Comment on FR Doc # 2010-04907

There is a general assumption throughout the wording of the proposed standards that somehow gender identity, sexual preference, sexual orientation, etc., has something to do with victimization. In truth, it does, but the standards have missed their mark in terms of their intent. The Commission made no secret that they believed that "these types" of conditions or lifestyles should be protected; however they erred in numerous ways while trying to reach that standard in their written documents, not the least of which is the actual proposed Standards. First, by definition, every same-sex assault is perpetrated by a homosexual. The Standards seek to protect these very predators by including them in the gay or lesbian category. They don't say as much, but as you work your way through the Standards, it is clear that protection, and even segregation to a degree, will ultimately encompass the predators, if the predators are savvy enough to admit their sexual preference/orientation. In short, we end up housing the predators with their most likely victims. Also, in the Juvenile Standards, beginning with the mental health and medical screening and permeating itself thoughout the Standards, is the message that somehow a person's sexual preferences and conditions are a mental health or medical condition. To my knowledge, only actual physical deviations are medically related; but the Standards require that ONLY mental health and medical staff screen people about these things, even if there is no reason to suspect that the person has mental health or medical needs associated with their sexual being. This gives the appearance that we somehow believe that people who have certain characteristics or feelings about their personal situation are somehow mentally or medically ill. Is that the perception that the Commission was trying to achieve? If it is sensitivity they seek, then that is what should be stated. It cannot be assumed based on a medical or mental health background.