Angry in the Great White North

Hill & Knowlton prepared a management review of the financial position of the gun registry in April of 2004, authored by John D. McLure. That report, obtained by Conservative MP Garry Breitkreuz via an Access to Information request, and heavily blacked out, is available from his web site.

First, despite the media reports, this is not an audit. It does not meet the standards of an audit, nor does it call itself an audit. Where I come from, we call this a "risk analysis". Essentially, it outlines the possible ways forward, the pitfalls associated with each choice, and makes a recommendation. The report looks backwards into the past only inasmuch as the past can help suggest what the likelihood of certain outcomes will be. It is that look back that casts the government in such a poor light.

The report depends heavily on other reports (and lists them in detail in section 1.3). These include reports from the Auditor General, internal assessments, government-led program reviews, and other external reviews.

The report runs 40 pages, and if you are interested in this issue, I highly recommend you read it yourself. I will point out some highlights.

To start, I have no reason to doubt the quality of the work in this report. I have checked Hill & Knowlton, John D. McLure, EDS, and Team Centra through various databases, including the Lobbyist Registration Database, and I have found no evidence that Hill & Knowlton, active lobbyists though they are, ever worked for the firms who are attempting to build the gun registry.

Interestingly, the blame for the problems in the registry seem to be assigned either to people who register their firearms, or the government how is defining what the registry is supposed to do, but not with the companies doing the work (p 4):

Difficulties in the program's launch, including low levels of application by firearms owners, high rates of errors on applications, and adjustments to the program after being launched, resulted in very high development costs for the first few years.

Because of these problems, the government switched contractors. EDS and their CFIS I system would be replaced by CFIS II, developed by Team Centra. Bill C-10A (January 2003) would come into force just as the Team Centra system was ready, and everything would run smoothly then on out, since the CFIS II system would be designed on what everyone knew was going to be in C-10A.

The plans as laid out above did not come to pass. Team Centra's contract had to be substantially amended due to the complexity of the actual system requirements being greater that what had been revealed in the RFP [request for proposal], plus the legislation was not passed by Parliament as proposed, and was substantially delayed. When finally approved by both Houses of Parliament, the legislation was substantially changed from what had been specified in Team Centra's contract, resulting in the need for further multi-million dollar changes to align the new system with the legislation as passed

Details of the changes were blacked out by government censors.

The report follows this pattern. An explanation, either in general or in detail about how the government moved the target, or failed to meet a deadline, or changed its mind, and how that screwed up either EDS or Team Centra, and made the costs go up. Specific items and costs are always removed by the censors.

For instance, on page 6:

The situation of Team Centra developing a system according to Government specification, that upon completion does not align with legislation illustrates the seriousness of the disconnect.

The actual disconnect is blacked out.

The government seem determined to make things as difficult as possible for Team Centra, though they though they were encouraging creativity (p 18):

Team Centra's cost to build the CFIS II system rose during the "due dilligence" process, which revealed that the actual requirement was considerably more complex than had been estimated, based on the specification. The Government did not make all the information it had available to bidders at the time of the RFP, out of concern that too much exposure to the existing system might inhibit bidders from conceiving completely new approaches to the requirement. In particular the "use case" documentation was withheld until after the award of the contract.

For those who are not in this business, you are forgiven for not dropping your jaws at this. A "use case" is written by the person buying the system (or the person designing the system on their behalf) to show to potential bidders what the system is supposed to do. Notice that a proper "use case" does not describe how the system achieves it. The difference between what and how is huge, and the Government was correct in worrying about telling the bidders how to solve the problem, instead of just describing what the problem was. But to award a contract, and then show them what the system was supposed to do?!

Here are some concrete examples of how the legislation differed from what the contract dictated (see p 19). The contract said the licences could be renewed over the internet, but the legislation required only paper copies. The contract had a simplified renewal form, but C-10A required full forms for renewals at every renewal, including full personal histories repeated. The contract allowed for photos to be supplied at every other renewal, but C-10A required photos at every renewal. Moreover, at the time the report was written, a ministerial review was underway, so even these assertions as to what would be required by the system were suspect, and the report admitted as much.

The report goes on at length to identify more examples of the government adding new requirements, more complexity, and different measures of success. On page 29, the report is polite in its assessment:

On the basis of experience to date, it would be naive to assume the results of the current Ministerial Review, once adopted as Government policy, will necessarily be translated into enacted legislation at any particular date.

I've only scratched at the surface, but it is clear that the report constitutes a damning indictment of the inability of the government to decide what the gun registry is supposed to do, and that waffling is the core reason that the system is costing so much, and achieving so little. It is no wonder that this financial report was kept under wraps, and when grudgingly released, was heavily censored.