https://bugs.winehq.org/show_bug.cgi?id=45320
--- Comment #18 from Jason Edmeades us@edmeades.me.uk --- Glad it sorts out the problem, and thanks for the windows testing.
My gut feeling is go with what we have (so char** array doesn't point to them but they are actually in the space allocated for the environ but not referenceable unless you walk the environ explicitly) until we find an app that will care. Anyone walking the char** array wont see them, and whether there are gaps or not seems an implementation detail not exposed to the user through normal API means.