A Response to the Transgender Action Plan (TGAP)

A copy of the Coalition-Government’s Transgender Action Plan (TGAP) is available here.

Below is a copy of the letter sent to Ministers the Rt Hon Theresa May, MP (Home Secretary and Minister for Women and Equalities) and Ms Lynne Featherstone, MP (Minister for Equalities) regarding the proposed TGAP and the key issues affecting born-females.

Rt Hon Theresa May, MP
Home Secretary and Minister for Women and Equalities
House of Commons
London SW1A 0AA

Ms Lynne Featherstone, MP
Minister for Equalities
House of Commons
London SW1A 0AA

5 March 2012


Dear Mrs May
Dear Ms Featherstone

Re: Transgender Action Plan: Advancing Transgender Equalities

We are an informal Coalition for Women’s Equality and are writing regarding the Coalition-Government’s Transgender Action Plan. We welcome all Government efforts to ensure equality for all citizens, although we have serious concerns regarding some aspects of the proposed action plan.

We believe all human beings should have the right to decent housing, jobs, comprehensive health care, and a life free from violence and abuse regardless of race, gender presentation or sex. We emphasise that we fully support the rights of people who consider themselves to be transgendered or transsexual. However, these rights should never be at the expense of any other marginalised or disadvantaged group.

We are concerned about the wider social implications of the normalisation of transsexualism and transgenderism. There is a long-established history of sexological and psychiatric literature and practices that promote stereotypical and sexist understandings of ‘gender’ (gender roles) and are antithetical to equality between women and men. Transsexualism is in many ways a re-entrenchment of archaic sex roles that constitute a major obstacle to women’s equality. Our particular concerns involve both the consultation process via which the TGAP was developed, along with specific aspects of the Plan itself. Our main concerns are as follows:

1. The consultation process

We, and other women’s organisations and individuals, are interested to know which organisations and experts were involved in the initial consultation. We understand from the Introduction to the TGAP that the transgender community, practitioners and the voluntary sector had “active involvement” in the consultation, but no list of participants is provided. For example, was there any involvement of individuals who have been through a transitioning process, and who are now in opposition to the practice of transsexualism? ‘Trans-regretters’[1] are beginning to speak out, but there is little or no recognition of these people and their experiences. We are interested to know the level of engagement that the UK Government had with all affected groups in formulating the TGAP.

Similarly, as women’s organisations representing equalities issues from a Female Assigned At Birth (FAAB) perspective, we are extremely concerned that we were not consulted in relation to the development of the TGAP. Given that the majority of transgendered individuals are male to female[2], the TGAP obviously has serious implications for spaces and organisations designed to serve FAAB women.

2. Inequities in the criminal justice system

According to proposals in the TGAP, violence against transgender people will be treated as hate crime, and would thus carry very severe penalties. Violence against women is currently excluded from this category. Should this proposal be implemented it will lead to gross inequities in the sentencing of violent crimes carried out against women, in relation to those suffered by transgender victims. It will thus lead to the anomalous position wherein male-born transsexuals, or men with gender identity issues, will be protected from ‘hate crimes’ whereas those who are biologically female are still not afforded the same protection. Violence against women remains endemic within our society. Born-female women (FAAB) deserve the same protections and considerations as male-born transwomen (MAAB).

3. Implications for women-only space, safety and service provision

The TGAP Action Plan is overly broad in its use of Transgender, and makes no distinction regarding those included under the ‘Transgender umbrella’. The term is inclusive of Transsexuals (the most likely group to have Sexual/Gender Reassignment Surgery, SRS/GRS); Transgender and Genderqueer (these latter groups unlikely to have GRS) and Cross-dressers. Informal surveys reveal that well over half of the males under the ‘Transgender umbrella’ have no desire for surgery. Nor is it a requirement for males to have GRS under the Gender Recognition Act (2004). This creates a major issue for women-only services.

Under current TGAP proposals which are even broader than the GRA (2004), male-to-female individuals will have an absolute right to access women-only spaces and services, including women’s toilets, changing rooms and women-only activities, clubs and societies. Women-only charities that work with vulnerable and marginalised women also have concerns about potentially being forced to employ or provide services to people who are biological males, particularly those who have not had GRS.

Similar assumptions were made under Canadian Legislation until women’s organisations and employment lawyers challenged such assumptions[3]. Following this challenge, Canadian Law was amended to allow any group protected under Section 41 of the Canadian Human Rights Code to restrict its services and employment to a sub-group of the group it was created to serve. In this case, it means that a women’s charity may limit its services to women who are biologically female, rather than serving individuals who are, or have been, biological males. There are, numerous reasons why the interests of biological females must be protected[4], which we would be happy to discuss with you in greater depth.

4. Medicalised transgenderism and children’s rights

As is widely recognised, children grow up in a society that imposes strict gender norms and stereotypes upon them. We believe that more progressive social policies designed to specifically combat rigid and narrow gender stereotypes are needed. In our view, an egalitarian society is one that refuses to ascribe particular behaviours, interests, and tastes to either male or female children or adults. Gender role stereotypes form a large basis on how women are kept subjugated within society, and should be abolished.

We are particularly concerned about the implications of the TGAP regarding medicalised transgendering practices on children, merely because these children are gender role non-conforming. The trend of diagnosing children with GID is dramatically increasing[5]. The ultimate medical destination for many of these children is to be put on hormone blockers (from as young as 10). Many of the procedures and fast-tracking ‘transgender treatment’ involves permanent sterilisation.

We understand that the Nuffield Hospital in Leicester, which once routinely carried out sex re-reassignment operations for individuals, has now ceased that practice at its Leicester site, following their own consultation which suggested that the administration of powerful hormone drugs and surgical intervention may be of little benefit to GID individuals.

There is an alarming lack of information regarding the long-term consequences of artificial hormone treatments including hormone-blockers, hormone replacement therapy, and other pharmaceutical interventions on the physical and mental well-being of individuals. We would argue that what is actually needed is a support mechanism to protect vulnerable children against the medical professionals and courts that seek to ‘transgender’ them.

In conclusion

As a coalition of women’s organisations and individuals, we are very keen to discuss these issues with you further. Whilst we recognise that the TGAP has already been launched, we hope that you will appreciate that the concerns we raise have wider implications for vulnerable women, and we would very much value the opportunity to discuss them with you at in greater depth. We have also created a website[6] of resource material and supporting information..

We thank you for your attention and look forward to your response.

Yours sincerely


[name withheld]
Primary Liaison
The Coalition for Women’s Equality

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[1] ‘Trans-regretters’ see http://www.sexchangeregret.com/examples and our own website for a collation of ‘trans-regretters’ https://ensuringfairness.wordpress.com/resources-reference-material/trans-regretters/

[2] Most estimates indicate splits between 70/30 and 85/15 MTF/FTM. Two sample quarters from the Gender Recognition Panel correspond with this range. Jan-Mar 2008 state that of the 77 certificates issued, 53 were to male-at-birth, and 24 to female-at-birth, a percentage split of 69/31 MTF/FTM. For the quarter Apr-Jun 2011, 49 certificates issued, 30 to MTF and 11 to FTM, a percentage split of 78/22 MTF/FTM. See our Statistics page for more information.

[3] See: Vancouver Rape Relief Society v. Nixon 2005 BCCA 601 http://www.rapereliefshelter.bc.ca/learn/resources/vancouver-rape-relief-society-v-nixon-2005-bcca-601-summary-decision

[4] For a brief overview, see https://ensuringfairness.wordpress.com/resources-reference-material/female-only-services/

[5] The Tavistock and Patman Foundation Trust, the national body for gender identity disorder, said the number of children diagnosed with the condition had steadily risen from 97 in 2009-10 to 165 so far this academic year, which it said may reflect greater awareness. Only seven children under the age of five were diagnosed last year.

[6] Our website, available from 12 March 2012: https://ensuringfairness.wordpress.com/