Draft policy accommodating transgender students imposed on state school divisions violates Constitution First Amendment rights, is poorly written, violates parental responsibilities, endangers student health and welfare and adds unfunded requirements on struggling schools.

Virginia's parents and students will have fundamentally different transgender views depending on ethnicity, religion, culture, and education and are free to express their opinion.  Failure to use a student's "preferred pronoun", which can change from day today, can be considered discriminatory under this draft policy.  Poorly written draft language raises First Amendment issues and encourages unfounded discrimination charges. (Draft Policy p. 10, Recommended Standard p. 10, 12, Definitions p.6)

Draft VDOE policy violates parenting legal responsibilities preventing a parent's full transparency into their students activities, school environment, friends, and safety.  Parents have a right to know what their children are doing in school.  (Draft Policy p. 12, Recommended Standard p. 12, p 13)

Students are not mature.  Bullying, teasing, up-skirting, inappropriate use of Smartphones, silly and disruptive behavior, etc. are difficult to supervise in gender-neutral facilities without invasive CCTV systems, staff supervision or an open communal soace that removes comfort and privacy.  Failure to recognize gender neutral privacy and safety issues for children is irresponsible. (Draft Policy p. 18)

United Kingdom experiments promoting gender neutral bathrooms resulted in girl's privacy being invaded, with many girls avoiding using school facilities resulting in increased urinary tract infections.  At what point does Virginia ignore a girl's need for privacy and the historical role that sexual harassment and sexual assault have influenced women's rights and history?  (Draft Policy p. 18)

Draft policy encourages students to make gender change and sexual identity decisions without informing their parents.  Draft encourages students to make critical psychological and health decisions when students do not have the knowledge, maturity, or understanding of their decision's long-term effects.  This, when students cannot consent to sexual activity, cannot legally consume alcohol, are not considered mature enough to vote, may not be old enough to legally drive and must be supervised while taking parent approved doctor prescribed medications in school. (Recommended Standard p. 13)

Draft policy demolishes effective communications between parents and teacher.  Subjective language in this poorly written draft is open for abuse and misinterpretation.  Teachers are prevented from having a free and open discussion with parents.  Parents cannot engage with teachers without the real fear of being reported to Child Protective Services. (Recommended Standard p. 10, p. 12, p. 13)

Poorly written draft policy permits abuse and creates "gender neutral" sports attire issues  such as female topless swimming. (Draft Policy p. 16)

Issue of biological males competing in female sports was not adequately addressed.  Issue must be included and be unambiguous to ensure fairness to female athletes.

VDOE intends to impose liberal transgender policies that affect some fraction less than 2% of Virginia's student population at a time when VDOE priorities, focus and resources should be to ensure all state students are educated when schools are locked down due to Covid 19 pandemic concerns, ensue that students with disabilities are provided the best possible education, and school safety and security is improved state-wide.  VDOE must better implement effective state-led strategies improving academically under performing schools.

VDOE can and should do better. It must recognize the needs of all students, recognize the need for local solutions to individual student issues while ensuring privacy and safety for an established and objective majority - females, especially the little ones.