Tuesday, June 4, 2013

Comments filed with federal government

The  federal government is proposing adding “sexual orientation” and “gender identity”  to its CFC regulations.

PFOX filed comments asking the U.S. government to include former homosexuals in its definition of “sexual orientation:” 


Keith Willingham, Director

U.S. Office of Personnel Management


Re: Proposed Regulations for the Combined Federal Campaign (CFC) RIN 3206-AM68


Dear Mr. Willingham:


Parents and Friends of Ex-Gays & Gays (PFOX) supports the ex-gay community, homosexuals with unwanted same-sex attraction, and their friends & families. PFOX ensures that ex-gays and their supporters can be open, honest, safe, and respected in a diverse society. 


We submit these comments in response to the proposed Combined Federal Campaign (CFC) regulations of new prohibitions of discrimination on the bases of “sexual orientation” and “gender identity.”  The CFC is a program run by the federal government which strongly encourages federal government employees to contribute a portion of their paycheck to a charity of their choice.  Last year, over $258 million was raised for charities.  The federal government is now proposing to add “sexual orientation” and “gender identity” to its regulations for participating charities.


Specifically, the Notice of Proposed Rulemaking (78 Fed. Reg. 20820, April 8, 2013) proposes to amend the current provision on “Prohibited Discrimination” (5 CFR §950.110) to include sexual orientation and gender identity:


“Discrimination for or against any individual or group on account of race, ethnicity, color, religion, sex (including pregnancy and gender identity), national origin, age, disability, sexual orientation, genetic information, or any other nonmerit-based factor is prohibited in all aspects of the management and the execution of the CFC.”


And the current eligibility rules for family support and youth activity programs on military bases

(5 CFR 950.202(a)(4)(v)) would be amended to require that such programs:


(v) “Have a policy and practice of nondiscrimination on the basis of race, color, religion, sex, sexual orientation, gender identity or national origin applicable to persons served by the organization.”


Although the proposed federal government regulations define sex to include gender identity, sexual orientation is not defined. Accordingly, we respectfully request that your office define sexual orientation to include former homosexuals.  Thus the proposed language would read: “Discrimination for or against any individual or group on account of … sex (including pregnancy and gender identity) … sexual orientation (including former homosexuality) or any other nonmerit-based factor is prohibited in all aspects of the management and the execution of the CFC.”


Language that specifically includes former homosexuals is necessary because of intense prejudice and discrimination against the ex-gay community and their supporters.  Larry Dombrowski, a federal government employee with the Federal Aviation Administration (FAA), was suspended without pay for seven days and transferred to another state because, among other things, he spoke about former homosexuals in conversations with co-workers. 


After Dombrowski filed a civil rights lawsuit against the FAA, the federal government agreed to clear Mr. Dombrowski’s record and pay his attorneys’ fees and costs.  We must ensure that the federal government never again discriminates against former homosexuals and their allies.  Hence our proposed language not only serves to maximize diversity, but is necessary to counter past discrimination. 


Moreover, in the case of PFOX v. Government of the District of Columbia Office of Human Rights, No. 2008 CA 003662, slip. op. at 12 (D.C. June 26, 2009), the Superior Court of the District of Columbia ordered the Washington D.C. Office of Human Rights to recognize former homosexuals as a protected class for sexual orientation nondiscrimination purposes.  Our federal government should do no less.




Parents and Friends of Ex-Gays & Gays

Box 510, Reedville VA 22539



        ~ Supporting Equal Rights for the Ex-Gay Community ~


PFOX Note: If you are interested in also filing comments, write to Keith Willingham, Director, Combined Federal Campaign, U.S. Office of Personnel Management, Room 6484A, 1900 E Street NW., Washington, DC; or email cfc@opm.gov , include "RIN 3206-AM68" in the subject line of the message, or FAX to (202) 606-5056 Attn: Keith Willingham. You may also submit comments using the Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.





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