To the Division of Professional and Occupational Licensing of the State of Utah,
I experience same-sex attraction. It was critical for me to be able to explore ways of managing behaviors and feelings that would help me to live according to my own deeply-held religious beliefs. That included discussions that had the goal of and ended up altering behaviors, feelings, and even attractions. If I had not been able to explore these possibilities and have open and unrestricted discussions with my therapist, I would not have been able to trust my therapist and would have likely left therapy.
Before I attended therapy, I frequently had suicidal ideation, often considering throwing myself in front of a car while I rode my bike to work. Since therapy, those feelings are gone. I would not have been able to stop those suicidal feelings if my own wishes had not been allowed to be respected by my therapist.
I am concerned that if youth are not allowed to talk openly with their therapists and are not allowed to explore questions about sexuality and gender in a manner that supports their values, allowing them to explore changing behaviors and modifying feelings, they will likely be driven to the same suicidality that I had for some time.
All therapy employed for any reason has a goal of change. Therapy for unwanted same-sex attractions is no different. The goal of therapy should always be the client's goal, not a government-mandated goal.
The rule as currently written focuses on a goal of therapy, rather than a therapy modality. Youth should be protected from coercion and aversive therapies. But they should be able to determine what the goal of therapy will be.
I believe the rule should be modified to focus on specific practices and modalities of therapies to outlaw aversive practices. It should also set limits on promises made by therapists. Therapists should not promise cure, or substantial and permanent changes. They should not use aversive techniques. They should not coerce their client into choosing a specific goal of therapy. They should allow the client to determine the goal and progression of therapy.
Another problem with the rule is that it does not protect individuals who have deeply-held religious values that prohibit same-sex sexual involvement. I have heard a number of stories from my friends about therapists pushing their clients into abandoning deeply-held religious values. Some of my friends who also experience same-sex attraction found it very difficult to find a therapist who would not encourage them to seek out same-sex sexual partners.
Therapists should not push their clients into abandoning their value systems. Nor should they make statements that imply or explicitly state that the only way their clients can find peace and happiness is by engaging sexually with someone of their same gender.
Please modify the rule so that the rights of all clients are respected.