Written evidence submitted by Ms   Allen [GRA1349]


Gender Recognition Act Call for Evidence

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

No. Gender Identity is not a concept that exists in British Law. Removing the requirement to be diagnosed with a medical condition (gender dysphoria) makes gender identity ideology part of British law. I do not believe that beliefs that are based on faith or personal opinion should be codified into British law. Unlike the concept of biological sex, the idea that all people have an innate ‘gender identity’ is a faith based belief.

Removing the diagnosis of gender dysphoria will also make it easier for predatory men who wish to access women’s spaces to get a GRC.

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

No. This would make it much easier for predatory males to access women’s spaces by ‘identifying’ as women. As a woman I am very concerned about males with autogynephilia (that is, men who are aroused by the idea of themselves as women) accessing women’s spaces and using them to fulfil their fetishes.

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?

This provision is required to protect partners who do not want to remain in a relationship with a transitioning partner. This provision needs to be maintained as protection for primarily women who want to end relationships with late transitioning male partners. Transition completely changes the nature of a relationship and is a unilateral action by one partner. Women from more conservative or religious backgrounds may feel that they cannot access divorce due to personal faith or fear of rejection by their family or culture. Thus the necessity for annulment to protect these women remains and it should be retained in law.

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

No. In my personal opinion, it would make more sense to raise the age to 21.

I am a natal female who experienced Rapid Onset Gender Dysphoria (ROGD) at the age of 18. ROGD can be defined as: when teenagers (generally though not always biological females) suddenly express discomfort with their biological sex despite no previous evidence of gender dysphoria. A study on the concept was published by Lisa Littman in 2018. Some people question the concept but it has a strong evidentiary basis, with evidence of ‘clusters’ of trans-identified children in the same friendship groups. My own case of ROGD, which happened at a time when transgender issues were barely even discussed, was caused by a traumatic incident and resolved without any kind of medical intervention, hormones or surgeries – or affirmation of a trans identity. I am not transgender and would have regretted medical transition.

I do not believe that young people have the mental capacity to fully understand the rigours of medical transition. Lowering the age of issue for these certificates would make it easier for children to access irreversible and possibly sterilising treatments (if someone is legally classified as the opposite gender, it seems doubtful that clinicians could refuse to give them cross-sex hormones).

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?

It needs to be made clear that single sex spaces such as toilets are protected under law. There seems to be a large amount of confusion on this issue, for example Stonewall guidance for schools states that it is legally required under the Equality Act 2010 to allow transgender identified students to use the facilities of their chosen gender. In fact single sex toilets are legal in order to make women and girls feel safe and to reduce the threat of male violence. ‘Gender identity’ is not a category that exists in British law and is not protected under the Equality Act –only ‘sex’ and ‘gender reassignment’ are protected categories. This needs to be made clear to all schools and service providers in order to protect women and girls from male perversion and male violence.

November 2020