Sep 224 min read

Open Letter to Paddle UK

September 19, 2024

Dear Ashley Metcalfe and Paddle UK leaders:

The International Consortium on Female Sport (ICFS) wishes to offer input into your proposed Transgender Policy.

We are a collective of women’s groups from 10 countries whose specific mandate is to advocate for the preservation of the female-only sports category (see https://www.icfsport.org). We believe that safety and fairness for women and girls in sport must be preserved by having a category that remains exclusively female.

Female athletes pay a steep price when men and boys are permitted access female sports competitions. Whether athletes are the best in the world, youths in a junior talent pathway, or masters of all ages, male domination in body size, speed, strength, power, endurance, and overall performance is well documented.

At the prepuberty level boys are taller, heavier, stronger, faster, more agile, more explosive (in jumping and throwing), and have better cardiovascular endurance than girls.[1] And this difference is greatly magnified post puberty, with males being stronger by 25%-50%, more powerful by 20%-160% (depending upon the sport), 40% heavier, and 10-13% faster than females.[2]

To date, at least nineteen peer review studies have shown that it is not possible to mitigate the male performance advantage through testosterone reduction,[3] which is why the UK's Sports Councils concluded in their 2021 Guidance for Transgender Inclusion in Domestic Sport [4] that it is not possible to reconcile inclusion of male-born participants with safety and fairness to women and girls.

Canoeing and kayaking are, with out a doubt, gender-affected sports,[5] which is why there are men’s and women’s categories. Taking note of your proposed “Paddle UK Transgender Policy,” there are statements made within the text that we wish to address, specifically:

Item 1: “4.1.2. Women or those competing in the female category: Any transgender woman over 16 and post-puberty (male-to-female transgender person) may compete in the female category of Domestic Competition run under the auspices of Paddle UK and run in accordance with Paddle UK regulations and policies, by providing evidence that they meet the eligibility requirements as set out in Clause 5 OR she may compete in any male, Open or Mixed category, if she has not started hormone treatment.”

Item 1 ICFS rebuttal:

This is dystopian and completely antithetical to safety and fairness for athletes born female. Any person born male enjoys a massive competitive advantage over women. Neither surgical intervention nor simple hormonal reduction will ever be enough to mitigate this advantage.[6] Paddle UK would make life much easier for yourselves to, instead, say the following: “Any participant born male must remain in the male category. Transphobia by other male competitors will not be tolerated.”

Item 2: “4.1.4. Any transgender girl pre-puberty (male-to female transgender person) may compete in any female, Open or Mixed category of Domestic Competition subject to confirmation of her stage of pubertal development. There is no gender-related advantage pre-puberty. Evidence must be provided to Paddle UK in the form of sufficient information from her GP and/or consultant to ascertain the stage of pubertal development that the individual has reached. She will not be permitted to compete until this has been submitted and assessed. This is subject to an annual review and once a GP and/or consultant has determined that the athlete has reached puberty, then they must meet the requirements outlined in section 4.1.2.”

Item 2 ICFS rebuttal:

Saying that males have no sex-based advantages pre-puberty is demonstrably wrong.[7] [8] [9] All data sets of physical education standards reflect that boys are faster, stronger and have more endurance than girls, while girls have more flexibility.[10] Even though the male versus female physical and performance differences greatly amplifies during puberty, clear differences do exist pre-puberty. Boys have distinct sport performance advantages over girls and to allow them to self-identify into the female category is unethical. Furthermore, Paddle UK’s position unnecessarily places its leadership in a position to delve into the private medical files of children who simply wish to participate actively. Why put yourselves in this position when it would be so much simpler to say: “Any participant born male must remain in the male category. Transphobia by other male competitors will not be tolerated.” [A simple check of sex as recorded at birth would be the only documentation required.]

In conclusion, here is what your policy says in section 1.2. “We are committed to fairness, equity and promoting diversity and inclusion in all we do. We are therefore committed to ensuring that the sport is accessible to all who wish to participate and that individuals are treated fairly.” Having a female-only eligibility policy for women and girls in your sport is the only way to treat “fairly” Paddle UK members who happen to have been born female. All evidence supports this position. Allowing male-born competitors into the female section is the opposite of “inclusive.” As we have now witnessed across many sports in recent years it leads, inevitably, to the (very unkind!) EXCLUSION of female athletes from their own prizes and opportunities.

We urge Paddle UK to consult with your female athletes on this matter, giving them a means to express their preferences in privacy so as not to place them at risk of ostracization. And throughout your policy review, we urge you place the needs of your female members at the forefront of any regulation that pertain to eligibility in the female category.

Thank you for the opportunity to offer our feedback.

Yours in Sport,

Founding Members, ICFS

Email: hello@ICFSport.org

https://www.icfsport.org/