Eco-Network Comments on National Strategy Respecting Environmental Racism and Environmental Justice
On December 12, 2025 the Manitoba Eco-Network (MbEN) provided comments on the on the development of the National Strategy Respecting Environmental Racism and Environmental Justice being conducted by Environment and Climate Change Canada (ECCC).
Over the past three years, MbEN has been working with community members in Manitoba to encourage governments at all levels (federal, provincial, and municipal) to enact meaningful legal
and policy changes that will better protect disproportionately impacted populations from negative and health consequences and improve their access to environmental justice.
The following comments reflect the past input we provided to the implementation team for the right to a healthy environment framework through written comments, meetings, and a local
consultation event held by MbEN on March 27, 2024. More information and the recording of the event can be accessed here.
Through collaborative projects, MbEN has also received considerable input from Manitobans on the need for more access to environmental legal tools, plain language legal information, and more
opportunity for meaningful public engagement. The feedback provided in this submission also reflects this previous work:
● Empowering Impact Assessment Project
● Healthy Environment, Healthy Neighbourhood Project
● Navigating the Law to Project the Environment Project
● MbEN engagement in the parliamentary process for Bill S-5
MbEN’s comments can be read useing the links below.
MbEN Comments Foundation 1
MbEN Comments Foundation 2
Summary:
●Little to no acknowledgement nationally of environmental racism in Manitoba in a number of contexts – e.g., drinking water, hydroelectric developments, forestry, and mining.
- In Manitoba, some of the most significant examples of environmental racism involve the past and ongoing impacts of hydroelectric developments on Indigenous communities and access to clean drinking water. This includes the sourcing of Winnipeg’s drinking water from Shoal Lake First Nation #40 territory with no regard for the significant and detrimental impacts this would have on local Indigenous rights-holders.
●Meaningful engagement with the communities who have experienced environmental racism to determine the full scope of information and appropriate methods required to meaningfully document their experiences is required.
●Dissappointing that information provided in the engagement materials did not reflect a comprehensive understanding or definition or environmental justice. It is particularly troubling that restorative justice is not explicitly acknowledged as an important component and outcome of environmental justice. This limited definition of environmental justice does not align with the feedback we’ve received from Manitobans, as environmental justice was understood to have a broad, encompassing meaning. This broader understanding reflects the need to move away from anthropocentric governance models and capture a more holistic approach to environmental protection.
●The proposed vision is acceptable and seems to reflect the expectations of the public in terms of the potential outcomes of the Strategy and other federal efforts to improve access to environmental justice in Canada. However, MbEN finds the proposed principles weak and/or too narrowly focused. The principles and priorities should reflect the growing body of literature and legal standards associated with environmental justice and the right to a clean, healthy, and sustainable environment both in Canada and at the international level.
●There is also a need for environmental protection measures to reflect an eco-centric approach – the environment should be protected for its own sake, not just for the benefit of humans. The National Strategy’s approach to environmental justice should go beyond the protection of humans and include broader considerations of ecosystem health and the protection of natural entities and animals. The National Strategy should also encourage respect for nature and acknowledge the sacred role of the environment in many cultures and communities.
● The National Strategy should meet a higher standard than “inclusive” participation, a term that has no practical meaning. We recommend updating this principle to instead reflect the standard of “meaningful public participation” For example, see the research memo on Meaningful Public Participation in IA produced by MbEN and our partner organizations as part of a recent impact assessment reform project.
●There are a range of other principles that could be adopted to support the interpretation and application of the National Strategy, such as Intergeneration Equity, and Non-Regression.
More information about the background documents can be found below.
