The comment and notice period on Secretary of Education Betsy DeVos’s proposed Title IX regulations ended Feb. 15.

Carrie Phillips | Student Life

Wash. U. students attend a comment-writing drive hosted by Title Mine and WU Planned Parenthood Generation Action on Jan. 17. Students, University administrators and the AAU all submitted comments on the proposed changes to Title IX.

The Department of Education reopened the comment period for one day only, Feb. 15, after people experienced difficulties submitting their comments to the government website for the Jan. 30 deadline.

Title Mine and WU Planned Parenthood Generation Action (WUPPGA) held two comment-writing drives Dec. 7 and Jan. 17, and provided resources for Washington University students to write and submit their own comments on the proposed regulations.

Title Mine provided a channel for students to submit their comments when the federal register was down. According to Title Mine organizer junior Luka Cai, students submitted eight comments through Title Mine.

“I think the students submitted really thoughtful comments. I think quantity matters less than quality. When I was reading through the comments it was clear that the comments were worked on by a team of students who did a lot of research and put a really structured coherent argument together,” Cai said. “I really liked that as a movement, we have motivated and given students the space to write these really thoughtful comments. I want to recognize the students who didn’t attend the comment-writing drives but who used the resources or who were motivated by the drives to write their own comments and I’m really heartened by that.”

WUPPGA co-organizer senior Sophie Elliott said that she believes the comment-writing drives were successful.

“I think more than anything it helped raised awareness that this is an issue, because I think the government pretty deliberately kept this under wraps and didn’t advertise [that] this comment-writing period was even open or available,” Elliott said. “So I think it was important that people knew what these new regulations are and had a chance to voice their concerns, and I think it provided a platform for a ton of people to do that.”

Senior Elana Ross acted as a table facilitator for the second comment-writing drive and said she thought the drives were a “great way to get people sharing frustrations and learning together.”

“I wrote a comment and submitted it the day before the deadline. I do wish more people would have commented, but it’s always hard attracting crowds with difficult issues and especially because Title Mine is still a new name on campus,” Ross wrote in a statement to Student Life. “I hope when the inevitable and unfortunate changes this admin proposes surrounding sexual violence on campus continue, more people will keep showing up.”

Vice Chancellor for Student Affairs Lori White wrote a letter on behalf of Washington University on the proposed regulations; the University also submitted a comment as a member of the Association of American Universities (AAU).

“I actually liked Dr. White’s comment more than I liked the AAU comment, because it was specific to Wash. U.’s context and describes how Wash. U.’s current process, well, to be blunt, is better than the rules being proposed,” Cai said. “In the second to last paragraph of Dr. White’s comments she said, ‘we also are aware that some of our students are preparing to submit comments on their own behalf and we urge the Department to consider their personal stories.’ I really liked that Dr. White used her own comment to amplify student’s voices.”

Cai said that they believe both the University’s and the AAU’s comments were “lacking” in addressing some of the concerns students had about the proposed Title IX regulations.

“They didn’t mention at all some of these other concerns that students had, including the fact that under the new rules, schools will only need to investigate reports of unwelcome conduct on the basis of sex that are so severe, pervasive and objectively offensive that it effectively denies a person equal access. That piece of how the new rules will limit the definition of sexual harassment that gives rise to investigations…is completely not mentioned at all in either comments,” Cai said.

Another concern not mentioned by either comment was the reduction of universities’ responsibilities for Title IX violations that occur off campus. According to Cai, that specific regulation was a concern for many of the students at the drive.

“My comment focused on the proposed policies concerning cases that occur off campus and…would not be considered any longer under [DeVos’] new addition to the policy,” Title Mine organizer Katie Gemperli said.

Missouri state legislators have introduced two bills that propose changes to Title IX policies in Missouri, allowing more protection for the accused.

“Missouri just released they want to make a policy that would raise the burden of proof and we think our next event will revolve around the state policy,” Gemperli said. “Going forward we’re definitely going to be focused on this same general area.”

Title Mine, recently recognized as a Student Union group, will meet with Dr. White on Feb. 26, Mar. 20 and Apr. 24 to discuss Title IX policies at the University.

“We’re going to be talking about the comments that Wash. U. wrote for the notice and comment period and also moving forward [with] how Wash. U. will be responding and making changes to Title IX,” Cai said. “If you want to join any of these meetings or get updates from them, please reach out to Title Mine.”

Title Mine plans to commemorate the April 2018 rally that kickstarted the Title Mine movement. The rally is tentatively set for April 12, 4-6 p.m. in Edison Courtyard.

“We invite everyone who’s interested, who wants to see where this movement is going next [or] who wants to hear their voices heard at the rally, to email us, to reach out to us and share with us what you think the rally should be like,” Cai said. “It was a really huge milestone event for Wash. U. as a campus. To me, it was a very traumatic event that at the same time also gave a lot of energy and awareness to the issues of sexual violence on this campus.”

Cai said that Title Mine is recruiting volunteers to help “amplify the voices of this movement” and encourages students to get involved anyway they can.

“I also want to add that these issues of sexual violence and Title IX have been primarily fought by student activists and progress has primarily been made because student activists have used their voices to raise awareness about these issues,” Cai said. “So almost one year into this movement, we see that national policy changes are still making it hard for this movement to make progress.”