Dear Christopher,
On behalf of the National Indigenous Economic Development Board (NIEDB), please accept this letter as a formal response to the Additions To Reserve Policy Reform and Modernization Consultation during our February 13th virtual board meeting.
As you know, the NIEDB has always advocated for a faster and more efficient ATR process that supports First Nations in building their land base to grow economic prosperity. The Board has published three reports on ATRs:
We begin by affirming that we stand by our reports and the recommendations within. We were pleased to see the latter report included in the literature review for the ATR reform thus far, but we urge for the others to also be examined and incorporated in your process.
As discussed in our consultation, the ATR process is often delayed because of:
Although seemingly unrelated to the ATR process, financial statement audits provide the First Nation with critical information and insight into the sources of their revenue which is essential to understand the state of a community’s financial health and where to make improvements.1 Evidence of good financial health improves the confidence that possible lenders and business partners have in the First Nation, improving the First Nation’s ability to utilize and benefit economically from these partnerships.2
A First Nation’s good standing with lenders and businesses can be beneficial for the use of new ATR lands for economic growth. As set out in our report Additions to Reserves: Lessons Learned from First Nations, ATR lands can be an asset for economic growth for First Nation communities through the generation of own-source revenue, such as through taxes or commercial leases, or with the collection of profit from community owned and operated businesses. Non-Indigenous owned businesses on the reserve land, in addition to revenue from commercial leases, can also provide job opportunities for community members.3
This connection was drawn in our 2014 report, Identifying Success Factors in Urban Nations, in which all six First Nations interviewed identified good governance and the confidence this provides investors and development partners as a key factor to their community’s successful economic development. Four of the six First Nation’s interviewed identified own-source revenue as a key factor as well.4 The work of the First Nation Financial Management Board and their ”Roadmap” is also critical to building financial capacity in those communities undergoing the ATR process.
In response to the lack of land surveyors and financial auditors, the Board views this as an avenue for government investment to assist young Indigenous people in getting into these areas of work.
We therefore recommend the government support the initiatives suggested by the National Aboriginal Land Managers Association (NALMA) and the First Nation Tax Commission for training and institutional supports for the development of First Nations Auditors, Tax Assessors and Land Surveyors. Perhaps the Aboriginal Finance Officers Association could also play a role in building this capacity. The Board views investments in these initiatives is needed to provide career paths for Indigenous youth and improve the availability of scarse services that are inhibiting First Nations from accessing and benefiting from ATRs.
Increased capacity is required at both the community level and the government level to speed up the ATR process and the idea of an ATR Institute of Excellence. This vision aligns with the NIES Call to Economic Prosperity #46: the creation of an “Indigenous Centre of Excellence for Land Management” to which current government programming is devolved. This Centre will develop and manage an Indigenous Lands Registry. The NIES has a vision of Indigenous communities having the capacity, resources and rights to govern the use and development of their lands, which in this context involves Indigenous management and development of ATRs through a designated institute.5
NALMA is an organization that provides tools and resources to its members that support and promote best practices in First Nation land management.6 The Board therefore recommends supporting the expansion of NALMA’s mandate to undertake the role of this ATR Institute which will be more efficient as these employees already have expertise in land management. This would be a quick and easy change that would advance First Nation economic reconciliation.
Other Board recommendations include:
These recommendations, as well as those put forth in the NIEDB’s three ATR reports must be considered in the ATR Policy reform and modernization. It is long overdue for the slow and inefficient process to be streamlined and better supported to ensure all First Nations can successfully navigate the ATR process
and reap the economic benefits additional land parcels provide.
Thank you again for meeting with us Christopher, and for considering these recommendations. Because of our keen interest in these important issues, we ask to remain engaged throughout the policy reform process. Therefore, we look forward to a continued dialogue on this matter.
Sincerely,
Dawn Madahbee Leach
Chairperson
National Indigenous Economic Development Board
Cc: ATR Policy Redesign Consultation