| Action | Promulgate Regulations Governing Biological Sex Specific or Separated Spaces and Activities |
| Stage | NOIRA |
| Comment Period | Ended on 12/17/2025 |
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Dear Members of the Virginia Board of Health,
I write today in strong opposition to the proposed regulation that would bar transgender women and girls from participating in girls’ and women’s sports teams and from accessing female designated facilities such as locker rooms. I urge the Board to reject these restrictions as they would cause real harm to a small but vulnerable population, undermine community cohesion, and distract from genuine public health priorities.
1. Transgender Virginians Are Part of Our Community — Not a Threat
Transgender people are Virginians: our neighbors, classmates, coworkers, friends, family members, and children. Estimates suggest that roughly 1–2% of youth identify as transgender, including in Virginia. Policies that target them do not improve public health but stigmatize and marginalize people whose existence already faces disproportionate prejudice and misunderstanding. Virginia Mercury
Efforts to single out transgender women and girls in sports and facilities reinforce a false narrative that their presence inherently causes harm. This narrative is rooted in fear and misinformation, not in credible evidence of risk to others.
2. Participation in Sports Is a Fundamental Part of Youth Development
Participation in team sports and physical activities provides well-documented benefits: increased physical health, improved mental health, teamwork skills, self-esteem, and community belonging. Transgender youth suffer significantly higher rates of depression, anxiety, and suicidal ideation compared to their cisgender peers; and exclusionary policies make these disparities worse. Inclusive sports policies allow transgender youth to enjoy the same lifelong benefits of team participation that all young people deserve. Center for American Progress
Importantly, inclusive policies have long existed across the country, and transgender athletes have competed with their peers without evidence of systemic harm. Trans inclusion in sports predates this debate, demonstrating that competition and inclusion can coexist.
3. Claims of “Unfair Advantage” Lack Scientific and Policy Consensus
Arguments asserting that transgender girls and women necessarily possess unfair athletic advantages oversimplify complex biological and social realities. Peer-reviewed research indicates that performance among individual athletes varies widely based on training, access to resources, talent, and many other factors, regardless of gender identity. Policies that focus solely on excluding transgender athletes rest on assumptions, not comprehensive science. Gender Justice
Many major sports organizations, including those outside Virginia, have historically adopted evidence-based, inclusive participation guidelines designed to ensure competitive equity. Policies with nuanced criteria (for example, hormone thresholds or individualized review processes) reflect a commitment to fairness and belonging without marginalizing participants.
4. Inclusive Facilities Policies Can Respect Privacy and Safety for All
Concerns about safety or privacy in locker rooms are often driven by sensational anecdotes rather than broad patterns of behavior. Inclusive facility policies such as privacy partitions, staff training, and ensuring everyone can use facilities consistent with their gender identity can uphold dignity and safety for all Virginians without singling out or excluding transgender people.
5. Exclusionary Regulations Harm Health and Equality
Restricting access to common spaces and opportunities based solely on gender identity is discriminatory. It sends a message to transgender individuals that they are less worthy of participation in public life, exacerbating feelings of isolation and distress. Such policies can unsettle school environments, detract from learning, and elevate mental health risks just when supportive inclusion is most needed.
By contrast, public health leadership should aim to reduce stigma, promote equitable access to health and social resources, and support every person’s dignity — especially those facing disproportionate barriers.
6. Efforts to Divide the Trans Community Are Part of a Broader Political Strategy
This proposed regulation is part of a larger wave of policies nationally that seek to restrict transgender rights, including limits on participation in sports, access to health care, and the ability to live authentically. These efforts often use transgender individuals as a “wedge issue” to generate controversy while real pressing public health needs such as maternal health, mental health care access, HIV prevention and treatment, and affordable health care go unaddressed.
Rather than targeting a marginalized minority, the Board should prioritize initiatives that improve health outcomes for all Virginians, focusing on inclusion, resilience, and community wellbeing.
7. Inclusive Policy Is Consistent with Virginia’s Values
Virginia has a long tradition of valuing equality, fairness, and respect for all individuals. Policies that build bridges, not barriers, enrich our commonwealth. Excluding transgender women and girls from sports and facilities contradicts these values and undermines our shared commitment to fairness and opportunity.
Conclusion
For the reasons above, I respectfully urge the Virginia Board of Health to reject the proposed regulation that would restrict transgender women and girls from participating in sports and using female-designated spaces. Instead, the Board should champion policies that promote inclusion, protect the dignity of all Virginians, and focus on real public health priorities.
Thank you for your thoughtful consideration.
Respectfully submitted,
Alan