After reading guidance document 115-10, http://www.townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\GuidanceDocs\223\GDoc_DHP_6578_v3.pdf the two points made are:

1) Conversion therapy of youth (whether the youth or parent request it) to transition from LGBT to heterosexual does not work and can cause harm

2) This document does "not" cover those who want to transition from heterosexual to LGBT, but clearly says it OK for someone to seek, "identity exploration and development."

Since the state recognizes identity exploration from heterosexual to LGBT identity then it needs to do recognize the same for LBGT to heterosexual identity, especially when those in the LBGT community have 4-8X the rate of attempted suicide as the heterosexual community (This 8X number comes from ACA President Gerard Lawson testimony: https://www.counseling.org/docs/default-source/government-affairs/testimony-of-gerard-lawson-final.pdf )

This document needs to define the difference between exploration and conversion. It needs to do the same for exploration and reparation. Without it, there is too much ambiguity and the possibility for harm to youth. 

In like thinking, Victoria Cobb of the Family Foundation says,

"So let me get this straight: At the same time the new Left insists that adolescents as young as five years old be unconditionally supported in “changing” their birth gender and in “exploring” the outer reaches of their sexual curiosities, they are actively demanding that those same kids be legally barred from receiving professional counseling to overcome certain sexual thoughts and feelings they may develop along the way, even when those feelings are unwanted or unhealthy?" http://www.familyfoundation.org/blog-posts/no-conversion-allowed

Please also define whether the youth is receiving this voluntarily or involuntarily (https://thinkprogress.org/federal-judge-florida-halt-ban-conversion-therapy-free-speech-6e98a2d3a2ea/). That makes a big difference to this document.

Before the state should base its decision in any way off of "harm", harm should be proved in a double-blind placebo-controlled study. Many said, "Could cause harm." After investigating these sites, none of them showed that conversion therapy actually caused harm: ACA's response, https://www.counseling.org/government-affairs/state-issues/conversion-therapy-bans, and the APA's https://www.apa.org/pi/lgbt/resources/therapeutic-response.pdf

If the state is going to quote the ACA, then it should acknowledge that there are many of its members that are discriminated against based on their anti conversion-therapy stance: https://www.crosswalk.com/blogs/dr-warren-throckmorton/american-counseling-association-and-religious-liberty-11568568.html

Should the state's resources be spent on this versus other pressing issues because this is going to be a drawn out legal battle: https://www.sun-sentinel.com/local/palm-beach/fl-ne-conversion-ban-20190411-story.html. It will also cause many questions about diveristy training and who suppports and pays for it: http://www.bpnews.net/33439/christianity-gay-rights-clash-in-counseling-controversies

Do those who believe the LBGT sexual acts are not Biblical have a right to free speech and to not be discriminated against in Virginia, even if they are certified counselors?

For example, should a caring, certified counselor say to a youth who is LBGT and mentioned thoughts of suicide that they should continue exploring their LGBT identity, knowing that will keep the LGBT youth in the higher suicide rates? It is simple logic that a counselor should help repair a person by moving them toward an identity that will cause less suicide. Could a counselor recommend that 15 year old explore sex with another 15 year-old female and then 15 year-old male, and then compare? (This would be legal: https://www.wboycelaw.com/Articles/Does-Virginia-have-Romeo-and-Juliet-laws.shtml) Where does exploration (recommended) start and stop relative to reparation relative to conversion?

If it does not work then why are there inspiring stories of change like https://changedmovement.com/ ?

Both the NIH and the Williams Institute explain that those living the LBGT lifestyle have 4X the suicide attempt rate: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5675322/ and https://williamsinstitute.law.ucla.edu/wp-content/uploads/AFSP-Williams-Suicide-Report-Final.pdf. In real numbers that means for every 100K, there are 14 actual suicide deaths (https://www.americashealthrankings.org/explore/annual/measure/Suicide/state/VA). Given there are roughly 200K LBGT in VA (https://williamsinstitute.law.ucla.edu/wp-content/uploads/Virginia-fact-sheet.pdf), that means 14 * 4 = 56 will kill themselves. Telling counselors that they cannot counsel patients to leave/repair/explore the LBGT lifestyle, especially if one of these 56 requested it, is not in keeping with being a good steward of the Virginia people. All political agenda aside, can you sleep at night knowing more Virginians will die because of this policy?

In summary, this document should be stopped now because it does not give equal exploration/repair/conversion rights to LBGT and heterosexual people alike, will put VA resources into activities that are not as high priority as other needs in VA, will stifle free speech to religious communities and will cause more harm than good to VA people.