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The Women and Equalities Committee invited individuals and organisations to send written submissions to their inquiry into implementation of UN Sustainable Development Goal 5 in the UK, the aim of which is to end all forms of discrimination against women and girls by 2030, including the elimination of all forms of violence against women and girls.

We submitted evidence that gender identity legislation is incompatible with the stated targets of SDG5 in regard to both the safety and the advancement of women and girls in the UK. The pdf version of our submission can be seen here and the full written text is below:

Written evidence submitted by Transgender Trend (SDG0022)

Transgender Trend is a UK organisation of parents concerned about the medical transition of
gender non-conforming children and adolescents, and the establishment of gender identity as
a legal concept which replaces the reality of biological sex as the distinction between men
and women. We are a non-political, non-religious campaign group.[1] We believe that equality
for housing, employment and physical safety is a basic human right for all and specifically,
equality and safety from male violence is a right for both transgender individuals and
females.

Our submission calls attention to the actual and potential negative effects on girls and women
of current proposed self-declared gender identity legislation which the committee has
promoted without consultation with women and which we believe is incompatible with the
stated targets of SDG5.

It is well-documented that physical and sexual violence against women and girls is on the rise
globally, including here in the UK; it has been referred to as “a global health crisis of
epidemic proportions.” [2] Protection of women and girls must be prioritised in any Government
legislation.

Legislation which prioritises gender identity over sex in classifications of persons as male or
female takes away women’s hard fought sex-based rights and protections under the Equality
Act 2010:

 The threat to current sex-based rights and protections which keep males and females
segregated in public places where women and girls might be physically vulnerable. These
include single-sex facilities and services such as toilets, changing-rooms, rape crisis
centres, women’s refuges, hospital wards and prisons.

 “Gender identity” reinforces the gender and sex-role stereotypes which place girls and
women as subordinate to boys and men. The elimination of these cultural stereotypes is
required by CEDAW Article 5 (a) in recognition that they are detrimental to the health
and advancement of women and girls.

 The meaning of the word “woman” itself is changed from “adult human female” to an
“identity” which any man may adopt. Redefining “sex” (a biological reality) to mean
“gender identity” (a self-defined subjective feeling) renders men legally indistinguishable
from women and extinguishes the independent legal existence of women and girls. The
protected category “sex” under the Equality Act 2010 has effectively been erased.

 The Government’s definition of “transgender” is so wide as to be meaningless; including
cross-dressers, those who define themselves as “non-binary” and “anyone else who may
not conform to traditional gender roles.” [3] As well as the implicit redefinition of women
as a group which does conform to gender roles, the Government posits personality
characteristics as new legal definitions of men and women. It also fails to recognise
autogynephilia [4] as a reason for the transition of a significant number of heterosexual males.

Women and girls cannot be expected to look inside someone’s head to find out how they
“identify.”

The World Health organisation defines “gender” as “the socially constructed roles,
behaviours, activities, and attributes that a given society considers appropriate for men and
women.”

The WHO defines “sex” as “the biological and physiological characteristics that define
men and women.”

To maintain legal status as the female sex is crucial for women and girls.

1. Biological sex is the only definition with established and recognisable characteristics and
boundaries, and is the root of female oppression. Women’s reproductive systems are
controlled through legislation (abortion laws); the sex industry is built on the sale of women’s
bodies; sexual violence is enacted on women’s bodies because of their sex, not their identity;
child-rearing and care work are designated ‘women’s work’ because of female biology, and as
such are undervalued; socialisation of girls into a passive, decorative role begins at birth
because they are the female sex, not because of how they identify; cultural control of
women’s sexuality, from media sexual objectification to harmful cultural practices such as
FGM, is because of women’s sex and not their identity.

2. Females have a right to be safe from male violence and therefore a right to single-sex
facilities and services which exclude males, no matter how they identify. Men who transition
have been shown to retain male-pattern criminality, including for violent crime. [5] An
increasing number of male prisoners convicted of sex crimes are seeking transition. [6] We see
more stories of “transgender women” who are previous sex offenders. [7] Any man may
“identify as a woman” in order to access the private spaces of women and girls. Voyeurism
and indecent exposure cease to exist as criminal acts, but a girl in a public female changing
room may be liable to the charge of a transphobic hate crime if she names a person exposing
his penis as male.

In schools, girls are already expected to accept teenage males into their toilets and changing rooms
and must comply in re-defining a male classmate as a “girl.” [8] This contempt for girls’
boundaries is rape culture: “consent” cannot meaningfully be taught in schools if girls are not
allowed to set their boundaries; if they are coerced into accepting males into their private
spaces. The word for this is “grooming.”

We already hear examples in news stories [9] of men accessing women’s toilets or changing rooms;
predators will go to any lengths to access women and girls’ private spaces and this
legislation makes it much easier for them to do so. The Government Guidelines for service
providers gives them all the protection they need, and takes all protections away from
women and girls.

3. Women’s distinct health needs have historically been neglected as research is based on the
male body. The word “woman” is currently being erased from the language of women’s
health and reproduction [10], including in media reports. [11] Any reference to “female biology” is
now considered to be exclusive of “transwomen” and therefore transphobic. Women need
to have the words to talk about female bodies and specifically female health and reproductive
issues without couching their language in ‘gender neutral’ terms to save the feelings of others
or align with someone else’s agenda. The historic shame around female biological functions
is recognised to be detrimental to women’s knowledge and care of their own bodies, their
self-esteem and their confidence in talking to doctors. Girls should be able to name and
discuss freely issues of female biology without being accused of “transphobia” for doing so.

4. Children and adolescents are now being taught regressive and discredited “pink brain” and
“blue brain” theories in schools by transgender activist groups [12] , in contradiction to NUT
teaching resources designed to tackle those very stereotypes which disproportionately harm
girls. [13] Parents are encouraged in “gender-policing” their own children, who are judged to be
boys or girls based on toy and clothes preferences and preferred length of hair, [14] even though
we know that around 80% of children grow out of cross-sex identification and, if left alone,
are overwhelmingly likely to be gay or lesbian as adults, not transgender. [15] Affirming a prepubertal
child’s “gender identity” is therefore akin to gay conversion therapy.

The use of puberty blockers followed by cross-sex hormones results in sterility, while no
public debate on the ethics of this is allowed. We are pathologising and medicating nonconformity
at the same time as normalising a transgender identity in children.

We are applying an “identity” protected characteristic to children and adolescents whose
identities are not fixed but still developing. Teenage girls make up the largest group referred
to gender clinics but we are not asking why so many girls don’t want to become women.
Parents cannot find therapists who will do anything other than “affirm” their child’s identity.

Young women who subsequently regret their “transition” are left with irreversible effects.
They overwhelmingly report a lack of adequate counselling before transitioning; [16] serious
factors behind their cross-sex identification, such as psychological problems, mental health
issues [17] and previous sexual abuse, remained covered up. We are failing our young women if
a “trans” identity, encouraged by transgender forums on Tumblr and Reddit, [18] denies them
the counselling they really need.

5. Women have lost all political representation. No women’s group or organisation dares any
longer to define women as the female sex, but must represent all “self-identified women”
which is inclusive of males. Women’s right to advocacy as a boundaried, distinct sex class
has been taken away. A whole new arena of bullying, intimidation and silencing of women
who refuse to give up the reality of female biological sex has sprung up, including no-platforming, [19]
censoring of women’s writing [20] and speaking [21], and online threats of rape with
a “lady penis” and new words to insult women: “cis-scum” and “TERF,” a slur which stands
for Trans Exclusionary Radical Feminist and is commonly used in the phrases “Die in a fire
TERF” and “Kill all TERFS.” [22]

6. The idea that ‘gender’ is an innate identity rather than a socially-enforced phenomenon
suggests that women identify with their oppression; women choose to be the subordinate sex;
they are ‘naturally’ suited to unpaid care-work and unsuited to positions of power within
society. It is impossible, however, for women and girls to identify out of the female sex class;
they are still at risk of rape and sexual violence [23] , because they are female.

Answers to specific questions

1. How well understood are the goals in the UK and what more can be done to promote
them?

We do not believe that the goals are well understood or widely known by either the general
public or Members of Parliament, as evidenced by the lack of any move to conduct an
Equality Impact Assessment on women and girls in regard to the Transgender Equality
Inquiry. Women’s fears of assault and harassment are well-founded and based on well-documented
reality. Criminal law repeatedly fails women in areas such as sexual and
domestic violence. The goals should be promoted across all policy areas which will impact
on the lives of women and girls. The minimising of women’s genuine concerns should be
challenged as a matter of course, as should any suggestion that women’s fears are rooted in
bigotry. Government ministers should lead the way in listening to women and taking their
concerns seriously.

2. Is there consensus across Government about what the terms used in Goal 5 mean in
the UK context?

No. Successive governments have failed to ratify the Istanbul Convention so we cannot see
that there is any consensus on the meaning or urgency of women’s equality or the ending of
violence against women and girls.

3. What action is the UK taking to implement Goal 5 to achieve gender equality and
empower all women and girls in the UK by 2030? What more can the UK Government
do to achieve this?

The UK is taking a backward step by prioritising gender identity over sex, as outlined above.
More action could be taken in the prevention of inequality and violence against women and
girls, specifically in education. Feminism should be included in PSHE lessons in schools as
part of a No Tolerance policy towards sexual harassment and abuse, and consent should be
taught within the context of everyone’s right to have and express personal boundaries, and
have those boundaries respected. The Government and agencies such as the ASA should be
robust in tackling the cultural and media messages that young people see which encourage a
socially-sanctioned disrespect for women and girls, and which foster attitudes conducive to
violence against women and girls. The Prostitution Inquiry should implement the Nordic
model which decriminalises women exploited within the sex industry and criminalises the sex
industry profiteers as well as the men who buy the bodies of women and girls. The
Government needs to send a strong message that in the UK, women and girls are not for sale.

4. What more do individual government departments need to do to prioritise Goal 5
targets? What practical steps need to be taken?

The Women and Equalities Committee need to prioritise the needs and rights of women and
girls and the particular discrimination faced by members within that category, for example,
Black and ethnic minority women, disabled women, older women and lesbians. It is crucial to
maintain established women-only social spaces if women are to participate fully in public
life: for example, many women rely on women-only sports and swimming sessions where
they can participate away from the “male gaze,” in particular Muslim, disabled and older
women and those who have suffered sexual abuse. Lesbophobia is not tackled seriously
enough in schools or society and yet it is born out of both homophobia and misogyny.
Teenage lesbians are increasingly encouraged to transition into “straight guys” to counter the
discrimination and hatred they face as lesbians. Lesbian culture is being erased by queer and
identity politics. [24] The Government needs to take practical steps in listening to these women.

5. What resourcing is in place for the implementation of Goal 5? Is further resourcing
required?

Resourcing is required but will be cost-effective, eg. the cost to the UK caused by the lack of
women in STEM subjects and the cost of domestic violence.

6. How effective is coordination and leadership across UK government departments on
implementing Goal 5? Is a single point of responsibility preferable to delegated
responsibility across departments, and who should lead?

All department leaders need to factor in the impact on women and girls for all policies,
including economic. All new policies and legislation need to be measured against SDG5
goals, which requires leadership and commitment from all departments.

7. What monitoring mechanisms are in place to measure progress in the UK against
Goal 5 and how can these be improved?

There has been inadequate monitoring of domestic violence figures resulting in a
minimisation of the disproportionate impact on women. Adequate monitoring is crucial;
domestic violence figures have misled the public and may have an impact on funding for
support services. Again we have gone backwards with gender identity legislation: instances
of rape have been recorded by gender identity, not sex, since 2009. We hear of more and
more cases in the news of violent and sex crimes being committed by “women” [25] which
renders male violence against women invisible, misleads the public into thinking that women
are as violent as men, prevents us from recognising and naming the problem as male violence
and will inevitably have a knock-on effect in terms of funding for support services.

8. Which targets under Goal 5 are the most difficult to measure progress against? How
can the Government ensure that the hard to measure targets are not neglected?

All targets are undermined by gender identity legislation as all targets become unmeasurable.
It will be impossible to measure the proportion of female sexual assault/rape/domestic
violence victims who do not access support services out of fear of being counselled by, or in
a support group with, males, or finding themselves alone with a male in a toilet. These most
vulnerable women will be unlikely to complain, out of fear of being accused of “transphobia”
so they will remain invisible. Measuring the number of women attaining career positions or
entering male-dominated fields of work will similarly be impossible to record accurately. [26]
As males increasingly take these positions we will be misled into believing that policies
specifically for women have been successful.

9. Which targets/issues under Goal 5 have been hardest to make progress on and why?
Which require a greater emphasis?

Male violence, especially sexual violence and harassment of women. The sexual harassment
and abuse of girls in schools across the UK is shameful. [27] We have made no progress, we
have gone backwards.

10. What role do the private and third sector have to play in achieving Goal 5 in the UK
and how effectively are these roles supported by the Government?

The third sector has developed grass-roots expertise on issues affecting women and girls.
Localised women’s support services have the best knowledge and experience of the needs of
the women they serve and yet they are losing funding and being replaced by larger charities
who have no such understanding. There are reports of women’s services denied funding
unless they define “women” as “anyone who identifies as a woman.” This is effectively
erasing women-only services; support services for transgender people should be set up and
funded separately if the most vulnerable women are to be protected.

11. What examples of good practice are there in the UK or abroad, for implementing
and monitoring progress against these and other global targets? How effectively does
the UK Government learn from such practice?

The Nordic countries (Iceland, Sweden, Norway, Finland) have made the greatest progress in
terms of gender equality, especially in the area of prostitution and trafficking. The
Prostitution Inquiry in particular needs to learn from Sweden in the establishment and
implementation of the Nordic model, and listen to the survivors of the sex industry. All
Government policies send a strong message to the girls growing up in the UK. The message
should not be that this country sees prostitution as an acceptable safety net for our most
vulnerable women and girls.
December 2016
______________________________
1 http://www.transgendertrend.com/
2 http://www.who.int/mediacentre/news/releases/2013/violence_against_women_20130620/en/
3 See Government Guidelines for Service Providers
4 http://www.annelawrence.com/autogynephilia,_a_paraphilic_model_of_GID.pdf
5 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0016885
6 See British Association of Gender Identity Specialists submission to the Transgender Equality Inquiry
7 For example http://www.dailymail.co.uk/news/article-3476199/Transgender-woman-25-jailed-eight-yearsraping-15-year-old-girl-changed-sex-male-female.html
http://www.mirror.co.uk/news/uk-news/transgender-paedophile-jailed-attacking-girls-9307905
8 http://www.dailymail.co.uk/news/article-3846466/Transgender-pupil-18-wins-right-wear-girls-clothesschool.html
9 See for example: http://news.sky.com/story/man-wanted-after-girl-photographed-in-toilet-10292115
http://www.christianpost.com/news/targets-transgender-bathroom-policy-leads-to-10-crimes-targeting-womenundressing-170300/
http://www.dailymail.co.uk/news/article-3967234/Man-secretly-filmed-womenundressing-UEA-sentenced.html
10 For example: http://www.theestablishment.co/2016/05/25/on-trans-menstruation-a-roundtable/
11 The BBC calls women ‘menstruators’ https://twitter.com/BBCRadio4/status/799030970288635905
12 http://www.gires.org.uk/education/classroom-lesson-plans
13 https://www.teachers.org.uk/files/boys-things-revise-8875.pdf
14 For example https://www.theguardian.com/society/2015/sep/12/transgender-children-have-to-respect-who-heis
15 http://www.sexologytoday.org/2016/01/do-trans-kids-stay-trans-when-they-grow_99.html
16 http://guideonragingstars.tumblr.com/post/149877706175/female-detransition-and-reidentification-survey
17 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4396787/
18 https://transgenderreality.com/2016/08/04/questioning-teens-and-social-contagion/
19 https://www.theguardian.com/commentisfree/2010/jan/31/julie-bindel-transgender-nus
20 https://glosswatch.com/2014/10/16/an-unspeakable-post/
21 https://www.theguardian.com/commentisfree/2012/may/29/transgenderism-hate-speech?fb=optOut
22 https://terfisaslur.com/ http://violentreceipts.tumblr.com/
23 http://www.cbc.ca/news/canada/manitoba/transgender-sex-assault-winnipeg-taxi-1.3603515
24 http://www.wweek.com/culture/2016/11/30/who-crushed-the-lesbian-bars-a-new-minefield-of-sexual-politics/
25 http://www.mirror.co.uk/news/uk-news/pre-op-transgender-woman-who-8887971
http://www.telegraph.co.uk/news/2016/09/22/fell-runner-lauren-jeska-admits-attempted-knife-murder-of-britis/
26 https://www.thesun.co.uk/news/1799205/sex-change-soldier-is-britains-first-female-to-fight-on-front-lineafter-being-born-a-boy/
27 https://www.theguardian.com/commentisfree/2016/nov/29/epidemic-sexual-assaults-schools-gropedpornographic-images-slags?CMP=share_btn_fb