Manitoba Eco-Network Comments About Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act
The Manitoba Eco-Network submitted the following written comments with respect to Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act, which is presently being considered by the Manitoba Legislature.
Manitoba Eco-Network Comments About Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act
April 22, 2026
Written by: Heather M. Fast, J.D., LL.M., MbEN Policy Advocacy Director
Thank-you to the members of the Standing Committee on Social and Economic Development for considering our comments on Bill 51, The Public Sector Artificial Intelligence and Cybersecurity Governance Act.
The Manitoba Eco-Network (MbEN) agrees that artificial intelligence (AI) systems “have the potential to be misused or to have an inequitable impact on society” (Preamble). We have been hearing many concerns from the environmental community about the increasing use of artificial intelligence systems by Government and other institutions before there is clear understanding of the impacts that AI infrastructure will have on the environment and society as a whole.
We appreciate the Government of Manitoba’s attention to this issue and work to introduce regulatory requirements for the use of AI. This is an important opportunity for Manitoba to lead the way in Canada and facilitate the development of legal protections to mitigate the growing range of potential harms that can result from irresponsible use of AI. However, the regulation of AI systems needs to go beyond its use by Government and must include robust impact assessment and regulation of the infrastructure needed to provide the computational resources necessary to run AI systems. This includes the construction of large-scale AI data centres and the high volume of energy and water resources needed to operationalize AI compute infrastructure. It is also extremely problematic that this proposed legislation is progressing before the Government’s public AI Consultation has even started, despite the announcement made in early March 2026.
Although MbEN is supportive of the development of a new provincial framework that requires “transparency, accountability, impact and risk assessments and human oversight to ensure the responsible use of technology in the public sector” (Preamble), it is currently unclear how the proposed The Public Sector Artificial Intelligence and Cybersecurity Governance Act will accomplish this. The purpose of the Act is to “govern the use of artificial intelligence systems in a transparent and accountable manner” (s 2), however, the text of Bill 51 provides little transparency in terms of what the final regulatory framework will address since most of the details about how this legislation will work, and who it will apply to, have been left to be figured out in future Regulations. There is also a lot of discretionary language contained in this Bill about what “may” or “could” be decided by Government at a later date and a lack of enforcement mechanisms, so it is also unclear how Bill 51 will ensure AI is used in an “accountable” manner. For example, there are no details about the mandatory elements of the “accountability framework” that will be required under s 4 of the Act.
MbEN’s biggest concern with Bill 51 and the Government of Manitoba’s regulatory approach to AI is the absence of provincial legal provisions that require proposed AI infrastructure developments to undergo the impact assessment and licensing process under The Environment Act or an equivalent process. Although Bill 51 makes reference to “impact and risk assessments”, there are no details about what these assessment processes will involve, nor the types of risks and impacts that will be considered. There are also no details about the potential content of the technical standards for AI use that may be adopted under the Bill. It therefore appears that Bill 51 does not recognize nor will it require consideration of the environmental and climate impacts that occur from the use of AI.
We strongly recommend the addition of language to Bill 51 that recognizes the environmental impacts that result from the use of AI systems and requires public sector entities to consider these impacts before AI tools are used. We also recommend the Government of Manitoba make corresponding regulatory amendments to facilitate the proper assessment of AI infrastructure, such as updating the Classes of Development Regulation to specifically list AI Data Centres as a Class 2 or 3 development depending on the scope of water and energy use.
MbEN is very supportive of the development of new provincial regulatory requirements to regulate the use of AI in Manitoba. However, we feel that as is, Bill 51 will not guarantee that AI is used in a responsible, transparent, or accountable manner by the Government of Manitoba. There is a lack of details and a heavy reliance on the future exercise of regulation making powers that has shifted the development of this regulatory framework from the public legislative process to behind the closed doors of Cabinet.
Overall, we feel that the Government of Manitoba should seek to minimize the use of AI unless necessary, especially when it comes to the use of generative AI tools. It is essential that we maintain human capacity within Government and ensure strong human oversight of the use of AI. Most of all, it is imperative that the Government of Manitoba not contribute to the squandering of precious water and energy resources by unnecessarily using AI when there are more than enough capable human beings available to take on the work.
Thank-you again for the consideration of these comments.
