Written evidence submitted by Ms Susan Green [GRA1301]



Community Consultant Specialist Handsworth Birmingham


GRA Consultation and Review of Gender Recognition Process.

How inclusive was the original 2018 GRA Consultation Process?

The people in my area were not consulted and are not aware of the review of the Gender Recognition Consultation,this Review or the impacts it may have on their lives, especially the lives of women and children.

I live in Handsworth Birmingham, a densely populated, majority BAME, inner city working class area, I have, for twenty years, actively participated in community events,consultations, local campaigns and for ten years I was Secretary of my residents group Grove Residents Association. In my professional capacity I have worked for third sector agencies like People & Organisations and Departments in Public Sector across the UK on delivering effective community consultation & participation with hard to reach groups. Since the 2018 Public Consultation on Gender Recognition I have not found a single resident in my area who knows anything about Gender Self ID, Transgender, or the changes happening locally that have resulted for instance in the women's toilet near the main entrance at our local hospital being converted to mixed sex aka gender neutral facility. Many older local women do not have English as a first language and literacy levels are generally low across our population.

With Gender Recognition Reform the Government seeks to make significant law changes that have real world impacts upon all aspects of life for women and children. I urge you to take time. To reflect on who else has a stake in these changes other than those men who self identify as women. Do not the millions of women citizens who will be impacted by the changes under review, who are currently wholly unaware of what is going, on deserve consideration?

        The 2018 Public Consultation failed to reach the majority of UK citizens.

        The process of drawing up the terms of reference of the consultation was too biased in favour of those with a vested interest in seeing a particular outcome.

        The delivery of the consultation process was inadequate. In particular it made no attempt to engage with and reach out to working class women from BAME communities.




The Gender Recognition Review.

This Review follows on from the poor quality 2018 Public Consultation. Once again we see an in built bias that assumes these proposed law changes mainly concern those declaring themselves transgender. This is simply not true. These law changes are hugely significant to women. Women currently have the right to set their own boundaries and have these upheld in law. These Rights are Sex based. Sex is clearly defined, backed by millenia of empirical evidence. Gender is not the same as Sex. Redefining Women as a Gender category in UK law, open to anyone who chooses to opt in regardless of their Sex, renders our protections and rights useless.

                    Will the Government’s proposed changes meet its aim of making the process “kinder and more straight forward”?

'kinder' is too vague a term to be useful in this context. Processes need to be accessible and easy to understand.

                    Should a fee for obtaining a Gender Recognition Certificate be removed or retained? Are there other financial burdens on applicants that could be removed or retained?

Retained. It is not a lot of money compared to what it costs for other health documents; vaccine certificates, passports, GP letters.

                    Should the requirement for a diagnosis of gender dysphoria be removed?

No. The massive spike in numbers of teenage girls in UK between 2016 and 2020 who are presenting with rapid onset of gender dysphoria is a red flag. It needs further investigation. The process of transition is physically and emotionally traumatic it should be slow, considered and individuals given proper support and counselling.

                    Should there be changes to the requirement for individuals to have lived in their acquired gender for at least two years?

No. This process should be slow and considered not rushed.

                    Does the spousal consent provision in the Act need reforming? If so, how? If it needs reforming or removal, is anything else needed to protect any rights of the spouse or civil partner?

No. Wives of those men who seek to transition and live as opposite Sex have the right to say no, this is not the relationship I signed upto. Marriage & Civil partnerships are legal contracts between individuals. One partner cannot unilaterally change the nature of that contractual relationship.

                    Should the age limit at which people can apply for a Gender Recognition Certificate (GRC) be lowered?

Absolutely not. Gender identity ideology has exploded over a short period of time, we need to monitor and proceed with caution especially where young people are involved.

                    What else should the Government have included in its proposals, if anything?

A promise to undertake a thorough in depth review of all aspects of  the impacts of gender identity ideology before proceeding with law change and not rely on the original 2018 Public consultation which was badly handled.

                    Does the Scottish Government’s proposed Bill offer a more suitable alternative to reforming the Gender Recognition Act 2004?

NO.  Scottish Government Bill has been drawn up in consultation with funded gender identity groups and excluded women's groups from the process, the data used to draw up the Bill is inadequate.

Wider issues concerning transgender equality and current legislation:

                    Why is the number of people applying for GRCs so low compared to the number of people identifying as transgender?

Because most of those identifying as Transgender are not gender dysphoric. Many are young and exploring identities. Over 85% of those men who identify as women seek no change to their bodies ie they're transvestites or autogynephiles.

                    Are there challenges in the way the Gender Recognition Act 2004 and the Equality Act 2010 interact? For example, in terms of the different language and terminology used across both pieces of legislation.

              YES. More than anything else this review needs to clearly define it's key terms; Gender, Sex & Transgender. The conflation of Sex and Gender is confusing and unhelpful. In use,Transgender functions as an umbrella term, it may include; Gender Dysphorics, those with Variations in Sexual Development               and autogynephiles. Transgender needs a clear legal definition that               allows us to distinguish it's members  and their specific needs from others.

                    Are the provisions in the Equality Act for the provision of single-sex and separate-sex spaces and facilities in some circumstances clear and useable for service providers and service users? If not, is reform or further guidance needed?

Retaining Sex as a protected characteristic is vital as is clarifying the difference between Sex and Gender. Misrepresentation of the protected characteristics of the 2010 EQ Act is widespread. Shockingly even amongst key government departments like Justice. This needs sorting asap. 

                    Does the Equality Act adequately protect trans people? If not, what reforms, if any, are needed

Yes. Transgender citizens currently enjoy the same rights, protections and freedoms as every other citizen.

                    Are legal reforms needed to better support the rights of gender-fluid and non-binary people? If so, how?

NO. They enjoy the same rights as everyone else.


November 2020.