While I agree wholeheartedly with the goal of protecting all students, I strongly oppose the Model Policy as currently formulated.  Its ambiguous terminology and definitions, unacceptably vague legal terms, and sweeping assertion of school authority, jeopardize the safety and privacy of both students and staff.  

Generally, the Policy: 1) gives unprecedented and illegal power to schools to intervene between parents, students and medical providers; 2) jeopardizes the safety of girls in particular by removing all legal recourse to abuse of privacy in places where they have the legal right to emotionally and physically secure facilities such as restrooms, lockers and overnight accommodations, and 3) places an untenable burden on staff and students who have philosophical, scientific or religious objections to claims by other students and to the ideological and scientific assertions of the Model Policy.

1)  The Policy explicitly allows schools to conceal from parents consultations with minors (p.12). Such intentional secrecy is both illegal and tremendously harmful to students and families.  School staff at best have a highly limited awareness of the student's needs and circumstances, and are in no position to unilaterally determine the best interests of the student.  To intervene intentionally, in secret, on such a sensitive topic is prejudicial, wrong, and illegal.

Relatedly, the provisions of p. 13 are unacceptably broad and vague, and grant inappropriate and dangerously broad authority to the school for decisions it is not qualified to make.  Parents, not the school, are best suited to provide support and make medical decisions for their child.  To equate questions of how to handle a student's request for name or pronoun changes with child abuse--as this language broadly does--puts the best interests and health of the child at great risk and usurps the ability and rights of parents to care for that child.  

It is not the place of the school board, or staff, who have but a momentary glimpse into the child's psyche, circumstances, needs and health, to intervene in ways that can have lasting adverse psychological impact on the student, including by damaging the fabric of family relationships.  These provisions of secrecy are both illegal and harmful, and they are absolutely unacceptable.

2) In seeking to provide safety and prevent "emotional harm" for transgender students (p. 16, 17, 18) the Policy puts a far greater number of students at risk of physical and emotional harm, by removing any ability to protect designated female spaces. Any male can access protected female spaces and inflict harm, with no ability on the part of students or staff to question the student/staff, as the Policy bars staff and students alike from confronting students upon entrance to facilities.  Decades of privacy provisions designed to protect women and girls are removed, giving any intruder with ill intent full access to young girls.  This provision will lead inevitably to abuse and assault, and nowhere in this Policy is protection provided. Such tragic abuse will rightfully lead to lawsuits and damages against the school that actively opened the door to assault.

This policy must be altered BEFORE girls and women are irreparably harmed by those who will abuse it. There is no emotional harm to transgender students if gender neutral bathrooms are accessible, and female spaces are protected. Until the safety of half the student population can be assured, the policy cannot place the safety of a few over the safety of the many.

Relatedly, the Policy denies parents and students the right to know if their child will be sharing lockers, facilities or overnight accommodations with a student of the opposite biological sex.  The Policy provides no means of ensuring the child's safety from abuse of this provision, and harms the entire student body by placing the claims of a few students prejudicially above the safety of all the others.  The Policy must find a way of accommodating the safety of students, particularly of girls, and must be modified accordingly.  The policy gives transgender students the right to any accommodation, while stripping the rest of the student population of the presumptive right to emotional and physical safety and requiring the majority, not a tiny minority, to affirmatively request exceptions for lodging and facilities.

3)  The Policy provides no protections for staff or students who have objections of conscience, science or religion to unquestioning affirmation of gender identity over biological sex.  Further, the training, terminology, phrasing and resources are entirely one-sided in the perspectives presented.  Gender identity and transition are developing medical fields, and the resources cited largely rely on a handful of advocacy groups and small numbers of medical professionals who have authored policy papers for associations, often heavily funded by advocacy groups. There are countless medical professionals and scientists who do not support unexamined gender identity affirmation, and the science is not one-sided as presented in this Policy explanation.  

This Policy relies primarily on advocacy groups and makes no provision for staff, students and families who may choose to respectfully disagree with the philosophical, ideological, and scientific claims asserted by this Policy.  Whether such objections are scientific, philosophical, or religious, they cannot simply be subverted wholesale by the school or students, particularly if there are consequences or damages involved in expressing such objections.  

This is particularly the case as the definitions are so vague as to be nearly meaningless, and therefore open to abuse.  To cite but one example, the discussion of Student Identification on page 12 describes a student as transgender if there is "more than a casual declaration of gender, but...not necessarily requir[ing] any substantiating evidence nor any required minimum duration of expressed gender identity".  This phrase has no clear or defined legal meaning and yet is used as a standard for identification, and possibly claims of abuse or discrimination, and punitive action. 

This Policy should not be put forward under any circumstances until appropriate provision is made for the the rights of staff and students who have objections of conscience and/or religion to the ideological or scientific claims (in part or in whole) of gender identity.  

It is clear from both the Policy itself, and the resources and references provided, that this Model Policy was developed from a unilateral perspective, without involving any stakeholders other than the advocacy and position papers representing the claims of transgender and advocacy groups.  The Policy should be put on hold until participation of stakeholders across scientific, philosophical and religious perspectives can demonstrably be shown to have occurred.  To ensure that the needs of all students are met, this process must particularly include parents and families drawn from broader student populations, beyond the families of transgender students only.

In sum, this Model Policy usurps parental, staff and student rights, creates vague and ambiguous standards that may be abused, and strips away physical and emotional protections for women and girls.  While the goal of ensuring the mental and physical health and safety of transgender students is laudable, this iteration of a Model Policy is absolutely unacceptable as written, and will perpetrate real harm in the name of doing good.