I was taught in school that a counselor was to start where the client is, respecting the client's world view and right to make decisions about life.  This is the first guidance document or regulation that throws aside the ethics of self-determination under the guise of protection in such a way that only one portion of the population is actually able to experience self-determination, while the other is trapped by laws that are politically skewed.  

There is no way that the national ethics organizations and this board can say that decisions about standards of practice have been developed after looking at all of the evidence, research and testimonies on both sides of the argument related to same sex attraction.  This is clearly a case of the board supporting only one side of the argument to protect one part of the population and not all of the citizens of Commonwealth of Virginia.  

It is quite clear that this board did not listen and respond to all of the public comments related to the guidance document.  There has been no change or alteration of the regulation to reflect the information that at least half if not more than half of the public comments made as far as those who want youth that do not share the world view that they were born gay.  In the same way that people struggling with cravings or urges come to acknowledge but not act on impulses related to addictions, youth that do not want to act on same sex attraction or desires, should be permitted to gain professional support to manage these impulses.

 In some ways this would be similar to youth (under 18) choosing not to act on impulses of opposite sex attraction until they are older and more mature or married, Christian or non-Christian.  This draft of the regulation prohibits any efforts to reduce sexual or romantic attractions or change behaviors toward any gender.  Having self-control until one is old enough to make mature, rational decisions that can impact your entire life is important and should be encouraged.  Take a look at all the negative consequences that have occurred related to sex, any form of sex by youth because of acting on impulse, rather than having discernment or discretion.   There are countless cases of babies born outside of marriage, sexually transmitted diseases, broken hearts, and suicides based on the pain of perceiving rejection after having sex. 

Except for one member of the Board of Counseling, the other members are implementing regulations based on their own world views, believing their views are right, totally violating the basic tenets of the ethics of self-determination.   In this situation they are basing their decision on doing no harm, but be assured - this will bring harm - they will not be on the front lines dealing with the repercussions because they have never counseled someone that sincerely did not want to act on same sex attraction for whatever reason.  The decision making in this situation demonstrates how limited their exposure to clients that have no religious affiliation at all but still do not want to act on unwanted sexual attraction.  

During the Workgroup Meeting last fall, some members ridiculed conservative Christians as being rigid, uneducated, closed-minded and prejudice.  Many board members made sarcastic, degrading, truly demeaning comments toward anyone that doesn't think like they do.  I find this sad and truly hypocritical of behavioral health professionals that are trained to be mindful and respectful of their clients' world views.  The national ethics boards are requiring people to do "gay sensitivity training".  I believe that the national boards need to start doing sensitivity training toward people of faith, especially Christians because that is truly lacking in the way that this whole situation has been handled.  

I understand the intent to protect young people that want to explore and act on same sex attraction.  But please do not hurt those that do not want to act upon these desires simply because you lack sensitivity, knowledge or awareness of the many hundreds, if not thousands of people who have received counseling professionally and in their churches over the years without any signs of being traumatized or harmed by the experience at all.  

I think that some of the testimonies heard at the public forums were people that interpreted shame, experienced this as a result from ministries that did not have professional training and were just trying to do the best they knew when families were coming asking for help.  I hope you realize that this regulation would force people seeking help with same sex attraction to go to the churches even more where there is less training and protections.  

I would like to know how current the information regarding the extremes that were mentioned related to shock therapy and aversion techniques.  These interventions were more common in the 1950's.  These days "shock therapy" is still being used for severe cases of depression.  How do you know that major depression wasn't the intent of the professional and the person giving the testimony intentionally skewed it to support their world view?

Virginia state code and regulations permit a case by case investigation with hearings to deal with professionals accused of harm. Yet you have gone beyond what is the board's typical mode of operation to outlaw a specific form of therapy.  This has never been done before.  This step is not reflected in any of the previous regulations.

Has the Board really examined themselves as to their true motive in making this broad, sweeping regulation in this manner? 

If you won't listen to the sector of the public that is not supporting your world view, you are setting up a situation for far more people to feel abandoned and rejected because they perceive no place to go for help, particularly if their place of religious affiliation does not provide experienced pastoral counseling.

I ask you to reconsider your current course of action. Write a regulation that is more inclusive and concerned with all of the citizens of the Commonwealth of Virginia.