I am retired from a prominent school of medicine, after a career including research, assessment and training regarding public policy for better public health and better public safety. 

Earlier I has also been involved with groundbreaking research on the health of transgender identifying men and women in virginia ( https://www.icpsr.umich.edu/web/RCMD/studies/31721 ; https://pmc.ncbi.nlm.nih.gov/articles/PMC3780721/) and I had supported development and funding of various programs, projects, and reliable services to improve the health and safety of Virginians experiencing gender dysphoria, experiencing discrimination harmful to their health and safety because of their actual or perceived sexual orientation, experiencing violence and/or threats of violence and attendant trauma because of actual or perceived sexual orientation, gender presentation or professed gender identity. 

The full scope of available evidence, including public testimony provided by named individuals, supports that boys  - generally - before puberty - have some advantage in strength, speed and power.  Of course, individuals vary, and opportunities and contributions of training, matter a lot.   After puberty, important research found that "striking postpubertal increase in male circulating testosterone provides a major, ongoing, cumulative, and durable advantage in sporting contests by creating greater muscle mass and strength. These sex differences render women unable to compete effectively against men, especially (but not only) in power sports." (https://pmc.ncbi.nlm.nih.gov/articles/PMC6391653/#:~:text=The%20striking%20postpubertal%20increase%20in,not%20only)%20in%20power%20sports.  ). 

Colloquially, therefore: boys after puberty in girls sports are likely at substantial biological advantage, and boys with that biological advantage in girls sports put the girls at substantial disadvantage.  Again, individuals vary, and opportunities and quality of training matter.  

The part of the petition for rulemaking responsive to this particular problem - boys biological advantage after puberty - is honorable.

However, as a trained professional in matters of public policy ethics, I advise that other parts of the petition may not be honorable. Any part of the petition that intends to stereotype negatively individuals experiencing gender dysphoria, individuals with disliked gender appearance or gender behavior,  and/or with non-heterosexual sexual orientation would is a dis-honorable contribution to the Commonwealth of Virginia's public policy discourse, despite a First Amendment right to say any number and any variety of shameful, hateful and cruel things.  The plethora of shameful, hateful, and cruel comments suggests that even if dis-honorable intentions are not explicit in the petition, they are there implicitly, 'virtue-signaling' ignorance, hatred and cruelty. 

Virginia's laws, policies, rules and regulations should never favor ignorance, hatred and cruelty.   They most certainly did in the past as Black Virginians, gay and lesbian Virginians, and other Virginians well know. 

Coming to a conclusion here, we note that the petition has numerous technical and logical flaws:

it does not define 'biological male'. IF it is defined in Virginia law the citation MUST be included.  It is NOT included.

'expected places of undress' is also not defined.  Does that include private homes? private gyms, pools, etc? 

there is no discussion of protections from bullying, sexual and other harassment, verbal abuse and other traumatizing behaviors that certainly must include that individuals experiencing gender dysphoria, individuals with different (or disliked) gender presentation or behaviors, individuals with different (or disliked) sexual orientation.  There is strong evidence for damaging incidence and prevalence of bullying, sexual and other harassment, verbal abuse and other traumatizing behaviors against them. 

there is not discussion of alternative athletic opportunities - training opportunities, team competition opportunities, practice opportunities, learning opportunities, etc  - for individual currently or in the past victimized by bullying, sexual and other harassment, verbal abuse and other traumatizing behaviors.  The Commonwealth of Virginia MUST provide EQUAL OPPORTUNITY for all youth. 

these are SERIOUS logical, moral and legal flaws that Commonwealth of Virginia MUST consider.  In the early research I mentioned/cited we found that individuals experiencing gender dysphoria also experienced serious harmful discrimination in many domains of concern to the Commonwealth of Virginia.  Including lack of access to best quality primary and mental health care.  THESE, sadly, continue to be conditions for many Virginians.  And particularly in rural Virginia.  We have, in rural Virginia, persistent, pervasive health professional shortages; we have hospital and clinic closures and threats of closure; we have to find a way to get to health services without reliable public transportation, to get to service that may be one hour or more away; distance to a qualified ER - in matters critical to health, safety and life - e.g. with stroke or CV events, with accidents and injuries, threats to a pregnancy, etc - can be outside the 'golden hour' to preserve life and capacities.  And more.  Therefore, rural Virginians endure systematic disadvantages to be healthy, stay healthy, and life a healthy life. 

Please consider this in your discussion. 

Thank you.