expert assistance, were redirected to HRDC.

An innovation was the minister's internet bulletin board, which provided information and allowed internet users to "pull down" copies of the discussion paper. Over 7,000 people accessed the discussion paper in this manner. It was a learning experience. The communications group experienced difficulty in supporting distribution of the document, and did not have sufficient capacity and, procedures for responding to requests for information or handling letters from the minister. (35)

The "Have Your Say" workbook

Another interesting experiment was the "Have Your Say" workbook, despite some early internal scepticism about its merits. Its goal was to give individuals an opportunity to reflect on and contribute their ideas on social security reform in a more private manner.

The workbook idea emerged from the strategic communications group in February 1994. (36) The research and analysis group developed the questionnaire, and the SSR group handled writing, design and distribution. The key challenges involved conveying complex information succinctly and at the right level for communicating with the largest group of citizens. Finalization of the workbook awaited release of the discussion paper and testing with focus groups. It was revised and distributed in the first week of November. (37)

The HRDC distributed the workbook through Canada Employment Centres and contracted out for distribution to post offices, YMCAS/YWCAS and grocery stores. They were also distributed to SCHRD hearings, the MP town halls, and to MPS for distribution to constituents. A three-week advertising campaign announced a 1-800 telephone number and where the book could be obtained. The response exceeded expectations: at one point over 1,000 workbooks were received each day, but a typical stream was about 700 per day. A total of 43,700 workbooks were returned, with one or two thousand sent in protest with stickers. A consulting firm was retained to code and analyse the workbooks on an arm's-length basis, which took three months. (38) It produced a final report, including a separate appendix with detailed analysis and a binder filled with detailed comments gleaned from the workbooks, some of which later appeared in other HRDC publications. (39)

Background papers: drafting and releasing

If drafting the discussion paper was frustrating, so too was preparing the supplementary or background papers. First, they were difficult to finalize while the discussion paper steadily evolved, even days before its release. Second, they required vetting by the PMO, causing delays of weeks. (40) Twelve supplementary papers were planned; four were released in October, three in December and one in January. For supplementary papers to have been released on 5 October, the discussion paper would have had to be finalized by 15 September. And, securing approval of the supplementary papers proved difficult after 5 October because HRDC and central agencies were coping with the consultations.

The delay in releasing the background papers greatly frustrated SCHRD members, who viewed HRDC as unresponsive. Expectations had been created about the availability of background papers for public consumption. Committee members could not distribute them to participants at hearings and town halls. Some national business associations balked at making presentations to early hearings because the papers were not available. Penultimate drafts were sent to committee members for personal use, but could not be circulated to individuals and groups appearing before the committee.

The standing committee hearings

The SCHRD hearings attracted the most media attention, largely because they were targeted by groups protesting cuts to social programs. Its experience was poignant because its plans for innovative consultations were undermined by the delays in releasing the discussion paper. The SCHRD wound up doing precisely what it sought to avoid.

The original plan was for a mix of traditional hearings, site visits, town hall meetings and meetings with provincial and territorial counterparts. However, the more elaborate plans were jettisoned when it was learned that the discussion paper would be released on 5 October, that SCHRD had to submit its report well before the next federal budget, and that the government wanted SCHRD to maximize the number of groups attending its hearings. The itinerary covered twenty-two cities and towns over five weeks, and SCHRD was inundated with requests from groups. Many of these groups had received funding from HRDC, and SCHRD'S early worry about possibly not granting such groups a hearing came to pass. Rather than listen to 400 groups, as originally planned, the committee eventually heard 637 groups, but difficult decisions were made about who could participate. Hearings began in Ottawa on 17 October with the minister and the deputy minister, and then with groups and experts until 8 November. The SCHRD moved from west to east across the country during mid-November to mid-December. Additional hearings took place in Ottawa on 19 December and on 16 and 17 January.
 An observer characterized the consultations as consisting
 of "parallel tracks and points of intersection."
 The coordination centre was pivotal in making the
 intersections work. Despite the broader politics swirling
 around the SSR and final budget decisions, a broad,
 detailed picture of public and expert opinion across the
 country was assembled


The SCHRD leased a plane to reduce costs and to maximize the time available to members, and used video-conferencing technology to reach smaller, more distant communities. The committee also invited groups to participate in short roundtables, but these were unwieldy since they included the witnesses and committee members. The committee considered splitting up to conduct hearings but decided that, on balance, it was more economical to travel as a full committee. In some instances, a subcommittee was struck and a note taker provided to handle overflow witnesses in rooms nearby--those discussions were included as part of the official record of the hearing. Subcommittees were formed to visit smaller centres or deal with protesters. (41) The full committee made some on-site visits, but far fewer than first planned. The MP town hall meetings proved useful because they complemented SCHRD activities.

The HRDC'S coordination centre arranged for two staff--one from the centre and one from local regional operations--to attend each hearing. They faxed notes to the coordination centre, which were converted to summaries for review by the minister's office, PMO and PCO, and circulated at the 7:30 strategy meeting every morning. Centre staff provided media analysis for SCHRD and prepared "forecasts" of concerns of the groups they would meet the next day, sometimes suggesting questions to ask. The PCO's Consultation and Communication group developed a four-layer spreadsheet to track all consultations--by SCHRD, MPS, public seminars and budget consultations--flagging potential conflicts, which rarely occurred. The centre responded to groups angry about receiving invitations on very short notice, or not receiving invitations at all.

The SCHRD received extra resources to plan and conduct its consultations. Usually a committee has two or three staff; towards the end of the hearings SCHRD had between twelve and fifteen staff (another clerk, consultants, analysts and more secretaries) and additional office space. Nevertheless, HRDC initially worried about whether SCHRD had sufficient capabilities and resources. Offering assistance was a delicate matter, requiring low-key dialogue. (42) However, the demands of the process required that HRDC and SCHRD staff learn and adapt quickly; limited resources meant cooperation was essential. A good working relationship emerged between the minister's office, the department and committee staff.

The SCHRD concluded its hearings in mid-January, and began drafting its final report. The HRDC sent summaries to SCHRD from the parallel consultation events, as well as early analysis and samples of the workbook replies. On February 6th, SCHRD released its final report that, in addition to its analysis and dissenting opinions, included summaries of the early workbook analysis and of the first 200 town hall meetings held by seventy-five MPS. (43)

Supporting the MP town halls

When SCHRD prepared its itinerary and briefing book for its consultations, it included the MP town halls. About seventy-five MPs, mainly Liberals, agreed to host meetings, and some held several. Well over 200 meetings took place from November 1994 until early February 1995, and about 20,000 people attended.

The HRDC'S coordination centre worried about whether SCHRD could support MPS when managing their own consultations and decided to support MPS in a low-key manner. Communications sent out a newsletter for MPS and groups attending the town halls. Regional HRDC staff took notes at the town halls. Generally, the meetings proceeded smoothly, but MPS found it difficult to deal with organized protests or individuals seeking to dominate meetings. The coordination centre installed a special 1-800 number to respond to requests from MPS for information and documents, and encouraged them to contact police if protesters got out of hand. If necessary, MPS were connected to the minister's office.

When encouraging MPS to host town halls, the prime minister, the minister, and the SCHRD chair requested that reports be submitted to SCHRD, not through the coordination centre. The reports were prepared with notes from HRDC regional staff, and fed into the daily briefings of the coordination centre. Staff also prepared summaries of SCHRD meetings. A summary report prepared by the coordination centre could not inform SCHRD'S final report but did feed into HRDC'S April 1995 roll-up report on all of the consultations. (44)

HRDC public seminars

The SCHRD hearings provided a forum for groups while the public seminars sought to systematically reach out to communities and citizens affected by the proposed SSR policy. Many participants were recipients of unemployment insurance and welfare. The public seminars were similar to the MP town hall meetings except they were smaller and used a roundtable format.

The seminars were organized at arm's length from HRDC for practical and political reasons. Organizations were approached by the consultation coordinator for expressions of interest and proposals. The HRDC sought some consistency in format, but the seminars were tailored to the region and the preferences of host organizations. Contracts were given to the Laurier Institution (British Columbia and Alberta), Institute for Urban Studies at the University of Winnipeg (Saskatchewan and Manitoba), United Way/Centraide (Ontario), Andre Masse (Quebec), and Atlantic Provinces Economic Council (Newfoundland, Nova Scotia and New Brunswick). The seminars took place during November and December 1994, and the coordination centre had to minimize conflict with the SCHRD hearings and MP town halls. There were twenty-four seminars with twenty to thirty people attending each; about 500 people attended in all.

The HRDC supported the seminars by sending officials, usually from regional offices, to provide either a briefing on the discussion paper or a video on the SSR. Often officials were asked to stay for the deliberations and supply additional details. Trained facilitators typically oversaw the events, usually relying on the questions from the discussion paper and workbook to animate the "in-depth focus groups." Some seminars were targeted by protesters (but there were fewer disturbances than at the SCHRD hearings). Most of the seminars had a similar format, except for those in Ontario, which were decentralized to United Way/Centraide local groups. The host organizations sent summary reports to the coordination centre, which were sent to the SCHRD chair under the minister's signature as a single document. (45) Unlike the town hall summaries, the regional and national summaries conveyed the unique concerns of each region.

HRDC policy colloquia

The policy colloquia were designed to engage experts and practitioners, and explore issues in the discussion papers that had received insufficient attention in the other forums. In late October 1994, HRDC asked leaders of selected organizations to organize and host the events in late November or early December. The challenges for HRDC were to identify appropriate topics, and to select think-tank organizations with an appropriate combination of experience in hosting events, substantive expertise, and access to pertinent expert networks. Interested organizations were invited to submit proposals and contracts were negotiated. The HRDC established broad criteria for selecting participants and suggested some speakers, but generally the host organizations selected and invited participants.
 Rather than produce a well-defined strategy, the SSR led
 to confusion about government intentions, and public
 acrimony, and provided sites for conflict. Nevertheless,
 it was remarkable for the array of consultation instruments,
 administrative structures and managerial
 strategies


As with the pre-budget conferences, (46) HRDC limited the seats available to government observers, and a system for allocating them was developed. The Conference Board of Canada and the Caledon Institute for Social Policy relied on video-conferencing capabilities to tap into keynote speakers unable to attend in person.

About 200 participants attended each colloquium, for a total of 800. (47) All but one lasted a single day. The conference board held the "Lifelong Learning and the World of Work" event on 13 January in Toronto despite bad weather. The Public Policy Forum hosted "Post-Secondary Education and the World of Work: New Linkages" on 19-20 January in Calgary. The PPF insisted that student groups be represented along with universities and colleges, despite their previous criticism of the minister. The Caledon Institute hosted the "Child Poverty" event on 26 January in Ottawa with workshops on income security, work/family and community services. Participants were asked to identify reform proposals before arriving, and then asked for recommendations towards the end. The Niagara Institute hosted "Employment Development Services: New Directions" on 14-15 February in Hull. The participants, who were either experts or worked for organizations providing employment services, evaluated options for training and other assistance from client perspective. The organizers experimented with software and video technology to capture the strength of preferences for options, then tally and display results, but this proved time-consuming.

The minister and officials were pleased with the events, but participants and organizers felt there was insufficient time to delve into issues properly. The host organizations commended HRDC for clearly defining needs, delegating responsibilities and ensuring that the minister attended several sessions. Government observers prepared reports for the coordination centre, but the host organizations produced their own, which were sent to SCHRD and HRDC. (48) The coordination centre also arranged for the proceedings to be taped by C-Span, and then televised on the Parliamentary channel.

Winding up the consultations

The SSR consultation instruments fed into and complemented each other. For example, the workbooks, discussion paper and supplementary papers were circulated to the town halls, public seminars and policy colloquia, and findings of most events were forwarded to the minister and SCHRD. An observer characterized the consultations as consisting of "parallel tracks and points of intersection." The coordination centre was pivotal in making the intersections work. Despite the broader politics swirling around the SSR and final budget decisions, a broad, detailed picture of public and expert opinion across the country was assembled.

A final task was to assemble reports and prepare summaries for two key clients: the minister and SCHRD. The deadline for the SCHRD report was 6 February 1995. The work of the centre quickly tailed off and was disbanded shortly after the last colloquium in mid-February. Summary reports were circulated to key clients, and an overview of the findings of all the consultations was published in April 1994. (49)

Bureaucratic capacity and managing consultations: Lessons from the SSR

The popular images associated with the SSR tend to be negative, typically emphasizing the delays in releasing key documents, and in reconciling its social policy ambitions with federal-provincial issues and fiscal restraint. Indeed, the SSR led to the very outcome many internal and external advocates sought to avoid: the last major overhaul of social programs initiated by the Department of National Health and Welfare in the early 1970s was neutralized by the Department of Finance for fiscal and other reasons. (50) Rather than produce a well-defined strategy, the SSR led to confusion about government intentions, public acrimony, and provided sites for conflict. (51) Nevertheless, it was remarkable for the array of consultation instruments, administrative structures and managerial strategies.

This case study has provided an account of how a temporary administrative adhocracy was established to manage a complex consultation process, assembled requisite capabilities and went about its work. Despite the confusion about timelines for papers, policy directions and drafting responsibilities, the SSR adhocracy appeared to be well conceived and, in addition to grappling with a significant challenge, took the load off an HRDC executive team dealing with a host of other policy and administrative challenges. The adhocracy arguably performed well under the circumstances. While HRDC was not unique in creating such capabilities; the SSR adhocracy confronted unique challenges in managing "mega-consultations" involving multiple actors and consultation instruments. Several features of the social security reform adhocracy are worth exploring.

Addressing capacity and communications proactively

Experience in other domains suggests adhocracies are often established reactively, following the failure of existing structures and capabilities to take on new or more complex challenges. (52) This was not the case with the SSR, where HRDC recognized that mega-consultation was a distinct challenge requiring appropriate capabilities and a focal point it did not have. Moreover, existing capabilities in HRDC were simultaneously protected and tapped into for the SSR. Early on, a premium was put on regular and full communications at the working level (policy, consultation and communications staff connected to the SSR), with the executive team, the minister's office and, later, the centre.

Seeking strategic advice and information for planning

Strategic information on consultation was sought from inside and outside HRDC early on. The advice from the Earnscliffe Group was valued because they had a broad perspective on policy-making in Ottawa and the rest of the country, and because they had experience with and knowledge of other consultation exercises outside the social policy arena. They proposed alternative models for consultation, as well as warnings about what might go awry. Such expertise was crucial because several senior officials had not managed a process of such scope. Additionally, useful information on public opinion was obtained early on from the research and analysis group in strategic communications, albeit less strategic in nature.

Recruiting outside talent to supplement core competencies

The deputy minister and top advisers identified key roles and skill sets required for the SSR, including working well across functional divides (policy, communications, consultation, operations). If such talent was not available in a functional area or elsewhere in HRDC, talent was secured on a temporary basis. Three key individuals were brought in from outside the department and two others were shifted to new positions from within. Creating new capacity need not require completely overhauling existing capacities; a few crucial appointments can allow a department or a unit to meet new challenges.

Communication and flexible structures

Recruiting talent is one matter; it is quite another to array people and assign responsibilities. The matrix structure was made up of the senior ADM strategic policy, the ADM social security reform, and the ADM communications managing many of the same staff. It worked well because several committees shared information and senior officials did not defend and expand turf. Each ADM was familiar with the policy function, and had a good grasp of the requisite skill sets for policy, consultation and communications. This is not to say that there were not personal tensions, or considerable frustration with the constant stream of meetings which undoubtedly blurred into each other. However, the daunting challenges led officials to take on tasks as needed. Such give-and-take was facilitated by a flexible structure with overlapping responsibilities and extensive internal communication.

Using outside contractors

The deputy minister did re-deploy staff, but, for two reasons, fewer were moved than might have been expected. First, virtual policy teams were created and key senior executives were appointed to manage and coordinate staff in a matrix manner. Second, outside contractors were retained for critical tasks such as conducting polling and focus groups, managing the 1-800 telephone lines, distributing and analysing the workbooks, and planning and hosting the policy colloquia and public seminars. Contractors generally met expectations and much was accomplished with a minimal reallocation or expansion of full-time or indeterminate staff.

Creating a coordination centre

Advice that proved extremely valuable concerned the need to establish the coordination centre before consultations began in October 1994. By finding dedicated space for phone lines, computers, fax machines and meetings, HRDC fostered continuity and rich communications. (53) The coordination centre liaised with PCO'S consultations and communications staff, who monitored the Department of Finance's budget consultations as well as the activities of the two standing committees on finance and on human resources development.

Given the scope, complexity and turbulence of the SSR, it is not surprising that there were some deficiencies or gaps. The process could have been improved in several ways:

Better utilizing the MTF

The task force could have been used more productively. First, more clarity about MTF'S role would have reduced frustration, and might have allowed the HRDC policy teams to work more productively. Second, MTF met often, making it difficult for HRDC to respond fully to information requests and for members to deepen their knowledge. Finally, by chairing MTF early on, the minister was linked to its deliberations, leading to close vetting by PMO and other central agencies. The minister could have granted the MTF more autonomy and gained critical degrees of freedom.

Linking social policy debate to budget parameters

The 5 October 1994 leak of government intentions to reduce social policy spending in the 1995 budget was a watershed moment, although the February 1994 budget had already indicated that the growth in social expenditures would be curtailed. However, many outsiders believed that the minister could persuade cabinet colleagues to soften reductions and perhaps increase spending on social policy, and the government did not galvanize around a fiscal policy trajectory until later in 1994. Openly acknowledging that aggregate expenditure was an important issue, perhaps by identifying different levels of funding in the context of the overall budget, would have reduced cynicism about the SSR and lessened stress on consultations during late 1994 and early 1995.

Clarifying who held "the pen"

Even if the minister never intended the MTF to draft the action plan or discussion paper, there remained confusion at the political and bureaucratic levels within HRDC about primary drafting responsibilities. Leaving aside the question of whether the government had a coherent policy vision, one view is that HRDC did not have sufficiently adroit policy and communications capabilities to properly respond to the minister's needs. However, it is difficult to find writers who can help ministers develop and articulate policy ideas: it requires interpersonal chemistry and respectful challenge. It was unlikely that someone like Gherson could be found inside the department; locating such talent should have been an early priority of the minister or key political advisers.

Creating capacity for political management

The deputy minister created sufficient capacity within HRDC to manage policy development and consultation with an adhocracy made up of committees and overlapping structures, although the virtual-team concept could have been extended to officials working in communications and consultations areas. A problem was that parallel capacity was not established in the minister's office in early 1994, to complement the emerging bureaucratic adhocracy. This would have created a potent alignment of capacities for dealing with the prime minister, PMO, and Cabinet Committee on Social Policy.

Improving relations with SCHRD

The government and the minister initially envisioned a critical role for SCHRD, but its members felt they were not treated as equal partners. For example, the IFP program was designed without anticipating committee needs, and some HRDC consultations were seen as unnecessary overlap and even subversive. The MPS were miffed about the government's inability to stick to announced schedules, and the delay in action plan, discussion paper, and background papers. For its part, SCHRC sought autonomy from HRDC and its minister, leading to less communication than desirable, and refused to proactively accept HRDC support, although a good working relationship was forged by necessity.
 Choosing not to proceed with a comprehensive policy
 intervention following the SSR does not mean that the
 government failed to develop a strategic approach


Most of these deficiencies and gaps emerged from outside the SSR adhocracy. Indeed, it was unlikely that any government or department could design a comprehensive policy intervention and hold fulsome consultations in the time frame originally announced. This points to several larger strategic questions. Was it wise for the government to lead with a comprehensive policy innovation? Was a mega-consultation strategy appropriate under these circumstances? Was the government well served by the SSR?

Strategic decisions: Comprehensive policy innovation, mega-consultation, managing change

If the SSR is judged in terms of whether a comprehensive policy innovation was introduced by the February 1995 budget, then it was a failure. It also failed to produce strong consensus on any policy option, save that most Canadians agreed reform was necessary (and to the unemployment insurance program in particular). Both outcomes were predictable: it is difficult to design and implement fundamental policy changes, and to generate consensus on new policy directions even with incremental recommendations. Moreover, the SSR was superseded by the deficit-reduction agenda of the minister of finance. This section considers the strategic decisions that created the operating environment in which the SSR and its adhocracy proceeded, as well as its legacy.

Attempting comprehensive policy innovation

Unless driven by crisis, there are circumstances when a fundamental policy innovation could be designed and implemented by a government: planning would start early in a mandate and ministers would have well articulated preferences and firm intent to move forward in certain policy domains, and the requisite bureaucratic capacity would be identified to support the initiative. (54) The divergence between these pre-conditions and the SSR experience should be clear: although the Liberal government understood in late 1993 that it had important social policy challenges to tackle, it hadn't yet developed strong preferences about a policy mix nor a good sense of how it might fit with other priorities.

Walters, Aydelotte and Miller argue that the "greatest room for public involvement is with ill-structured issues," (55) but this would have required that the Liberal government had understood this and conceived of the SSR as exploratory and formative, as a process of "discovery" rather than commit to an "action plan." Even if the government had strong policy preferences and plans, and HRDC had the analytic and data capabilities to inform policy development within and across all aspects of this policy domain, it is difficult to imagine how consultations would have effectively informed an implementation plan in a relatively short time frame.

In short, the early policy ambitions of the minister (with the approval of the government) set the SSR on a certain trajectory. Expert and public consultations were undoubtedly a useful formative strategy for the government and HRDC, but it required time to digest findings and produce either a comprehensive plan or sequential initiatives, which could have again been vetted with consultations.

Choosing a mega-consultation strategy

Comprehensive policy innovation and mega-consultation need not imply the other. The government could have pursued a mega-consultation strategy without committing to a comprehensive policy intervention, or it could have utilized selective consultations at different phases as it developed ideas and a broad approach to social policy. Both alternatives would have de-coupled timelines for policy decisions from consultations, allowing consultations by HRDC, SCHRD or MPS to develop their own integrity.

Mega-consultations--which rely on several instruments and, in the case of the SSR, many different hosts of events--can reach out to many citizens, communities, organizations, experts and regions. There is the promise of an avalanche of information on values and issues through multiple channels, which can provide a useful collage on which to base decision-making. Arguably, the information gleaned from each instrument had limited "added value" compared to the entire corpus of information. In the case of the SSR, the public seminars or the workbooks could have been dropped, but the information obtained from multiple consultation instruments minimized the possibility of skewed or unrepresentative results from one or two instruments, and the government greatly expanded how many citizens and groups could be canvassed. Although the ideas from hundreds of individuals and groups were typically not accompanied by comprehensive visions for social policy, the government emerged with a better understanding of the willingness of citizens to tolerate change and countenance certain tradeoffs, and how these views varied in different regions.

Mega-consultations have several disadvantages, however, particularly if explicitly linked to a promised comprehensive policy intervention. First, citizens and interest groups are more likely to be overwhelmed and less likely to have sufficient expertise to produce comprehensive, integrated proposals for change. Second, the breadth of the issues means consultations are more open to attacks by a larger constellation of affected interests, and proposals less likely to be supported by other ministers and departments in a constrained fiscal environment. Finally, to the extent that deadlines for policy decisions, discussion documents and various consultation instruments are tightly coupled, there is greater potential for delay and complications across consultation instruments. These drawbacks were exacerbated with the SSR by the government's ambivalence on several issues. In effect, the scope and formative quality of the SSR combined to transform the exercise and provided multiple sites for what Kane and Bishop term "political contests" and options it could not contain. Indeed, within the government, the SSR had the hallmarks of a high-stakes contest with Finance and, to a lesser extent, with SCHRD.

In short, the government could have better assessed and communicated how it might fit into the process of developing a comprehensive policy innovation in social policy, and whether, as a government, it was truly prepared to take that leap. The mega-consultation strategy was too intertwined with, and contingent on, a comprehensive policy development process. One alternative would have been to rely on a royal commission, but there are several well-understood issues associated with this instrument (emphasis on research, cumulative expense, control of mandate, meeting deadlines, etc.). Another possibility would have been to create a task force or an expert panel at some arm's length from the government with less autonomy than a royal commission, and with tight budgets and timelines.

Legacy of policy and political learning?

In a provocatively entitled article, "Citizen Participation in Decision Making: Is it Worth the Effort?," Irvin and Stansbury suggest that poorly structured consultations can be time-consuming, costly, and might "backfire" by creating more hostility among groups and towards the government. (56) While the SSR was undoubtedly an incredibly frustrating exercise for the minister, HRDC officials, SCHRD and many citizens and groups, few HRDC officials felt it was a mistake. The SSR was an opportunity to educate the government, citizens, groups and the media about how a diverse set of social policy programs were linked. Many believed that major reforms to any given program (for example, unemployment insurance) would only likely proceed if broader linkages and trade-offs could be discerned across social policy programs. Some officials believed that the capacity of outside groups to think about social policy reform had expanded.
 An important general lesson is to ensure that the right
 capacities are assembled in ministers' offices, government
 departments and legislative committees, and that
 good communication and support occurs within and
 across these actors


Judging the SSR a failure is also superficial because it downplays the role it played in informing how the Liberal government proceeded with social policy reform. Choosing not to proceed with a comprehensive policy intervention following the SSR does not mean that the government failed to develop a strategic approach. Arguably, the Liberal government became more surefooted in how it approached social policy reform and HRDC learned what additional capacity is needed to support these initiatives. Reform subsequently proceeded in a sequential manner, and included: the Canada Health and Social Transfer in the February 1995 budget, the employment insurance legislation introduced in December 1995, the labour market development agreements negotiated with the provinces, the Canada Pension Plan reform process announced in the 1996 budget, and the Canada Student Loan Program in the 1998 budget. Later, the government negotiated the Social Union Framework and also sought advice on skills and life-long learning in separate initiatives such as the Expert Panel on Skills and the Innovation Strategy, a joint effort of Industry Canada and HRDC. These initiatives produced new perspectives and change to a critical policy area over the longer term.

Concluding remarks

This paper has provided a chronicle of a comprehensive or "mega" consultation process, remarkable not only for the breadth of consultation instruments and the range of actors involved, but also for the MP town hall meetings and because HRDC and SCHRD began using the internet as a distribution and communications tool. This paper focused on how HRDC created a temporary administrative adhocracy to handle the SSR, how it evolved over time, and identified some best practices and deficiencies. Finally, this paper argued that many of the tensions and stresses experienced by principal actors arose from strategic decisions made by the government to pursue simultaneously a comprehensive policy intervention and mega-consultation strategy, each relatively rare precisely because of the associated political and logistical challenges.

The SSR process did not result in the Chretien government announcing a comprehensive blueprint in early 1995. It had to square social policy reform with an emerging deficit-reduction strategy, the program review decisions, and federal-provincial considerations. Nevertheless, the government did sequentially reform several social programs, leading to a significant restructuring of federally funded programs. There are several key lessons:
 --governments need to assess frankly whether they are prepared to
 launch and sustain comprehensive policy interventions because of
 the complexities and politics they engender, as well as the
 benefits and risks of parallel consultations;

 --governments need to consider carefully the fiscal and
 federal-provincial-territorial environments in which the
 policy issues embraced by the mega-consultations
 must proceed, and how to convey those in meaningful ways
 to those consulted;

 --if a government is determined to pursue mega-consultations,
 it should probe alternative ways to conduct them--whether by a
 department, task force, commission, or outside group--and how
 best to sequence them with policy development;

 --if a department must launch significant consultations, but does
 not have extensive capabilities and experience, it should establish
 an adhocracy to assemble and tap into the requisite expertise,
 liaise with the minister and the executive team, and manage
 relations with cabinet and central agencies;

 --bureaucratic adhocracies must be astutely led and managed,
 which requires recruiting capable staff with crucial skill sets,
 emphasizing team work and good internal communications, and
 shrewdly retaining outside contractors as required;

 --more extensive citizen engagement by governments can be
 consistent with greater involvement of elected representatives
 (with committees or town halls), (57) but this requires careful
 and proactive management of the relationship between ministers,
 department officials, and MPS; and

 --the minister's office should have key capabilities to
 complement the bureaucratic adhocracy in the areas of strategic
 advising, coordination and drafting.


An important general lesson is to ensure that the right capacities are assembled in ministers' offices, government departments and legislative committees, and that good communication and support occurs within and across these actors.

Readers should not conclude that HRDC was unique in establishing an adhocracy, or that the consultation strategy and choice of instruments were necessarily exemplars, although the scale of the SSR was impressive. Any significant consultation initiative--whether administered by a department, task force, royal commission or independent secretariat--requires establishing an adhocracy, but the challenges will vary according to the scale and arm's-length nature of consultations. There are several more recent consultations where the concept and workings of adhocracy could have been fruitfully explored. (58) Moreover, despite the SSR'S innovations, governments are now more familiar with web-based interaction and distribution to reach citizens and experts, and officials and political leaders use increasingly more sophisticated consultation techniques, such as the deliberative forums with citizens incorporating scenarios for the Royal Commission on the Future of Health Care in Canada. (59) Finally, the latter commission demonstrated how a government can employ an alternative sequencing strategy for mega-consultations, appointing the commission to undertake arm's-length work and, following the release of its report, both houses of Parliament held their hearings. Nevertheless, the SSR was the capstone of a remarkable era of experimentation with consultation associated with the Spicer Commission, the Charlottetown Accord, and Martin's second budget as minister of finance. What is striking is how few such ambitious consultations have since been held by successive Canadian governments since 1995.
 This broader goal of systematically monitoring the
 performance of consultations and citizen engagement,
 and, more specifically, comparing the value-for-money
 of different instruments, points to a promising research
 agenda with practical implications for democratic and
 public sector reform


That governments resort to mega-consultations from time to time raises another important question, one this study could not take up: the value-for-money of different consultation instruments. Too many studies, including my own on the budget process, (60) have promoted the virtues of adding new techniques for citizen engagement and deliberation to the mix of traditional types of consultation without assessing the relative costs, the kind and quality of background material required, and the quality and usefulness of findings against the expectations of the government, task forces or commissions, and those who were consulted. (61) This study focused on the administrative dimensions of a mega-consultation; a different methodology could have assessed the comparative benefits and costs of SSR consultation instruments. This gap in the literature is not unique to Canada: indeed, in an unusually sharp comment, a recent Organization for Economic and Development study noted "a striking imbalance between the amount of time, money and energy the OECD countries invest in strengthening government-citizen relations and the amount of attention they pay to evaluating effectiveness and impact on policy-making." (62)

This broader goal of systematically monitoring the performance of consultations and citizen engagement, and, more specifically, comparing the value-for-money of different instruments, points to a promising research agenda with practical implications for democratic and public-sector reform. Mega-consultations provide excellent opportunities to explore such questions since they constitute natural experiments with different instruments. Researchers may be able to gain access to and re-interpret data and information collected for these consultations for this purpose. (63) Another possibility is to persuade government sponsors to insinuate such research questions into future mega-consultations as part of the performance-management regime.

The author is director and professor, School of Public Administration, University of Victoria.

Notes

(1) John Kane and Patrick Bishop, "Consultation and contest: The danger of mixing modes," Australian Journal of Public Administration 61, no. 1 (March 2002), p. 94.

(2) Lawrence C. Waiters, James Aydelotte and Jessica Miller, "Putting more public in policy analysis," Public Administration Review 60, no. 4 (July/August 2000), p. 357.

(3) I was invited to prepare this paper by HRDC officials to provide a general account of the SSR process and some critical reflection for the Canadian Centre for Management Development. I relied on confidential interviews with HRDC officials familiar with the policy, communications, and consultations functions during the SSR and with staff in the minister's office, the Privy Council Office, the Ministerial Task Force, and SCHRD, as well as with individuals contracted to provide services. I received superb comments from Ralph Heintzman and two anonymous reviewers and, more recently, from Herman Bakvis, Ian Clark, Steve Dupre, David Good, John Langford, Barbara Wake Carroll, and anonymous reviewers of CPA. They led to a shorter, more effective paper, but the assessments and responsibility for any errors are my own.

(4) For reviews of the policy quandaries and options embraced by the SSR, see Herman Bakvis, "'Shrinking the house of HRIF': Program review and the Department of Human Resources Development" in Gene Swimmer, ed., How Ottawa Spends 1996-7: Living Under the Knife (Ottawa: Carleton University Press, 1996), pp. 133-70; Keith G. Banting, "Keeping our balance: The political imperatives of social policy reform," Policy Options 15, no. 6 (July-August 1994), pp. 64-69; and Caledon Institute for Social Policy, Critical Commentaries on the Social Security Review (Ottawa: Caledon Institute for Social Policy, 1995).

(5) For a gripping account of this struggle, see Edward Greenspon and Anthony Wilson-Smith, Double Vision: The Inside Story of the Liberals in Power (Toronto: Doubleday, 1996).

(6) On HRDC'S restructuring, see Herman Bakvis, "On 'silos and stovepipes': The case of the Department of Human Resources Development" in Peter Aucoin, ed., Restructuring the Canadian Government: The Management of Organizational Change (Canadian Centre for Management Development, manuscript); and David A. Good, The Politics of Public Management: The HRDC Audit of Grants and Contributions (Toronto: University of Toronto Press, 2003).

(7) Human Resources Development Canada, Social Security in Canada: Background Facts (Ottawa: Human Resources Development Canada, 1994).

(8) See the case studies in Donald J. Savoie, ed., Taking Power: Managing Government Transitions (Toronto: Institute of Public Administration of Canada, 1993).

(9) For a summary of the literature, see Evert A. Lindquist, "Citizens, experts and budgets: Evaluating Ottawa's emerging budget process" in Susan D. Phillips, ed., How Ottawa Spends 1994-95: Making Change (Ottawa: Carleton University Press, 1994), pp. 104-8. See also Debora L. VanNignatten and Sheila Wray Gregoire, "Bureaucracy and consultation: The correctional service and the requirements of being democratic," CANADIAN PUBLIC ADMINISTRATION 38, no. 2 (Summer 1995), pp. 204-21; Peter Sterne with Sandra Zagon, Public Consultation Guide: Changing the Relationship between Government and Canadians, Management Practices No. 19 (Ottawa: Canadian Centre for Management Development, 1997); and OECD, "Engaging Citizens Online for Better Policy-making," Policy Brief (March 2003).

(10) For details and examples, see Evert A. Lindquist, James A. Desveaux and Glen Toner, "Organizing for policy innovation in public bureaucracy: AIDS, energy, and environmental policy in Canada," Canadian Journal of Political Science 27, no. 3 (September 1994), pp. 493-528.

(11) Several authors consider how consultation strategies might vary at different stages of the policy cycle. See Waiters, Aydelotte and Miller, "Putting more public in policy analysis," pp. 349-59; Susan Phillips and Michael Orsini, Mapping the Links: Citizen Involvement in Policy Processes, CPRN Discussion Paper No. F21 (Ottawa: Canadian Policy Research Networks, 2002); and Richard Curtain, "What role for citizens In developing and implementing public policy?" in Facing the Future: Engaging Stakeholders and Citizens in Developing Public Policy, the collected papers from the National Institute on Governance and Australian Public Policy Research Network Conference, Canberra, 22-23 April 2003 (Canberra: National Institute on Governance, University of Canberra, 2003), pp. 127-46.

(12) See Phillips and Orsini, Mapping the Links, For another state-centred "management" perspective, see Patrick Bishop and Glyn Davis, "Mapping public participation in policy choices," Australian Journal of Public Administration 61, no. 1 (March 2002), pp. 14-29.

(13) When the responsibility for postsecondary education and student loans was transferred to HRDC in June 1993, it came with little policy expertise, since the Secretary of State essentially performed a cheque-writing function.

(14) Patrick Johnston, a social policy activist, had once led the National Anti-Poverty Organization.

(15) Created in the 1980s in the former Department of Employment and Immigration, it was rare to have such capacity inside departments; usually ministerial offices would contract out for analysis at the political level.

(16) Its communications operations group drafted communications strategy in January 1994, which cabinet reviewed in early February and which outlined ways to tap into elite and general public opinion, and how to directly engage citizens including interest groups, MPS, the public, department officials and, later, students. Officials were targeted because Canada Employment Centre managers worked with local groups in the regions and the SSR might lead to new service-delivery models.

(17) If the action plan had a release date in late April, followed immediately by comprehensive consultations, their planning had to start by early March.

(18) Its members included Kathy O'Hara (chair), Cathy Drummond, Karen Jackson, Partick Johnston, Anne-Marie Smart, Jim Lahey and Ian Green (the assistant deputy minister for social development).

(19) Peter Harrison, The Constitutional Conferences Secretariat: A Unique Response to a Public Management Challenge (Ottawa: Canadian Centre for Management Development, 1992).

(20) The deputy minister wanted policy and communications staff to work together, despite different worldviews. Moreover, the latter were typically more junior than the former.

(21) Human Resources Development Canada, Proposed Changes to the Unemployment Insurance Program: Backgrounder (Ottawa: Human Resources Development Canada, 1994).

(22) Meetings were typically held on Mondays or Tuesdays. Packages had to be ready to be sent to the MTF by Thursday or Friday so they could be prepared for the meeting early the next week. These deadlines were met, but it was difficult to do so if more substantial cost data or analysis was requested.

(23) Canada, Parliament, House of Commons, Standing Committee on Human Resources Development, Interim Report: Concerns and Priorities Regarding the Modernization and Restructuring of Canada's Social Security System (Ottawa: Public Works and Government Services Canada, 1994).

(24) Appendix D in Interim Report, ibid., p. 73.

(25) In addition to the consultation and communications committee and the intervenor funding committee, there were four other committees where SSR progress could be discussed: the strategic planning committee (chaired by Kathy O'Hara and attended by Lazar, Drummond, Jackson and the Earnscliffe Group), a weekly SSR steering committee (chaired by the deputy minister), and a committee on federal-provincial matters. The management board, HDC'S executive committee, which included the deputy minister, ADMS, and the regional executive directors, was not a primary forum for handling SSR issues.

(26) For a list of the recipients and the amounts awarded, see "Intervenor Funding: Project Sponsors and Approved Budgets" in the dissenting opinion of the Reform Party in Canada, Parliament, House of Commons, Standing Committee on Human Resources Development, Security, Opportunities and Fairness: Canadians Renewing their Social Programs, Report (Ottawa: Public Works and Government Services Canada, 1995), pp. 310-14. Another $1 million went to aboriginal groups through a different process and timeline.

(27) The ad hoc committee was a subcommittee of the Cabinet Committee on Social Policy.

(28) Bechterman began working with the standing committee in June 1994, and left in early September. He was replaced by Professor Michael Prince of the University of Victoria.

(29) See "M.P.'S Consultation: A Proposal by Andy Scott, M.P.--Public Consultation: Putting Grass-Roots Policy Development in Practice" (no date, c. September 1994) and Office of Andy Scott, M.P., Public Policy Forums and Canada's Review of Social Programs (July 1994).

(30) Greenspon and Wilson-Smith, Double Vision, chapters 15 and 19.

(31) The deputy minister visited but was informed via the steering committee.

(32) Government of Canada, Human Resources Development Canada, Improving Social Security in Canada: A Discussion Paper (Ottawa: Human Resources Development Canada and Minister of Supply Services, October 1994).

(33) Derek Ferguson, "Social reform price tag: $7 billion," Toronto Star (5 October 1994).

(34) The Canada Communications Group was able to shift operators from other projects if necessary.

(35) Not long after, the release of the employment insurance legislation in December 1995 led to an impressive 160,000 "hits" on the web site, which was easier for HRDC to establish and manage.

(36) Early polling and focus groups conducted by Angus Reid in February 1994 indicated that Canadians wanted to be consulted and seventy-five per cent would contribute to workbooks (as opposed to sixty-two per cent for an interactive television show, fifty-six per cent for an information booth or forty-five per cent for a meeting organized by an MP. The SSR group in strategic communications examined how other jurisdictions used workbooks used to engage citizens.

(37) Belisle Marketing Ltee, Social Security Reform: Workbook Pre-Test, Final Report prepared for Human Resources Development Canada (November 1994).

(38) D.R. Harley Consultants Limited, Canadians Respond to Ideas for Reforming Canada's Social Programs--Final Report: "Have Your Say" Workbook (March 15, 1996). The influx of workbooks led the firm to hire extra students. One million workbooks were released at a cost of approximately $1 million and about 46,000 copies returned, a 4.4 per cent return rate; the advertising campaign cost $1 million.

(39) In interpreting the results, care was taken to emphasize that it was not a scientific survey, but another way to discover what Canadians felt about social security reform. For example, males were over-represented and Quebecois were under-represented in the sample. Another problem was that many respondents inked in comments in all parts of the book, so they were difficult to analyse.

(40) The supplementary papers included: Persons With Disabilities (October 1994); From Unemployment Insurance to Employment Insurance (October 1994); Income Security for Children (October 1994); Child Care and Development (October 1994); Reforming the Canada Assistance Plan (December 1994); Employment Development Services (December 1994); The Context of Reform (December 1994); and Federal Support to Post-Secondary Education (January 1995).

(41) Protesters were given an opportunity to meet separately with some committee members and then were given a fixed amount of time to present to the full committee.

(42) One alternative for assistance was to second department expertise to SCHRD, as had been done in the past with other committees, but SCHRD felt this would compromise its independence.

(43) See Canada, Parliament House of Commons, Standing Committee on Human Resources Development, Security, Opportunities and Fairness: Canadians Renewing their Social Programs, Report (Ottawa: Public Works and Government Services Canada, 1995), pp. 234-5 and pp. 245-7, respectively.

(44) "Report to the standing committee on human resources development on town hall meetings on social security reform held by members of Parliament," January 1995.

(45) Human Resources Development Canada, "Consultation Seminars on Social Security Reform: Third-Party Reports" (January 1995), mimeo.

(46) Lindquist, "Citizens, experts and budgets."

(47) The structure of the HRDC policy colloquia were informed by the models presented by the 1992 constitutional public conferences and 1994 budget public conferences. Like the constitutional conferences they focused on particular topics and strove for balanced representation, but did not maximize the participation of ordinary citizens. Like the budget conferences they lasted a day.

(48) Government of Canada, Human Resources Development Canada, Report on Public Consultations: Canadians Speak out for Changes to Social Programs (Ottawa: Human Resources Development Canada, 1995).

(49) See Report on Public Consultations, ibid., which provided some polling data, and overview of the findings, and executive summaries of the policy seminars and policy colloquia.

(50) For details on this episode, see Rodney S. Haddow, Poverty Reform in Canada 1958-1978: State and Class Influences on Policy Making (Montreal and Kingston: McGill-Queen's University Press, 1993), pp. 84-142.

(51) Kane and Bishop, "Consultation and contest: The danger of mixing modes," pp. 87-94.

(52) See the cases in Desveaux, Lindquist and Toner, "Organizing for Policy Innovation."

(53) However, the room was too confining for the number of staff that typically met (and lived) there. To launch the Employment Insurance legislative package in December 1995, officials arranged for two rooms in order to allow for more space and for meetings to proceed without background noise.

(54) See Desveaux, Lindquist and Toner, "Organizing for Policy Innovation." See also James A. Desveaux, Designing Bureaucracies: Institutional Capacity and Large-Scale Problem Solving (Stanford: Stanford University Press, 1995).

(55) Walters, Aydelotte and Miller, "Putting more public in policy analysis," p. 359.

(56) Renee A. Irvin and John Stansbury, "Citizen participation in decision making: Is it worth the effort?," Public Administration Review 64, no. 1 (January/February 2004), pp. 55-65.

(57) This tension is not seen as insurmountable, particularly given that instruments for consultation and citizen engagement can be simultaneously or sequentially employed by governments. See Phillips and Orsini, "Mapping citizen involvement," and Jocelyne Bourgon, "A voice for all: Engaging Canadians for change," Notes for an address to the Institute on Governance Conference, Alymer, Quebec (29 October 1998). Interest groups can also feel disenfranchised by citizen engagement processes. See Carolyn Hendriks, "Institutions of deliberative democratic processes and interest groups: roles, tensions and incentives," Australian Journal of Public Administration 61, no. 1 (March 2002), pp. 64-75.

(58) Examples include the National Forum on Health, the Rural Dialogue, and the Innovation Strategy. See Steve Patten, "Democratizing the institutions of policy-making: democratic consultation and participatory administration," Journal of Canadian Studies 35, no. 4 (Winter 2001), pp. 221-39.

(59) For a list of different consultations undertaken, see Annex B on "Consultations" and Annex C on "The External Research Program" in Commission on the Future of Health Care in Canada, Building on Values: The Future of Health Care in Canada--Final Report (November 2000), pp. 271-308.

(60) Lindquist, "Citizens, experts and budgets."

(61) Phillips and Orsini, in Mapping the Links, compare the features of instruments and persuasively argue that selecting Instruments is highly situational and best used In parallel with others. While they do not address value-for-money and impact questions, their framework could easily be extended for this purpose.

(62) OECD, Citizens as Partners: Information, Consultation and Public Participation in Policy-Making (Paris: OECD, 2001), p. 13.

(63) But see Judith Maxwell, Steven Rosell and Pierre-Gerlier Forest, "Giving citizens a voice in healthcare policy in Canada," British Medical Journal 326 (10 May 2003), pp. 1031-33, a high-level review of the benefits, impact and costs of the citizen dialogue strand of the Romanow Commission consultations. Aside from comparing the findings with a later survey done for the commission, the authors did not compare the dialogues with the other instruments.
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