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Comment Period Regarding Policies for Transgender Students in Virginia’s Public schools is Open Now

January 5, 2021


Dear Arlington Parent Coalition members,


We sent an alert to APC members on December 28th about the Virginia Department of Education (DoE) model policies on the accommodation and affirmation of transgender students.

An open comment period regarding Model Policies for the Treatment of Transgender Students in Virginia’s Public Schools is open now until February 3, 2021.


Arlington Parent Coalition urges all parents to submit their concerns

ACTION: Click HERE to enter a comment on the townhall.gov website, and tell VDOE you do not approve of their proposed guidelines based on radical theories that eradicate all distinctions between male and female and indoctrinate our school children. While there are plenty of reasons to oppose these guidance policies, here are TEN* that will help you form your comments:


1. Failure to use a student’s new “preferred pronouns” – which can change from day to day and even defy basic rules of grammar (“ze/hir/hirs”, “they/them/their”) – would be “harassment” and “discrimination”, for which both faculty and students would be subject to disciplinary action. “For transgender students, acts of verbal harassment may include the intentional and persistent use of names and pronouns not consistent with their identity.” (Recommended Standard, p.10) “A school administrator may need to direct school staff to abide by the wishes of a student on their asserted name and pronoun. A school employee’s intentional and persistent refusal to respect a student’s asserted name and pronoun is considered discriminatory.” (Recommended Standard, p.12) “Complaints alleging discrimination, harassment, or bullying based on a student’s actual or perceived transgender status shall be handled in the same manner as other discrimination or harassment complaints.” (Draft Policy, p.10)


2. Schools will be permitted to help a student explore, facilitate, and make decisions regarding their gender expression of sexual identity while at school, without a parent even knowing! “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)


3. The definition of “Gender identity” is completely subjective to each person claiming it, hence it cannot possibly be known by anyone except that person. Since it cannot be tested or ascertained by any objective method, nothing could prevent any student from constantly “changing” his or her “gender identity” to exploit many situations. “Gender Identity: A person’s internal sense of their own identity as a boy/man, girl/woman, something in between, or outside the male/female binary. Gender identity is an innate part of a person’s identity and can be the same or different from the sex assigned at birth.” (Definitions, p.6) .

4. Parents who encourage their children to embrace their biological sex would be at risk of being reported for child abuse or neglect by the school. “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) 5. Students will be allowed to claim to be either a biological male or female (or both, neither, or something else entirely) for any duration of time, without providing any evidence to a teacher or administrator, making it impossible for teachers to comply with these policies. “A student is considered transgender if, at school, the student consistently asserts a gender identity different from the sex assigned at birth… it does not necessarily require any substantiating evidence nor any required minimum duration of expressed gender identity ...” (Recommended Standard, p.12) “Schools shall allow students to assert a name and gender pronouns that reflect their gender identity without any substantiating evidence.” (Draft Policy, p.13)


6. Schools would be prohibited from notifying parents if a biological male is using the same changing facility as their daughter that was designated for girls. “In addition to adhering to all legal standards of confidentiality, school personnel shall treat information relating to a student’s transgender status as being particularly sensitive, shall not disclose it to other students and parents, and shall only disclose to other school personnel with a legitimate educational interest.” (Draft Policy, p.12)

7. All students will be allowed to use any bathroom or locker room they choose, without being questioned by any school administrator or faculty, eliminating privacy and safety of students in states of undress. “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)

8. The requirements for schools to maintain gender-neutral dress code standards will cause disruptions and distractions, permitting boys to wear skirts and girls to go topless in activities where boys can – such as swimming activities or teams. “Students have a right to dress in a manner consistent with their gender identity or gender expression. Schools shall administer and enforce dress and grooming codes consistently across the student body, regardless of actual or perceived gender identity or gender expression. Requirements for attire for school-related programs, activities, and events shall be gender-neutral.” (Draft Policy, p.16)

9. Parents will not be notified that their child is being interrogated by school officials for allegedly violating these policies, or have the opportunity to intervene on their child’s behalf UNLESS the complaints are not resolved “at the school level.” “Any incident or complaint of discrimination, harassment, or bullying shall be given prompt attention, including investigating the incident and taking appropriate corrective action, by the school administrator. …The [School Division’s Designated Contact] shall be available to hear concerns from students or parents when complaints are not resolved at the school level.” (Draft Policy, p.10)

10. 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.


These troubling policies proposed by VDOE are totally unworkable and will force all students, faculty, and administrators to comply with an empirically false view of sex and gender, even if it directly conflicts with their own fundamental beliefs.


* Points of concern written by The Virginia Family Foundation in their January 4, 2021 blog post.


Thank you for helping to protect children in Arlington County and the Commonwealth of Virginia.


Arlington Parent Coalition.



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