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Right to a Healthy Environment Policy Intervention: Shake Up The Establishment Submitted Intersectional, Community-Centred Feedback on the Discussion Document (April 2023)

Author: Anna Huschka (she/her)

Editors: Asha Swann (she/her), Manvi Bhalla (she/her)

Cover Image Designer: Iris Molony-Everett (she/they/them/theirs)

Author’s Positionality:

My name is Anna (she/her), and I am a white settler located on the lands of the Williams Treaty First Nations - the Alderville First Nations, Beausoleil First Nation, Chippewas of Georgina Island, Chippewas of Rama, Curve Lake First Nation, Hiawatha First Nation, and Mississaugas of Scugog Island. I do not intend to speak on behalf of any communities I am not a part of. I hope to leverage my position of privilege as a cisgender white woman to amplify the efforts and voices of those doing so much work towards climate justice in their communities across the country. I want to be a part of challenging the Euro-settler-centric and Western values that currently shape climate policies, to counteract colonial and systemic barriers, ensuring that the concerns, exposures, and knowledges of diverse communities are adequately incorporated into the implementation framework. I hope to do work that addresses systemic acts of environmental racism that disproportionately expose BIPOC communities to environmental harms. What is currently Canada is home to a bounty of natural resources, including accounting for 7% of the world’s renewable freshwater (1). Despite having so much, freshwater is not accessible to many communities, especially marginalized communities who have had their freshwater sources actively polluted by the disproportionate placement of industrial facilities, landfills, and other exposures. As of January 2024 there are still 28 boil water advisories in place for 26 Indigenous communities (2). This is just one example of environmental injustice happening across the country. It is vital that the Right to a Healthy Environment Implementation Framework is shaped so that marginalized communities do not continue to bear the brunt of environmental burdens as a result of systemic exposures in their communities, including the places they live and work. I hope that by contributing to Shake Up The Establishment’s feedback on the right to a healthy environment, that I can help identify key gaps in the government’s approach and obtain access to a healthy and thriving environment for all.

As a part of amendments to the Canadian Environmental Protection Act (CEPA) in June 2023, “every individual in Canada has a right to a healthy environment” (3). As a part of this commitment, the federal government has until June 2025 to explicitly define what exactly the right to a healthy environment (RTHE) is going to look like, and how the government will implement it (3). The Government of Canada recently held a consultation period on a discussion document. The feedback collected will be used to shape the Right to a Healthy Environment Implementation Framework, of which the first draft is expected to be released in Fall 2024, followed by a secondary consultation period (4). 

You can learn more about how you can get involved in further stages of the development of the right to a healthy environment here.

Executive Summary of Our Feedback

Shake Up The Establishment led the research, writing, and community-engagement processes that shaped the policy feedback we submitted to the federal government on April 8, 2024.  Our report was also endorsed by six youth-centred, community-serving organizations from across what is currently Canada: 

We endorsed the Women’s Healthy Environment Network’s feedback, which was also crafted using an intersectional feminist lens alongside their teams’ legal expertise on environmental and commercial exposures to toxins. 

Shake Up The Establishment’s feedback report was split into three key sections: 

  1. Feedback on the contents of the government’s discussion document, including wording choices, framing, and key gaps, as identified by members of our team

  2. Community responses to government-identified discussion questions, collected via a Jamboard and Google form

  3. Formal recommendations to the government indicating the changes we would like to see included in the implementation framework

Shake Up The Establishment’s Key Recommendations

  1. We ask that the government use clearer wording choices that reflect a stronger commitment to upholding RTHE and better indicate their intentions with RTHE’s implementation and scope of protection. 

  2. The government must maintain continuous engagement with the communities most disproportionately impacted, not only in improving access to consultation processes but also in providing them with linguistically accessible, culturally competent information for their unique environmental health needs to increase informed decision-making, agency and resiliency. 

  3. The government needs to be more ambitious in developing an intersectional, justice-based approach to the implementation of RTHE to ensure they are protecting everyone’s right to a healthy environment, and that they do not unduly limit the scope due to known issues with environmental hazard mitigation, such as jurisdictional ambiguity, or other excuses that privilege some groups (e.g., white, Anglo-Euro settler cisgender heterosexual men) to the detriment or underservice of other groups. 

  4. The government needs to better incorporate Indigenous leadership, Indigenous Knowledge Systems, as well as other ethno-culturally diverse ancestral, traditional, embodied, and community-based knowledges, into the implementation of the right to a healthy environment in a manner that does not unduly tokenize, invalidate or perpetuate harm through extractive processes in the design, use and inclusion of these forms of expertise. 

  5. The government must explicitly design and implement immediate resources to support research that helps to fill existing research gaps and more effectively address community-identified environmental health needs of minoritized, marginalized and underserved communities. 

  6. There is a need for significant adjustment to the management cycle being implemented under CEPA to better align with equity-centred, community-based needs and priorities. 

Policy Brief: Shake Up The Establishment’s Feedback on the Right to a Healthy Environment Discussion Document

By Shake Up The Establishment, April 8th, 2024

Authors: Manvi Bhalla (she/her), Anna Huschka (she/her), Zeina Seaifan (she/her), Nadine Ivanov (she/her), Aarisha Haider (she/her), Tolu Amuwo (she/her)

Discussion Document Feedback for RTHE_SUTE_Apr 8 2024
Download PDF • 968KB

If you have any questions or concerns, please email 


  1. Canada E and CC. Water: frequently asked questions [Internet]. Canada: Environment and Climate Change Canada; [modified 2018 Aug 13; cited 2024 Apr 12]. Available from:

  2. Indigenous Services Canada. Ending long-term drinking water advisories [Internet]. Canada: Indigenous Services Canada; [modified 2024 Jan 25; cited 2024 Apr 12]. Available from:

  3. Canada E and CC. A Right to a Healthy Environment under the Canadian Environmental Protection Act [Internet]. Canada: Environment and Climate Change Canada; [modified 2024 Feb 08; cited 2024 Apr 12] Available from:  

  4. Government of Canada. Right to a Healthy Environment under the Canadian Environmental Protection Act [Internet]. Canada: Government of Canada; [modified Aug 11th, 2023; cited 2024 Apr 12]. Available from:

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