Thank you for the opportunity to comment on the NOIRA for 12 VAC 5-660. I appreciate the Board's focus on public health and safety, but I have significant concerns about how this regulation could realistically be enforced. 

Biological sex is not something can be confirmed without invasive or inappropriate methods. Any attempt to enforce sex-specific spaces or activities would place schools, athletic programs, and public facilities in extremely difficult positions - forcing them either to ignore the regulation or to adopt practices that could violate privacy and invite discrimination. 

Without clear, lawful, and non-intrusive enforcement mechanisms, this regulation risks being unworkable and potentially harmful to even individuals who are not transgender. This type of legislation ignores the fact that transgender people are humans who deserve dignity just like anyone else. 

Because no realistic or non-intrusive enforcement method appears possible, I ultimately oppose moving forward with this regulation.