RE: Draft Guidance on Asbestos in Drinking Water

To Whom It May Concern,

I appreciate the opportunity to participate in Health Canada’s consultation on asbestos in Canadian drinking water. This is an understudied and unregulated issue, affecting the health of thousands of citizens across the country. While the effects of inhaling asbestos
are well understood due to significant research and monitoring over time, research on the effects of oral exposure to the fibrous mineral is lacking. This is a concerning gap that needs to be addressed to ensure all Canadians can access safe drinking water—as is their right.

In finalizing guidance on asbestos in drinking water, I urge you to consider the background, health impacts, pathways to exposure, global standards, replacement and research recommendations, elaborated below.

Problem Overview
I have long advocated for action on this matter, recognizing the potential public health implications and need for proactive infrastructure management. On November 9, 2023, I tabled parliamentary petition e-4375 in the House of Commons. The petition called for urgent federal action regarding asbestos-cement (A-C) water pipes across Canada. Many of these pipes were installed between the 1940s and 1950s and have degraded significantly over time. It is estimated that approximately 14,000 kilometres of A-C pipe remain in use across the country. Roughly 20 percent of the composition of these pipes is asbestos. As deterioration continues, concerns have grown about potential fibre
release, infrastructure reliability, and the long-term safety of drinking water systems, underscoring the need for coordinated federal attention and support for replacement efforts.

Health
Protecting the health of all Canadians should be of utmost importance to the Government of Canada, particularly when dealing with substances known to lead to serious health risks. Asbestos is a known carcinogen that can ultimately lead to various forms of cancers such as liver, GI tract, bladder in addition to lung disease. Health Canada notes that the majority of animal studies on asbestos exposure demonstrate ingestion can result in cancer, and many additional studies demonstrate its cancer-causing effects in various tissues. Although the majority of research has focused on the health effects of inhaling asbestos, there is little reason to believe that ingesting asbestos in drinking water would be any less harmful to the human body.

Another significant issue includes the lack of standards or accredited laboratories in Canada that study the effects of oral exposure and digestion of asbestos in the body. Establishing clear standards for asbestos in drinking water would set limits based on particle sizes similar to other cancer-causing pollutants, such as PM2.5, which are about 2.5 microns.

Pathways to Exposure
There are multiple pathways to asbestos exposure through water systems. The thousands of kilometres of A-C pipes across Canada continuously expose Canadians to high levels of this carcinogen in drinking water. Likewise, asbestos can enter drinking water from natural sources, such as the erosion and runoff of asbestos-containing soil
and rock. It can also be introduced through human activities, including mining, as well as from the deterioration of aging asbestos-cement (A-C) pipes within drinking water distribution systems. Asbestos fibres have no detectable taste or odour, and they neither dissolve in water nor evaporate. As the thousands of kilometres of A-C pipes are at the
end of their lifespan, A-C pipes can result in costly water outages and unexpected repairs. Further, as pipes are not used regularly, a build-up of “slugs” can take place. When water flow resumes, these slugs may be released all at once, potentially resulting in higher concentrations of asbestos being consumed in a single exposure. When you have multiple points of exposure, the health risks of asbestos are amplified too.

Global Standards
In contrast to the Canadian context, since 1993, the United States Environmental Protection Agency has regulated asbestos in water. Several countries around the world, including those in the European Union (EU), have likewise implemented asbestos drinking water regulations. These countries have investigated and performed extensive
research on the impacts of ingesting asbestos fibres on the body. To that extent, the EU has urged member states to stop permitting asbestos-cement (A-C) pipes and to undertake systematic renovation efforts aimed at removing asbestos from existing drinking water distribution infrastructure. Proactive infrastructure replacement to mitigate potential long-term public health risks associated with asbestos fibre ingestion
is not progressive or innovative, it’s simply catching up. Replacement and Research Recommendations While a nation-building project focused on replacing asbestos-cement (A-C) pipes would require significant upfront investment, the long-term benefits to public health,
infrastructure reliability, and environmental safety would be substantial and should outweigh any costs. Many of these pipes are reaching the end of their life, increasing the likelihood of deterioration, breakage, and the potential release of asbestos fibres into drinking water systems. Replacing aging A-C infrastructure now would reduce these risks while strengthening the resilience and longevity of Canada’s water distribution
networks. Further, establishing laboratory methods and capacity in Canada is essential. This would allow for a full, elaborate study to be performed on the effects of ingested asbestos fibres on human health in addition to a full review of related medical literature.

Conclusion
The old water pipes in Canada must be replaced with safe alternatives. The fact that millions of Canadians are ingesting asbestos via drinking water is unacceptable. Canadians expect their government to deliver public infrastructure which supports, not erodes, their health. Replacing pipes is critical to restoring trust in this government’s ability to deliver for the best interests of citizens. Immediate action must be taken to research and regulate this national emergency. Without significant action, Canadians will continue to face health risks from aging infrastructure that has already been deemed unsafe by countries around the world.

Sincerely,

Elizabeth May, O.C.
Member of Parliament
Saanich—Gulf Islands

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RE: Public engagement on how to strengthen federal leadership in emergency management.

To whom it may concern,

I am attaching to this email the Green Party of Canada’s submission to the 2021 consultation on Canada’s National Adaptation Strategy. I am disappointed that, five years later, little action has been taken on the recommendations outlined.

Emergency management is an economic and moral imperative for Canada. Climate change-fueled disasters cost Canada billions of dollars every year. Thousands of lives have already been tragically lost. I think especially of the horrific 2021 heat dome that claimed 619 lives in my province of BC. We cannot simply prepare and respond to emergencies; we must actively work to mitigate, adapt to and prevent them. The burden can no longer fall onto municipalities: the federal government must step up.

It is absolutely shocking that the only emergency preparedness measure in Budget 2025 was $257.6 million over four years to lease four water bombers. We have experienced year after year of devastating heatwaves, wildfires, floods and other extreme weather events. This is a completely insufficient measure to meet the scale of this moment.

We need immediate action on a coordinated, cross-jurisdictional plan to respond to, rebuild from and adapt for climate disasters. We need shared decision-making tables that bring actors from different levels of government together to respond to crises. We need warning systems that can reach everyone, especially those in rural, remote and Indigenous communities. We need significantly more investment in our firefighting capacity. We need a National Recovery Strategy that quickly and fairly compensates communities for damage. We need a National Flood Insurance program to provide Canadians coverage where private insurers will not.

Now is the time to act. Thank you for your consideration of my comments.

Elizabeth May, O.C.
Member of Parliament
Saanich-Gulf Islands
Leader of the Green Party of Canada

Read the full submission here: National Adaptation Strategy Submission – GPC

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February 10, 2026

RE: Consultation on New Nuclear at Wesleyville Project

To whom it may concern,

Nuclear energy has no place in any plan to mitigate climate change when cleaner and cheaper alternatives already exist. The federal government must stop pouring billions of dollars into the nuclear industry and instead redirect investments towards smarter, proven solutions.

Nuclear fails on many grounds, including economics. Nuclear technology is capital intensive. New nuclear is already far more expensive than proven renewable energy sources like wind and solar, and there is no guarantee these nuclear experiments will ever generate electricity safely and affordably. The Darlington OPG project has already
experienced huge cost overruns and it has not yet broken ground. The price tag has soared from the initial cost estimate of $7.7 to $21 billion.

I urge that all energy investments be measured on the same set of metrics. Every investment should be assessed by asking three key questions:
1) For every dollar invested, how many tonnes of greenhouse gases              are avoided?
2) For every dollar invested, how many jobs are created?
3) What is the effective timeline from initial funding to achieving                     results?

Using these metrics, nuclear will always finish at the bottom of any hierarchy of energy investments. The winners, every time, will be investments in retrofitting buildings for energy efficiency and investments in renewable energy.

Apart from the economic argument, there remains the issue of nuclear waste. The federal government does not have an effective plan to deal with radioactive waste. The proposed Near Surface Disposal Facility in Chalk River and the Deep Geological Repository in Ignace are deeply problematic projects that have not properly consulted with affected First Nations. The true environmental and health impacts of these disposal sites have not been adequately studied, especially for the significant length of time nuclear waste remains radioactive. Canada has a legal obligation to ensure Free, Prior and Informed Consent of Indigenous people.

The 2022 World Nuclear Industry Status Report states that the development of nuclear energy is too slow to address the climate crisis. Nuclear power creates fewer jobs than renewable energy, such as solar, wind, district energy, and geothermal. These energy alternatives are cheaper, faster to deploy and more readily available. This is where
Canada should be making investments.

In the words of critic Fred Knelman, nuclear was a “future technology whose time has passed.” I urge you to stop investing in an industry whose time has passed. There are better energy alternatives for Canada to tackle the climate emergency. Canada is wasting time that must be spent urgently on genuine climate action. The federal government must redirect funding away from nuclear technology and towards renewable energy for the sake of all Canadians, and for future generations.

Thank you for your time and consideration.

Sincerely,
Elizabeth May, O.C.
Member of Parliament
Saanich-Gulf Islands
Leader of the Green Party of Canada

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February 4, 2026

RE: Deep Geological Repository Nuclear Waste Disposal Project
To whom it may concern,

I have significant concerns with the proposed Deep Geological Repository nuclear waste project in the Wabigoon Lake Ojibway Nation and Ignace.

Firstly, the structure of the Nuclear Waste Management Organization (NWMO) is unacceptable. The only decision-makers in the organization are facility owners. It is a blatant conflict of interest to mandate them to regulate themselves.

This consultation process is woefully inadequate. The Impact Assessment Agency of Canada (IAAC) and NWMO cannot expect the public to read a very long, technical brief and comment on their concerns in only a month.

I strongly urge the IAAC and NWMO to conduct a full impact assessment and panel review. More robust study is needed of environmental impacts and required mitigation measures. The environmental and health risks of nuclear waste extend far beyond the
160-year timeline of this project. The current 70-year monitoring plan is insufficient. What is the IAAC and NWMO’s plan to safely store 150,000 tonnes of highly radioactive nuclear waste for the long term? There is little information on the costs of storage, transport, infrastructure and maintenance. This responsibility cannot be left to the small host municipality to bear indefinitely.

Transport must be included in environmental assessment. The rationale for exclusion does not make sense: transport is a necessary step for the designated activity. The proposed site is over 1500 km away from the reactors in Southern Ontario and would rely on northern roads susceptible to harsh weather conditions. Moreover, at least 210
First Nations along the route could be affected by the transport of waste. Their rights to proper consultation and consent must be respected.

The proposed site at the headwaters of the Wabigoon and Turtle-Rainy River watersheds carries a high level of risk to interconnected lakes and rivers. More stringent water protection measures beyond the Clean Water Act are needed.

This project has faced pushback from many neighbouring First Nations, including from the Saugeen Ojibway First Nation, the Chippewas of Nawash, Treaty 3 chiefs, Eagle Lake First Nation and Anishinabek Nation. The repeated decision to store nuclear waste next to First Nation communities (as is the case with the Kebaowek First Nation and
Chalk River) fundamentally violates Indigenous rights. There are numerous other communities in the area who must be properly consulted: the city of Dryden, Lac Seul First Nation, Nigigoonsiminikaaning First Nation, Naotkamegwanning First Nation and others.

I echo the concerns raised by the Assembly of First Nations around the lack of transparency around the site selection process and the need for support for First Nations-led impact assessment. Much more needs to be done on local and regional consultation. The major backlash to this project from First Nations is evidence that this project has not received free, prior and informed consent.

I also raise a recommendation submitted by the Concerned Citizens of Renfrew County and Area (CCRCA). CCRCA urges the NWMO to examine the use of ramps instead of vertical shafts. Ramps are safer for evacuation and transport. They would allow easier waste monitoring and retrievability and reduce accidents.

Canada continues to invest in nuclear energy at its peril. Solar, wind, geothermal and hydroelectricity are proven solutions: magnitudes cheaper, safer and quicker to deploy than nuclear reactors. We cannot continue to make shortsighted decisions and saddle the costs – economic, health and environmental – onto future generations.
Thank you for your consideration of my comments.

Sincerely,

Elizabeth May, O.C.
Member of Parliament
Saanich-Gulf Islands
Leader of the Green Party of Canada

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RE: Review of 1999 Salmon Allocation Policy

To whom it may concern,

As the Member of Parliament for Saanich-Gulf Islands I became aware of this consultation on the Salmon Allocation Policy (SAP) through concerned constituents. As the deadline is today, I wanted to offer some thoughts. However, I want to preface this submission by noting that the consultation is clearly for those entities playing an operational role in the BC salmon fishery. It is not a conventional public consultation.

The 1999 SAP appears to have served us well. No doubt in 2026 it is clear some updates are needed. The former Minister of Fisheries, the Honourable Dominic Leblanc, made the decision in 2018 that it was time for modernization. Balancing and respecting Indigenous rights holders with the settler culture and divergent interests of sports fishers
(recreational) and commercial, all with varying degrees of priority in the conservation of five species of wild salmon is a complex and sensitive endeavor. The role of non-governmental groups specializing in science-based wild salmon conservation has been significant and valuable.

I want to commend DFO for having undertaken this exercise with caution and respect to those interests. In my own consultations with various participants in this process, I have heard praise for DFO’s work in reform of the related and complex issue of hatcheries for Chinook. Currently Chinook are plentiful due to the Chinook hatcheries in Washington
State. DFO has made real progress in reform of the hatchery policy.

The concern I want to share is that despite careful efforts from DFO to communicate the steps being taken regarding the updating of the SAP, it is clear that the short timeline for this online process has created unnecessary concerns, even panic, in some sectors.

As the first posting for this process was in early December 2025 with a deadline of today, January 23, 2026, the timing was not ideal. Obviously, many concerned with the salmon allocation process were, like all Canadians, on holiday through much of this period. My suspicion is that a longer timeline for this phase of the multi-year consultation framework might have alleviated concerns, particularly in the recreational fishery sector. By far, the largest number of letters of concern I have received, as well as people speaking up in my local community meetings have been from recreational fishery representatives fearing an imminent re-allocation to their detriment.

To avoid unnecessary ruptures in the delicate balances achieved in allocation policy, I suggest a pause would be wise. We must respect Indigenous rights. That is fundamental. So too we must ensure that the conservation of wild salmon is the paramount objective. So too, all British Columbians are concerned with the fate of our Southern Resident Killer whales. Those issues are related but not currently central to this exercise.

Thank you for your consideration of my comments.

Sincerely,
Elizabeth May, O.C.
Member of Parliament
Saanich-Gulf Islands
Leader of the Green Party of Canada

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Bill C-226 

In June 2024, I was pleased to see my Private Member’s Bill C-226, National Strategy Respecting Environmental Racism and Environmental Justice Act, passed into law. Many thanks to former MP Lenore Zann (Cumberland—Colchester), Senator Mary Jane McCallum, Dr. Ingrid Waldron, and countless other allies who helped push this legislation through. 

The primary goals of Bill C-226 are to advance environmental justice and to assess, prevent, and address environmental racism. This Act requires the Minister of Environment and Climate Change to produce a national strategy for environmental justice by June 20, 2026. The Minister must then report on progress every five years. 

This Act builds on the work of Bill S-5 (Strengthening Environmental Protection for a Healthier Canada Act) which became law in 2022 and amends the Canadian Environmental Protection Act (CEPA). Bill S-5 guarantees the right to a healthy environment and specifically considers environmental justice in decision-making. The Act also reflects the government’s 2021 commitment to implementing the UN Declaration on the Rights of Indigenous Peoples (UNDRIP).  

This consultation will walk you through the government’s progress thus far on addressing environmental racism and environmental justice. You do not need to be an expert on the topic to participate. I encourage you to share your personal reflections and experiences, especially if you have been disproportionately affected by environmental impacts or climate change due to identities you hold (e.g., if you are Indigenous, young, racialized, low-income, or have a disability).  

Environmental Racism

According to researcher Dr. Ingrid Waldron, environmental racism describes “environmental policies, practices, or directives that disproportionately disadvantage individuals, groups, or communities (intentionally or unintentionally) based on race or colour”. Often, it is Black and Indigenous communities that are most impacted by health and environmental harms due to contamination and pollution. Examples of communities that have experienced environmental racism include: 

• Aamjiwnaang First Nation near Sarnia, Ontario (an area known as Chemical Valley), which is greatly impacted by air pollution from oil refineries and power-generating stations
• Shelburne, Nova Scotia, home to the largest concentration of Black Nova Scotians and where the Morvan Road Landfill is situated 
• Kebaowek First Nation near Chalk River, Ontario, which is fighting against the development of a near-surface nuclear waste disposal facility on their land

More resources:

• Environmental Racism in Canada (2020) – Dr. Ingrid Waldron 
• “Environmental racism in Canada: What is it, what are the impacts, and what can we do about it?” (2020) – Ecojustice
• There’s Something in the Water (2019) 
  • Documentary about the disproportionate environmental impacts faced by Indigenous and Black communities in Nova Scotia (links to watch)

Environmental Justice

Environmental justice, a term coined by activists at the 1991 People of Colour Environmental Leadership Summit, seeks to ensure meaningful inclusion of affected people in decision-making and the equitable sharing of costs and benefits of environmental decisions. This means that all communities have fair access to voice their concerns and that no one community bears the brunt of environmental harms. This is a critical consideration as we pursue climate solutions that guarantee a livable future for all, not just a select few. 

More resources: 

• 17 Principles of Environmental Justice (1991) – First National People of Color Environmental Leadership Summit in Washington, D.C. 
• Principles of Climate Justice (2009) – Environmental Justice Leadership Forum on Climate Change
• Summary of the September 2024 Canadian Environmental Justice and Racism Symposium 

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Link to pdf of consultation submission

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Fisheries and Oceans Canada (DFO) sought feedback to inform potential amendments to the Marine Mammal Regulations. They invited stakeholders and the public to inform the Marine Mammal amendment  process. Elizabeth’s submission focuses on long-term planning for Southern Resident Killer Whale (SRKW) protection and recovery, and proposed administrative amendments.

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