Nutrition North Canada Engagement 2016: Final report of what we heard

General observations

Northerners feel that everything in the North is expensive, with a number of participants stating that, as Southerners, it is difficult to understand those struggles, which is then further intensified with many people living off a fixed income. Even with the subsidy provided through NNC, for which they generally expressed an appreciation, many families are not able to afford healthy food. There were significant concerns regarding the overall quality and availability of nutritious perishable food in the North. In addition, there was significant concern regarding how climate change will impact food availability through changing availability of country/traditional food and seasonal transportation, such as a shortened timeframe for the winter road and unreliable sealift.

Program sustainability and cost effectiveness

In order to understand what Northerners and Indigenous people are eating and would like subsidized, there was a desire for regions/communities to have their own customized eligibility lists. However, comments received regarding what items should be included on and off the eligibility list were generally homogeneous across regions.

Engagement participants were concerned that the eligibility list was developed from a southern perspective and did not take into account traditional diets. As a result, the majority of participants desired that increased subsidy was given to:

• ingredients for baking bannock and bread (flour, baking soda, butter, lard, etc.)
• support for country/traditional food through a variety of channels
• "staples" including rice, pasta, nutritious dried/dehydrated foods, coffee/tea
• all juice sizes and canned goods

In addition, it was found that there was largely support for personal/direct orders to remain a part of the program.

Capacity and efficiency

From interviews it was often mentioned that the program (especially the INAC component) appeared to operate in a standalone fashion rather than working with the large number of other government and non-government organizations tackling food security in the North. Across the interviews, suggestions were made for NNC to investigate partnerships with potential programs and organizations to better operate within the fixed budget.

Because of the cost and complexity of shipping food by air to remote northern communities, a number of potential program efficiencies related to better transportation and supply chain management were identified by participants. Examples of such changes include developing partnerships (e.g. leveraging complimentary subsidy programs, etc.) or redesigning the program, including increasing program scope and/or funding. Other examples included revaluating and/or considering alternative transportation methods, while noting the issues and possible efficiency gains with air transportation. There were also examples provided on addressing issues related to spoilage and waste (e.g. enforcing packaging, penalizing waste, etc.), enhancing nutrition education initiatives (e.g. improving reporting requirements), and considering changes to the management of the subsidy (e.g. allowing for inflation).

Fairness and consistency

In terms of fairness in determining the subsidy rate for communities there were a number of different approaches suggested by participants such as being based on the cost of food, cost of living, transportation freight rates, distance of the community from a major supply centre, and equalizing the cost of food, among others. Underlying this, however, was a desire by a number of participants for the subsidy rate approach/formula to be communicated clearly and transparently.

Following the implementation of the change in community eligibility criteria in October 2016, there were a number of participants who suggested that the eligibility criteria should be expanded to communities not currently eligible for the program. This included communities connected to the South with all-season surface transportation that some participants considered to be isolated northern communities that should also be eligible for the program.

In terms of developing a consistent set of eligibility criteria, there was largely support for restaurants to have access to the subsidy and limited support for hotels and outfitters to be eligible for the program.

Transparency

There were varying interpretations of program objectives by the participants, including the program's role in the larger issue of food security in the North. A number of participants mentioned a variety of ways that the program could be more transparent with respect to its objectives that would allow for better understanding of the program and measuring success. Examples include better communicating the program's purpose, setting clear and measurable goals, providing accessible information and data on the program, and addressing concerns regarding the subsidy being passed to consumers in full.

Though a number of participants felt that showing the subsidy on the store receipt was a major positive step in improving transparency, a significant number of participants expressed concerns that the subsidy was not being passed on to the consumer. A number of suggestions to improve transparency were provided, such as requiring more information from registered partners, reviewing subsidy levels, and enhancing monitoring activities.

Communications

From the engagement, it was clear that NNC was not well understood within eligible (particularly newly eligible) communities or by key stakeholders. There was an overarching lack of awareness and understanding of key information including eligibility, subsidies and administration.

A number of participants suggested ways to improve communications, which included building and leveraging relationships by reaching out to and leveraging key stakeholders; creating a dialogue with stakeholders focused on improving the program using appropriate formatting of messages; developing and utilizing appropriate communication vehicles such as in-store signage, radio, social media, newsletters/magazines, online videos suggestion boxes, surveys, and in-person visits; and tailoring information and engagement at a community level such as developing community-based summaries and outreach activities.

Innovation

A large number of innovative ideas on how to improve the program were brought forward by participants. Areas of innovation included developing new program objectives; developing a new program model/design; establishing a new management and governance structure; finding additional program budget/funding sources; redesigning the subsidy; undertaking new research; and developing new nutrition education initiatives.

1.1  Program background

1.2  Need to update the program

Northern and Indigenous people have raised concerns about the program to the NNC Advisory Board, the program, and the INAC and HC Ministers. There was also an internal evaluation completed in 2013 to inform the new performance measurement strategy for the program.

In addition, in 2014, the Auditor General of Canada (AG) report on NNC noted a number of areas for improvement for the program in areas such as:

• program sustainability and cost-containment measures to stay within budget
• fairness and consistency of community eligibility criteria
• better transparency to ensure the subsidy is being passed on to consumers

As a result of these efforts, NNC initiated a broad public engagement to hear from Northerners and Indigenous people, community groups, provincial/territorial and municipal government members, registered retailers and suppliers, and other interested parties on how to improve the program.

1.3 Overview of the engagement

Interis | BDO was contracted to undertake the engagement on behalf of INAC. In broad terms, the purpose of the engagement strategy was to canvas the views of as many NNC stakeholders as possible on the objectives, operations, and impact of the current program, and to seek ideas on how to improve NNC without the program incurring any additional costs.

While trying to cast as broad a net as possible to encourage innovation and creative ideas from participants, the engagement was organized around certain themes:

• program sustainability and cost effectiveness
• expanding program capacity/improving program efficiency
• fairness and consistency
• transparency
• communications
• innovation

These themes are outlined in the subsections below.

1.4 Structure of the engagement

In terms of guiding principles, it was important to hear from a broad cross-section of stakeholders and representatives on the current program and how it might be improved. The engagement exercise had to be cost and time-efficient. The engagement involved:

• Public engagement sessions (i.e. town halls) were conducted in 16 eligible communities. The list of communities is provided in Appendix A.
• Interviews either in-person or by telephone with key stakeholder groups. The list of organizations and participants interviewed is provided in Appendix B and include:
  • regional and community leadership
  • national and regional stakeholder groups
  • retailers
  • provincial and territorial governments
  • air carriers
  • health workers
  • hunter and trapper organizations;
  • academics
• Written submissions provided by direct mail or email. The list of organizations and individuals who provided written submissions is provided in Appendix C.
• Questionnaire submissions provided by direct mail or completed online. There were 260 anonymous questionnaires received.

Engagement sessions were moderated by Interis | BDO. Participants were given an opportunity to propose any new ideas so that there was not a feeling of restrictiveness to the engagement. The process of the engagement and content were sufficiently flexible to allow a broad range of input. In addition, all reasonable means were taken to make engagement sessions accessible to as many participants as possible.

1.5 Content of this report

This report is a summary of what was heard during the engagement. Given the breadth of the engagement, it was not possible to detail all of the comments received having engaged more than 500 people and noted over 3,500 comments, which included the review and incorporation of content from written submissions and hundreds of surveys. This report represents Interis | BDO's independent view of the highlights and themes of what was heard.

"One-off" comments are typically not reflected in this report – particularly if they were divergent from all other comments received. In addition, many people were unaware of NNC or how it operates, so some comments in this report may reflect a misunderstanding of the program rather than an error in reporting.

Throughout this report, Interis | BDO will refer to groups/individuals engaged as participants. Participants included regional and community leadership, national and regional stakeholder groups, retailers, provincial and territorial governments, hunter and trapper organizations, health workers, air carriers, academics, and individuals.

1.6 Terms used in this report

A glossary of terms related to NNC can be found in Appendix D.

Specific to this report, the following terms were used to describe how often certain views were voiced by various participants:

• Vast Majority: Greater than 80% as observed by Interis | BDO;
• Majority: Greater than 50% but less than 80% as observed by Interis | BDO;
• Minority: Fewer than 50% but occurred more than twice as observed by Interis | BDO; and
• One-Off: No more than two comments as observed by Interis | BDO.

3.1 General eligibility list comments

The following were general comments made regarding the creation of the eligibility list and the list itself:

• There was no agreement from participants on whether the eligibility list should be larger or smaller than it currently is, though the majority of communities stated a preference for a broad list when compared to a narrower list.
• There was a lack of awareness regarding how the list was developed, and a number of Northerners and Indigenous people and organizations were critical of NNC using a list developed by Southerners.
• There was a concern that the eligibility list was developed using the Canada Food Guide rather than taking into account the First Nations Food Guide or a northern food guide.
• There was a desire for regions/communities to have their own customized eligibility lists. That said, for the most part, comments received regarding the eligibility list from across the isolated communities were very similar and communities tended to want the same items subsidized with minor exceptions.

3.2 Eligibility list comments made by the vast majority of communities

The following eligibility list additions were mentioned in the vast majority of engaged communities:

• flour (with the majority commenting on its use in baking traditional food such as bannock)
• country/traditional foods
• hunting/fishing support products including gasoline, ammunition, fishing nets, traps, and snowmobile parts

Given the extent of participant feedback regarding subsidizing country/traditional food and the complexity of subsidizing it within the program, the related comments are outlined in the Country/Traditional Food section below.

3.3 Eligibility list comments made by the majority of communities

The following eligibility list additions were mentioned by the majority of engaged communities:

• baking soda
• infant food such as formula and baby food, with some suggesting it should receive an additional subsidy beyond the level 1 subsidy^{Footnote 1}
• diapers, wipes and other infant or child care items such as bottles
• bottled water

The following eligibility list items were requested to be moved from level 2 subsidy to level 1 subsidy by a majority of engaged communities:

• butter
• lard and lard substitutes
• margarine
• rice
• pasta (some participants suggested all pasta while others suggested raising the subsidy level for whole wheat pasta only)
• nutritious dried and dehydrated foods (dried beans, lentils and grains)
• canned goods
• coffee/tea
• large sizes of juice

3.4 Eligibility list comments made by a minority of communities

The following eligibility list items were mentioned by a number of engaged communities (but less than the majority) that should receive an even higher subsidy (higher than level 1):

• fresh vegetables
• frozen vegetables
• fresh fruit
• frozen fruits
• meat
• milk
• soy milk
• whole grain products

The following eligibility list additions were mentioned from a number of engaged communities (but less than the majority):

• sugar
• salt
• spices and seasoning
• sauces for seasoning food
• yeast
• canned and sandwiched meats
• household cleaning products, including dish soap, laundry detergent, and kitchen cleaner
• personal hygiene products, including feminine hygiene products, toothpaste, toilet paper, and soap
• gardening supplies and equipment, including seeds, soil, fertilizer, shovels, and rakes
• dough for making bread
• camping equipment, including tents, stoves, and outdoor clothing

The following eligibility list items were mentioned to be moved from level 1 subsidy to level 2 subsidy or removed altogether by a number of engaged communities (but less than the majority):

• non-nutritious or high-sugar ready-to-eat cereals
• processed cheese

The following eligibility list items were mentioned to be moved from level 2 subsidy to level 1 subsidy by a number of engaged communities (but less than the majority):

• cooking oils (some northerners mentioned all cooking oils while others suggested only increasing the subsidy for the healthier cooking oils)
• ice cream
• crackers and biscuits
• sour cream

The following eligibility list deletions from a number of engaged communities (but less than the majority):

• "fancy" fruits and vegetables (dragon fruit, cherries and kiwis were provided as examples)
• juice
• ice cream
• canned/evaporated/powdered milk
• frozen pizza
• frozen lasagna

3.5 Eligibility list comments made by a very small number of individuals

There were a variety of comments received from a very small number of people (sometimes one person). For sake of completeness, a selection of these comments has been provided below. These comments should be considered as outliers and not representative of the broader views of participants. The following comments were made regarding items to be added to the eligibility list:

• all food
• all food except "junk food"
• all food from the canada healthy food guide
• all store-bought products
• bulk items for families
• livestock and associated supplies to maintain animals in the north
• juice crystals
• sweetened juice cocktails
• sweetened drinks that have less sugar than pop such as sport energy drinks
• reduced sugar content items (e.g. plain cereal) for diabetics
• nutrition shakes or meal replacement items
• organic and non-genetically modified organism (non-gmo) food
• coconut flour (flour substitute)
• nut-based milk substitutes
• soya sauce
• artificial sweeteners
• maple syrup
• honey
• pumpkins
• "ethnic" foods
• chocolate and other treats
• frozen fried chicken
• sewing equipment and supplies
• clothing

The following comments were made regarding items to be removed from the eligibility list:

• tofu;
• side bacon^{Footnote 2}
• fish.^{Footnote 3}

The following comments were made regarding the use of a seasonal subsidy:

• The subsidy should be adjusted based on cost and availability of products during a particular season.
• There should be a safety net in certain seasons to ensure healthy food items are available throughout the year.

3.6 Eligibility list comments made by health workers/stakeholders

The opinions of health workers/stakeholders were not homogeneous. That said, below is a summary of the key recommendations from health workers.

A number of health workers/stakeholders interviewed recommended the following items be added to the eligibility list:

• country/traditional food
• locally grown vegetables
• breastfeeding support equipment including breast pumps and pads
• bottled water, specifically, though not exclusively, in communities where there are water advisories

a number of health workers/stakeholders interviewed recommended the following items be moved from level 2 to level 1:

• flour
• dried lentils and beans
• juice

A number of health workers/stakeholders interviewed recommended a reduction in eligible items by removing them from the list altogether, including:

• juice
• side bacon
• ice cream
• processed cheese spreads
• processed meats
• anything but the most basic healthy items (only fruit, vegetables, meat and milk should remain on the list) to have the biggest impact on healthy outcomes
• cereal with high sugar
• fruits and vegetables that are out of season

3.7 Personal/direct orders

Throughout the engagement, it was found that the majority of participants supported personal/direct orders to remain a part of the program. Below are a number of comments/concerns regarding personal/direct orders:

• Across communities, there was very little awareness that personal/direct orders were permitted under the program. In addition, most participants did not know which southern suppliers are registered with the program.
• In many regions/communities, participants expressed a desire for INAC to increase the number of registered southern suppliers to increase access and choice of more items, such as for dietary restrictions, for their region/community as well as create competition for local stores. Some communities reported that there were no registered southern suppliers in their area available or willing to provide personal/direct orders to individuals.
• A number of Northerners reported ordering from large non-registered southern suppliers (Walmart was frequently used as an example) due to price and selection rather than using the registered southern suppliers.
• There is a concern among participants that people without access to credit cards cannot easily access the registered southern suppliers. Some participants expressed a desire for INAC to put in place a mechanism to facilitate these individuals accessing personal/direct orders.
• There is a need for service standards to be introduced to ensure that any personal/direct orders are received in a timely manner given the nature of the perishable goods being shipped.

"Perishables orders from suppliers are not delivered within 72 hours – What is the policy?"

• Some participants felt there should be a review of the packaging requirements of personal/direct goods to allow eligible items to be shipped with non-eligible items to avoid suppliers separating them into level 1 or level 2 shipments, or not including non-eligible items in a shipment with eligible items.
• Retailers expressed concerns that an increase in personal/direct orders would reduce the availability of food items in northern retailers.
• Some communities, particularly, but not exclusively, with band/local-owned stores, expressed a desire not to allow personal/direct orders to keep the money "in the community".
• There were concerns that registered southern suppliers, due to their low volume of shipments, were paying higher rates for air freight and receiving lower priority on the air carriers, making them more expensive and subject to higher levels of spoilage.
• A number of participants indicated that they travel and shop in non-isolated communities and pay for their own freight back to their community. They requested that INAC put in place a mechanism to allow these individuals to claim the subsidy.

5.1 Program capacity – developing partnerships

In the interviews, it was often mentioned that the program (especially the INAC component) appeared to operate in a standalone fashion, despite the fact that other government and non-government organizations were quite involved with the issues of healthy eating and food security. It was suggested that there could be greater program capacity if NNC reached out to investigate potential partnerships either with existing programs or by developing new ones to address the objectives of providing access to affordable nutritious foods. In the interviews, participants identified many organizations and programs which might offer an opportunity for potential partnerships.

It is important to note that many of these programs are already connected and receive funding from NNC, though participants seemed largely unaware of these relationships.

Programs for prenatal women or new mothers

Participants mentioned a number of jurisdictions have nutrition programs for prenatal or new mothers, including:

• The Kativik Regional Government (KRG) has a program that offers coupons and education to pre-natal women.
• The PHAC funds 276 projects under the Canada Prenatal Nutrition Program in over 2,000 communities annually. There is a separate stream run by HC for Inuit and First Nations women living on-reserve. The program provides vouchers or milk coupons, for example, and may offer some potential alignment opportunities with NNC.
• The IRC has a prenatal cooking program.

Food security initiatives

Participants mentioned a number of organizations in Canada are doing food security work, which offer opportunities for partnerships in research, food surveys, education, outreach, and advocacy. Some of these include:

• The Inuit Food Security Working Group is coordinated by Inuit Tapiriit Kanatami and includes representation from the IRC, NTI, Pauktuutit Inuit Women of Canada, National Inuit Youth Council, Nunavik Regional Board of Health and Social Development, Nunatsiavut Government, and the Inuit Circumpolar Council Canada.
• HC and Manitoba's Northern Healthy Food Initiative are funding food security work in four northern communities in Manitoba.
• Nishnawbe Aski Nation (NAN) in northern Ontario is doing work on food security, including a current project in Fort Albany. Knowledge from the program could help promote the initiative in the territory.
• There is a food security group working in Nunavik called the Nunavik Regional Working Group on Food Security.
• Food First NL is a provincial membership-based, non-profit organization working to improve food security in Newfoundland and Labrador.

Direct food subsidies or cost-of-living programs

In limited cases, participants mentioned there are complementary or parallel food subsidy programs:

• Makivik Corporation works with the KRG to subsidize a number of basics including milk and juice. There are signs in the stores which identify the KRG subsidy.
• The KRG also has a Cost-of-Living Program, Inuit Hunting, Fishing and Trapping Support Program, and a Transportation Subsidy Program for the summer sealift.
• Newfoundland and Labrador did have an Air Foodlift Subsidy program which subsidized some basic foods, but the program ended in April 2016. It will be replaced by the Labrador Aboriginal Nutritional and Artistic Assistance Program which will be used among other things to assist food banks, and also to transport moose meat from Newfoundland to Labrador while there is a moratorium on caribou hunting.
• There is a program called Affordable Food in Remote Manitoba (AFFIRM)^{Footnote 4} operating in northern Manitoba that reduces the price of milk, fresh vegetables, and fresh fruits in eligible, remote communities through a subsidy.

"Whole-of-government" approach

A number of participants felt that NNC should include coordination with various levels of government rather than just HC/PHAC. A number of examples were given:

• The former Air Foodlift Subsidy program in Newfoundland and Labrador also included health and community services, environment and conservation, natural resources, as well as non-governmental organizations. The new program will be replaced by the Labrador Aboriginal Nutritional and Artistic Assistance Program.
• Makivik Corporation which works with the KRG addresses food issues as part of economic development. Makivik Corporation looks at wildlife and the natural environment and coordinates research. For example, the use of greenhouses is accelerating in Nunavik for both families and commercial organizations. Makivik Corporation is looking at the potential for burning waste to heat the greenhouses.
• Makivik Corporation is also looking at local production in Nunavik, for example, they initiated a chicken project in Kuujjuaq. Their intent is to make these initiatives more economical by offering it to other stakeholders beyond community members, such as large mining companies who operate in the region.

Support to local production

Participants mentioned that another way to enhance capacity is to increase the amount of local food production which would reduce transportation costs, increase local economic development, and enhance community pride and cohesiveness. A number of initiatives are already underway:

• As mentioned, Makivik Corporation is supporting the development of greenhouses in Nunavik, as well as the cultivation of livestock.
• The Nunatsiavut government supports local gardening projects.
• The Northern Healthy Foods Initiative in Manitoba assigns partners to communities to focus on local self-sufficiency, including greenhouses, poultry, and gardening.
• The Ministry of Agriculture in Saskatchewan has asked if there is some way that small businesses and food producers could connect to and work with NNC.
• The NWAC/PEKE program supports work on community gardens using the example of Haida Gwaii.
• It was also suggested that there be greater cooperation with the NTI Nunavut Harvester Support Program.

Joint communications

Participants mentioned that many organizations have communications vehicles which could be used by the program. These organizations include:

• The Athabasca Health Authority sends out a monthly newsletter to stores, airports and health clinics, and a digital version is sent to Athabasca health centres.
• Digital signage on health centre monitors where NNC could provide program information and updates.
• Makivik Corporation has a magazine which goes regularly to beneficiary households.
• Makivik Corporation also owns First Air and Air Inuit which have in-flight magazines.

5.2 Program capacity – program design

A number of comments were made about the current program design which potentially limited the capacity of the program. A number of these will also be discussed in the section on Innovation.

Although participants were advised that NNC was to work within its budget with an annual escalator, many still requested that the program be expanded both in scope and funding.

5.3 Program efficiency – transportation and supply chain management

Because of the cost and complexity of shipping food by air to remote northern communities, the majority of potential program efficiencies revolved around better transportation and supply chain management.

5.4 Spoilage and waste

An issue that was raised often by participants was food spoilage. Not only does it affect the food supply in a community, but it also adds to the cost of the program. Specifically, the following comments were made about spoilage:

• It was reported that some air carriers were not following the rules in place through negotiated and agreed to contracts to ship perishables first.
• There was concern about the temperatures on aircraft in the freight areas.
• There was concern with the packaging methods used by suppliers when sending perishable food to the North, with participants noting that it is packaged for the South and extra precautions (e.g. plastic-wrapped, boxed, etc.) are required to avoid spoilage.
• Some communities lack the necessary infrastructure, such as freezers.
• There is poor refrigeration in some stores.
• It was suggested that there be penalties for excessive waste and non-compliance.
• Some people questioned why certain unpopular food (e.g. tofu) were sent to certain regions (perhaps suggesting that it was simply to take advantage of a subsidy that might be greater than the freight rates).

5.5 Nutrition education

There were a number of comments by participants on the nutrition education aspect of the program that might affect its efficiency. It is worth noting that though funding for nutrition education initiatives is provided to all eligible communities, there is no consistent manner on how funding is provided by the program, with HC funding First Nation and Inuit communities and with PHAC funding the remainder. In some circumstances, funding is transferred to and managed by another entity (e.g. provincial/territorial government). Interis | BDO heard:

• There are too many players involved in the nutrition education component (e.g. First Nations and Inuit Health Branch, HC/PHAC regional offices, etc.).
• HC/PHAC provides the nutrition education only in certain areas in certain regions.
• There has to be better linkages between the INAC and HC/PHAC aspects of the program.
• There should be stronger links to other health programs, including the Canadian Prenatal Nutrition Program and the Aboriginal Diabetes Initiative (see comments under Developing Partnerships earlier in this section).
• There should be more reporting on the nutrition education component of the program.
• There are partnership opportunities such as implementing home economics classes in school.

5.6 Management of the subsidy

The prime way to control the efficiency of NNC is through the subsidy. The subsidy is paid to eligible retailers and suppliers who provide eligible products to eligible communities. Because of its importance to the management of the program, Interis | BDO heard the following comments about the subsidy:

• The subsidy rate does not allow for inflation as well as for increases in population and consumption of eligible foods, and as such, there is a need for an escalator clause in the subsidy. As currently set, the subsidy is inadequate and will continue to lead to food security inequities between communities.
• The subsidy rates have not changed since the start of the program and need to be reviewed and updated.
• Concern that the subsidy rates are not equal to the airline freight rates.
• There were reports that the subsidy for certain communities is greater than the freight rates in place.
• High subsidy rates could lead to "gaming" of the system where companies may have an incentive to ship food even if it does not sell, or to ship spoiled or unwanted products just to capture the subsidy.
• The program needs to verify the accuracy of the subsidy for each eligible community.
• Level 2 subsidies should be raised to meaningful amounts or not provided at all in order to preserve the integrity of the program.
• If the subsidy is to be changed, clear program objectives must be established and objective, and meaningful criteria must be used to assess program efficiency.

6.1 Fairness in subsidy rates

In terms of criteria for determining the subsidy rate between communities, there were very different perspectives from the various participants. Some perspectives were shared among a number of participants, while other approaches were raised by only a few participants. The following is a list of the criteria raised by participants:

• Subsidy rates should be based on the cost of food with some participants adding that income levels should be taken into consideration as well.
• Subsidy rates should be based on transportation freight rates to the community.
• Subsidy rates should be based on the cost of living either alone or taking into account income levels.
• Subsidy rates should be based on distance of the community from the supplier.
• Subsidy rates should be the same within a particular region.
• Subsidy rates should be comparable to the (average food prices of the) nearest, non-isolated centre, such as Yellowknife for NWT communities.
• Subsidy rates should make the cost of food equal for a particular region, with more isolated regions having a higher cost of food than less isolated regions.
• Subsidy rates should take into account micro-economic effects related to the community (for instance, if a community is on an island or has unique surface transportation issues).
• Subsidy rates should be based on a measure of isolation.
• Subsidy rates should be based on the program objectives to maximize the impact on what the program is actually trying to achieve.
• Subsidy rates should consider seasonality, weather, surface-access, and other factors that could influence the price of food.
• Subsidy rates should consider the size of the community.
• Subsidy rates should consider the number of retailers in a community.
• Subsidy rates should consider the availability of commercial flights.
• Subsidy rates should be the same for every community.
• Subsidy rates should make food costs comparable to the South.

6.2 Fairness within the community

The majority of participants felt that NNC was fair to all members of northern isolated communities as the retail model made it accessible to everyone in the community.

A minority of participants felt that the program was not fair within a community in the following areas:

• Hunters, trappers, and local food producers do not receive subsidy for the food they produce.
• Personal/direct orders are most accessible to those with credit cards and is difficult for those without Internet and telephone access, so it is harder for the most vulnerable populations to access personal/direct orders.^{Footnote 5}
• Program communications and information are largely web-based, so not accessible to those without Internet.
• Low and fixed income families did not get their fair share of the subsidy as they could not afford to buy the nutritious perishables subsidized by the program.
• Government employees who already receive a northern allowance are perceived to be "double dipping".

6.3 Fairness of community eligibility criteria

During the overall engagement, the eligibility criteria for communities changed (announced July 2016 and implemented October 2016).

Prior to the change to the eligibility criteria, there were several comments received regarding the need for a more needs-based approach to community eligibility criteria.

Following the announcement of the change to the community eligibility criteria, there were a number of comments from participants who suggested that the eligibility criteria should be expanded to include more communities. Suggested changes included adding communities connected to the South with an all-season road with one or more of the following:

• High costs of food;
• Poor condition road or other surface transportation for part of the year, which included communities with infrequent and/or unreliable service (rail was used as an example);
• Small communities that are a long distance from a store; and
• Communities that lose their surface transportation for very short parts of the year.

6.4 Subsidy for restaurants, hotels, and outfitters

There were varying opinions among participants on whether hotels, restaurants, and outfitters should continue to have access to NNC given the breadth of comments. Interis | BDO's opinion as to weighting of opinion (i.e. majority, minority, etc.) of the participants are shown in the subsections below.

7.1 Improving transparency

7.2 Areas where NNC could improve transparency

The program has been addressing the lack of transparency (e.g. AG recommendations, subsidy savings on receipts, etc.), with participants asked to provide suggestions on how transparency could be further improved. To address the lack of transparency with the program, there was an effort to determine what information stakeholders required.

There were a number of suggestions observed by Interis | BDO for improving transparency of the program, including:

• Addressing all recommendations from the 2014 report for the Auditor General to demonstrate commitment to improving the program and the lack of transparency felt by the Northerners and Indigenous people.
• Consider alternative models beyond the current approach with a retail-based subsidy.
• Evaluate "profit margins over time" and review changes in "mark-up rates" pre- and post-application of the subsidy, which would also give insight into seasonal price changes.
• Mandate full transparency of all operational costs, including preferred freight rates and profit margins of registered southern suppliers and registered northern retailers. A number of participants stated that this was applicable to all items, not just those on the eligibility list, as there was concern that there was an unfair benefit being realized by marking up unsubsidized items.
• Mandate all registered northern retailers to show the subsidy saved on receipts.
• Provide information on how the subsidy rates were determined.
• Conduct periodic (e.g. annual) revisions of the subsidy levels within communities and provide the results to stakeholders.
• Clearly associate any programs funded through the nutrition education initiatives budget provided by HC/PHAC through the program.
• Relocate administration efforts of NNC to the North; have regional Northern and Indigenous staff and management.
• Implement systems/tools to effectively collect and analyze data, which would provide the ability to monitor changes in the price of food by community and by store, for eligible communities.
• Implement a standard system of claims auditing and compliance reviews for all parties receiving subsidy payments.
• Enhance monitoring and evaluation practices of the program to include measures of food availability, as well as the quality and consumption of nutritious foods.
• Introduce independent food costing for all eligible communities to ensure transparency that the subsidy is being passed along and that prices are not being raised to manipulate the system.
• Address the recommendations of the 2012 report of the NNC Advisory Board.
• Consolidate and communicate best practices from eligible communities, as well as other national and international programs, to identify opportunities and share lessons learned.
• Provide information on NNC in a more effective manner. For an overview of feedback related to improving program communications, please refer to the Communications section.

8.1 Lack of understanding of the program

A large number of individuals at a community-level stated that they knew very little or had no information on the program, including even that their community was receiving a subsidy. It was commonly suggested that this was a result of a lack of communication and failure to use the appropriate channels from INAC to Northerners and Indigenous people.

Participants suggested that the program should communicate more general information in a consistent, accessible, and supported manner across a variety of communication media.

The areas where there was little awareness or where there was a poor understanding included:

• Community eligibility criteria:
  • The criteria used to determine eligibility of a community within the program, including why it does not extend to other remote communities.
  • The reason that certain communities are only just being considered eligible within the program.
• Eligibility list:
  • the items that are eligible and their subsidy rate
  • the frequency that the subsidy rates are reviewed and changed over time to reflect the increasing cost of food in the north
  • the frequency that eligible food is reviewed to ensure alignment to preferences
  • the eligibility of country/traditional food to receive a subsidy and how people can access it
• Personal/direct orders – How to complete personal/direct orders, including actively advertising this component of the program and promoting the registered suppliers that can complete personal/direct orders.
• Application of the subsidy:
  • how the subsidy is applied
  • an overview of how the subsidy levels 1 and 2 are chosen, including the contributing factors that are considered or the formula used
  • an overview of how local retailers can leverage the program
• Program budget – What the program budget is, including any increases to reflect the growing cost of food in the North
• Program administration:
  • An overview of the evaluation activities that take place, and how those results are shared; and
  • An overview of the monitoring activities that take place, including the mechanisms to ensure the subsidy is being passed along to consumers and on avoiding food spoilage.

The majority of the most commonly requested information is readily available from the NNC website for those who have access to the Internet and are aware it is available, though, as one participant said:

"All information to date is meaningless because [people] aren't seeing it".

8.2 Awareness of newly eligible communities

In July 2016, the Ministers of INAC and HC announced an expansion to the current program budget as a result of updates to the community eligibility criteria. The program was expanded to an additional 37 communities, with a commitment in Budget 2016 for an additional $64.5 million to NNC over five years. However, there was lack of awareness of the program in the communities visited among those new communities which received full eligibility effective October 1, 2016. For the most part, community leadership as well as individuals within the newly eligible communities had very little to no awareness of the program or how it operated.

In addition, multiple stakeholder groups, including highly-engaged participants, held the misconception that these new communities took away from the current program budget. There was little knowledge of the year-over-year budgeting increase of five percent, which is also in place.

8.3 Comparing against the food mail program

The lack of understanding of NNC and the many misconceptions when compared with the previous Food Mail Program were noted throughout the engagement. Nevertheless, on multiple occasions, preference was indicated for the Food Mail Program that NNC replaced in April 2011. The general misconceptions raised were as follows:

• Unlike the Food Mail Program, with NNC, you are not able to do personal/direct orders.
• A view that with the Food Mail Program it could be assured that the subsidy could be passed on along to consumers.
• People were not always aware that retailers used the Food Mail Program.

Further, there were a number of other comments made related the Food Mail Program:

• The Food Mail Program was more efficient and resulted in better food quality at lower prices for consumers. People could purchase items at the same costs found in the South.
• The more limited choice of subsidized goods, as a result of NNC, led to retailers making their profits elsewhere, including on items that were previously subsidized through the Food Mail Program. Retailers are the only ones benefitting from the current program.
• There are problems with completing personal/direct orders, unlike the Food Mail Program.
• The Food Mail Program was better, especially for those on a fixed income or social assistance, because they had more ability to choose where and how to spend their money.
• There were a number of comments from participants stating a preference for the Food Mail Program due to preferring the Food Mail Program eligibility list over the NNC eligibility list.^{Footnote 7}
• Some people still refer to personal/direct orders as "Food Mail".

"When we used the Food Mail Program in the past, products were delivered promptly and in good condition. It was affordable and provided much more variety for the consumer. How does NNC compare?"

There was also some disdain for the structure of the Food Mail Program as a possible alternative:

"As a community leader, I would not accept NNC directly subsidizing people as the Food Mail Program did".

8.4 Improving communications

To provide a more clear understanding, NNC is looking to improve its communication to better share the important and necessary information with people in the eligible communities, and the relevant stakeholder groups.

To improve communication practices, the question that was asked was:

What would be the best way for the program to communicate to and engage with the community?

The general observation was that NNC needs to ensure a sustainable and long-term engagement with the eligible communities. These findings can be categorized into four key focus areas:

• building and leveraging relationships
• creating lasting dialogue
• developing and utilizing appropriate communication vehicles
• tailoring information and focusing engagement at a community-level

8.5 Role of the advisory board

The NNC Advisory Board is in place to allow Northerners and Indigenous people a direct voice in the program. Their role involves providing information and advice to the Minister of INAC to help direct the program to ensure people receive its full benefits. It is worth noting that board members serve as volunteers and do not act as representatives of any particular organization, area, or special interest. In order to better understand the role, participants want them to take in the future of the program; the following question was asked:

What role should the NNC Advisory Board play in terms of outreach, engagement, and communications?

The following is a list of observations provided by participants:

• In general, there was little or no awareness of the NNC Advisory Board, particularly in newly eligible communities.
• Those who were aware of the NNC Advisory Board felt that their continued, and active, involvement was necessary.
• NNC should provide a follow-up on the recommendations of the 2012 report of the NNC Advisory Board.
• There should be broader geographical representation of the NNC Advisory Board, including currently unrepresented areas such as Nunavut and northern Ontario.
• The NNC Advisory Board should have a greater role in providing oversight and advocacy for Northerners and Indigenous people, including the ability to enact change.
• The NNC Advisory Board should be independent, acting in the best interest of Northerners and Indigenous people, and not have to promote the program.
• The selection criteria should be open and transparent, and ensure the necessary experience and expertise.
• There should be Indigenous people on the NNC Advisory Board.
• There should be efforts to increase the NNC Advisory Board visibility, including completing additional community visits, which would have the bi-annual meetings take place in eligible communities across the country on a revolving basis, whenever possible.
• There are some feelings of INACcessibility to reach members of the NNC Advisory Board, with many participants not knowing how to reach them.
• There is interest in better understanding how people can apply to be on the NNC Advisory Board, including the appointment process and criteria.

9.1 Develop new program objectives

A number of participants felt there was a need to expand and restate the program objectives, as noted in the Improving Transparency section. The current goal of the program "to make nutritious foods more accessible and more affordable for Northerners and Indigenous people who do not have year-round land or water transportation links to supply centres" was seen as too narrow and restrictive.

The following comments were heard:

• The program should address overall food security in the North which includes, but is not restricted to, accessibility and affordability. This also involved a recognition that Northerners have the same right to access affordable food as Southerners.
• The program, and its objectives, should recognize and address the affordability of food in context to income as well as the price of food.
• The program should be aligned/linked to the new National Food Policy being developed by Agriculture Canada.
• The program should recognize and respond to Canada's human rights obligations, under various United Nations charters and covenants including: Article 11 of International Covenant on Economic, Social and Cultural Rights; and Articles 20 and 26 UN Declaration on the Rights of Indigenous Peoples.
• The program should expand beyond nutrition to supporting healthy living (i.e. lifestyle), including personal hygiene products, infant products, and household cleaning products.
• The focus should be on communities, and those groups and individuals living within them, rather than on just reducing the price of food alone, in respect to the people seeking to afford eating healthy perishables in the North.
• Local food production should be tied to community economic development.
• The program should support specific community initiatives, such as school meal programs, soup kitchens, and food banks.
• The program should recognize the health benefits of country/traditional foods and support their harvesting, transport, and consumption.
• The program should support the values of a sharing system for food, particularly for country/traditional food, rather than a market economy.
• The program should develop clear performance targets and metrics on food costs to assess its efficiency and effectiveness against the stated program objectives.
• INAC, in its best effort, should ensure that the program be or become sustainable, including maintaining its current funding while also developing sustainable practices in support of food security in eligible communities.

9.2 Develop new program model

There was a great deal of feedback in changing the existing program model, ranging from minor tweaks to wholesale restructuring. The following represent some of the ideas that Interis | BDO heard:

• The program should be flexible to each community, not "one size fits all".
• The program should be innovative, with innovation coming from local communities supported by additional research on northern food security (see section on Need for New Research and Strategies later in this section).
• Many people wanted a new standalone program for country/traditional food, although, some wanted an expanded version within NNC.
• Some participants wanted the program to include "more than food", including investment in harvesting, hunting and fishing equipment, greenhouses, community freezers, as well as income support and additional nutrition education programs.
• There was support for exploring community-based models or social enterprise.^{Footnote 8}
• Some supported a multi-channel program, including:
  • subsidies on food (nutritious, culturally appropriate, etc.)
  • subsidies for individuals to ship country/traditional food to relatives
  • support to local production (greenhouses, community gardens, hydroponics, grow tunnels, etc.)
  • support to harvesting country/traditional foods
  • community infrastructure (freezers, food processing units, etc.)
  • support to community programs (school meals, soup kitchens, elders, etc.)
  • provide nutrition education.^{Footnote 9}

9.3 Develop new program design

Interis | BDO heard comments on both the design of the current program as well as the design of a new program model. Many of these comments also appear in other sections of this report.

Specifically, Interis | BDO heard a number of comments in the areas of food costs and competition, transportation, waste and spoilage, new program components, and new program links.

9.4 New management and governance structure

Some participants felt that the current management and governance structure of the program had to be amended when looking at any changes in the program objectives, model, and design. One participant stated:

"This program feels like it was designed by Southerners… Northerners should be consulted".

In terms of the management and governance structures of a future program, Interis | BDO heard the following:

• The program should reflect a "whole-of-government" approach, and leverage partnership opportunities amongst various levels of government.
• Other departments such as Transport Canada and Agriculture and Agri-Food Canada should have greater involvement.
• Establish a management and decision making governance body that would give Northerners and Indigenous people more say in the program.
• There should be a greater role for and broader geographical representation on the NNC Advisory Board.
• A working group should be formed to look at northern food accessibility and affordability.
• There should be consideration to implement and support community advisory committees consisting of community members to provide information on and collect feedback for the program.
• Relocate the administration of the program to the North, or have regionally-based employees. This includes ensuring that there is Indigenous staff working for the program.
• There should be greater coordination between INAC and HC/PHAC on determining the allocation of funding.
• Eliminate the involvement of the CFIA in country/traditional food (seen as barrier).
• There should be better policy alignment and support for local agricultural initiatives.
• There should be more direct regulation of food suppliers.
• Set a minimum quality on food being transported to the North by the program, and provide oversight that it is being met.

9.5 Increase program budget

Despite the fact that participants were advised that NNC must remain in budget, which did expand as of October 1, 2016, most still felt that the budget of the program should be increased further. Some participants also provided ideas on where additional money could be found to increase the program budget.

There was a broad range of opinion raised by participants as to how much the cost of food in the North should be affected as a result of the program. These comments ranged from equalizing to the cost of food in the South, or comparable to the nearest non-isolated centre.

Specifically, with respect to increasing program budget, Interis | BDO heard:

• The program requires more than $80 million a year to address food security in the North. Participants could not determine what the overall cost might be for eliminating food insecurity altogether in the North.
• Take political action to redistribute benefits from the South to the North, such as applying a sugar tax and using the proceeds to offset food insecurity.
• Investigate partnerships with private sector organizations (as exemplified by the NWAC/PEKE partnership with Colgate Palmolive).

9.6 Redesign the program model

Interis | BDO received many comments on the existing subsidy and how it could or should be redesigned. The following subsections outline key comments made by participants.

Specifically, Interis | BDO heard a number of comments in the areas of changing the current subsidy model, modifying the current subsidy model, capping retailer profits, changing the calculation of the subsidy, and improving the subsidy calculation process. There was no consensus from participants on their preference for redesigning the program model, however, Interis | BDO received many suggestions noted below.

9.7 Need for new research and strategies

Some participants felt that an improved program should be supported by new research, and that it should be part of broader government strategies.

Specifically, Interis | BDO heard the following:

• A new nutrition strategy for Canada should be developed by the Government of Canada.
• A national food security strategy should be developed for Canada, as well as food security strategies for individual regions and communities.
• Northern food security should be looked at more broadly, including the economics of the northern retail system and the fragility of northern air transportation (including competition, risk, economies of scale, start-up costs, investment costs, costs of regulation, infrastructure costs, etc.).
• More research is required on northern family profiles to get a better understanding of family purchasing patterns and preferences. Specifically, there is a need to develop models for what families on certain budgets can afford.
• Research and test other models for food security in remote communities, including:
  • Australian and New Zealand models of food distribution focused on smaller and more remote Indigenous communities
  • Greenland model that more effectively enables people to be access country/traditional food directly through local markets
  • Greenland model of utilizing state-owned stores in small villages and highly regulated stores in larger communities
  • European models (e.g. Sweden, Norway) of using Permanent Standing Offers where carriers bid on routes to northern communities and the government determines who will service which routes and whether they will be subsidized
  • farmers' market concept (e.g. Fort Albany) where community members coordinate the bulk purchase and sale of healthy perishables
  • programs utilizing food stamps for low income households, such as the Alaska Food Stamp Program
• Review and expand the RNFB to better reflect what Northerners consume (including more Indigenous foods) and the size of northern families.
• Evaluate the Nunavut Food Guide (which some participants indicated had been well received) in consideration of the eligibility list.
• Consider alternative methods of transportation, including modern airships that could significantly reduce the cost of food in the North.
• Support independent research by cooperating with researchers to access the necessary tools and data, including funding research completed by others.
• Consider new technologies and processes to support greenhouses, gardening, and other agricultural production in northern communities (including hydroponics).
• Evaluate programs to help raise livestock in isolated communities.
• Investigate new technologies and equipment for northern food processing, including mobile country/traditional food processing units.
• Study the differences between a sharing economy and a market economy.
• Develop an inventory of food banks and other relevant food security related initiatives.
• Set up a national food program for students.
• Develop and promote a breastfeeding strategy.
• Consider nationalizing food distribution.
• Consider nationalizing air transportation in the North.
• Encourage and utilize community-based innovation by actively engaging communities and its members.
• Develop a system to share best practices and lessons learned.

9.8 New nutrition education initiatives

While the HC/PHAC nutrition education initiatives under are generally well received, there was often a lack of awareness of these programs in certain communities. Participants suggested a variety of improvements to the nutrition education initiatives.

Specifically, Interis | BDO heard:

• More nutrition education and awareness of existing initiatives was desired in many communities, tailored to the individual community.

"Education makes a huge difference in increasing the consumption of healthy food within the community"

• There should be multi-year funding for nutrition education.
• The nutrition education delivered under NNC should be integrated with other nutrition and health-related programs, particularly for diabetes and the treatment of cancer.
• Nutrition education should be provided on:
  • how to access healthy foods
  • how to eat healthily on a certain budget
  • when to buy seasonal foods
• There should be more courses on food preparation for both store-bought foods and country/traditional food.
• Promote healthy products in-store through appropriate signage and/or store layout.
• There should be more food demonstrations in the stores.
• Nutrition education should be provided on how to prepare big meals (more efficient use of food).
• Cooking and healthy eating should be taught in the schools.
• More nutrition education should be provided on breastfeeding.
• Nutrition education should be provided on community gardening and other local production initiatives.

Commercially prepared food

Food that is prepared and distributed by food manufacturers, and that individuals typically buy in a store. This food can be fresh, frozen, raw, or cooked, and is usually pre-packaged.

Country food

Food obtained through local hunting, fishing or harvesting. Examples include caribou, ptarmigan, seal, Arctic char, shellfish, and berries.

Country food processors/distributors

Government-regulated establishments that produce country food approved for export and are located in a community eligible for a subsidy under the program.

Direct orders

Individuals and certain institutions (for example, schools and daycares) in eligible communities are able to buy eligible subsidized items directly from a supplier in the South that is registered with the program and offers this service. Direct orders are often referred to as personal orders.

Eligible communities

Communities eligible for food subsidies. These communities lack year-round surface transportation.

Eligible food

Lists of the types of food which are eligible for a subsidy.

Non-food items

Items that are also eligible for a subsidy. For example, in all eligible communities, non-prescription drugs are subsidized. In Old Crow, Yukon, which rarely has access to surface transportation at any time of the year, other non-food items such as diapers, toilet paper and toothpaste are also subsidized.

Non-perishable food

Food which does not spoil quickly when stored at room temperature and has a shelf-life of more than one year. Examples include dry pasta, dehydrated vegetables, and canned fruit.

Northern retailers

Retailers who operate stores located in eligible communities and who sell eligible food. These retailers are registered as a business with the Canada Revenue Agency and have a contribution agreement with INAC to govern the funds (the subsidy) they receive under the program.

Perishable food

Food that spoils quickly especially if it is not stored at the proper temperature. Perishable food can be fresh or frozen and has a shelf-life of less than one year. Examples include meat, milk, bread, fresh vegetables, and frozen fruit.

Personal orders

See Direct orders.

Retail subsidy

An amount of money that the federal government transfers to registered northern retailers and southern suppliers in the program to help reduce the cost of perishable nutritious food in eligible isolated, northern communities.

Revised Northern Food Basket

A list of 67 food items and quantities required to nutritiously feed a family of four for one week.

Southern suppliers

Retailers and wholesalers who operate a business located in Canada but not in a community eligible for the program and who sell food that is eligible under the program. They are registered as a business with the Canada Revenue Agency and have a contribution agreement with INAC to govern the funds (the subsidy) they receive under the program. Southern suppliers provide eligible products to small northern retailers, eligible institutions, establishments and individuals living in an eligible community.

Surface transportation

Access to permanent road, rail or marine service.

Traditional food

See country food.