I am submitting public comment in opposition to Petition 432 on behalf of Advocates for Youth. Advocates for Youth is a 501(c)(3) organization in Washington, D.C. We partner with young people and their adult allies to champion youth rights to bodily autonomy and build power to transform policies, programs, and systems to secure sexual health and equity for all youth. As an organization that advocates for both transgender young people and survivors of sex-based harassment and violence, we know that these attacks on transgender people’s rights are rooted in bigotry and categorically false narratives that transgender people’s existence is a “threat to public health” for cisgender students and survivors. This is a harmful and untrue narrative based in sex-based stereotypes about transgender people, and fails to recognize that locker room and bathroom policies excluding transgender people increase sexual assault. Transgender girls who are forced to use boys’ facilities are at 2.49 times the risk of sexual assault than trans girls with access to girls’ locker rooms and bathrooms. Similarly, trans boys are at 1.26 the risk of sexual assault if they are denied access to facilities according to their gender identity. In actuality, trans people are the ones who are most vulnerable in bathrooms: 68% have been verbally harassed and 9% have been physically assaulted when using a public restroom.

Moreover, research shows there is no link between trans-inclusive bathrooms and crimes in bathrooms or locker rooms. Nondiscrimination laws protecting transgender people in these kinds of facilities have been around for a long time, with no increase in public safety incidents in restrooms or locker rooms. The national consensus of survivor-led, anti-sexual assault and domestic violence organizations is support for transgender people’s full and equal access to use restrooms and locker rooms that align with their gender identity. 

Policymakers advancing sports bans are simply bullying transgender people to score cheap political points, instead of focusing on tackling the most urgent gender-based priorities in school sports – such as ensuring girls’ and womens’ sports teams have adequate resources and student-athletes are protected against rampant sexual violence. Transgender women and girls have participated in sports at various levels for years, and there has been no “wave” of transgender women and girls dominating sports. For years, numerous state and local policies have supported trans youth playing sports, with little notice or fanfare. Many of the politicians pushing hateful anti-trans laws at the state level could not identify even one trans girl playing school sports in their state, much less “dominate” in the sport. To date, there is no reliable evidence that transgender athletes have a competitive advantage, or that transgender athletes pose a threat to their cisgender peers’ safety.

In fact, trans-exclusionary policies perpetuate sex stereotypes and lead to harmful and inappropriate scrutiny of all girls’ bodies. Advocating for anti-transgender policies puts both transgender and cisgender people at risk of being subjected to gender-based violence. This includes "sex verification" practices, which refers to forcing women and girls in sports to undergo a variety of humiliating and invasive tests and examinations, including hormonal and chromosomal testing, genital exams, and even pressure to undergo unwanted medical procedures–-all for the purported purpose of “proving” whether they are “really” a woman or a girl. These practices are unscientific, unnecessary, and expose youth to trauma, harassment, and abuse. Banning trans athletes makes all girls and women in sports less safe by promoting practices that scrutinize their bodies, traumatize them and violate their privacy, and expose them to harassment. 

If legislators truly wanted to protect women in sports, encourage leadership among women in environments that are for women and by women, they would be focusing on the years of efforts and struggle to improve Virginia schools’ reporting of Title IX compliance, increase funding for women and girls’ in sports whether cis or trans, and support the development and leadership of female coaches. Anti-trans sports bans do not just impact transgender athletes, but athletes of all genders whose bodies are subject to ridicule and examination if they don’t fit arbitrary stereotypes. Exclusionary policies promote the idea that it’s acceptable to question whether someone is a “real” woman or girl simply because they’re especially tall, strong, muscular, or “too good” at their sport—which hurts all women and girls by punishing them for defying stereotypical notions about gender. For example, in 2024, a Utah State Board of Education official publicly questioned the gender of a 16-year-old cisgender girl participating on a high school basketball team. As a result, the student was subjected to harassment, bullying, and threats of violence, necessitating police protection for herself and her family. These bans especially harm intersex, Black, and brown girls and women who fall outside stereotypical or white standards of femininity. Excluding transgender, nonbinary, and intersex athletes from sports participation inflicts more harm on an already marginalized group, and does nothing to promote safety, inclusion, or fairness. 

In denying transgender young people the ability to play sports with their peers, the Virginia Board of Health puts all students at risk of harassment, scrutiny, and discrimination. Sports allow young people to learn to work together and to challenge themselves in a safe and supportive environment. Every student deserves the chance to play with their friends – it’s really that simple. This attempted ban on transgender students’ sports participation and locker room access is a cruel attack on young people everywhere who just want the chance to exist and to grow up in peace. Advocates for Youth stands firmly in our unwavering support for transgender young people and to protect their unfettered access to education and fairness.