Shake Up The Establishment’s Feedback on the draft National Strategy Respecting Environmental Racism and Environmental Justice 2026-2031
About the Strategy.
When passed in June 2024, the National Strategy Respecting Environmental Racism and Environmental Justice Act mandated that Environment and Climate Change Canada must publish a federal strategy before the end of 2026 (1). As legislated in the Act, the Strategy had to include:
- A study of the link between race, socioeconomic status, and exposure to environmental hazards
- Measures (e.g. legislative changes, funding and programming, community consultations) for how the federal government plans to prevent and address environmental racism and advance environmental justice (1)
For more information on environmental justice in Canada and the Strategy: https://shakeuptheestab.org/2026-nej-factsheet/
Environment and Climate Change Canada published a draft Strategy Respecting Environmental Racism and Environmental Justice 2026-2031, and opened public consultations on the draft from July 26, 2026 – August 10, 2026.
Key Recommendations
Shake Up The Establishment submitted our feedback on the draft Strategy on August 10, 2026. Our submission was endorsed by four community-serving organizations – Mental Health and Climate Change Alliance, Seniors for Climate Action Now!, re-generation, and Women’s Healthy Environments Network. Shake Up The Establishment’s Submission consisted of the following recommendations:
1. Strengthen Governance, Accountability and Implementation
a) Explicitly acknowledge in the Strategy’s introduction how settler-colonialism, structural racism, and discriminatory policies have historically and continue to disproportionately harm Indigenous, and racially and ethnically-minoritized communities.
b) Commit to the principle of non-regression, grounded in the Right to a Healthy Environment under the Canadian Environmental Protection Act, 1999, and establish an Environmental Justice Advisory Board and National Environmental Justice Secretariat to oversee implementation, coordinate research, and strengthen accountability across government.
c) Require annual public accountability reports, rather than five-year reporting cycles, and ensure every Strategy commitment identifies responsible department(s), implementation timelines, measurable indicators, funding commitments, and public reporting mechanisms.
d) Develop an Environmental Justice decision-making tool, modelled on Gender-Based Analysis Plus, require environmental justice training for all federal public servants, and strengthen coordination across federal departments and all orders of government.
e) Establish a dedicated environmental justice support function to help communities navigate jurisdictional responsibilities and access the appropriate government departments, decision-making processes, and remediation pathways.
2. Advance Community Participation, Indigenous Partnership and Environmental Justice
a) Establish accessible, ongoing community engagement processes that include in-person and virtual participation, participant compensation, childcare, transportation, interpretation, technology supports, and a federal Inclusive Engagement Framework.
b) Partner with trusted community organizations through long-term funding agreements to co-design and facilitate engagement, publish all “What We Heard” reports and community partnership reports, clearly explain how community recommendations informed the Strategy, and commit to implementing existing community recommendations while continuing ongoing engagement.
c) Uphold Indigenous rights through meaningful partnership, shared decision-making, Indigenous data sovereignty, implementation of relevant UNDRIP and Truth and Reconciliation Commission commitments, and adoption of Etuaptmumk (Two-Eyed Seeing).
d) Broaden the definition of environmental racism to reflect its structural drivers, frame environmental justice through an anti-colonial and intersectional lens, add Epistemic Justice as a fifth principle, strengthen access to justice, embed the Right to a Healthy Environment throughout the Strategy, translate restorative and distributive justice into concrete accountability, remediation, reparations, and resource reallocation, and reframe the Strategy’s four guiding principles as testable standards that decisions can be measured against, rather than general aspirations.
3. Invest in Communities and Strengthen Financial Accountability
a) Establish an Environmental Reparations Fund alongside the Environmental Damages Fund, financed through penalties for high-polluting industries and dedicated to community-led remediation, recovery, healing, research, compensation, and environmental justice initiatives.
b) Open annual Environmental Damages Fund calls focused on environmental justice, establish a Community Consultation Accessibility Fund, and provide multi-year funding to community-serving organizations supporting engagement, outreach, community-led research, biomonitoring, and environmental justice programming.
c) Support workers affected by the transition away from polluting industries through retraining and employment supports, and compensate community organizations for the advocacy, education, consultation, and service delivery work they have undertaken in the absence of adequate government action.
4. Strengthen Research, Data and Evidence
a) Rewrite Part 2 of the Strategy in plain language and improve its organization, accessibility, methodological transparency, and statistical accuracy, ensuring the study states its actual findings, including which communities are most affected and the scale of inequities identified, and resolving the contradiction between claiming there is no universal data shortage and the Annex’s own acknowledgement that its methods required specialized GIS software and trained analysts.
b) Expand the study to include newcomer and immigrant communities, gender, intersectionality, cumulative and workplace exposures, historical pollution, and disaggregated racial and ethnic data, while completing the qualitative analyses originally committed to under the Act.
c) Build and maintain a publicly accessible national environmental justice database and commit to ongoing community-led biomonitoring, cumulative exposure monitoring, and intersectional environmental health research.
d) Recognize and build upon existing community-led research and mapping initiatives, ensure all conclusions are consistently supported by evidence, and disseminate findings across relevant federal departments to support a whole-of-government approach.
5. Prevent Environmental Harm and Fulfil Legislative Obligations
a) Ensure federal funding does not support projects that undermine environmental justice objectives, including committing to a phased divestment from oil, gas, and LNG, while excluding industry from environmental justice decision-making and maintaining financial accountability through penalties and reparations.
b) Require federal decision-making to assess cumulative environmental, health, and social impacts, prioritize preventing future harms alongside remediating existing environmental injustices, and include concrete measures that directly reduce environmental exposures.
c) Ensure the Strategy fulfills the requirements of the National Strategy Respecting Environmental Racism and Environmental Justice Act by including compensation measures, identifying federal legislation requiring amendment, and embedding clear, measurable implementation commitments directly within the Strategy rather than deferring them to a future action plan.
Policy Brief: Feedback for Canada’s draft National Strategy Respecting Environmental Racism and Environmental Justice 2026-2031
References
- Department of Justice. National Strategy Respecting Environmental Racism and Environmental Justice Act. Government of Canada. Updated August 6, 2026. Accessed August 10, 2026. https://lois-laws.justice.gc.ca/eng/acts/N-16.85/FullText.html


