Racism belongs on the agenda of Impact Assessment

By Debra Davidson and Ian Stewart

What kinds of questions are appropriate to ask in the context of conducting an impact assessment? If we refer to Canada’s Impact Assessment Act, which draws attention to “the environmental, health, social and economic effects of designated projects with a view to preventing certain adverse effects and fostering sustainability,” the answer to that question clearly encompasses what social scientists have identified as systemic, racialized differences in exposure to environmental harm and the capacity to defend oneself from those harms; in other words, environmental racism. 


Recently, NEDIA hosted an important webinar, in which our panelists sought to articulate the contours of environmental racism and environmental justice, and provided compelling evidence of the prevalence of environmental racism in Canada. Panelists then went on to justify the inclusion of environmental racism in impact assessment processes and offered guidance for how we might do so. Indeed, we await the potential revival of the now-defunct federal Bill C230, an Act—introduced in 2020 but which died on the floor with the latest federal elections—to support the development of a national strategy to address environmental racism in Canada. Aspects of that Bill C230 made their way in the mandate letter from the Prime Minister to the Minister of Environment and Climate Change Canada. It continues to be imperative that scholars and practitioners of impact assessment acknowledge the means by which pre-existing racialized inequities pertain to proposed new industrial development, and how those development have the potential to produce environmental racism.


What is environmental racism? One of our panelists, Professor Ingrid Waldron, Hope Chair in Peace and Health at McMaster University, describes environmental racism as the disproportionate location of environmental risks, translating into inequitable exposure within Indigenous and racialized communities, both to human compromised health and to the degradation of the ecosystems and nonhuman beings upon which communities depend. As Professor Waldron explores in her ground-breaking book and ongoing work on conditions in Nova Scotia, Environmental racism can manifest not only in conjunction with the operation of polluting facilities; it also manifests as disproportionate impacts of environmental policies that normalize inequities in contamination and cleanup. Environmental racism further encompasses the lack of political power within racialized and Indigenous communities to negotiate on behalf of the community when development decision-making occurs, in the determination of impact, and the actions taken in light of impacts; this disempowerment is exacerbated by the exclusion of members of those communities from those advisory boards, governing bodies, and environmental organizations that are influential in environmental decision-making.


Our second-panel presentation offered an in-depth case study illustration of environmental racism, and the struggles of community members to pursue environmental justice. This was presented by Sharilyn Johnston, Environmental Coordinator for Aamjiwnaang First Nation, and her collaborator Scott Grant (C&S Grant Environmental Consulting), both of whom are experts in air pollution, and who previously have worked with the Ministry of Environment in Ontario. They co-presented a detailed exposition on the plight of the Aamjiwnaang First Nation. The historic, current, and future home of the Aamjiwnaang First Nation is located on the shores of the St. Clair River and Lake Huron, within the region now known as Sarnia. Their community is also located at the epicenter of over 60 industrial facilities, some dating as far back as the 1950s, many of which have been the source of both legacy contamination, and current pollution. As a result, the Aamjiwnaang community is exposed to the cumulative effects of multiple chemical contaminants and their interactions, and face some of the worst air pollution in North America. The community has attracted international attention, with the United Nations Special Rapporteur of Human Rights and Hazardous Substances, referring in 2019 to conditions facing the Aamjiwnaang First Nation in Sarnia as “deeply unsettling.”


Despite the extraordinary costs the members of this community have paid in the form of health and ecological impacts, they and their allies have persevered, and sought to counter the enormous power imbalances they face through local mobilization. The Aamjiwnaang First Nation established an Environmental Department in 2007 and since then has taken a number of organizational steps to protect themselves, including filing numerous complaints to the companies themselves and government agencies, and have begun to engage in active air quality monitoring at the community level.


While the efforts of the community are laudable, responsibility for confronting environmental racism should not be left to affected communities alone. Environmental racism, noted Dr. Waldron, is an illness, and the only cure for such illness is environmental justice.  While not all communities in Canada experiencing environmental racism are Indigenous, many are, exemplifying the importance of environmental justice to reconciliation. As sovereign nations, Indigenous peoples have the right to uphold their own environmental protection policies and standards, including the right to withhold consent to the siting of polluting facilities. 


One important goal of the field of Impact Assessment is thus to ensure environmental justice, encompassing procedural justice, geographic justice and social justice. Any environmental policy or decision based on impact assessment must include mechanisms to ensure community-defined best practices in facility siting that respect Indigenous sovereignty, treaty rights, community priorities, Indigenous Knowledge. We cannot any longer address these issues after the fact.  And this work may require the difficult work of “puncturing Western ways of knowing,” in Waldron’s words, and also accommodating pre-existing socio-economic conditions that contribute to environmental racism. This ultimately requires that we overcome our discomfort with talking about the deeply rooted, systemic sources of racism, and colonialism, in Canada.


For further ways you can get involved, one Canadian coalition Prof. Waldron has recently helped initiate is a great place to start.

View our webinar on this topic HERE

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