Written evidence submitted by Miss Emma Bateman [GRA1987]


The Government’s response to the GRA consultation:

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

It makes sense to move the majority of the GRC submission process online, nevertheless it is imperative that the requirement that a diagnosis of gender dysphoria is retained , and this should be done in person.

The proposals to open 3 new gender identity clinics is welcome. There is clearly a need for them if the long waiting times reported are true. However, I would add a caveat that all gender identity clinics must be able to thoroughly explore alternatives to the gender affirmation model . The reports coming out about the Tavistock clinic , where 35 staff have resigned over a short period, are extremely disturbing. As Marcus Evans, who resigned from the Tavistock board because of the push towards employing the affirmation model, suggested a 'therapist must resist the temptation to suspend curiosity, uncritically accept the patient’s presentation at face value, and then act as an “affirming” cheerleader for life-changing acts of transition. '

It is profoundly disturbing to learn that confused teenagers are being herded towards puberty blockers, hormones and eventually surgery without a thorough exploration of other ways of treating their mental distress or gender dysphoria.


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?

I do not believe that the fee should be removed. I have heard it said that the fee is prohibitive, however for people on benefits and low incomes, the fee is waved or reduced already (which is reasonable), So the people having to pay should have the means to do so. It is not a huge amount – something akin to a TV licence .

Allowing any male to identify as female and thus allow them to inhabit female spaces, has an impact on women that is not trivial.

It should not be a trivial matter to transition. The process should be serious and rigorous, and it is reasonable that one of the hurdles in a fairly modest fee.

I have seen suggestions that services such as hair removal should be covered by the NHS.
I disagree. Women pay for such services.


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

No it should not. It seems to me that trans tenets straddle seeing trans as medical – a painful condition for which a prime solution is  drugs for life and surgery, and trans as  unremarkable – no need for gender dysphoria, everything is just about want and feels, and no necessity to adapt or change anything other than pronouns.

The logical conclusion of the removal of any kind of professional psychological assessment along with the relaxation of all the other boundaries is that it will become perfectly normal to see males in women's spaces – they will not be challenged by women . There would be no point in complaining .

Women do not tend to challenge males who are strangers.

If being trans is a particular condition that removes all convention over sex segregated spaces that have afforded protection , privacy and dignity to women , it should at least require a diagnosis .

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

First it would be useful to know what is meant by living in a particular gender . I live as a woman only because I am a woman and so I can't live as anything else, but if I was asked what it means to live as a woman, what the essentials are, I don't know what would be the universal factor (other than biology!). Obviously, there is the fact that we generally do more of the caring, own less, earn less, and are responsible for only 2% of violent and sexual crimes as opposed to the mens 98%.

Beyond that, I think the requirement should stay. Particularly because it gives a space for young people to change their minds before changing their bodies. As Marcus Evans said:

“When doctors always give patients what they want (or think they want), the fallout can be disastrous,... And there is every possibility that the inappropriate medical treatment of children with gender dysphoria may follow a similar path.”


What is your view of the statutory declaration and should any changes have been made to it?

I have no faith whatsoever in the statutory declaration, in part because as indicated  above, there is no prescribed  way to live as a woman or man. It would be unworkable to arrest someone for not adhering to an undefinable gender identity.

There appears to be very little consequence to breaking a statutory declaration, even if it could be policed.

It is clear that males are able to claim themselves as females regardless of how they behave. There are numerous instances of male rapists, sex offenders etc. being recorded as female. Sexual violence is definitely not a female trait.

The statutory declaration also leaves de-transitioners in a fix. The low statistics from stonewall of detransitioning rates have been debunked and there is likely to be a rise in the number of young women detransitioning as a consequence in the 4400% rise in transitioning rates.

A person with a GRC who subsequently de transitions is then breaking the declaration .


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

Definitely not. Young people are still changing and exploring who they are and they do not need to be locked in to signing the declaration. If they can transition socially , and change their other day to day documents . The breathing space for changing minds is essential . It is already known that beginning puberty blockers traps a child into moving on to hormones.

The repressive and aggressive atmosphere has curtailed studies into aspects of transitioning such as the rapid rise in girls transitioning, and the phenomenon of Rapid Onset Gender Dysphoria . It is imperative that open and accurate data can be collected and studied so we have an insight into what young people are going through.  

Making a declaration should have the effect of making a person more cemented in their transition, and that is not sensible to do to young people.

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

A comprehensive study into how this will effect women and girls , (and perhaps a study  into why men find it so difficult to accept non conforming males )

It would be useful to have a commitment to using accurate language and terminology and ensuring that in surveys people understand what is meant by the different terms for example how transsexual differs from transgender.


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?

A GRC is not a necessity for most peoples day to day lives. It is impossible to challenge anyone's gender identity anyway. Asking to see a GRC is forbidden, and a person can change their birth certificate , driving licence etc. without a GRC, so I suppose people do not bother getting them.


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.

Most certainly. The acts can be misinterpreted , the language is muddled , with sex and gender being conflated. It is a fudge.

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?

No. there is a  lot of confusion over which circumstances the single sex exemptions can be applied in. In reality , because a GRC cannot be asked for , they don't work in practice because someone presenting at a woman's shelter for example cannot be asked to show a GRC.

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

It does not adequately protect women and girls or sex segregated spaces. Women are an afterthought.

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

Social change  rather than legal reforms are what are needed  to widen the band with of what men and women can be. Men in particular should learn to accept men who want to express themselves in traditionally feminine ways.

November 2020