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Lynda Gullason is an adjunct research professor at the School of Indigenous and Canadian Studies at Carleton University.

Prime Minister Justin Trudeau is a feminist, apparently. He has, after all, mandated Status of Women Canada to implement the adoption of gender-based analysis and ensure gender equity across the federal government.

But the gender-based analysis initiative is predestined – perhaps even predesigned – to fail.

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Intended to assess the potential gender-specific impacts of policies, programs, legislation and services on women and men, its critical shortcomings severely limit its utility.

To start, there are no mandatory requirements for federal departments and agencies to conduct such analysis. Only 30 out of 110 departments are even signed on to the gender-based analysis action plan – 22 years after it was initially adopted.

There is no monitoring or evaluation or reporting of the implementation and outcomes by Status of Women Canada or by the departments and agencies themselves, although SWC was required to do so after the 2009 audit.

In fact, Status of Women Canada has no authority to enforce the application of gender-based analysis and there are no consequences for departments and agencies which do not conduct it.

There is no measurement of gender equity: no data collection to analyze and correct unfair practices and policies; no baselines or targets and no performance indicators to track progress.

Departments conducting gender-based analyses are required to, but do not, propose measures to address gender inequities. The Canadian Armed Forces, for example, which has set an employment target for women of 25 per cent, has developed no employment equity strategy to achieve that target, and its actual number remains unchanged at 14 per cent.

And so it follows, there are no consequences for departments and agencies which fail to ensure gender equity.

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Auditor-General Michael Ferguson has expressed frustration with the federal government's inability to address gender discrimination, which persists despite decades of audits. Fully half of the gender-based analyses conducted by the audited departments in his 2015 report were incomplete. Yet for the incomplete analyses, these departments "nevertheless concluded" that there were no gender-specific impacts, "and they provided these conclusions to decision-makers." This is serious: because the conclusions were not supported by evidence, there is the question of "whether Cabinet had been adequately informed about existing and potential gender considerations."

In response, Status of Women Canada has plans to "explore the development of gender equality indicators," according to its statement to the Standing Committee on Status of Women last spring. "This is work that is just beginning in terms of how we are going to define success and how we are going to attract progress as we continue to monitor and report," says Meena Ballantyne, the head of the agency, in her 2016 presentation to the Public Accounts Committee. Except that the agency neither monitors nor reports, and the work should not be "just beginning" some 20 years after the principle of gender-based analysis was first accepted.

When asked at a Status of Women committee meeting how gender-based analysis is measured and how we know whether it is actually implemented, the response of the agency's gender-based analysis manager, Vaughn Charlton, was, astonishingly, "That is the million-dollar question." Status of Women Canada, she said in a written reply to the same questions, "simply does not collect this type of information."

Moreover, the agency's plan to develop an evaluation strategy will actually measure and report on the agency's progress in implementing gender-based analysis, rather than the progress made in correcting gender discrimination. And that evaluation of its own performance won't even be completed until 2020, 25 years after such analysis was introduced.

The fundamental goal of gender-based analysis must actually be gender equity. And that is only achieved when discriminatory policies and practices are corrected.

Thirty-four years after Justice Rosalie Abella wrote in her 1984 Report of the Commission on Equality in Employment that, "Equality in employment will not happen unless we make it happen"; 22 years after gender-based analysis was first adopted by the Canadian government; eight years after the previous negative audit, and 18 months after the most recent one, there is, as the Auditor-General notes in his 2016 Fall Reports "no mandatory requirement subjecting policy, legislation and program decisions to gender-based analysis."

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A more ill-conceived approach to correcting gender discrimination is hard to imagine. No analysis, no monitoring, no evaluation, no enforcement, and no consequences: no surprise, really, that gender inequity will continue under the federal government's gender-based analysis implementation plan.

Even worse than taking no action is to claim to be correcting gender discrimination, but doing nothing of the kind.

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