A/HRC/45/12/Add.3 Para 20, last sentence, comments: We request that a reference citing evidence of a silent pandemic in Canada be included; we are not convinced that this statement would apply to Canada. Para 26, 2nd sentence, suggested language: Canada does not have national legally binding ambient air pollution standards, and some provincial emission source specific laws offer considerable flexibility for industry to develop their own standards, for example this can be considered the case in Sarnia, Ontario. Para 26, 4th sentence, comments: In reference to “exceeding odour and health thresholds”: there are Canadian Ambient Air Quality Standards (CAAQS) for NOx, ozone, PM2.5. Since the document referenced in footnote 29 referencing Alberta thresholds (example from Fort McKay) it would be helpful to clarify this refers to provincial thresholds. Para 28, 1st sentence, comments: Please note that this statement is not factually accurate as the Government of Canada (GoC) makes public information on the risk assessment of substances, and not just for those declared toxic. Risk assessment reports provide information on the potential hazards of substances as well the potential exposures/risks. The information is provided via publications and GoC websites. We recommend that it be conveyed here. Para 28, 2nd sentence, comments: Please note that this is already the case in Canada. Once a substance is added to the toxics list CEPA, Environment and Climate Change Canada must develop and publish a proposed instrument within 2 years, and a final instrument 18 months later. (See sections 91 and 92 of CEPA) https://www.canada.ca/en/environment-climate-change/services/canadian-environmentalprotection-act-registry/publications/canadian-environmental-protection-act-1999/part5.html Para 29, last sentence, comments: Please note that this statement is factually incorrect as the 2015 National Environmental Effects Monitoring report shows that despite high compliance with the Fisheries Act, 76% of mines have confirmed effects on fish, fish habitat or both. Among these mines, 92% confirmed at least one effect of a magnitude that may be indicative of a higher risk to the environment. Para 29, last sentence, recommended language: “For example, despite high compliance with the Fisheries Act, 76% of mines have confirmed effects on fish, fish habitat or both. Among these mines, 92% confirmed at least one effect of a magnitude that may be indicative of a higher risk to the environment”. Para 32, 4th sentence, comments: Please note that this does not reflect the Government of Canada’s position. The ENJEU case (referenced in footnote #41) was at the class certification stage (not merits) and there was no discussion by the court around Charter and environmental rights protections. We would therefore recommend changing this part of the sentence to read “While some have argued that the Charter…” Para 39, 4th sentence, comments: This sentence needs to be supported by evidence; most communities are in favor or do not oppose the Project. 4