As a proud Virginia citizen, I recognize Virginia among its many firsts, like the 400th Anniversary of the first representative legislative assembly in the western hemisphere; the Virginia Declaration of Rights (1776) to proclaim the inherent rights of men, including religious rights, passed over ten years before the Bill of Rights of the United States of America (1791; and the Virginia Statute for Religious Freedom (1770’s) by Thomas Jefferson that guaranteed freedom of religion to people of all religious faiths, including Christians of all denominations, Jews, Muslims, and Hindus and was a notable precursor of the Establishment Clause and Free Exercise Clause of the First Amendment to the United States Constitution (Wikipedia). And both our Virginia Constitution via its Declaration of Rights and our United States Declaration of Independence acknowledge the Creator, God, God with “laws […] of Nature's God” and with self-evident truths to be, a Creator who endows us with certain unalienable (not changeable) rights.  The founding fathers like Virginians George Wythe, Richard Henry Lee, Thomas Jefferson, Benjamin Harrison, Thomas Nelson, Jr., Francis Lightfoot Lee, and Carter Braxton appealed “to the Supreme Judge of the world for the rectitude of [their] intentions.” And for the support of their Declaration they did so “with a firm reliance on the protection of Divine Providence.”

The Statute for Religious Freedom is one of only three accomplishments Jefferson instructed be put in his epitaph. (www.virginiahistory.org)  It recognized “Almighty God hath created the mind free;”  and “That all attempts to influence it by temporal punishments or burthens, or by civil incapacitations tend only to beget habits of hypocrisy and meanness, and therefore are a departure from the plan of the holy author of our religion, who being Lord, both of body and mind yet chose not to propagate it by coercions on either, as was in his Almighty power to do.”

I am greatly concerned that (1) the proposed action to  specify in Virginia regulations that “the standard  of practice requiring persons licensed, certified, or registered by the board to "Practice in a manner  that  is  in  the  best  interest  of  the  public  and does  not endanger the public health, safety, or  welfare"  “precludes the provision  of conversion therapy” will have great risk of adversely impacting the very stated purpose of government, which “is, or ought to be, instituted for the common benefit, protection, and security of the people, nation, or community protection” by risk of taking away the “protection of Divine Providence” because of potential and real departures from the plan of the holy author of our religion, and (2) the proposed action to  specify in Virginia regulations as stated will prohibit the free exercise of religion.

Per Article VI of the United States Constitution “all executive and judicial Officers, both of the United States and of the several States,” like Jaime Hoyle, Executive Director, Board of Counseling, “shall be bound by Oath or Affirmation, to support this Constitution.” And by Article II of the Virginia Constitution, Section 7. Oath or affirmation. “All officers elected or appointed under or pursuant to this Constitution [like Jaime  Hoyle] shall, before they enter on the performance of their public duties, severally take and subscribe the following oath or affirmation: "I do solemnly swear (or affirm) that I will support the Constitution of the United States, and the Constitution of the Commonwealth of Virginia, and that I will faithfully and impartially discharge all the duties incumbent upon me as ...................., according to the best of my ability (so help me God)."  Thus, the U. S. Constitution and First Amendment appear to be mandatory to follow.  My understanding also is that since the Fourteenth Amendment was added to the U.S. Constitution, the U.S. Supreme Court has gradually used the due process clause to apply most of the Bill of Rights to state governments. Thus, the First Amendment now covers actions by federal, state, and local governments. The First Amendment says about religion “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof.”

John Ash’s “New and Complete Dictionary of the English Language” (1775) defines religion as ”the true fear of God in the heart; a particular system of divine faith and worship.”

We have serious sexual-related problems in the U. S.  The U.S. Department of Justice Office of Justice Programs 2009 https://www.ncjrs.gov/pdffiles1/ojjdp/227763.pdf “The victimization of youth by adult sex offenders has been an ongoing concern for some time. Although all crimes constitute an assault on civilization, the criminal violation of children is particularly disturbing.  In recent years, there has been increased public interest in the incidence of sexual victimization of youth by other youth.” “Juveniles account for more than one-third (35.6 percent) of those known to police to have committed sex offenses against minors.” “More than two million cases of chlamydia, gonorrhea and syphilis were reported in the United States in 2016, the highest number ever, according to the annual Sexually Transmitted Disease Surveillance Report released today by the Centers for Disease Control and Prevention (CDC).” https://www.cdc.gov/media/releases/2017/p0926-std-prevention.html “The vast majority of mass shooters in our study experienced early childhood trauma and exposure to violence at a young age. The nature of their exposure included parental suicide, physical or sexual abuse, neglect, domestic violence, and/or severe bullying.” Los Angeles Times (https://www.latimes.com/opinion/story/2019-08-04/el-paso-dayton-gilroy-mass-shooters-data) “Studies have found that GLBT youth attempt suicide more than 3 times more frequently than their heterosexual counterparts. A Canadian study estimated that the risk of suicide among LGB youth is 14 times higher than for heterosexual youth.” (https://www.healthyplace.com/gender/glbt-mental-health/homosexuality-and-suicide-lgbt-suicide-a-serious-issue)

And yet we have a God, Almighty God, Divine Providence, Creator, who according to God’s word in the Bible, Exodus 15:11: "Who is like you, O LORD, among the gods? Who is like you, majestic in holiness, awesome in glorious deeds, doing wonders?" Or in “2 Kings 20:1-6  In those days Hezekiah became sick and was at the point of death. Isaiah the prophet the son of Amoz came to him and said to him, “Thus says the Lord, Set your house in order, for you shall die; you shall not recover.’” Then Hezekiah turned his face to the wall and prayed to the Lord, saying, “Now, O Lord, please remember how I have walked before you in faithfulness and with a whole heart, and have done what is good in your sight.” And Hezekiah wept bitterly. And before Isaiah had gone out of the middle court, the word of the Lord came to him: “Turn back, and say to Hezekiah the leader of my people, Thus says the Lord, the God of David your father: I have heard your prayer; I have seen your tears. Behold, I will heal you. On the third day you shall go up to the house of the Lord, and I will add fifteen years to your life.”

The Virginia Code § 54.1-3500. Definitions “Counseling" means the application of principles, standards, and methods of the counseling profession in (i) conducting assessments and diagnoses for the purpose of establishing treatment goals and objectives and (ii) planning, implementing, and evaluating treatment plans using treatment interventions to facilitate human development and to identify and remediate mental, emotional, or behavioral disorders and associated distresses that interfere with mental health.” “"Practice of counseling" means rendering or offering to render to individuals, groups, organizations, or the general public any service involving the application of principles, standards, and methods of the counseling profession, which shall include appraisal, counseling, and referral activities.” “"Professional counselor" means a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development.”

The American Medical Association (AMA) issue brief https://www.ama-assn.org/system/files/2019-03/transgender-conversion-issue-brief.pdf  states “Conversion therapy” refers to any form of interventions, such as individual or group, behavioral, cognitive or milieu/environmental operations, which attempt to change an individual’s sexual orientation or sexual behaviors (sexual orientation change efforts [SOCE]) or an individual’s gender identity (gender identify change efforts [GICE])”  citing John Bancroft, et al., Peer Commentaries on Spitzer, 32 Archives of Sexual Behavior 5, 419-68 (Oct. 2003).  The AMA paper notes “Practitioners of change efforts may employ techniques including: • Aversive conditioning (e.g., electric shock, deprivation of food and liquids, smelling salts and chemically induced nausea)• Biofeedback• Hypnosis• Masturbation reconditioning• Psychotherapy or systematic desensitization.”

Religious counselors don’t do these things. They use the power of God’s word “All Scripture is breathed out by God and profitable for teaching, for reproof, for correction, and for training in righteousness, 17 that the man of God[b] may be complete, equipped for every good work.” 2 Timothy 3. They use prayer.  To address emotional, or behavioral disorders and associated distresses that interfere with mental health and development, by the standards of God’s word – Divine Providence.

The Virginia Guidance document 115-10 uses a different definition: “For the purposes of this guidance "conversion therapy" or "sexual orientation change efforts" is defined as any practice or treatment that seeks to change an individual's sexual orientation or gender identity, including efforts to change behaviors or gender expressions or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of the any gender.”

God tells us in His Word that “God said, “Let us make man in our image, after our likeness. And let them have dominion over the fish of the sea and over the birds of the heavens and over the livestock and over all the earth and over every creeping thing that creeps on the earth.  So God created man in his own image, in the image of God he created him; male and female he created them.”  Thus gender identity is what God creates, and is religion as ”the true fear of God in the heart; a particular system of divine faith and worship” means we must be allowed to rely on the power of God and let man, men and women, have the true fear of God in our hearts."

2016 report from the think tank Theos (www.theosthinktank.co.uk) considers the relationship between 'religion' and 'well-being'. Starting with what can be meant by these terms, the Theos researchers assess the evidence and tease out some of the reasons for it. “Religion and Well-being: Assessing the evidence evaluates the evidence from nearly 140 academic studies conducted over the last three decades examining the relationship between religion and well-being in a wide range of countries and contexts. “Across the majority of these studies, the data show a positive correlation between religion and well-being.”  God is able!

God’s power to change hearts is clear:  Romans 8 “By sending his own Son in the likeness of sinful flesh and for sin, he condemned sin in the flesh, in order that the righteous requirement of the law might be fulfilled in us, who walk not according to the flesh but according to the Spirit. For those who live according to the flesh set their minds on the things of the flesh, but those who live according to the Spirit set their minds on the things of the Spirit. For to set the mind on the flesh is death, but to set the mind on the Spirit is life and peace. For the mind that is set on the flesh is hostile to God, for it does not submit to God's law; indeed, it cannot. Those who are in the flesh cannot please God.”

“You, however, are not in the flesh but in the Spirit, if in fact the Spirit of God dwells in you. Anyone who does not have the Spirit of Christ does not belong to him. But if Christ is in you, although the body is dead because of sin, the Spirit is life because of righteousness. If the Spirit of him who raised Jesus from the dead dwells in you, he who raised Christ Jesus from the dead will also give life to your mortal bodies through his Spirit who dwells in you.”

Let religion counsel under the Word and Power of God - do not block it. Let God protect us by his common grace - do not go against God's word and power.