Brennan-Hungerford response to “Making Shelters Safe for Transgender Evacuees”

Making Shelters Safe for Transgender Evacuees (see below) is a document issued last month by the National Center for Transgender Equality, Lambda Legal, and the National Gay and Lesbian Task Force in anticipation of Hurricane Irene. Cathy Brennan and I take issue with the manner in which these guidelines seek to protect transgender evacuees, as it appears to do so at the expense of some female-bodied persons. We oppose policies that establish a double-standard of safety, fail to take sex-segregated space seriously,  neglect to ask women about their safety needs, or that dismiss “other [non-trans] people’s” concerns as “not valid.”

As such, we have sent the following response to the organizations that issued these guidelines. We are sharing these concerns as a serious effort to have a real discussion about issues of gender equality.


We write in response to your document entitled Making Shelters Safe for Transgender Evacuees (the “Guidelines”), released in anticipation of Hurricane Irene last month.[1]

We support measures to promote the safety of all persons; ensuring safety is of paramount importance, particularly in the wake of a natural disaster.  Sadly, the Guidelines do little to ensure the safety of female-bodied persons.  Rather, the Guidelines completely ignore the direction, history, and psychology of the harm females face because of their sex.  The Guidelines explicitly direct emergency shelters to unconditionally allow male-bodied people who claim that they “live and identify as women” to access female-segregated spaces without any regard to proof or duration of such condition.  In so doing, the Guidelines disregard the right of female-bodied people to sex-segregated space and prioritize the safety of self-identified transgender women above the safety of nontransgender females.    The result – a willful disregard of the concerns about female safety in the name of so-called “gender equality” – constitutes an unconscionable position for any organization that seeks to promote social justice, let alone organizations that claim to represent females.  Female needs and vulnerabilities deserve representation and serious consideration in all matters that compromise the boundaries of sex-segregated space.

Ironically, the Guidelines do in fact recognize the actual harm that female-bodied people can experience at the hand of male-bodied people.  The Guidelines provide that “a person’s own evaluation of his or her safety should always be respected. For example, transgender men may be concerned that they would be perceived as female in a men’s shelter, and feel safer housed with women.  Reasonably, we believe, the Guidelines acknowledge that  nontransgender males in a shelter may perceive transgender men as female,[2] thus placing these transgender men at risk of female-specific harm if such transgender men become the target of violent attack.  The Guidelines implicitly recognize that male violence against females is a valid concern.  Although the Guidelines advise shelter workers to protect transgender men – who may grow a beard or use a male name and pronouns, among other transition efforts – by allowing them to seek refuge with females if they feel safer in female-only space, the Guidelines demonstrate no corresponding concern for nontransgender females.  Rather, the Guidelines direct nontransgender females to accept male-bodied trans “women” in their space without question, proof, or complaint.  This internal inconsistency promotes a double standard of care: one for trans people and another, lower standard for nontransgender females.

Female needs and vulnerabilities deserve representation and serious consideration in all discussions that compromise the boundaries of sex-segregated space, as females have a long-standing and legitimate interest in maintaining these boundaries.  We recommend that the Guidelines incorporate a balancing test to weigh the social discomfort and safety of transgender people against the rights and expectations of everyone else in the world, particularly females.  One reasonable compromise would be to limit the meaning of the term “transgender” to those whose medical history or treatment of transsexualism and/or government identification show one’s preferred “gender.”  Given that your organizations seek to override the boundaries of sex in sex-segregated spaces, such documentation should be the minimum prerequisite for access to sex-segregated space opposite one’s sex assigned at birth.  No doubt, this approach would deny some trans women access to the sex-segregated space of their choosing.  But the Guidelines endorsed by your organizations, while claiming to stand for “gender equality,” entirely disregard female need for sex segregation. This is unfair and unacceptable.

If NCTE, Lambda Legal and NGLTF can assert that fear of male violence constitutes a valid reason to allow transgender men to seek safe harbor with females, no doubt it should be quite clear why female concerns about male violence also constitute a valid reason to enforce the sexed boundaries of sex-segregated space to protect all females.  In other words, male violence (against females) is not ONLY a problem for transgender men – it is a problem for females as well.  We ask you to revise the Guidelines to more clearly balance the needs and interests of all people equally.


Elizabeth Hungerford

Cathy Brennan

[1]               The Guidelines appear at

[2]               Indeed, such nontransgender males may perceive these transgender men as lesbians. Lesbians as a class may experience a heightened risk of violence because of their gender nonconformity.


Pdf of letter sent here:

Source of our concerns:


  1. So, if I’m reading the guidelines created by the NTCE correctly, if someone should come into a shelter who looks completely like a man, acts like a man, but simply says they identify as a female, then the shelter is supposed to house them with women? Really? Am I missing something here? If I’m not, then these guidelines are WAY too general.

  2. Mary Sunshine · ·

    Thank you, thank you both so very much for your fine work on this.

    xoxox Mary

  3. You are WELCOME, Mary! It is my honor to represent female interests in the eternal fight for a room of her own. xoxoxox

  4. YES, LeeAlani! Exactly. Much too general. From the NTCE Guidelines:

    According to the National Coalition for the Homeless, if someone identifies herself as a woman, she should be treated as a woman in all circumstances, regardless of whether she was born male and regardless of her anatomy or medical history.


    Generally, if shelters are sex-segregated, people who identify as men should be housed with men and people who identify as women should be housed with women. This is true regardless of whether people have ID showing this name/gender, regardless of whether they look masculine or feminine, and regardless of whether they’ve had sex reassignment surgery.

    My bold. This is ridiculous. Especially when being instructed that TRANS MEN should be housed with women, WHILE CONTINUING TO IDENTIFY AS MEN:

    transgender men may be concerned that they would be perceived as female in a men’s shelter, and feel safer housed with women.

    The dissonance. It’s hard to read.

    Further, about WOMEN, and about homeless women’s unique vulnerabilities, FROM THE NATIONAL COALITION FOR THE HOMELESS, itself:

    Considering the cost and prevalence, as well as the direct relationship between housing and domestic violence, a majority of homeless women are victims of domestic violence. 28% of families were homeless because of domestic violence in 2008 (U.S. Conference of Mayors, 2008). 39% of cities cited domestic violence as the primary cause of family homelessness (U.S. Conference of Mayors, 2007).

    This is not lesbian violence they’re talking about. It’s MALE violence against WOMEN and CHILDREN. Homelessness is not my expertise, I admit, but the research I’ve done focuses on the significance of the violent and traumatic histories homeless women, in particular, suffer from:

    The most comprehensive and rigorous studies on homeless women conducted to date continue to note the extraordinarily high levels of abuse and victimization that homeless women endure before, during, and after episodes of homelessness.In fact, although rates of victimization in this country have decreased overall, rates of victimization among homeless women remain relatively unchanged (Lee & Schreck, 2005). Research also highlights the grim finding that homeless women often report multiple episodes of violent victimization at the hands of multiple perpetrators, beginning in childhood and extending into adulthood (Browne & Bassuk, 1997; Goodman, 1991; Goodman, Dutton & Harris, 1995;
    Felix, 2004; Lee & Schreck, 2005; Stermac & Paradis, 2001; Wenzel et al., 2004). Indeed, homeless women have been described as enduring a “traumatic lifestyle” (Goodman, et al., 1995)– one in which traumatic incidents such as sexual assaults are layered upon ongoing traumatic conditions such as struggling to meet basic survival needs and living with ongoing dangers and threats.


    Sexual assault also effects homeless women’s physical health.For example, in one study of homeless women, those who reported a rape in the last year were significantly more likely than nonvictims to suffer from two or more gynecological conditions and two or more serious physical health conditions in the past year (Wenzel et al., 2000).

    In the context of shelters, sex-segregated space is an especially sensitive and IMPORTANT matter.

  5. I’m so glad you two took this apart! you’re doing great work!

  6. We advocate female safety. It is not rocket science, and it is a matter that is *abundantly clear* to most people who live outside of GLBT Land. Indeed, in the Guidelines, NCTE, Lambda Legal and NGLTF implicitly recognize that transgender men may be vulnerable because of their latent female reproductive capacity.

    When three major GLBT Organizations implictly recognize this risk, and yet continue to advocate policies that do not promote female safety, you have to ask, what *is it* that they *are* promoting?

  7. Andrea Rosenfield · ·

    “When three major GLBT Organizations implictly recognize this risk, and yet continue to advocate policies that do not promote female safety, you have to ask, what *is it* that they *are* promoting?”

    ^—- THIS —-^

    It would appear that they’re trying to remove the word “No” from the female vocabulary. Why say “GLBT” when “MRA” is a letter shorter? They don’t even do much about gay men’s issues any more, they just use “trans” to attack everything women hold near and dear. I’m supposed to believe these groups are anything other than far-right astroturf… why???

    Oh, and to the “trans” who are pushing this crap, the people you’re working for throw away their tools when the job is done. Fair warning.

  8. Hey, I just stumbled on your blog and felt a need to comment. You are absolutely correct. Women’s rights shouldn’t be curtailed, especially considering how hard it was to even earn, and by earn I mean force those in power to grant, those rights. The other side of the coin is that trans people are engaged in that same struggle. It will be difficult to find the point where it will not harm either group. I think your compromise is actually a very good one. There should be some standard of proof. Allowing anyone in who makes a claim is disastrous. There are two outlets with this policy, one, a man could claim to be a trans woman and enter, or he could claim to be a trans man who felt threatened in the men’s area. Both of these harms are real and should not be disregarded. They need to be considered.

    The opposite, however, is what is the standard of proof. In full disclosure I am a trans woman. I am 21 and I am hardly larger than the average woman, and much smaller than the average man. Being on hormones for nearly 18 months has done a lot to make my body appear more feminine. My voice was never very masculine, and in fact to “pass” as male in the all male school I was sent to I had to constantly force my voice down in pitch. I however have no medical history because I couldn’t afford the therapy sessions after the fourth one. I am not wealthy and have no paper saying I am a woman. Where would I lie on the scale? I ask truly not knowing because these sorts of things worry me. I refuse to use the restroom at work at all because I transitioned while employed and I am worried that someone may be made uncomfortable.

    I suppose the point of my comment is to agree that there needs to be a boundary and to ask you what makes you the most comfortable so that I can act accordingly. I say this partly with pressing urgency as my parents have decided they no longer want me living with them and I may need these sorts of services.

  9. DaveSquirrel · ·

    Elizabeth and Cathy, thanks for writing this response. It needed to be done in a more official format rather than just exposed in blog posts.

    I was never a big fan of LGBT orgs, they were always too gay-male focused. Now they seem to be (M2T) trans obsessed. You can see that in the wording of the NCTE document, apart from the specific mention of the ‘transmen’ situation, most of the F2Ts are mentioned as an afterthought or frequently forgotten. Clearly the main thrust of the document was to ensure M2Ts shelter in female-only shelter accomodations. Nor was it written with much of a legal viewpoint or knowledge (rather amateurish imho).

  10. We sent this letter to the three organizations identified above. I am unclear as to what might be “more official” than that. We will update if we receive a response.

  11. Mary Sunshine · ·

    In answer to Kate: if you’re still packing peen you definitely need to be in the men’s facilities. Whether you are or not, the most sensible and self-supportive thing to do is to use those “family” washroom things that are single-user, lock-the-door-behind-you after you go in.

    I’m not any kind of tran; I know I’m female if for no other reason that at one point in my life I had to extrude another human being from inside my body onto this planet. Decades ago. But even at that, I often prefer to use the “family” single-user dealie because my gender “signals” can be very ambiguous. I don’t want to have to go into details of a difficult delivery just to convince the other females in the washroon that I am one of them.

    If there’s no single-unit deal, then the only honest thing to do is to use the men’s facilities, and explain your situation to them if asked any questions.

    That’s what I would have to do when I use the women’s washroom, now that any female who isn’t trying to make herself look like a fem-bot is considered to be male.

  12. Grr I wrote this big, long, admittedly incoherent rambling response but unfortunately my phone decided it had no desire to submit it. I will try to just go through main points because I don’t have another 30mins.

    With restrooms I hold it till I get home, because I did make a habit of using the men’s room so as not to cause anyone discomfort and had some experiences that I’d like not to again. My question regarded relief and homelessness shelters, as I have a deadline to move out of my fathers house. I see no situation in which the uhh, organ in question, would ever possibly be seen or known about. It would simply not be on my list of things to do. However in the men’s facility my incongruence would be quite glaring and I simply don’t want those kinds of experiences again. Especially contained in a space for hours at a time. That just isn’t an option for me, I won’t do it again. That is why I somewhat ask for permission. I understand radical feminism’s objection to the inclusion of trans people in these spaces, I really do. Believe it or not I understand your perspective quite well. I simply need a place to stay and it has proven unsafe for me, personally, to be in confined spaces with men. I understand that sadly precedent needs to over rule individual people sometimes, and if that is the case I can buy some really warm clothes. I guess I’m just saying, why is it that a trans woman is necessarily discomforting in these situations. Shouldn’t it be judged on an individual basis? Just like with other women?

    The one thing I take objection with is the “only honest thing” part. This particular sentiment is probably the entire source of the conflict between rad fem and trans women. This statement says, and its hard to see it otherwise, as “you’re really a man and saying you’re a woman is lying.” I just don’t understand this attitude. I wish I could. It’s the same kind of logic as when men say “you’re just not womanly enough” and it kinda confuses me that it is said through a feminist lens. Patriarchy impresses women and trans women in very similar ways. Working together would help, but short of that infighting strengthens patriarchy. When you make arguments like this, patriarchy can and will turn and use it against you in anyway it can. If feminists are on record defining womanhood, and saying that not meeting certain criteria justifies separation/exclusion then men can and will take and use that against women. Frankly I don’t care what you call me. I’ve dealt with so much of people telling me who I am and how I should live that it begins to turn into the grown ups from Charlie Brown. After a lot of crap I’ve finally arrived at a place where no matter how loud it is screamed in my face, I will not let anyone see me falter in declaring my identity. But it is deleterious to feminism. And ultimately it is unnecessarily hurtful. It is not about “rightness” or “truth,” to redefine a persons identity to match your world view. It’s about power. It’s what men have done to women for years and will continue to do if we give them our example to follow.

  13. Mary Sunshine · ·


    There are “family” shelters, you know. Places where homeless male / female couples, with or without children, and single adult people of either sex can stay. Not all homeless shelters are sex-segregated if only because children are homeless, too. Children, remember them? often accompanied by one or more parents, of either sex?

    You can understand that.

    No honesty or dishonesty required.

    There is a reason why females need to have *some* sex-segregated shelters. Male violence. That thing that *you’re* afraid of if you go to a *men’s* shelter.

    Still with me?


    Those females are homeless because they have been attacked by males. Take a few deep breaths. Now. Females in such a shelter will know for a bloody fact that you are male. Without seeing your precious dick. Their stress hormones will go through the roof. They will fear for the safety of their accompanying children. You will make their shelter unsafe.

    We’re talking shelter safety here.

    Shelter safety.

    EVERYBODY’S. As in, you’re not the only person in the world.

    OK, let that breath out slowly and take another breath: breath in s-l-o-w-l-y and deeply, then wait.


    Given that homeless shelters exist that are *not* segregated, which one would you go to if you were to be honest with respect to the intentions of the differently purposed shelters? Honest, honest, honest.

    Yeah, I know you *may* be able to sneak into the women’s shelter. But don’t count on it.

    The guys in the “family” shelters aren’t going to be thinking about you in the ways that males in a men’s shelter would. It’s a different dynamic. You can deal with it. It’s a concept.

    Homelessness is not a piece of cake. Been there, done that. If you can get your hands on a car, live in the car. It’s superior to a shelter. I know from experience.

    If you’re homeless, being trans will be the *least* of your worries.

    Check out the homeless forums on the internet. I belong to one. Best, smartest people on the planet. They’ll talk to you, check in with you to see how you’re doing. It’s the best thing that you can do for your immediate survival.

    Stay safe, and respect female boundaries. Sex is not gender. And stop being a hostile aggressive little p—k.

    All females are not your mother. And I, specifically, am not your mother.

  14. Hi again, Kate. As always, we need to differentiate the *style* of gender, from the *substance* of sex. Your penis makes you biologically male; my uterus makes me female.

    You say that:

    I see no situation in which the uhh, organ in question, would ever possibly be seen or known about. It would simply not be on my list of things to do. However in the men’s facility my incongruence would be quite glaring

    I understand that *you* have no ill-intent, but allowing someone with a penis to reside in the female-segregated areas of a shelter could present an unsafe situation for a woman who suffers from PTSD as a result of male sexual assault (a not uncommon occurrence or condition). How you identify does not change that.

    On the other hand, the incongruence you mention in the context of the men’s facility is a result of gender, or the way you choose to present yourself. If you dressed in unisex-type clothing and refrained from feminine decoration while staying at the shelter, there would be no glaring incongruence. I recommend that.

    Identities are constructed; sex is not. So if someone is NOT actively in the process of “changing” their SEX, that person has NO right to cross SEX-segregated boundaries. Sex and GENDER are different. Gendered identity cannot and SHOULD NOT trump physical reality.

  15. Mary Sunshine · ·

    This is (in my opinion) the best homeless forum on the planet:

    I receive their updates by email.

  16. Mary, I was unaware of any family shelters in my area. I have never heard of one here but maybe that’s just cause they aren’t talked about. I really didn’t even know that was an option. And I’m sorry that I came off as hostile. That was not a very good day for me and the very stupid last straw was my phone deleting a post that took me quite a lot of time and thought. I got really frustrated with it and for some reason the question about honesty struck me different reading it that time and felt like an attack on my person. A response to that part wasn’t actually in the initial message, and while I think I made a few points that are true, I’m sorry that my attitude came of as it did. It was truly not my intention just an unintended expression of a lot of frustration that day. I’m sorry I hope you understand.

    eHungerford, I get your point, that’s why I posted here in the first place. I read the original post about how certain medical histories justify this type of access and agreed that this is how It should be. A line is good and I found this to be a very fair one. I merely was asking what that line was. I’ve been on hormones for a year and a half and If I had the money I would not have the offending anatomy. That I can guarantee you. My question is what level of medical history is appropriate.

    Whether in unisex, male, or female clothing I am still obviously not a man. The best I can do is be visibly trans and that is just as dangerous. And also contrary to stereotype I cannot sound like a man no matter how much I try, so any talking would expose me even if my appearance were overlooked. Which is why I discounted that option. I wouldn’t do so without an absolute reason.

    On my phone again sorry for grammatical errors.

  17. Hmmm. In spaces segregated by biological sex, I’m sure MANY heterosexual males would much prefer to be housed with the females and gee if the only requirement were mere words “oh sure really I’m planning on having surgery sometime but not sure when”, well I bet many of them would be willing to tell the person in charge that they’re transgendered.

    Which is why a bright line is required. Under all circumstances, the male prison houses male prisoners regardless how small in stature that male person is. For purposes of sex-segregation, male is not defined by pitch of voice or muscle mass or anything else, it’s defined by possession of a penis and chromosomes. Small heterosexual men have a more difficult time in prison, but the solution is never to house them with the females!!

    And far too often have I heard a trans describe themselves as “passing quite well” as their target gender, when in reality TO OTHER PEOPLE they look 100% male. So it is impossible to correctly assess that type of subjective comment over the internet. It is also important to remember that the VAST VAST majority of boys and men who feel feminine on the inside are turned away from medical treatment because no amount of hormones or plastic surgery would help them resemble an actual female.

  18. Andrea, I know and whole heartedly agree. I just am asking what the line is. What has to be proven? I am on hormones, and have seen doctors so I’m not just making claims. And I’m also not attracted to women. Thank you.

  19. […] no negative implications for females. Most administrative policies about transgender individuals require the users to treat trans people according to their “preferred” sex. This means that, for example, a male must be housed with females whenever the male demands it as a […]

  20. […] The persistent failure of transgender advocates to speak to the actual concerns of Women, as seen with the Colleen Francis debacle, at Florence House, at this D.C. shelter, and, more recently, with Paris Green’s rape of incarcerated women, is a significant weakness in their analysis.  Here is a prior feminist response to the failure of transgender advocates to properly account for th…. […]

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