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Virginia Regulatory Town Hall
Agency
Department of Education
Guidance Document Change: The Model Policies for the Treatment of Transgender Students in Virginia’s Public Schools guidance document was developed in response to House Bill 145 and Senate Bill 161, enacted by the 2020 Virginia General Assembly, which directed the Virginia Department of Education to develop and make available to each school board model policies concerning the treatment of transgender students in public elementary and secondary schools. These guidelines address common issues regarding transgender students in accordance with evidence-based best practices and include information, guidance, procedures, and standards relating to: compliance with applicable nondiscrimination laws; maintenance of a safe and supportive learning environment free from discrimination and harassment for all students; prevention of and response to bullying and harassment; maintenance of student records; identification of students; protection of student privacy and the confidentiality of sensitive information; enforcement of sex-based dress codes; and student participation in sex-specific school activities, events, and use of school facilities.
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1/8/21  5:49 pm
Commenter: Shannon Mills

Opposed
 

As a former public high school teacher, observing and enforcing many of these proposed regulations seems problematic to impossible.  If a student considers his/her gender to be fluid, he/she could change it daily thus making it difficult to impossible for teachers and fellow students to keep up with "preferred pronouns."  This is a serious concern if failure to do so means risking disciplinary action for "harassment."  

The language regarding parental authority vs. school authority on this matter is very concerning. “School staff should be prepared to support the safety and welfare of transgender students when their families are not affirming. … Whenever school personnel suspects or becomes aware that a student is being abused, neglected, or at risk of abuse or neglect by their parent due to their transgender identity, they should report those concerns to Child Protective Services immediately.” (Recommended Standard, p.13). Would encouraging one's child to embrace their biological sex/gender be construed as abuse or neglect?  Could a parent be reported for neglect for not providing a second wardrobe for a child who has decided to "transition?"  Likewise, the “School divisions will need to consider the health and safety of the student in situations where students may not want their parents to know about their transgender status … There are no regulations requiring school staff to notify a parent or guardian of a student’s request to affirm their gender identity...” (Recommended Standard, p.12) raises concern.  If parental consent is required to excuse an absence or approve a field trip, it would seem negligent of the school system NOT to inform parents if their child was considering or exploring gender reassignment under the guidance of school counselors, health personnel, etc.  

If the guidelines are enacted as proposed, you WILL have students taking advantage of these policies to gain access to restrooms and locker rooms of the opposite sex; individual restrooms and individual changing stations in the locker rooms would become the only way to protect the safety and discretion of each student. “Access to facilities such as restrooms and locker rooms that correspond to a student’s gender identity shall be available to all students.” (Draft Policy, p.18) 
“School staff should not confront students about their gender identity upon entry into the restroom.” (Recommended Standard, p.18). 

Lastly, the policies provide absolutely no exceptions or accommodations for a student or teacher whose religious faith, conscience, or understanding of biology and sociology prevents them from being able to go along with the “transgender” ideology and policies.  

As a teacher and as a mother sending her children to public school, I oppose this draft of trans policies and advise that language revisions be made, parental information and consent policies be reconfigured, and consideration be given to protect religious liberties within the school system. 

CommentID: 89119