Manitoba Eco-Network Comments About Bill 20, The Manitoba Hydro Amendment Act & Bill 39 The Manitoba Hydro Amendment And Tax Administration And Miscellaneous Taxes Amendment Act
The Manitoba Eco-Network submitted the following written comments with respect to the Bill 20, The Manitoba Hydro Amendment Act and Bill 39, The Manitoba Hydro Amendment And Tax Administration And Miscellaneous Taxes Amendment Act which are presently being considered by the Manitoba Legislature.
Manitoba Eco-Network Comments About Bill 20, The Manitoba Hydro Amendment Act & Bill 39 The Manitoba Hydro Amendment And Tax Administration And Miscellaneous Taxes Amendment Act
April 22, 2026
Written by: James Beddome, Manitoba Eco-Network Executive Director
Thank-you to the members of the Standing Committee on Social and Economic Development for considering our comments on Bill 20, The Manitoba Hydro Amendment Act and Bill 39, The Manitoba Hydro Amendment And Tax Administration And Miscellaneous Taxes Amendment Act.
The Manitoba Eco-Network (MbEN) believes that these bills are an okay first step, but they do not go far enough. The proposed reforms should also apply to other types of projects. It is unclear why the Government chose to bring forth two separate Bills rather than a single Bill given how interrelated the two Bills are. Accordingly we are providing a combined written submission for both Bill 20 and Bill 39.
It is unclear why Bill 20 only pertains to cryptocurrency operations, but not data centres or other large power supply projects. Cryptocurrency operations, data centres, and other large power supply users all use large amounts of energy. The production of energy has ecological and social impacts. For example, hydro-electric projects in Manitoba have caused historical and ongoing impacts to Indigenous communities, flooding, mercury contamination, shoreline erosion, loss of sturgeon populations and more. The burning of fossil fuels to produce energy leads to greenhouse gas (GHG) emissions, worsening the human-caused climate crisis that we are living through and feeling the impacts of.
Cryptocurrency operations, data centres, and other large power supply users also use large amounts of water (primarily for cooling). Drawing of water from aquifers and rivers, and discharging the same also has ecological impacts. It can threaten the ground water which many Manitobans rely upon and warmed water that is discharged directly into waterways or aquifers can negatively impact species and ecosystems.
We are supportive of empowering the Cabinet to establish a curtailable power supply program that applied to customers or classes of customers who use power for cryptocurrency operations (Bill 20), but we suggest that data centres (with separate classes for AI data centres and traditional data centres) and other large power supply projects be included too.
We note that definitions for cryptocurrency operation, data centre, and large power supply project are included in Bill 39, The Manitoba Hydro Amendment And Tax Administration And Miscellaneous Taxes Amendment Act. This means there are existing definitions that could be easily incorporated into Bill 20 with amendments. For convenience the definitions are reproduced below:
“cryptocurrency operation” means, subject to the regulations, an operation that uses electronic equipment dedicated to cryptographic calculations which, in particular, serve to validate successive transactions made by users of a blockchain. (« opération de cryptomonnaie »)
“data centre” means a facility, whether free-standing or within a larger structure, that
(a) primarily contains electronic equipment
(i) used to process, store or transmit digital information, or
(ii) used for digital information for a purpose specified in the regulations or in a manner set out in the regulations; and
(b) requires a large supply of power to operate as determined under section 49.2 and the regulations under that section.
For certainty, a facility that contains a cryptocurrency operation is not a data centre. (« centre de données »)
“large power supply project” means a project, other than a cryptocurrency operation or a data centre or two or more such related projects, for which the customer makes a request for service where the request
(a) is made in respect of a use of power for a purpose prescribed by regulation;
(b) is received on or after the day this section comes into force; and
(c) requires a large supply of power to operate as determined under section 49.2 and the regulations under that section. (« projet nécessitant une fourniture d’énergie en grande quantité »)
Although these definitions are sufficient, we recommend assigning AI data centers their own separate classification, given that AI data centers tend to use more energy (depending on the size and scale) than traditional data centers. Allowing them to be in separate classes, would allow for differential curtailment programs, rates and levies accordingly. We also suggest that it be a requirement that any new cryptocurrency operation, data centre, or large power supply project be required to participate in the Curtailable Rate Program (rather than making it optional).
The Manitoba Eco-Network is supportive of imposing a levy on cryptocurrency, data centre, or large-power users (Bill 39). It is important that we ensure that large power users adequately pay for their true costs to Manitoba’s grid.
It is imperative that we prioritize our electrical energy to ensure we best maximize outcomes for society and protection of our ecosystems.
We are (wrongly) being told by this government and Manitoba Hydro that we need to spend billions to build new GHG emitting fossil gas plants or we risk not having enough energy.
Investments in demand shifting, energy efficiency, wind energy, solar energy, battery storage, and ground source heat pumps would yield much better returns.
Achieving decarbonization is going to require electricity to shift from fossil-fuels as we replace burning natural gas with ground and air source heat pumps, and further adopt electric transportation options.
Utilizing the energy that we do have for decarbonization is likewise a much better investment than building new fossil gas power plants to large power users, such as cryptocurrency and data centres.
What we need to prioritize is clear. Do we need fossil-fuel free healthy sustainable homes here in Manitoba, or more AI slop photos for the planet?
In summary, allowing for curtailment (of cryptocurrency operations only) and additional levies for large power users, cryptocurrency and data centres is an okay first step. It does allow for some more prioritization based on societal needs than is currently provided for in law. But Bill 20 would be greatly improved if it allowed for the curtailment of data centres and other large power users as well.
We also note that Bill 20 and Bill 39 will require supporting regulations, and we urge the government to put these regulations in force without delay. Experience from other jurisdictions, especially in the US, shows that it is extremely difficult to introduce regulations on data centres after they have been set up, including for curtailing electricity use during peak load events. So if Manitoba wants to actually have a shot at controlling large loads, now is the time to do it.
To ensure the full scope of environmental and social impacts are considered, MbEN also recommends that the Classes of Development Regulation under The Environment Act be amended to specifically list Data Centres as a Class 2 or 3 development, depending on the scope of water and energy use. This will ensure that data centres undergo a thorough and robust environmental impact assessment before being approved.
Thank you for considering our comments.
