Written evidence submitted by Nic Turner (GRA0107)


Women’s and Equalities Committee GRA Reform Enquiry – Nic Turner Submission

Dear committee members,

My name is Nic Turner, I’m the national lead of a LGBTI+ staff support network (with over 5,000 members) in a public sector organisation and I’m a happily married lesbian. I am submitting evidence to this enquiry as an individual, for several reasons;

  1. I believe that it is important that the Government handling of the GRA consultation and reform needs to be scrutinised. It took far too long and lacks clarity on how decisions were reached.
  2. The delays around the consultation created a vacuum which allowed large scale campaigns of misinformation and fearmongering to stoke a “culture war” and led to LGBTI+ peoples existence and lives been treated as a “debate” which has had a dehumanising and deeply damaging effect on the LGBTI+ community.
  3. Numerous pieces of evidence which already exist from the; previous Women’s & Equalities inquiry into Transgender issues, National LGBTI+ survey, Government LGBT action plan and GRA consultations in both Scotland and England & Wales – which sought to directly consult with the LGBTI+ community about issues and needs appear to have been ignored.
  4. I have grave concerns that unless there is enough scrutiny and appropriate action, the damaging effects on all within the LGBTI+ community will worsen.
  5. There are several groups claiming to speak on behalf of all females and lesbians, who certainly do not speak for me and I have my own voice.
  6. I have followed LGBTI+ issues & legislation for several years, submitted to all the GRA consultations & LGBTI+ survey and have a more in-depth knowledge than most people about LGBTI+ issues, inclusion and various points you are likely to see raised in this enquiry. So, I feel that my evidence could be helpful to this enquiry.

I will start by answering the questions you’ve posed regarding the GRA reform proposals, before moving onto the questions about wider transgender equality and current legislation, where I will outline my concerns in more detail.

The Government’s response to the GRA consultation

The Government’s proposed changes of moving the process to an online one, reducing the £140 application fee to a nominal amount and opening 3 new gender clinics, does not meet its aim of making the process kinder or more straightforward. It instead represents a standstill; the 3 new clinics were announced a year earlier and are in no way enough to address the significant waiting lists for clinics. Reducing the application fee is the bare minimum that could have been done and does nothing to address the bureaucracy that currently presents a variety of issues to applicants, neither does moving the process online – all it does is retains the same system just on a different medium.

The fee for obtaining a Gender Recognition Certificate should be removed, there are a range of costs and financial burdens on applicants. As GIRES (https://www.gires.org.uk/obtaining-your-gender-recognition-certificate/ ) details applicants must provide a range of documentation with their application, all of which come at a cost, these are:



2 x detailed medical reports about their gender identity. Approx. £50 each


Statutory Declaration/Deed Poll confirming name change


Copy of Birth Certificate


Driving licence or passport

£43 or £85.50

If married/in civil partnership, copy of marriage/partnership certificate


If married/in civil partnership, statutory declaration of consent from spouse


Special delivery for sending items to panel



£167.25 - £224

The current application fee combined with the documentation costs means a person applying for a Gender Recognition Certificate faces having to find £307.25 - £364 just to apply to a panel of strangers they never meet who decide whether they are “trans enough” for recognition from documents received.

A report by LGBTory, highlighted that, in a survey conducted by the international transgender and intersex group T-Vox, 28.57% of transsexual respondents stated their spouse has made getting a divorce difficult. Almost 44 percent of respondents to the survey reported their spouse having actively attempted to prevent their partners transition.
https://www.lgbtconservatives.org.uk/sites/www.lgbtconservatives.org.uk/files/report_to_the_consultation_on_the_spousal_veto.pdf A direct quote from this report is “Providing spouses with a veto over their transitioning partner’s legal gender does nothing to protect the non-transitioning spouse. The spouse has no say over the medical process that usually leads up to gaining a gender recognition certificate and they have two years from the start of the transition process to the time when a transsexual person is eligible to apply for a GRC in order to determine whether they want the marriage to continue or not. The inclusion of the spousal veto in the Marriage (Same Sex Couples) Act has provided another weapon for the arsenal of malicious spouses, without any benefit or protection to transgender people and non-vindictive spouses. It is unjust, it is unwarranted, and it should be removed.”

In addition the outlawing non-consensual “normalising surgery on intersex infants, which has been classed as torture by the United Nations: https://www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session22/A.HRC.22.53_English.pdf should have been included, this has been outlawed in several countries including; Malta, Chile & India. The Maltese Gender Identity, Gender Expression and Sex Characteristics Act 2015 is progressive legislation, that I feel we should aspire to: https://tgeu.org/wp-content/uploads/2015/04/Malta_GIGESC_trans_law_2015.pdf

Wider issues concerning transgender equality and current legislation

For the final part of this section, I have re-arranged the order of questions and will outline my concerns first to provide context for my answers.

I am concerned about the inclusion of questions about the Equality Act provisions, because the GRA consultation was solely regarding the GRA, but the delays in the announcement of a consultation and start of the consultation process created a vacuum where numerous Trans hostile groups formed – Woman’s Place UK & Fair Play for Women (2017), Transgender Trend (2018), Safe Schools Alliance, Fair Cop & LGB Alliance (2019) all formed with stated intentions to oppose Trans inclusion (as outlined on their websites), but have attempted to present themselves as representing women, children and LGB people to gain legitimacy. These groups have been responsible for widespread campaigns of misinformation falsely representing GRA reform to attack Trans people’s rights which already existed under the Equality Act.

Their campaigns of misinformation have been aided and abetted by media outlets which have recycled 1980’s homophobic headlines about Lesbians been a danger to women and debates about banning them from Women’s sports and facilities, just replacing the word lesbian for transgender. The onslaught of negative media reporting over the past 2 years has been relentless and increasingly hostile, which has recently started to extend to the wider LGBTI+ community, which has been seen with the recent BBC restrictions on staff attending Pride and Telegraph publishing articles targeting Public Sector Organisations participating in the Stonewall Diversity Champions Programme – this programme is vital for removing barriers to participation and discrimination within employment for LGBTI+ people like myself by ensuring that policies are inclusive (e.g. family leave).

Even more concerningly, these groups appear to have the support of Conservative politicians, with Jackie Doyle-Price and Baroness Emma Nicolson regularly engaging with them on social media and Robert Jenrick who has recently announced this following review into toilet provision containing numerous transphobic dog-whistles and targeting gender-neutral facilities: https://www.gov.uk/government/news/government-review-to-boost-the-provision-of-toilets-for-women-and-men

The most concerning connections these groups have are with the Equalities Minister Liz Truss. On twitter she doesn’t follow any LGBT+ organisations other than LGBTory but follows:

The influence of these organisations over Liz Truss was demonstrated in May this year when a GEO funded Equaliteach Free to be LGBT+ inclusion schools pack was released, within hours of it’s release Maya Forstater released a tweet tagging in Woman’s Place UK, Transgender Trend, LGB Alliance and Liz Truss complaining about it. Liz Truss responded to them denying it was supported by the GEO, which was followed by a later tweet from the GEO denouncing the pack, which led to Equaliteach been told to remove the logo and having to release the following statement & links to the funding announcement to defend their reputation: https://equaliteach.co.uk/equaliteach-statement-on-geo-and-free-to-be/

Furthermore, given that Woman’s Place UK released a statement on 24/04/2020 following the deeply troubling statement from Liz Truss on 22/04/2020 which indicated a potential rollback in Trans rights, citing several meetings they’d had with the GEO (https://womansplaceuk.org/2020/04/24/wpuk-response-liz-truss-statement-women-equalities/amp/?__twitter_impression=true )

The relationships the Equalities Minister has with these organisations and influence they’ve had on decision making to ignore wider consultation results need scrutinising by this committee and addressing.

The Equality Act offers much needed protections to all minority groups, however the handling of the GRA consultation and transphobia which has been able to thrive in the UK over the past 2 years demonstrates that the protections aren’t adequate – the year on year above average increase in hate crimes based on sexual orientation & trans status evidences this. Online Trans hostile pressure groups have been able to influence serving government ministers into ignoring the results of direct consultation with LGBTI+ communities, denouncing work undertaken as part of the Government LGBT action plan and threaten the rollback of Trans rights, along with attempts been made at this by ministers, which the Home & Communities toilet provision review demonstrates. Public broadcasters (the BBC) have regularly platformed Trans hostile speakers, removed Trans organisations from support lists, amended LGBTI+ content with commentary from Trans hostile groups claiming impartiality and issued notices to staff telling them they can’t attend pride events which breaches their Human Rights. In addition, public bodies such as the General Pharmaceutical Council have enacted actions without due care that have directly harmed Trans people. Reforms are needed that specifically outlaw; the spreading of misleading information by media outlets, immediate actions been taken without due regard by public bodies, ignorance of direct community consultations by government and transparency in to government ministers associations & meetings regarding equalities issues.

I sincerely hope that this enquiry holds the Government to account regarding it’s handling of the GRA consultation, decision-making regarding this and damage that has been caused to the LGBTI+ community as a result in terms of impact on mental health and safety. Furthermore, I hope that it addresses the Government’s rejection of numerous consultation results and commitments outlined in its own Government LGBT action plan. Otherwise I fear that the actions we have seen so far will further escalate due to emboldening those seeking to repeal of LGBT rights, protections and inclusion in the UK. As a LGBTI+ person, I do not want this to happen as it will have a devastating effect on friends, family, colleagues and community, not just on our ability to live freely as ourselves, but also further detriment to our health (both mental & physical) and safety.

Yours sincerely,

Nic Turner

November 2020