We are the Rape Crisis Centre for Sussex, and we have been supporting survivors of sexual violence for approaching thirty years.
We are deeply concerned by the proposed rollback to safeguards for trans dignity and safety in this country detailed in a recent Sunday Times article, and the effort to justify this rollback through supposed protection of services like ours and the women we work with every day.
Our expert experience of supporting women, and survivors of all genders, has left us very worried about the potential impact of these plans on our clients, both cis and trans.
We know, through ground-breaking research, that trans people are disproportionately impacted by sexual violence. We also know that transphobic hate crimes recorded by police increased by 37% last year. This is a time where we should be coming together as a community to protect the most vulnerable in society, providing shelter and support. We are disappointed to see, instead, that the government are proposing to disregard the outcomes of the Gender Recognition Act Consultation and to further move to reduce the rights of trans people in our country.
As highlighted by the organisation Mermaids, “trans people have been using toilets, trying on clothes in changing rooms, accessing domestic violence facilities, and generally getting on with their lives for as long as single-sex spaces have existed and there is absolutely no evidence we’re aware of, from the police, local authorities, shops, refuges or anywhere else besides, that predators have used the provisions of the Equality Act 2010 to gain access to women’s spaces. None.” 
We would like to reiterate this point, and highlight that in the ten years since the Equality Act 2010 came into place we have not had a single issue in terms of survivor safety due to trans women being entitled to access our spaces.
We also know all too well that predatory men are already able to enact their abuse with few repercussions, including entering changing rooms and public toilets – they do not need to pretend to be part of a marginalised community to break the law and to violate women, and suggesting that they would do so is entirely unsubstantiated.
We are deeply concerned about the application of the proposed tightening of access to single-sex spaces. There is no safe or survivor-centred way to police the anatomy of someone accessing a service or using a bathroom/changing room. This will impact on gender non-conforming cisgender people, particularly cisgender women, as well as transgender people. Policing gender expression and defining someone’s womanhood by her conformity to state-sponsored specifications is an archaic practice that should not be considered in 2020 and is certainly not a feminist principle or one that will protect vulnerable women. This move will harm all women, but it is clear the intention is to functionally remove the ability of trans people to exist in public life.
We consider a trans inclusive feminism to be key to our values and central to our services as a Rape Crisis Centre. Our policies are led by a commitment to equality and support for all survivors. We are committed to supporting our trans siblings in their survival journey, and we are committed to speaking up as a feminist organisation when we see the human rights of survivors being threatened.
There are many other actions the government could be taking to better protect survivors – including addressing the criminally low conviction rate for sexual violence, the chronic underfunding of the women’s sector, the distress caused by digital strip-searching survivors and the lack of consent-based education in schools. Failing to implement any changes around these pressing issues, and instead moving to make accessing support services more difficult, will only harm the services and survivors they are claiming to protect.
Ignoring the outcome of a democratic consultation, acting to exclude trans people from public life, and co-opting vulnerable women’s experiences to justify this, would be a shameful move for a progressive country to take.