Blog: Environmental Justice a Key Pillar in National Adaptation Strategy

By Mathie Smith, Law Student

This summer has seen heart-breaking and devastating impacts from the climate crisis on low-income communities across the country. These impacts will only worsen unless there is immediate action to curtail greenhouse gas emissions. CELA is committed to ensuring that plans to adapt to the climate crisis focus on the communities most impacted.

The Government of Canada released the final version of the National Adaptation Strategy (“the Strategy”) in June 2023 after consultation with provinces, territories, municipalities, Indigenous groups, and the public. The Strategy is Canada’s national blueprint for reducing risks associated with the impacts of climate change.

The final Strategy identifies action plans to achieve near-term targets, medium-term objectives, and long-term goals. Some of them are as follows:

  • By 2025, 50% of Canadians have taken concrete actions to better prepare for and respond to climate change risks facing their household
  • By 2026, 80% of health regions will have implemented evidence-based adaptation measures to protect health from extreme heat
  • By 2030, consideration of health impacts and benefits are integrated into key climate change tools, guidelines, and standards
  • By 2040, deaths due to extreme heatwaves have been eliminated

CELA’s Recommendations

CELA provided several recommendations during July 2022 and urged the Ministry to establish concrete objectives in the Strategy. CELA also included recommendations such as calling for the Strategy to place an emphasis on environmental justice, for it to use data-driven strategies to track climate action, and for approaching budgets, emergency planning, and project funding through low-income lenses. This blog looks at whether those recommendations have been included in the final strategy.

A. Environmental Justice

The Strategy indicates that adaptation efforts must act to advance environmental justice. It acknowledges that vulnerable communities are often the least equipped to deal with climate disasters and they also bear the brunt of the effects. The Strategy also recognizes that First Nations, Inuit, and Métis communities experience climate change impacts in unique and serious ways. The effects of climate change in these communities are compounded by the impacts of historic and ongoing traumas they have and continue to experience. CELA is thrilled that the Strategy incorporates environmental justice as a guiding principle and the themes of equity and inclusion are prevalent throughout.

B. Data-driven approaches to track climate action and equity

Tools that enhance the knowledge and understanding of the effectiveness of newly implemented climate change risk mitigation measures are an essential part of measuring the success of the Strategy. Informed decision-making surrounding climate risks is an important part of risk mitigation planning at local, provincial, and national levels.

C. Implementation of Low-Income Barrier Studies

CELA previously recommended the use of Low-Income Barrier Studies. They are mandated in California through the Senate’s Bill 350 and are used to identify issues facing communities on a local scale. They are studies that would be beneficial for enhancing the understanding of the challenges communities in Canada will face. The Strategy makes no mention of the implementation of these studies as an aid in creating community-specific response plans. CELA continues to recommend low-income barrier studies as it allows for a nuanced understanding of issues facing communities in implementing climate adaptation measures.

D. The Adaptation Strategy Fails to Allocate Funding for Projects in Low-income Communities

While the Strategy appropriately acknowledges that climate change events and disasters amplify existing vulnerabilities and inequalities, it does not target funding to those communities to ensure they are able to participate in government adaptation programs.

The Strategy identifies members of certain communities, such as those who live with health conditions, disabilities, the very young or very old, Black, Indigenous, Racialized and 2SLGBTQI+, as those that are likely to experience more severe impacts from climate change. Importantly, the Strategy recognizes that underserved and marginalized populations have “limited capacity and resources to prepare for climate change”. These same groups are more likely to live in places with higher exposure to climate risks, such as in areas that are prone to flooding or buildings with limited cooling options during heat waves. However, without targeted funding, existing inequalities are likely to be exacerbated and the identified communities will not be able to access adaptation funding.

CELA submitted that the Strategy should implement the goal of directing at least 40% of federal climate investments to vulnerable communities. This goal is inspired by actions taken by several governments across the United States. CELA recommends immediate implementation of a targeted funding approach to ensure vulnerable communities do not fall further behind. The actions taken in California and Delaware should be used as a template for execution.

E. Intersection of the environment and health

The Strategy identifies five interconnected approaches which outline a path to a more resilient Canada, one of which pertains directly to health and well-being. Under this pillar, the Strategy identifies the goal of ensuring that all people in Canada are safeguarded and supported by an adaptive healthcare sector that can “account for and support the diverse components of well-being”.

CELA supports the Strategy’s focus on identifying ways to ensure climate change adaptation measures are inclusive for people with disabilities. It is imperative that the needs of persons with disabilities are accounted for and that intersectional perspectives are considered during the design phase of future programs and initiatives. The Strategy indicates that Canada’s disaster preparedness and climate change adaptation plans are in alignment with the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) and the Accessible Canada Act. The Strategy follows the “Nothing Without Us” principle and compliments national and provincial climate response plans specifically designed for those with disabilities.

F. Government of Canada Adaptation Action Plan

The final strategy is accompanied by an updated Government of Canada Adaptation Action Plan (“Plan”). The Plan includes funding from Budget 2023 to support work to achieve the targets, objectives, and goals laid out in the Strategy. It includes 73 actions, compared to 68 in the original report, that further federal contributions to achieving Canada’s climate change risk mitigation goals.

In the spring of 2023, Budget 2023 announced several investments intended to enhance adaptation efforts. Examples of programs that offer funding are below.

  • Disaster Mitigation and Adaptation Fund: The DMAF focuses on community-level resiliency to extreme events, such as flooding, wildfires, and drought, by investing in large built and natural infrastructure projects. Projects funded through DMAF complete a resilience assessment within the application process, ensuring that federal funding links to advancing climate resilience. The increase in community resilience is assessed as one of the main program criteria. It is measured by looking at if the infrastructure project will result in decreased socio-economic impacts of the exposed populations. In particular, the required Natural Hazard Risk Assessment report stresses four key indicators: loss of lives/missing people, the percentage of people directly affected, the percentage of local economic loss, and the percentage of the population without essential services. This is a program well-suited to CELA’s recommendation that 40% of funding be targeted to low-income communities, which are identified by the Strategy as less resilient to climate impacts.
  • Emergency Management Assistance Program: The EMAP exists to provide direct funding to First Nation communities to mitigate, prepare for, respond to, and recover from hazards, while also building resiliency using the four pillars of emergency management.
  • Emergency Management Public Awareness Contribution Program: This program provides funding to help vulnerable Canadians understand the risks associated with natural disasters and what can be done to prepare for and mitigate weather-related emergencies. The EMPACP helps communities to develop and maintain readiness, mitigation and recovery plans and policies that are inclusive of all populations and communities, and it helps vulnerable populations in Canada mitigate climate-related hazard risks.
  • HealthADAPT: HealthADAPT is Canada’s national health adaptation program. It was launched in 2018 to support health authorities in identifying and addressing the climate risks facing their operations and the health of the communities they serve.
  • Green Municipal Fund: The GMF exists to support a minimum of 1400 community-based climate adaptation initiatives, protecting Canadians and their communities, as well as minimizing costs associated with climate impacts. Environment and Climate Change Canada will collaborate with the Federation of Canadian Municipalities to expand and top-up the existing Green Municipal Fund (GMF). The new funding will support three broad areas of work under the GMF: adaptation planning, capacity building, and institutional mainstreaming; accelerating local-level implementation of adaptation solutions; and piloting adaptation projects to attract greater private sector participation in adaptation financing. We are pleased to see additional funding to municipalities for climate adaptation. CELA’s recommendations at the community level include adoption of maximum temperature by-law, urban tree cover targeted at low-income communities, and large-scale adoption of green roofs.

The Plan will be regularly updated as the federal government continues to make important contributions to climate resilience in Canada.


CELA is thrilled to see acknowledgment of environmental justice as a key pillar in the National Adaptation Strategy. Implementation of the Strategy should focus on targeting funds to low-income communities disproportionately burdened by climate impacts.

The next Strategy update will occur in 2030.