Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations Governing Biological Sex Specific or Separated Spaces and Activities [12 VAC 5 ‑ 660]
Action Promulgate Regulations Governing Biological Sex Specific or Separated Spaces and Activities
Stage NOIRA
Comment Period Ends 12/17/2025
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12/7/25  11:08 am
Commenter: An Anonymous Virginian

An Opposition to Proposed Action 4905
 

I am a woman living in Richmond, VA, and I oppose Action 4905.

The Board of Health has no business labeling groups of people harmful based on who they are, and I feel ashamed as a Virginian that this policy (and other harmful ones like it) are being considered by our state at all.

There are real public health issues facing women and girls in Virginia, like domestic violence, maternal health, and poverty. Don’t let this hateful petition distract from your important mission to protect the health and promote the well-being of ALL people in Virginia.

Across our races, backgrounds, and genders, we all deserve to be treated fairly. There is a nationwide effort by some politicians and interest groups to force transgender people and LGBTQ+ people out of public life. These political attacks harm us all, whether we’re gay or straight, transgender or not, because they foster discrimination and distract us from the real problems we face. 

I have lived in Virginia my entire life, across different areas of this wonderful state. Growing up in Hampton Roads, I enjoyed playing sports and going to the gym.  Attending university in Southwest VA, I continued my athletic hobbies by hiking and playing soccer. Since moving to our captial in Richmond, I'm still an athlete as an avid cyclist, climber, and kayaker.

All across our state, I've played sports alongside people of all genders, from co-ed soccer teams to co-ed bike races where gender is largely ignored as a factor. I've changed in dressing rooms alongside men and women, both transgender and cisgender. At no point have I ever felt threatened or uncomfortable. At no point did I feel as though a transgender athlete had any physical or innate advantage over me. Every competitor I faced who beat me in a competition did so because of their own hard work, not some innate advantage, regardless of gender. From my perspective, these people just wanted to enjoy the sport and activities as I was, and they wanted to feel safe and accepted in their athletic communities. For many of them, accepting and diverse sports teams or bike groups were some of the only places they felt included and comfortable in their daily lives.

I oppose proposed action 4905 because it will prevent Virginians from being able to connect with communities that support them while doing absolutely nothing to "protect women's health." As a woman, my health has never been negatively impacted by a transgender athlete as my competitor or teammate, nor by using a changing room with a transgender athlete.

While this action would not protect women's health in any way, it would actually harm Virginians of all genders by forcing transgender people into dressing rooms that don't align with their gender. In most circumstances, gender neutral or individual changing rooms are not an option. As such, transgender women may be forced into dangerous circumstances if they must use a men's changing room. Likewise, transgender men could make women uncomfortable by being forced to use a women's changing room.

This proposed regulation would also be difficult, if not impossible, to enforce without imposing on people's privacy and bodily autonomy. Many transgender people are indistinguishable from cis people in most ways, as there are many  physical variations among human beings. The primary way transgender and intersex bodies differentiate from cisgender bodies is by a person's genitals, though even this is fallible. This can, and already has in some areas of the United States, led to people demanding to see a person's genitals for them to "prove" their gender, and thus their ability to use certain spaces or join certain groups. This has also happened to cisgender women who were mistaken for being transgender. Ultimately there would be no other way to enforce this action without forcibly exposing people's genitals, which is sexual assault and is illegal.

This proposed regulation has nothing to do with the health of Virginians and everything to do with discrimination. No one should face discrimination because of who they are. Trans people have always been here, and always will be. Trans people cannot and will not be erased.

For the health and dignity of all Virginians, please reject proposed action 4905.

CommentID: 238499