Recently, the State Board of Education for the state of Michigan released its Statement and Guidance on Safe and Supportive Learning Environments for Lesbian, Gay, Bisexual, Transgender, and Questioning (LGBTQ) Students. The Michigan Department of Education (MDE) has requested public comment on the draft statement. Here is the letter I submitted to the MDE supervisor in Lansing.

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To the Michigan Department of Education,

I am writing to comment on the document entitled State Board of Education Statement and Guidance on Safe and Supportive Learning Environments for Lesbian, Gay, Bisexual, Transgender and Questioning (LGBTQ) Students (hereafter SBE Statement). I am grateful that the Michigan Department of Education (MDE) has initiated a process for receiving public feedback on such a controversial matter. In addition to sending my comments by surface mail, I will also post this written response online.

Before I get to my comments, let me tell you a little about myself. I am a graduate of the Michigan public school system (Jenison High School, class of 1995). My wife and I have six children; the four who have reached school age are enrolled in East Lansing Public Schools. For the past two years I have served on our district’s Sex Education Advisory Board. Moreover, as a pastor in the community, I know many parents, teachers, and staff who work hard to serve the students in our public schools. I am grateful for the many fine teachers I had as a student, and for the many excellent teachers my students now have. I do not write this letter as someone who has been uninvolved or unconcerned with the health and wellbeing of our state’s public schools.

Which is why I am so troubled by the SBE Statement.

First, the SBE Statement does little to make the case that such sweeping changes are necessary. The ostensible purpose behind these new guidelines is to promote “a safe, supportive, and inclusive learning environment for all students” (p. 2). To be sure, wherever there is name-calling and threatening behavior directed toward LGBTQ students, such behavior should be censured and corrected. We all agree that all students—Christians, Jews, Muslims, Mormons, rich, poor, male, female, gay, straight, and those wrestling with issues of gender identity—deserve to be treated kindly and with dignity and respect.

And yet, more work needs to be shown before we can conclude that our schools are manifestly unsafe places for LGBTQ students. It is disappointing to find that a document from the State Board of Education contain only two footnotes to support the claim that there is a “hostile school environment” across the state (p. 2). The first footnote cites “unpublished data” from the 2015 Youth Risk Behavior Study. How are we to interact with the statistics offered in the SBE Statement if we have no access to them? I doubt this approach would pass academic muster in our best schools. We simply do not know what we are comparing without being able to see all the data.

The second footnote cites a national report released by the Gay, Lesbian and Straight Education Network (GLSEN) which examines the difficulties facing LGBTQ students in our schools. For any student to be harassed, bullied, threatened, or assaulted is deplorable, but as the report indicates, students also face these difficulties because of religion, race, gender, and disability. Depending on each child and each district, students may feel out of place because they are gay or lesbian, or because they think marriage is between a man and a woman, or because they are Black or Hispanic, or because English is not their first language, or because they do not eat pork, or because they read the Bible in the cafeteria, or because their parents are Republicans or Democrats, or because they use a wheelchair or talk with a stutter. No one wants to see students struggle to fit in or feel accepted. But one cannot help but wonder whether a cultural agenda is being lobbied for under the guise of safety. In 1995, GLSEN’s founder spoke at a conference on “Winning the Culture War,” in which he observed:

Titling our report “Making Schools Safe for Gay and Lesbian Youth,” we automatically threw our opponents onto the defensive and stole their best line of attack. This framing short-circuited their arguments and left them back-pedaling from day one. Finding the effective frame for your community is the key to victory. It must be linked to universal values that everyone in the community has in common. In Massachusetts, no one could speak up against our frame and say, “Why, yes, I do think students should kill themselves”: this allowed us to set the terms for the debate. (Massachusetts News, December 2000).

Again, let me reiterate: every student deserves to be treated with kindness, dignity, and respect. The teenage years are hard for many students. But the massive changes proposed in the SBE Statement should be accompanied with massive research to support the need for those proposals. It would be a shame if “safe space” was really less about student safety and more about the sexual revolution.

Second, the SBE Statement usurps the role of parents in the formation of their children. Few issues are more important and more essential than helping one’s child navigate puberty and come to a healthy sense of sexual boundaries and sexual identity. While an educational institution may play a part in this development, the role of the school is only to come alongside the parent, never to cut the parent out of the process. The provisions under “Privacy and Confidentiality Regarding Disclosures” (p. 5) seem to indicate that a student may choose a different name at school, ask for different pronouns, start using a different locker room, and identify with a different gender, all without the parent or guardian ever being notified and brought into the discussion. Earlier on the same page, we read that this “student-centered approach” means engagement with the parent/guardian will happen “as appropriate.” If “parental acceptance and support are key determinants of LGBTQ health” (p. 3), why would parents be contacted only when “appropriate”? It is always appropriate—indeed, it is imperative—that parents lead the way in something as critical and controversial as establishing sexual norms and expectations for their children. They are, after all, our children.

Third, the proposed guidelines would make our school less safe and harm many of the people we are trying to help. Students who struggle with their biological sex and their own sense of gender should be loved and supported. But the SBE Statement only envisions one kind of support: the kind that unilaterally accepts a child’s own self-determination and demands that everyone and everything else be shaped accordingly. No doubt, some parents, out of a desire to love their children as they see fit, will encourage LGBTQ children to fully embrace whatever sexual identity they desire. But many other parents, also out of a desire to love their children as they see fit, will question whether more traditional sexual norms and an older understanding of gender “oughtness” should be so quickly discarded.

The SBE Statement assumes what, until very recently, almost no one assumed, and what most religious and cultural traditions around the world still do not assume; namely, that gender and sexuality are whatever we want them to be. The current edition of the Diagnostic and Statistical Manual of Mental Disorders (DSM-V) includes gender dysphoria, labeled as gender identity disorder until 2013, as a recognized condition when accompanied by distress over one’s biological sex. While some parents may encourage their children to embrace their chosen gender identity, whether it matches their biological sex or not, many other parents will see gender confusion as a natural part of passing through puberty and will encourage their children to embrace their biological sex. It is not the place of the schools to undermine what is taught in the home. If the MDE wants to bring transgender issues directly into the classroom, then, in the interest of diversity and inclusion, it should find a way to respectfully and intelligently teach our students how and why people of good will can come different conclusions on these important matters.

More to the point, the proposals themselves represent a vast overreach of institutional and cultural re-engineering. The guidelines for gender nonconforming (GNC) students allow for the chaos of teenage males using the girls’ restroom and of young men (who identify as female) dominating intramural and interscholastic sports as they compete against young women. How are our schools safer with boys and girls using the same private facilities? How are women helped by tilting the playing field to their profound disadvantage? There are other ways to help sexual minorities. As the SBE Statement suggests, “Any student who has a need or desire for increased privacy, regardless of underlying reasons, has the right to access a single-user restroom” (p. 5). Instead of making our schools a cultural battleground and a place for gender experimentation, we could simply handle these issues on “a case-by-case basis” (as the statement says at one point). We do not need added bureaucracy and sexual confusion as much as we need basic human decency and common sense.

It is my hope that the MDE will take into account all the feedback it has received in this process. The public school system works best when the state acquiesces to the will of the parents, and not the other way around.