Written evidence submitted by Lucy Cowlin [GRA1758]


Written evidence submitted by Lucy Cowlin.

I am a member of Gender Recognition Act Reform/Repeal Group (https://gcritical.org/2020/10/05/the-grarg-manifesto).
This submission is written in a personal capacity.

Key Points

  1. Modern transgender ideology redefines women to include men
  2. Men are thus being included in women’s spaces, being reported as women and taking women’s places in women’s sports, and most worryingly in prisons and refuges.
  3. This was facilitated by having a law which allows a person to change the sex on their birth certificate and have a legal sex which does not match their actual sex.
  4. Laws need to be based on reality and truth

Why am I responding to the call to evidence?

I am a woman who is concerned that women’s rights are under threat due to lack of sticking to reality when it comes to transgender issues.

My evidence

Wider issues concerning transgender equality and current legislation:

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.

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?

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

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

  1. I am addressing these questions together because I believe the problem is broader than that specifically covered by the Gender Recognition Act 2004 (GRA2004) and the Equality Act 2010 (EA2010). In practice, there has been the promotion of a transgender ideology which has both damaged women’s sex-based rights and doesn’t support people with gender dysphoria in a helpful way.
  2. The GRA2004 and Gender Reassignment as a protected characteristic in the EA2010 were both an attempt to help people diagnosed with gender dysphoria, those people known as transsexuals.
  3. In recent years, the word transsexual has gone out of fashion and has been replaced by transgender or just trans. The meaning has fundamentally changed from the meaning of transsexuals. The Stonewall definition of transgender includes the ‘old school’ transsexuals and also includes anyone who is gender non-conforming in any way, including cross dressers (https://www.stonewall.org.uk/what-does-trans-mean). I definitely fall into the Stonewall definition of trans as the female gender role, which I perceive to mean wearing makeup, high heels, interested in shopping, is not something I identify with. Indeed, years ago I did wonder if I was ‘more male’. I now realise I am simply gender non-conforming.
  4. In common usage ‘trans’ and ‘transgender’ now just mean whatever a person wants it to mean, I have seen articles about people being ‘trans non-binary’, ‘gender queer’, ‘gender free’ and many more. The BBC created PSHE content for schools stating that there are more than 100 gender identities (https://www.express.co.uk/showbiz/tv-radio/1176524/ITV-GMB-Piers-Morgan-cis-man-gender-identity-debate-Susanna-Reid-video-watch). The problem is that none of these are based in any kind of reality, it’s impossible to confirm or refute someone’s gender identity, it is simply something someone states about themselves.
  5. Throughout this document I use the following definitions as this is how the words are commonly used and understood.
    Woman: an adult human female.
    Man: an adult human male
  6. I believe using terms such as ‘trans woman’ are unhelpful when describing a man because the brain automatically thinks a type of woman is being discussed, and of course a woman should be in women’s spaces. The words we use are extremely important. The linked document ‘Pronouns are Rohypnol’ explains exactly how powerful words can be. https://fairplayforwomen.com/pronouns/#:~:text=Pronouns%20are%20Rohypnol.%20They%20change%20our%20perception%2C%20lower,differently%2C%20alter%20the%20reality%20in%20front%20of%20us.
  7. Despite the laws (GRA2004 and EA2010) both being clear that ‘legal sex’ is not the same as actual sex, and that ‘legal sex’ does not actually mean ‘for all purposes’ because there are exceptions, organisations such as Stonewall argue that ‘trans women are women’ and as such should be included in all women’s spaces and on things such as ‘all women shortlists’.
  8. Many organisations seem to believe the Stonewall version of the law, and now treat the word woman as meaning ‘woman’ or ‘man who says he is a woman’.
  9. This is corrupting the ability of women to discuss their position in society, is corrupting crime figures and making a nonsense of many news reports. I would describe this transgender ideology as highly aggressive and completely anti-women. I believe the Women and Equalities Committee should carefully consider the effects on women caused by adoption of this ideology.
  10. There are several things happening which make me very concerned for women’s place in society. Firstly, any situation where women are featured now frequently includes men as well as women. This appears to be because a man being given an actual women’s role ‘validates’ their identity.

    Some examples:

(10 cont)

  1. Secondly, many sports organisations are not using the exemptions in the EA2010 Part 14 Section 195 (https://www.legislation.gov.uk/ukpga/2010/15/section/195) to allow for separate competitions for men and women. This is needed because men have physical advantages over women in sports even if they undergo gender reassignment surgery and hormone treatment. Each time a man takes a woman’s place in a sporting activity they are directly disadvantaging the women who would otherwise be taking part in the activity, team or competition.

  1. Thirdly, crimes are being committed by men and are reported as by women in the news. I can only describe this as outrageous.
  1. In contrast, the word woman is much less likely to be used in situations where it cannot be used to validate men in their belief that they are women. This is noticeable on websites/leaflets giving information about women’s health.

(13 cont)

What are the adverse effects of all the above to women?

  1. That the word women is being redefined to include men, so women no longer have a word to describe themselves.
  2. Political positions, leadership courses or STEM scholarships designed to increase women’s participation are being used to reinforce men’s prime position.
  3. Women’s spaces – women’s centres, refuges, single-sex swimming sessions are being made ‘inclusive’ to men, so that some women will respond by not using these previously single-sex spaces. Whenever I see men who say they are women, I simply perceive a man. It doesn’t make sense to create supposedly single-sex spaces then include some men in them, no matter how nice those men are.
  4. Women are at risk of being housed with a rapist if they are put in a women’s prison, this has already happened, and women were, entirely predictably, sexually assaulted.
  5. Crime statistics can no longer be trusted to be accurate, men’s crimes are being recorded as if they were by women.
  6. News reports and court reports can no longer be trusted, they refer to men as women.
  7. Women’s health messages are getting obscured with language such as ‘people who menstruate’, ‘people with a cervix’. It’s easy for highly educated people to not see the problem here, but having worked in education, I am well aware that a significant proportion of society will not realise that this means ‘women’. Health messages need to be as clear and as simple as possible.
  8. Finally, it affects women because anyone who questions the above is considered ‘transphobic’ and attempts are made to silence women who speak out. Indeed, I discussed this issue with my own MP. I used the words woman/man throughout, at no point did he need to ask what I meant. During a civil discussion, he commented that he was aware that I am not free to state my opinion openly. I consider this a shocking admission for an MP to make to his constituent.
  9. I suspect that many of the submissions you will receive from women will be anonymous, and the reason will be that they are fearful of what affect it could have on their career, or that they will be reported to the police for transphobic hate incidents.
  10. The obvious high-profile example of this is JK Rowling. Anyone who has read her article which caused her to be labelled transphobic will find it very considered and sympathetic, but there are endless examples of aggressive language and actual physical threats made online towards her because of it. And even Radio 4 had a programme called Can I Still Read Harry Potter? The implication being that a reasonable person could find what JK Rowling said enough to ‘cancel’ her. https://www.bbc.co.uk/programmes/p08y8x0s
  11. The cases of Suzanne Moore and Selina Todd are both chilling examples of how women are treated if they question transgender ideology, as described in this article by Selina Todd. https://www.thetimes.co.uk/article/a5eb66d6-2a88-11eb-9d71-3a8cfebe9319
  12. At the heart of this issue was the decision to allow a small number of people to have a fake birth certificate to make their life easier. The way the ideology has progressed to the extent that rapists are being put in women’s prisons and men are winning women’s sports could not have been predicted. I believe that the GRA should be repealed and a kinder system of relying on the truth be implemented instead.


  1. The GRA2004 should be repealed.
  2. Guidance around the exemptions in the EA2010 around sports and single-sex spaces should be published.

November 2020