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Our Letter to the Vancouver Board of Parks and Recreation

Please use any part of this letter for your own use.


February 28, 2021

Donnie Rosa, General Manager 

Vancouver Board of Parks and Recreation

and the Vancouver Park Board

Dear Parks Board:


Re: Vancouver Park Board decision to open all washroom and change facilities to “Gender Diverse” people


We are writing on behalf of Women’s Space Vancouver.  We are an organization whose mission is to protect and enhance the sex-based rights of women, including their right to safe female-only public spaces. We note that such spaces are increasingly threatened and/or altered by governing boards seeking to include those who self identify as the opposite sex, be they transgender, gender fluid, or “gender diverse”. Many attempts at being inclusive have denied women’s participation, autonomy and safety in public life. Threatened spaces include bathrooms and change rooms, transition houses and women’s organizing centres. We are writing you to express our concerns about Vancouver Park Board’s plans to change single-sex (women and men) change rooms and bathrooms into mixed-sex spaces.


We are concerned about the following:

The process of “creating inclusive toilets and change rooms” in community centres was and is anti-democratic and anti-woman in violation of human rights and your  goals for the parks board.(1) According to the Vancouver Parks Board 2014 TGVI report,(2) you conducted a community survey comprising 3 (of 33) community centres and fewer than 150 individual participants.  This is hardly an adequate sample of community centre participants to take such a big decision to remove single-sex spaces for women.  The Park Board has a legislated responsibility to provide adequate sex-segregated toilets and change rooms. 


A document produced in June of 2018,,declaring that Park Board facilities would become safer and more inclusive, did not mention women, females or sex as categories requiring extra protections.  The designation of washrooms as mixed sex spaces (“gender diverse” or “gender neutral”) contravenes the BC Human Rights code prohibiting discrimination on the basis of sex, ignoring women’s distinct needs, including privacy from men.


Mixed sex toilets violate the principles of United Nations guidance. Sex segregation is presented as a priority in achieving equality for women, especially in developing countries:

  • Paragraph 2.1.2 of the UNICEF document on applying the UN Sustainable Development Goals (especially SDG 6) to sanitation specifies that separate school toilets should always be provided for girls (UNICEF, 2016).

  • The United Nations Report on The Human Right to Safe Drinking Water and Sanitation states that sex-specific toilets should be provided, especially in schools, where privacy to deal with menstruation is a major factor in determining whether girls continue their education (Albuquerque and Roaf, 2012, pp 35, 153-4).


Some Islamic, Hindu, and Orthodox Jewish women are forbidden to share intimate areas with male strangers, especially when menstruating.  In the interests of the inclusion of ‘diverse genders’ the City of Vancouver has excluded the needs and human rights of women including those women whose religious beliefs and practices won’t be respected.


Women have distinctly different needs than men.

Women have well established distinctly different needs than men. Female needs include dealing with menstruation, menopause, pregnancy, breastfeeding and caring for babies, children and elderly female relatives, all of which require the need for privacy from male observation. Separate cubicles do not resolve the need to have private space to deal with these matters.  The breadth of need for the above examples do not require just a toilet, or just a change space.  They are often dealt with in safe open space in front of other women.


Women require more time and space (booths take up more room than urinals) in washrooms and change facilities.  We do not have access to toilets in the numbers proportionate to that need.  The inevitable line up outside women’s washrooms, when there is little or no line up for the men’s, is evidence of the difference in needs.  There are already about one third fewer facilities for women than for men.


The answer to this deficit is to provide more room for women in sex-segregated facilities and provide separate facilities for those who do not want to use the facilities designated for their sex, be they “gender diverse” or uncomfortable for other reasons. The answer is not to sacrifice women’s needs and protected spaces to address the needs of other groups.


Welcoming “gender diverse” people into women’s bathrooms and change facilities leaves women vulnerable to all males, whether they self-id as women or not. 

Women in distress can find privacy and safety in the women’s washroom.  Women sometimes use the washroom to get away from predatory men or men pursuing a woman they wish to control. If a woman fleeing a man is able to go into the women’s washroom and be guaranteed to be away from men, she can have a moment’s reprieve, access a phone unmonitored, and ask for assistance from other women. 


If anyone can declare they identify as a woman to qualify as “gender diverse”, then any man can do so and enter women’s washrooms without being questioned.  This safe space will no longer be available if men can access all facilities for women.  According to many accounts on social media, the safe space of a women-only washroom is already no longer an option for women, as a result of this “gender diverse” inclusion.


This not only puts women at risk, but keeps women on high alert.  They can no longer feel at ease in the women’s facilities.  They will not know the motivation of a male-bodied person entering the washroom or change room.  Regardless of motive, many women have had experiences that justify their caution around men, especially in intimate spaces.  This is the antithesis of protecting the dignity and safety of women.  It puts them at risk of harassment and violence.


In order to adhere to the goals of the 2014 Park Board report, significantly retrofitted public washrooms will cost millions.  Such retrofitting will still leave women vulnerable and without privacy. 

It has already been shown in other jurisdictions that when males are invited into female facilities, the traditional knee-to-shoulder barriers are not sufficient for privacy, safety and dignity. They are an invitation to voyeurism, illicit filming and sexual harassment. Whether these stalls have floor to ceiling walls and doors with secure locks, the reality that they open to a shared, mixed-sex washing up area continues to violate women’s needs, as noted above. Women’s bodies and bodily functions, and those of children and aging female parents, are exposed in this area.  Women and girls will not have dignified space for privacy or safety.


Again, the answer is not to compromise safe, private space for women and girls in order to meet the needs of other populations. As noted above, separate facilities for those who are not comfortable using the facilities designated for their sex, or even for further privacy of any special need, is a far better answer and where Park Board money should be channeled.


In conclusion, we urge the Vancouver Park Board to respectfully consider the safety and privacy of all those who use the parks and recreation facilities in Vancouver. Special attention must be paid to including women, who have historically been disadvantaged and under-served by our recreation and parks facilities. In 2014, the Park Board promised discrete space for men, women and transgender or ‘gender diverse’ people, and have yet to adequately provide anything more than signage which results in compromising, or at worst, dismissing and eliminating, the needs and rights of women and girls. Though this may have been an unintended consequence, we must demand that this sexist and dangerous situation be corrected. We ask that you carry out a more democratic and inclusive consultation by consulting with women’s organizations about any changes to washroom and change facilities.

Thank you for your attention.

  1. A core value of the Park Board is the desire to create welcoming parks and recreation services for all. That’s why we are committed to improving the safety and inclusiveness of our spaces through programming, education, activities, events, and enhanced park design. 

  2. April 17, 2014 Vancouver Parks Board, “trans and Gender Variant Working Group” 

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