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Read our submission to the Standing Committee on the Status of Women's study on Women's Shelters and Transitional Housing Our Submission to the Standing Committee on the Status of Women Re: Study on Women's Shelters and Transitional Housing In response to a call for written briefs , we submitted the letter below. June 11, 2026 Women's Space Vancouver welcomes the Committee's study on women's shelters and transitional housing. This submission focuses on the importance of maintaining accommodation that recognizes women's sex-based rights and needs, including access to female-only spaces. Women experiencing homelessness or fleeing domestic violence, sexual violence, trafficking, and exploitation are among the most vulnerable people in Canada. Many have experienced male violence, coercive control, sexual assault, and profound violations of their privacy and bodily autonomy. Some seek shelter with children who have also been affected by violence and trauma. Access to female-only accommodation is a critical component of recovery, dignity, and safety for both women and the children in their care. A significant gap in current policy discussions is the decreasing provision of female-only options within the shelter system. At one time the condition of women-only space was considered critical for all women’s shelters and transitional housing. There is no evidence that the need for this condition has changed. In some jurisdictions, women who request female-only accommodation have faced criticism, exclusion, and even allegations of discrimination. Publicly reported incidents demonstrate that some women have faced adverse consequences for requesting female-only accommodation or expressing concerns about sharing intimate shelter spaces with male individuals (no matter their identity). For example, Kristi Hanna left a Toronto women's shelter after objecting to sharing accommodation with a male resident who identified as a woman.(1) In another reported case, two women were removed from a Kelowna women’s shelter after raising concerns about sharing accommodation with a male resident who identified as a woman.(2) Women's shelters and transitional housing should not be required to give up spaces, beds, or services, for men. If other vulnerable populations require similar types of services, those should be created for those populations, and not at the cost of services for women. Forcing women to share their spaces and services with men undermines the primary purpose of women's shelters. The Committee cannot ignore the safeguarding implications of allowing men in women’s shelters and transitional housing. There have been publicly reported cases involving men identifying as women who were subsequently accused or convicted of sexual offences against vulnerable women. Examples include Christopher Hambrook (also known as Jessica Hambrook) (3), who sexually assaulted women after gaining access to women's shelters and support services; Michael Collins (also known as Mika Lin Katz)(4) ; Cody D'Entremont (also known as Desiree Anderson)(5); Shane Jacob Green (also known as Stephanie Green)(6); and Tyler Porter, who publicly described exposing his chest and a “bulge in [his] pants” in a women’s shelter.(7) The reasons for providing women-only spaces are clear and long established: safety - no one can tell or predict which men are predators; privacy – women should never have to worry about men observing them in vulnerable situations; dignity – women should be able to feel physically and psychologically safe, to heal, and to recover in an environment that does not put them at risk, given the vast majority have experienced violence and trauma at the hands of men. The lack of women-only shelters and transitional housing is creating a serious barrier for women who need to access critical services, putting women at further risk of harm, including injury or death. The recent BC Coroner’s Report illuminates the dire need to increase access to women’s shelters and the removal of any barriers. Women's Space Vancouver recommends that the Government of Canada: Recognize the importance of maintaining and expanding female-only shelter and transitional housing, ensuring safeguarding standards that prioritize the safety, privacy, and dignity of women. Collect and publish data regarding the impacts of shelter admission policies on women's safety, service utilization, occupancy rates, and outcomes. Ensure that sex and gender identity are recorded as distinct variables in data collection to ensure evidence-based policy development. Women experiencing homelessness or escaping violence deserve housing options that are safe, appropriate, and responsive to their needs. Preserving female-only spaces while expanding services for other vulnerable populations is not exclusionary. Public policy needs to recognize that different populations may have distinctly different needs and that effective public policy should seek to meet those distinct needs. We thank the Committee for the opportunity to contribute to this study. Respectfully, Kim Zander For Women’s Space Vancouver Women’s Space Vancouver works to maintain and advance women’s and girls’ sex-based rights. We advocate for women-only spaces as places for us to resist our sex-based oppression, to create culture, to participate in political organizing, and to seek safety and privacy. We assert that these spaces must be protected. References Mohamed, R. (October 18, 2024). Woman files human-rights complaint after being denied female-only shelter room. National Post. https://nationalpost.com/news/canada/kristi-hanna-human-rights-complaint-transgender-woman-toronto-shelter Van Emmerik, K. (March 10, 2017). Concerns over transgender client at Okanagan shelter. Global News. https://globalnews.ca/news/3300518/concerns-over-transgender-client-at-okanagan-shelter/ Pazzano, S. (February 26, 2014). Predator who claimed to be transgender declared dangerous offender. Toronto Sun. https://torontosun.com/2014/02/26/predator-who-claimed-to-be-transgender-declared-dangerous-offender News Staff. (January 25, 2025). Edmonton man faces additional sexual assault charges after new victims come forward. CityNews Edmonton. https://edmonton.citynews.ca/2025/01/24/edmonton-man-faces-additional-sexual-assault-charges-after-new-victims-come-forward/ Chen, D. (August 22, 2024). Acquittal for person accused of sexual assault at a Windsor women’s shelter. CBC. https://www.cbc.ca/news/canada/windsor/cody-dentremont-desiree-anderson-women-sexual-assault-1.7299486 Hunter, B. (October 18, 2022). HUNTER EXCLUSIVE: Sex offender who IDs as woman busted for shelter attack. Toronto Sun. https://torontosun.com/news/provincial/hunter-exclusive-sex-offender-who-ids-as-woman-busted-for-shelter-attack Guest contributor. (September 26, 2019). Male transgender boasts of harassing women in crisis shelter. Women Are Human. https://www.womenarehuman.com/male-transgender-boasts-of-harassing-women-in-crisis-shelter/

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Highlights and reflections from International Women’s Day 2022 events and advocacy efforts in Vancouver. International Women's Day 2022 - Letter to BC Legislative Assembly Dear Member of the Legislative Assembly, Happy International Women's Day! We are Women's Space Vancouver, writing on this important day of international solidarity for women to raise a concern with you regarding women's safety. Recently, the BC Government implemented a change to allow men or women to identify as the opposite sex (or neither) on official government documents . This change was enacted without consultation or consideration of its consequences on the safety of women. Women have good reasons to have safety concerns. In Canada, one woman dies every three days at the hands of an abuser. Rape, sexual abuse, sexual harassment and violence from men are prevalent in the daily lives of many women, particularly in the lives of Indigenous and Asian women. The government may have had good intentions, but this change in government policy has given sex offenders and predatory men a welcome mat into women's intimate spaces. The threat posed now is that any predatory male who feels entitled to women's bodies can access all spaces reserved for women by a simple self-declaration. There are solutions to ensure the safety of everyone, such as providing gender neutral as well as male and female designated washrooms. The government's change of policy is not acceptable because their effort to provide safety for some has resulted in a lack of safety for many others. We enclose our brochure outlining other problems inherent in this ill-conceived policy change that affects the rights, needs, safety and sensibilities of women. We would like to discuss this situation further and request a meeting with you at your earliest convenience. Download our brochure on Gender Self-Declaration

Tools and guidance to contact your MP or MLA about policies affecting women’s rights in Canada. Contact your BC MLA Abbotsford-South - Liberal bruce.banman.MLA@leg.bc.ca Abbotsford-Mission - NDP pam.alexis.MLA@leg.bc.ca Abbotsford-West - Liberal mike.dejong.mla@leg.bc.ca Boundary-Similkameen - NDP roly.russell.MLA@leg.bc.ca Burnaby-Deer Lake - NDP anne.kang.MLA@leg.bc.ca Burnaby-Edmonds - NDP raj.chouhan.MLA@leg.bc.ca Burnaby-Lougheed - NDP katrina.chen.MLA@leg.bc.ca Burnaby-North - NDP janet.routledge.MLA@leg.bc.ca Cariboo-Chilcotin - Liberal lorne.doerkson.MLA@leg.bc.ca Cariboo-North - Liberal coralee.oakes.MLA@leg.bc.ca Chilliwack - NDP dan.coulter.MLA@leg.bc.ca Chilliwack-Kent - NDP kelli.paddon.MLA@leg.bc.ca Columbia River-Revelstoke - Liberal doug.clovechok.MLA@leg.bc.ca Coquitlam-Burke Mountain - NDP fin.donnelly.MLA@leg.bc.ca Coquitlam-Maillardville - NDP selina.robinson.MLA@leg.bc.ca Courtenay-Comox - NDP ronna-rae.leonard.MLA@leg.bc.ca Cowichan Valley - Green sonia.furstenau.MLA@leg.bc.ca Delta-North - NDP ravi.kahlon.MLA@leg.bc.ca Delta-South - Liberal ian.paton.MLA@leg.bc.ca Esquimalt-Metchosin - NDP mitzi.dean.MLA@leg.bc.ca Fraser-Nicola - Liberal jackie.tegart.MLA@leg.bc.ca Kamloops-North Thompson - Liberal peter.milobar.MLA@leg.bc.ca Kamloops-South Thompson - Liberal todd.stone.MLA@leg.bc.ca Kelowna-Lake Country - Liberal norm.letnick.MLA@leg.bc.ca Kelowna-Mission - Liberal renee.merrifield.MLA@leg.bc.ca Kelowna-West - Liberal ben.stewart.MLA@leg.bc.ca Kootenay-East - Liberal tom.shypitka.MLA@leg.bc.ca Kootenay-West - NDP katrine.conroy.MLA@leg.bc.ca Langford-Juan de Fuca - NDP john.horgan.mla@leg.bc.ca Langley - NDP andrew.mercier.MLA@leg.bc.ca Langley-East - NDP megan.dykeman.MLA@leg.bc.ca Maple Ridge-Mission - NDP bob.deith.MLA@leg.bc.ca Maple Ridge-Pitt Meadows - NDP lisa.beare.MLA@leg.bc.ca Mid Island-Pacific Rim - NDP josie.osborne.MLA@leg.bc.ca Nanaimo - NDP sheila.malcolmson.MLA@leg.bc.ca Nanaimo-North Cowichan - NDP douglas.routley.MLA@leg.bc.ca Nechako Lakes - Liberal john.rustad.MLA@leg.bc.ca Nelson-Creston - NDP brittny.anderson.MLA@leg.bc.ca New Westminster - NDP jennifer.whiteside.MLA@leg.bc.ca North Coast - NDP jennifer.rice.MLA@leg.bc.ca North Island - NDP michele.babchuk.MLA@leg.bc.ca North Vancouver-Lonsdale - NDP bowinn.ma.MLA@leg.bc.ca North Vancouver-Seymour - NDP susie.chant.MLA@leg.bc.ca Oak Bay-Gordon Head - NDP murray.rankin.MLA@leg.bc.ca Parksville-Qualicum - NDP adam.walker.MLA@leg.bc.ca Peace River-South - Liberal mike.bernier.MLA@leg.bc.ca Peace River-North - Liberal dan.davies.MLA@leg.bc.ca Penticton - Liberal dan.ashton.MLA@leg.bc.ca Port Coquitlam - NDP mike.farnworth.MLA@leg.bc.ca Port Moody-Coquitlam - NDP rick.glumac.MLA@leg.bc.ca Powell River-Sunshine Coast - NDP nicholas.simons.MLA@leg.bc.ca Prince George-Mackenzie - Liberal mike.morris.MLA@leg.bc.ca Prince George-Valemount - Liberal shirley.bond.MLA@leg.bc.ca Richmond-North Centre - Liberal teresa.wat.MLA@leg.bc.ca Richmond-Queensborough - NDP aman.singh.MLA@leg.bc.ca Richmond-South Centre - NDP henry.yao.MLA@leg.bc.ca Richmond-Steveston - NDP kelly.greene.MLA@leg.bc.ca Saanich-North and the Islands - Green adam.olsen.MLA@leg.bc.ca Saanich-South - NDP lana.popham.MLA@leg.bc.ca Shuswap - Liberal greg.kyllo.MLA@leg.bc.ca Skeena - Liberal ellis.ross.MLA@leg.bc.ca Stikine - NDP nathan.cullen.MLA@leg.bc.ca Surrey-Cloverdale - NDP mike.starchuk.MLA@leg.bc.ca Surrey-Fleetwood - NDP jagrup.brar.MLA@leg.bc.ca Surrey-Green Timbers - NDP rachna.singh.MLA@leg.bc.ca Surrey-Guildford - NDP garry.begg.MLA@leg.bc.ca Surrey-Newton - NDP harry.bains.MLA@leg.bc.ca Surrey-Panorama - NDP jinny.sims.MLA@leg.bc.ca Surrey-South - Liberal stephanie.cadieux.MLA@leg.bc.ca Surrey-Whalley - NDP bruce.ralston.MLA@leg.bc.ca Surrey-White Rock - Liberal trevor.halford.MLA@leg.bc.ca Vancouver-Fairview - NDP george.heyman.MLA@leg.bc.ca Vancouver-False Creek - NDP brenda.bailey.MLA@leg.bc.ca Vancouver-Fraserview - NDP george.chow.MLA@leg.bc.ca Vancouver-Hastings - NDP niki.sharma.MLA@leg.bc.ca Vancouver-Kensington - NDP mable.elmore.MLA@leg.bc.ca Vancouver-Kingsway - NDP adrian.dix.MLA@leg.bc.ca Vancouver-Langara - Liberal michael.lee.MLA@leg.bc.ca Vancouver-Mount Pleasant - NDP melanie.mark.mla@leg.bc.ca Vancouver-Point Grey - NDP david.eby.MLA@leg.bc.ca Vancouver-Quilchena - Liberal andrew.wilkinson.MLA@leg.bc.ca Vancouver-West End - NDP s.chandraherbert.MLA@leg.bc.ca Vernon-Monashee - NDP harwinder.sandhu.MLA@leg.bc.ca Victoria-Beacon Hill - NDP grace.lore.MLA@leg.bc.ca Victoria-Swan Lake - NDP rob.fleming.MLA@leg.bc.ca West Vancouver-Capilano - Liberal karin.kirkpatrick.MLA@leg.bc.ca West Vancouver-Sea to Sky - Liberal jordan.sturdy.MLA@leg.bc.ca Contact your BC MP Abbotsford - Conservative ed.fast@parl.gc.ca Burnaby-North Seymour - Liberal Terry.Beech@parl.gc.ca Burnaby-South - NDP Jagmeet.Singh@parl.gc.ca Cariboo-Prince George - Conservative Todd.Doherty@parl.gc.ca Central Okanagan-Similkameen-Nicola - Conservative Dan.Albas@parl.gc.ca Chilliwack-Hope - Conservative Mark.Strahl@parl.gc.ca Cloverdale-Langley City - Conservative tamara.jansen@parl.gc.ca Coquitlam-Port Coquitlam - Liberal Ron.McKinnon@parl.gc.ca Courtenay-Alberni - NDP Gord.Johns@parl.gc.ca Cowichan-Malahat-Langford - NDP Alistair.MacGregor@parl.gc.ca Delta - Liberal Carla.Qualtrough@parl.gc.ca Esquimalt-Saanich-Sooke - NDP Randall.Garrison@parl.gc.ca Fleetwood-Port Kells - Liberal Ken.Hardie@parl.gc.ca Kamloops-Thompson Caribo o - Conservative cathy.mcleod@parl.gc.ca Kelowna-Lake Country - Conservative Tracy.Gray@parl.gc.ca Kootenay-Columbia - Conservative Rob.Morrison@parl.gc.ca Langley-Aldergrove - Conservative Tako.VanPopta@parl.gc.ca Mission-Matsqui-Fraser Canyon - Conservative Brad.Vis@parl.gc.ca Nanaimo-Ladysmith - Green Party Paul.Manly@parl.gc.ca New Westminster-Burnaby - NDP peter.julian@parl.gc.ca North Island-Powell River - NDP Rachel.Blaney@parl.gc.ca North Okanagan-Shuswap - Conservative Mel.Arnold@parl.gc.ca North Vancouver - Liberal Jonathan.Wilkinson@parl.gc.ca Pitt Meadows-Maple Ridge - Conservative Marc.Dalton@parl.gc.ca Port Moody-Coquitlam - Conservative Nelly.Shin@parl.gc.ca Prince George-Peace River-Northern Rockies - Conservative Bob.Zimmer@parl.gc.ca Richmond-Centre - Conservative alice.wong@parl.gc.ca Saanich-Gulf Islands - Green Party Elizabeth.May@parl.gc.ca Skeena-Bulkley Valley - NDP Taylor.Bachrach@parl.gc.ca South Okanagan-West Kootenay - NDP Richard.Cannings@parl.gc.ca South Surrey-White Rock - Conservative kerry-lynne.findlay@parl.gc.ca Steveston-Richmond East - Conservative Kenny.Chiu@parl.gc.ca Surrey-Centre - Liberal Randeep.Sarai@parl.gc.ca Surrey-Newton - Liberal Sukh.Dhaliwal@parl.gc.ca Vancouver-Centre - Liberal hedy.fry@parl.gc.ca Vancouver-East - NDP Jenny.Kwan@parl.gc.ca Vancouver-Granville - Independent Jody.Wilson-Raybould@parl.gc.ca Vancouver-Kingsway - NDP don.davies@parl.gc.ca Vancouver-Quadra - Liberal joyce.murray@parl.gc.ca Vancouver-South - Liberal Harjit.Sajjan@parl.gc.ca Victoria - NDP Laurel.Collins@parl.gc.ca West Vancouver-Sunshine Coast-Sea to Sky - Liberal Patrick.Weiler@parl.gc.ca

Read our letter addressing concerns about Bill C-6 and its implications for law, language, and safeguarding. Our Letter to the House of Commons Standing Committee on Justice and Human Rights Regarding Bill C-6 Please use any part of this letter for your own use. Dear Members of Parliament, It is unfortunate that Bill C-6 conflates lots of good research and medical statements on the harms of conversion therapy related to sexual orientation with treatment of gender dysphoria. As a supporter of the bill, you appear to be unaware of the potential harm of Bill C-6 to prevent people with gender dysphoria, particularly young people, from getting the psychotherapy help they need before they proceed to irreversible and lifelong medical intervention. Please read this just-published article carefully critiquing the dishonest and politically-motivated research that is now widely cited purporting to support “affirmative care” for people presenting with gender dysphoria as the only option . One Size Does Not Fit All: In Support of Psychotherapy for Gender Dysphoria (Oct 2020) The caveat in Bill C-6 that "These new offences would not criminalize private conversations in which personal views on sexual orientation, sexual feelings or gender identity are expressed such as where teachers, school counsellors, pastoral counsellors, faith leaders, doctors, mental health professionals, friends or family members provide affirming support to persons struggling with their sexual orientation, sexual feelings, or gender identity,” is unclear. In the current political context, where therapists who did or do not immediately “affirm” a child or youth who is questioning their gender identity fear they will be or have been fired (reference Dr. Kenneth Zucker in Toronto), this is no assurance that they will not be accused of “transphobia” for providing the kind of careful psychological therapy many patients need. The politicized singular focus on “affirming therapy” is a gross disservice to children and youth who need thoughtful, evidence-based treatment for their distress. In many cases they need to be supported to accept their homosexuality, or bisexuality, which is still stigmatized, rather than be put on a path to lifelong medicalization as transgender. Yes, there are still religious groups and others who are homophobic. Yes, conversion therapy as it is properly understood — trying to change a person’s sexual orientation — is unacceptable and deserving of a prohibition. In the government’s news release the links to evidence of the need for this legislation are mostly about homosexuality — yet gender identity is included in this bill at a time when the debate over appropriate treatment for the increasing number of youth presenting as gender dysphoric is polarized, ill-informed and highly politicized. I urge you to read this article and think carefully about amending the bill to either remove gender identity or more specifically insert an assurance that medical practitioners will not be subject to spurious and intrusive accusations of providing ‘conversion therapy’ when they are not. The authors argue, "We believe that exploratory psychotherapy that is neither “affirmation” nor “conversion” should be the first-line treatment for all young people with GD, potentially reducing the need for invasive and irreversible medical procedures. This is especially critical now, when we are witnessing an exponential rise in the incidence of young people with GD who have diverse and complex mental health presentations and require careful assessment and treatment planning.” This clause in the bill’s preamble is also problematic: “Whereas conversion therapy causes harm to society because, among other things, it is based on and propagates myths and stereotypes about sexual orientation and gender identity, including the myth that a person’s sexual orientation and gender identity can and ought to be changed ;” This is inconsistent with the reality that many young people explore different gender identities over time and can decide to change to something new or to detransition. You owe it to the young people of this country to do no harm to them. In reviewing this bill, please call in medical professionals on all sides of this issue and create a safe space for dialogue to inform your decision. In your zeal to protect the human rights and dignity of all people, please don’t shy away from examining unintended consequences. Additional recommended reading: Submission on Bill C-6 from homosexual and bisexual Canadians Some excerpts: "With Bill C-6, gender therapy will become the primary form of gay conversion therapy in Canada. The Bill as currently drafted prevents therapists from making good-faith inquiries about whether gender dysphoria could actually be rooted in a negative reaction to same-sex attraction. Someone struggling with internalized homophobia won’t be aware of, or will deny, this fact. But the threat of criminal prosecution at the hands of homophobic parents or distressed clients will have a chilling effect on therapists’ ability to provide appropriate, culturally competent, gay-positive therapy to help clients struggling with their sexuality.” “Personal testimonials from our members demonstrate the profound consequences of not treating some of the mental health issues that commonly accompany gender dysphoria, including sexual abuse, bullying, bipolar disorder, schizoaffective disorder, and more. Therapists need to be able to assess and apply the appropriate treatment intervention for their clients without risking criminal prosecution.” "The definition of conversion therapy in this Bill is clear in allowing invasive transition-related medical interventions to continue with no limits on how young the child might be." Also: Letter to Justice Minister re Bill C6 (Conversion Therapy)

Analysis of Statistics Canada’s gender definitions and implications for data, policy, and women’s rights. Submission Letter to Statistics Canada on the Definition of Gender of a Person Public Consultation Please use any part of this letter for your own use. March 12, 2021 To whom it may concern: Please accept the following submission in response to proposed updates to the standard on gender of a person. This letter is submitted on behalf of the undersigned. As this submission also speaks to the Government of Canada’s government-wide directive to default to the collection of information on gender rather than sex [1] we copy the Prime Minister’s office on this correspondence. We recognize the challenges facing Statistics Canada regarding the task of collecting data on the expanding number of individual identities related to gender and we believe that is important to do so. For example, in the upcoming census, questions related to the number and demographic characteristics of those who self-identify as trans or non-binary or something else are important in understanding the scope of this social and cultural change. We appreciate the larger context of the Government of Canada’s direction to prioritize collecting gender rather than sex data (in most instances). However, this presents a further political complication illustrated well by Statistics Canada’s text in the preamble to this consultation. We agree with Statistics Canada’s explanatory text that "Gender is a complex subject with various cultural and international conceptions. Furthermore, this concept is strongly affected by ongoing social change and, as a result, is constantly evolving.” We also agree that “Some people may not identify…. with the concept of gender as a whole.” While gender identity is protected in human rights law it is not a requirement that all Canadians perceive themselves to have a gender identity – this is particularly true given the concept is constantly evolving. In the same way, the right to be protected from discrimination based on religion does not require everyone to hold a religious belief. Demanding Canadians define themselves using the vocabulary of a particular belief system would be a violation of an individual’s right to hold their own beliefs. Sex, as in the sex of a person, defined by government is also a protected characteristic along with other immutable characteristics. Equality rights set out in section 15 of the Canadian Charter of Rights and Freedoms are clear: “Section 15 of the Charter makes it clear that every individual in Canada – regardless of race, religion, national or ethnic origin, colour, sex, age or physical or mental disability – is to be treated with the same respect, dignity and consideration. This means that governments must not discriminate on any of these grounds in its laws or programs.”[2] As Statistics Canada has noted, sex and gender are different concepts. Using government’s definitions of sex and gender, if a person identifies as simultaneously male and female, for example, then the concepts of sex and gender are surely not at all related. But it appears that Statistics Canada’s approach to calculating the number of trans/non-binary/other identifying individuals in the upcoming census is to contrast answers to gender to that of sex. Since the definition of gender is constantly evolving, it is unclear what the answer to sex is really being contrasted against. Simultaneously, gender identity-related terminology like "cisgender", “sex at birth” and "sex assigned at birth" have crept into questions about sex at Statistics Canada and throughout government. Using gender-identity related language in questions where sex is the central inquiry poses the real problem of obfuscating sex in data and subsequently in public policy. At best data will be inaccurate at worst it is a violation of women’s sex-based rights set out in the Charter. Additionally, we know many Canadians are not aware that the government defines "sex" and "gender" differently and so in answering questions related to "gender” will assume it is a synonym for "sex". Other Canadians likely hold conflicting definitions or simply do not find gender identity to be a relatable concept. Recommendations: Statistics Canada should ensure it is inclusive of all Canadians and use neutral, broadly understood terminology that is consistent with the way most people understand themselves – male or female. For the purposes of gathering data about social and cultural trends, greater clarity is needed in the definition of gender to make it clear that questions about gender are gathering responses about personal beliefs and not to be conflated with a person’s sex. Noting it is a characteristic protected from discrimination, sex should not be subordinate to or conflated with gender identity in data collection. With respect to the upcoming census, Statistics Canada should consider treating gender identity as a cultural or metaphysical belief and asked as a direct question independent from questions about sex. We appreciate that it may seem we have gone beyond the scope of this consultation but our concerns encompass and go beyond this year’s or next year’s definition of gender. We assert that as long as sex and the definition(s) of gender are understood by government as inter-related, the gathering of data, and provision of services in keeping with Charter protections will be fraught with complications. Thank you for your consideration. Signatories: Women's Human Rights Campaign (WHRC) Women’s Space Vancouver About Us: Women's Human Rights Campaign (WHRC) is a group of volunteer women from across the globe dedicated to protecting women's sex-based rights. Our volunteers include academics, writers, organizers, activists, and health practitioners, and aim to represent the total breadth of the human female experience. The Canadian Chapter of the Women’s Human Rights Campaign launched on October 24, 2020. Women’s Space Vancouver is a collective of Vancouver-based feminists formed to protect women’s sex-based rights GBA + Applying the concepts of sex and gender Government of Canada, Guide to the Canadian Charter of Rights and Freedoms

Analysis related to the Office of the Correctional Investigator and policies affecting female inmates. Our Letter to the Office of the Correctional Investigator Please use any part of this letter for your own use. December 12, 2020 Dr. Ivan Zinger Office of the Correctional Investigator P.O. Box 3421, Station "D" Ottawa ON K1P 6L4 Dear Mr. Zinger, Re: Issues Affecting the Safety of Federally Sentenced Women We would like to make a complaint on behalf of all federally sentenced women in Canada. We have seen documentation that shows that there have been numerous allegations of sexual assaults by trans-identifying males in women’s prisons since the implementation of Interim Policy Bulletin 584 in 2017. We know the sexual assault of women in prison by trans identifying males has been a concern in other countries. This is not a new or uncommon problem. Many women in Canadian prisons are survivors of sexual assault, and many of them aboriginal women. The idea that they are being imprisoned with men, especially those known to be predators of women, seems like a form of torture. Women who have been caught in the justice system surely deserve safety and adherence to their human rights during their periods of incarceration. We request a national external review of the policies and practices allowing trans-identified male prisoners – who are often violent offenders -- to serve their sentences in women’s prisons. We request a moratorium on all transfers from men’s prisons to women’s prisons until it can be confirmed – if it can be – that female prisoners are not at increased risk. One of our members already wrote a letter to Deputy Commissioner Connidis but received only a formulaic response from her office. We are applying to you for justice for Canadian women prisoners. Attached are a number or links to references to help elaborate on our concerns. We look forward to hearing from you. Respectfully, Women’s Space Vancouver CC: Shawn Bayes, CEO - Shawn.Bayes@elizabethfry.com Bill Blair, Minister of Public Safety - Bill.Blair@parl.gc.ca Honorable Jack Harris - Jack.Harris@parl.gc.ca Honorable Shannon Stubbs - Shannon.Stubbs@parl.gc.ca Honorable Erin O’Toole - Erin.OToole@parl.gc.ca Honorable Jagmeet Singh - Jagmeet.Singh@parl.gc.ca Honorable Don Davies - d on.davies@parl.gc.ca Honorable Justin Trudeau - justin.trudeau@parl.gc.ca References: Women are Human: Violent Male Offenders are Being Transferred to Women’s Prisons in Canada Steve Mehlenbacher - Transgender Inmate Charged with Sexual Assault at a Women’s Prison Michael Williams convicted of first degree murder, kidnapping and sexual assault in relation to the 2005 murder and rape of 13 year old indigenous girl in Edmonton AB. As of January 2020 he is in segregation at Kent awaiting transfer to FVI (Fraser Valley Institute women’s prison) 33344 King Rd, Abbotsford, BC V2S 6J5. Child rapist ‘having the time of his life’ preparing for women’s prison after claiming to be trans HUNTER: 'Psychopathic' child sex killer uses trans card Appeal denied of Edmonton man convicted of murdering 13-year-old Nina Courtepatte Grisly video of slain teen draws tears in courtroom Matthew (Madylin Rebecca) Harks (multiple convictions, including three convictions of sexual assault against girls under eight years of age). Imprisoned at Grand Valley Institution for Women (GVI) 1575 Homer Watson Blvd, Kitchener, ON N2P 2C5, Canada Violent male convicts claiming to be ‘trans’ are terrorizing women in all-female Canadian jails Patrick (Tara) Pearsall (17 counts of sexual assault and 17 counts of sexual exploitation of a person with a disability, also been charged with failure to comply with probation) imprisoned at Vanier Centre for Women, 655 Martin St., Box 1040, Milton, ON L9T 5E6. Patrick “Tara” Pearsall (Canada) Man facing 34 charges after disabled woman lured online Patrick Pearsall. Tara Pearsall. Pathological liar either way Jean Paul (Fallon) Aubee (charged with first degree murder) imprisoned at Fraser Valley Institute women’s prison, 33344 King Rd, Abbotsford, BC V2S 6J5. Transgender inmate in B.C. wins right to move to a federal prison for women Inmate wins Transfer to Women's Prison In historic 1st, transgender inmate wins transfer to women's prison Adam Laboucan (Tara Desousa) (Dangerous offender, dangerous sexual offender, murdered (drowned) and raped a baby, confessed to murdering a three-year old child) imprisoned at Fraser Valley Institute women’s prison, 33344 King Rd, Abbotsford, BC V2S 6J5. Country's youngest dangerous offender to remain behind bars, says parole board A dangerous offender? Supreme Court of Canada R. v. Laboucan (A.F.), (1999) 23 B.C.T.C. 41 (SC) Youngest dangerous offender gets DD breast implants John (Jamie) Boulachanis (First degree murder). January 2020, requesting transfer to either Joliette Institution for Women 400 Rue Marsolais, Joliette, QC J6E 8V4 or Grand Valley Institution for Women (GVI) 1575 Homer Watson Blvd, Kitchener, ON N2P 2C5, Canada Boulachanis found guilty of first-degree murder after two decades of escape attempts, hiding and intimidation Killer Boulachanis demands transfer to penitentiary for women Crown admits mistake in handing accused murderer a list of witnesses — including addresses John Boulachanis, accused of murder, appeared to have slept with victim's wife shortly after slaying

Response to positions from the BC Federation of Labour on gender identity and women’s rights. Our letter to the BC Federation of Labour Please use any part of this letter for your own use. February 11, 2021 Dear Member of the Women & Gender Rights Standing Committee, BC Federation of Labour Feminist organizations in BC are concerned to learn that the BC Federation of Labour has adopted a resolution calling for the recognition of prostitution as work, for the decriminalization of prostitution, and for protections for this work under the law. This resolution is contrary to the 2014 law called for by feminist organizations across Canada. Bill C-36, the Protection of Communities and Exploited Persons Act, decriminalizes the sale of sex in most instances. It is the first law in Canada to govern prostitution in a manner consistent with Equality Rights, particularly those of women, as guaranteed by the Canadian Charter of Rights and Freedoms. As noted in the Preamble to the law it is “important to protect human dignity and the equality of all Canadians by discouraging prostitution, which has disproportionate impact on women and children”(1) and “it is important to denounce and prohibit the purchase of sexual services because it creates a demand for prostitution”. Versions of this law, often referred as the Nordic Model, have been called for by feminists around the world and have been adopted by progressive pro-women’s equality and pro-labour governments in Sweden, Norway, France, and Ireland. It is notable to us that these facts are absent in your Policy on Sex Work. As a result, we wonder whose criminalization you truly intend to repeal. While feminists are glad that women are no longer being criminalized for men’s pimping and purchasing of sexual access to women, we do not agree that these men should be equally decriminalized through repeal of our current law. Such a move would amount to de facto legalization of prostitution in Canada, a situation that in other countries has led to the proliferation of the prostitution industry, of the number of women who are prostituted, and of violence against women in prostitution. Many progressives are quick to claim that “sex work is work”. However, feminists, particularly those who have exited prostitution and who have worked on the frontlines in women’s anti-violence and legal advocacy organizations, know that prostitution is not a job. Most of the people in prostitution worldwide (approximately 40 million according to SPACE International) are women and girls. Women enter prostitution at young ages with approximately 50% entering prostitution before the age of majority in their countries, including in Canada. Most women who enter prostitution do so under conditions of poverty, incest, other forms of sexual assault, and racism. Women of colour and Indigenous women are vastly over-represented in prostitution. One third of the victims of serial killer Robert Pickton were Indigenous women. Vancouver Rape Relief found that among their callers in prostitution Indigenous women made up 27% and Black women made 14%. This is 9 times and 12 times more than their representation in the female population of Greater Vancouver respectively.(2) Once in prostitution, it is extremely difficult to leave, given few exiting services or financial supports available. Vancouver Rape Relief and Women’s Shelter report that the most common requests from the women in prostitution who call them are for safe shelter and exiting support.(3) Canada’s depleted social safety net and increasingly precarious employment options, contexts that are now compounded by the global COVID-19 pandemic, are only making this problem worse for women, particularly for working class, poor, racialized, and Indigenous women. Women want to leave prostitution because it is an industry in which sexual harassment and assault are what pimps sell and johns purchase. A 2003 9-country study of violence in prostitution found that violence is the norm in prostitution globally, including in countries where it has been legalized.(4) A 2013 UN Study found that men who buy sex are also likely to commit rape. The study found that the correlation between prostitution and other forms of violence against women is that both entail men enacting their dominance over women.(5) Women do not make a living wage or experience the benefits of skill development and seniority in prostitution. Women in regimes where prostitution has been legalized, including in brothels, experience degraded work conditions and diminished autonomy over their own bodies as pimps and brothel owners compete for the business of johns, who seek to pay lower rates for more invasive and violent acts. Neither has indoor prostitution led to greater safety for women, as was noted by The Women’s Equality and Liberty Coalition in their intervention in the appeal of the acquittal of Bradley Barton for the murder of Cindy Gladue at the Supreme Court of Canada.(6) Finally, as women in prostitution age, become ill, or suffer addiction, they are pushed to the margins where they are subjected to yet more violence, more degraded conditions, and even deeper poverty. Unionization cannot fix these problems, because they are inherent in prostitution itself: when men buy and sell sexual access to women, they do so to enact their power over women. Our current law recognizes and responds to this inequality in the prostitution transaction. The more we tolerate such inequality, such as by promoting prostitution legalization, the more likely we are to see it manifest in our society. This has already been made apparent through news stories of Pornhub and its Canadian parent company, MindGeek. These companies post non-consensual and violent imagery of women for purchase. In these situations, women have little to no recourse to stop such exploitation. Legalizing prostitution will only deepen this problem. We therefore find it inappropriate that prostitution be defended as work by a union organization whose purpose is to defend the rights of workers. Protective and positive labour conditions, especially for women, include freedom from sexual harassment and assault, strong health and safety protections, above poverty wages, recognition of seniority and skill, possibility for advancement, and freedom to refuse dangerous, unequal, and unfair work. Prostitution does not and cannot meet any of these conditions. We would like to meet with you to discuss a truly progressive position on prostitution among labour unions. The law that we have in Canada currently is protective of the wellbeing of women in prostitution because it prevents prostituted women (and men and trans-identified people) from being arrested and charged for crimes committed against them. The primary problem with this law is that it not enforced. Labour unions have an important role in bringing forward internal and public discussions on the failures of enforcement, of labour conditions generally, and of our social safety net. These failures embolden men and entrap women contrary to the wellbeing and equality of all women in Canada. Unions should never stand up for the idea that sexual harassment and sexual assault are normal work conditions for women. To do so is to abrogate your role in securing worker’s rights and, especially, in protecting the rights of women. For further information and discussion on this topic, we hope you will contact us to arrange a meeting between now and March 15, 2021. Additional information can be found through the following resources: The Sex Trade – NFB film by Eve Lamont (2015) Prostitution is not a job and never will be. Here’s why. - Dana Levy Nordic Model Now Consent, Coercion, and Culpability: Is Prostitution Stigmatized Work or an Exploitive and Violent Practice Rooted in Sex, Race, and Class Inequality? Rachel Moran and Melissa Farley PhD. SPACE International (Organization of women with lived experience of the sex trade ) Regardless of whether we hear from you, we intend to pursue this matter, using public channels if necessary. Sincerely, Aboriginal Women’s Action Network Asian Women for Equality EVE (Formerly Exploited Voices now Educating) Vancouver Lesbian Collective Vancouver Rape Relief and Women’s Shelter Women’s Space Vancouver https://www.parl.ca/DocumentViewer/en/41-2/bill/C-36/royal-assent https://www.rapereliefshelter.bc.ca/photos/vancouver-rape-relief-and- women%E2%80%99s-shelter-data-prostitution https://www.rapereliefshelter.bc.ca/photos/vancouver-rape-relief-and-women%E2%80%99s-shelter-data-prostitution Farley, M., et al. (2003). “Prostitution and Trafficking in Nine Countries: An Update on Violence and Posttraumatic Stress Disorder”. Journal of Trauma Practice Vol. 2(3/4), pp. 33-74 Fulu, E., Warner, X., Miedema, S., Jewkes, R., Roselli, T. and Lang, J. (2013). Why Do SomeMen Use Violence Against Women and How Can We Prevent It? Quantitative Findings from the United Nations Multi-Country Study on Men and Violence in Asia and the Pacific. Bangkok: UNDP, UNFPA, Un Women and UNV . https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/17800/index.do

Defending freedom of expression in discussions about sex-based rights, policy, and public debate. Freedom of Expression The Issue: Enforced Language The women’s movement for equal rights has had its share of pushback over the decades. But perhaps in no recent time has the need to express ourselves and maintain our rights, in our own words, been under more threat than in this early part of the 21st century. There is a clash of rights between women’s sex-based rights and gender identity rights (both ‘protected classes’ under the Canadian Charter of Rights). Gender identity activists—backed by some Canadian academics and politicians—have created a narrative that states that any expressed concerns about our female sex-based rights and needs for things like single sex spaces for women and girls (change rooms, prisons, and spaces on sports teams), constitutes a form of ‘hate’ speech. This constant ‘shape shifting’ around the word ‘woman’, and now, the questioning of even the material reality between female and sex classes, is moving women’s hard-won rights backwards. Why does enforced language matter? Language is power, and powerful. People who wish to undo the rights women have fought for over a century, understand this and are trying to re-define—or trying to have no objective, scientific recognized definition at all--around the meaning of the word ‘woman.’ Section 2(b) of the Canadian Charter of Rights and Freedoms establishes our right to freedom of expression, on issues like gender and sex. The Supreme Court of Canada has interpreted this right in a very broad fashion. What false narratives do: Go against our Freedom of Expression rights; Attempt to shut down our ability to debate openly and express counter arguments to new ideologies, which we would base on critical thought, material reality, reason and science; At its base, attempts to strip us of our agency as Canadian women and citizens What can we do about enforced language? Women’s Space Vancouver has written a letter to the BCCDC and multiple politicians in response to the BCCDC Language Guide . We can all refuse to use the new language. We can refuse to accept it, and let people know why. We can boycott products sold by companies that use the new language and let them know why. Resources Women are human Pronouns are Rohypnol

Analysis of Canada’s 2021 Census and issues related to sex, gender, and data accuracy. Census 2021 The issue: Changes to the 2021 Census Those who fill in the 2021 Canadian Census, and by law, we must do so, will notice some troubling changes. The changes to the 2021 Census are, according to the Government website, to be in keeping with Bill C 16. ”In 2017, Bill C16 was passed in Parliament, adding gender expression and identity as protected grounds under the Canadian Human Rights Act and the Criminal Code”. The Government website goes on to explain, that when “funds were allocated to create the Centre for Gender Diversity and inclusion Statistics, “this was direction to Stats Canada to begin to gather statistics regarding gender identity. However, in the Stats Can Technical Report that gives background to the 2021 changes, Stats Canada was, from 2016 on, engaged in a proactive strategy to serve gender identity activists to fill “publicly identified” gaps. An online consultation was conducted to gather input from Canadians on the Gender, Diversity and Inclusion Statistics Hub . Also, invitations were sent out to specific LGBTQ groups soliciting suggestions for changes to the next Census. In 2018, the Treasury Board of Canada Secretariat released a Summary Report, Modernizing the Government of Canada’s Sex and Gender Information Practices . There are some troubling descriptions and expectations as to how the Canadian Government will define and treat the categories of sex and gender that lead to conflating the two categories and/or privileging gender. Self-identification of gender leads to the erasure on Government documents of the category of biological sex . Why do the changes to the 2021 Census matter? The resulting changes in the next Census provide for an identification of female or male sex and an additional question on gender identity. A Citizen can identify with a gender different than the ’Sex Assigned at Birth”. Adding “gender identity” to the Census has not been publicly examined or debated in Canada. We could find no specific concerns raised by the Canadian academic community such as those raised by UK academics (the UK and Scottish 2021 Censuses will add a third option for gender identity). In an open letter published in the Sunday Times in December the UK academics said, “As social statisticians, quantitative social scientists and epidemiologists, we are concerned about the proposed online guidance to accompany the sex question which advises respondents that they may respond in terms of their self-identified gender. The guidelines “will effectively transform the sex question into one about gender identity.” The fear was that these changes would “undermine data reliability on a key demographic variable and affect the ability to measure sex-based discrimination and inequality. “The signators to the letter emphasized that “Sex and gender identity are distinct and should not be conflated.” The fears of the UK academics hold true for the upcoming Canadian Census. Feminists must become aware of the intentions of the Government to fulfill the goals of the gender identity activists to privilege gender over biological sex. Women, as a category, are being eliminated from political platforms, policy development, government action, and the justice system. The Census 2021 questions on gender identity deepen this dilemma.

Analysis and response to positions from the Canadian Centre for Policy Alternatives on women’s issues. Our Letter to the Canadian Centre for Policy Alternatives (CCPA) Please use any part of this letter for your own use. October 17, 2021 Dear Canadian Centre for Policy Alternatives, We are writing this open letter on behalf of Women’s Space Vancouver to CCPA Board Directors, Steering Committee Members and senior staff members regarding a political position recently taken by the CCPA. In June of this year, 2021, the CCPA signed onto a document called, “ An Affirmation of Feminist Principles .” Individuals and groups, by signing, indicate support for a list of “key feminist principles and their alignment with issues pertaining to sexual orientation, gender identity, gender expression and sex characteristics.” As several members of our group are decades long sex-based rights advocates and are also contributors to the CCPA, we are very concerned about the position the CCPA has taken to “align with issues” that leave out the issues of discrimination against women based on their sex. By signing the document, you have taken a position in support of changing Canadian laws to legalize prostitution, that drastic experimental and physical interventions on the bodies of children and teens seeking help with gender dysphoria is not to be questioned and, even more disturbing, that the CCPA agrees that “sex, gender and sexuality are social constructs like race, class and caste.” Does the CCPA actually agree that biological sex is a social construct? Does the CCPA believe that race is a social construct? Does the CCPA believe that homosexuality is a social construct? Is the CCPA not convinced by massive global UN data that women are an oppressed class, based on their immutable sex? Has the CCPA forgotten that patriarchy around the world oppresses, terrorizes and murders women and girls based on their biological sex, a reality they cannot identify out of or deconstruct? The CCPA is a highly respected organization that has gained the trust of many Canadians for the high quality of research done, for the depth of coverage you provide on issues of social and economic importance to Canadians. The Institute describes itself as “an independent, non-partisan research institute concerned with issues of social, economic and environmental justice.” However, by signing this document, which is clearly a statement of gender credibility. For this reason, we ask that the CCPA withdraw its endorsement of the Affirmation of Feminist Principles. We suggest that the CCPA do some research into the money supporting the gender ideology movement worldwide and the money several of these “philanthropists” stand to make through their pharmaceutical interests. Ask who benefits when children are convinced they need to become medical patients for life in order to be their “true selves.” Homophobia runs rampant when children are told they “must be affirmed as the opposite sex” because they do not “identify” with the stereotypes ascribed to their birth sex. In order for the CCPA to live up to its reputation for independence, we challenge you to provide space in the Monitor for the expression of alternate points of view on the issues of trans rights in relation to sex-based rights, laws regarding prostitution, and the consequences of irreversible medical interventions promoted for children who may identify with the opposite sex or with stereotypes associated with the opposite sex. Finally, the CCPA has signed a statement that includes this: “We recognize that there is no common human experience, including in the experience of gender.” Women’s Space Vancouver regards this as a dystopian, neoliberal fallacy that undermines the solidarity of shared experience in the workplace, home and communities, among women and men, across national boundaries and among the oppressed. We look forward to your response so that we may share it with our members. Sincerely, Women’s Space Vancouver These letters have been written by allies in support of our actions. They have allowed us to share them here. Please feel free to use the content of these letters for your own submissions. CCPA re: An Affirmation of Feminist Principles To Whom it may concern, I am cancelling my monthly donation to the CCPA. As a radical feminist, I no longer believe that the CCPA is committed to working toward equality for all women. When the CCPA signed the document called, “An Affirmation of Feminist Principles,” you signed on to a statement that seeks to change Canadian laws to legalize prostitution, that supports experimental interventions to sterilize children and teens and you agree that sex, gender and sexuality are social constructs. You have become advocates for and proponents of Gender Identity Ideology, that conflates sex and gender, privileges gender over sex, ignores human biology, says we are born with an internal gender, and that makes the sex based category, women, meaningless, thereby undermining women’s protected sex based rights as stated in the Charter of Rights and Freedoms. The CCPA would have shown an intent to address the category women, an oppressed class, if you had instead signed onto the Convention on the Elimination of all Forms of Discrimination against Women (CEDAW) adopted by the United Nations General Assembly on 18 December 1979. In the recent BCSOLUTIONS Shanon Daub writes to celebrate 25 years of research for hope and change. What is missing from the list of struggles she says the CCPA is committed to addressing, is any mention of sexism, misogyny or the Patriarchy. I am sorry to withdraw financial support from the CCPA. As a long time supporter, and, who has made a portion of my estate willed to the CCPA, I will instead donate to organizations that I know support women’s sex based rights. I find untenable that the CCPA has signed on to an Ideology that undermines these rights. CCPA re: An Affirmation of Feminist Principles Dear Shannon Daub and the BC office, I was a dedicated supporter of the CCPA. I worked with teachers in Burnaby (as union President) in 1996-98 to become members of the CCPA just as the BC office was getting off the ground. I am a monthly supporter and attended many fundraisers over the years. I have included a substantial donation to you in my will. But my disappointment with your endorsation of the document, “Affirmation of Feminist Principles” has brought me to a new understanding of how far you have strayed from being a research organization. Your silence regarding the letter from Women's Space Vancouver was truly disappointing. Surely I thought, if they are going to sign a letter that denies the existence of sex based rights, they will have a rationale or some research that seeks to justify this action. Nothing. I understand it is a strategic response in a world that now punishes anyone who questions gender ideology. Powerful forces have aligned to make it impossible for organizations like the CCPA to raise questions or examine actual research that might identify problems with gender identity ideology or prostitution as a normalized form of work. You must conform or be attacked as transphobic or uncaring of women’s safety. Sometimes our work and our positions take courage. I am truly sorry that you have chosen the least line of resistance. I have been here before. The political left had huge problems when women asserted their rights to address their oppression and not just that of the working class as a whole. Once again, women are being told that someone else’s rights, needs and sensibilities are more important than ours and we must adjust to a new reality—sex is just a social construct—gender is the more modern approach. The worst part is that my “research” organization has now told me that too. So I choose to assert my sex based rights because understanding my own oppression in a capitalist world is how I understand racism, homophobia, colonization and class oppression. I can’t be a progressive feminist on the political left and accept your under researched position that panders to a fragile hold on reality and barely masquerades as analysis. You do good work in many areas. But in this instance, you cross a line—a core value—that means I can no longer support you. Please stop my monthly payments and membership. I will amend my will soon.