January 23, 2019

We are committed to upholding campus safety and preserving each student’s right to learn in an environment that is free from harassment and violence. The New Hampshire Campus Consortium Against Sexual and Interpersonal Violence and The New Hampshire Coalition Against Domestic and Sexual Violence stand with the NH Federal Delegation, Governor Chris Sununu, the National Association of Student Personnel Administrators, and the American College Personnel Association in expressing our concerns with the recently proposed Title IX regulations brought forward by the U.S. Department of Education.

We fear that the proposed regulations would have a chilling effect on New Hampshire campuses, and jeopardize student and campus safety by:

  • Narrowing the scope of cases that schools are required to respond to by adopting a stringent definition of sexual harassment, allowing schools to ignore instances of violence that happen off-campus, and creating barriers for students to report misconduct;
  • Allowing schools to adopt problematic standards and processes that closely mirror the criminal justice system, such as the use of a higher standard of proof in adjudication and requiring in-person cross-examination of the victim and witnesses; and
  • Permitting schools to use mediation processes rather than formal investigations in cases of sexual assault.

“Schools have a responsibility to keep all students and members of the campus community safe. We are concerned that the proposed regulations will deter students from coming forward and reporting, therefore limiting a school’s ability to respond to potential threats to campus safety,” said Robin Burroughs Davis, Chair of the NH Campus Consortium Against Sexual and Interpersonal Violence.

“It is difficult enough for students who have been sexually assaulted or harassed to come forward and report their experience – institutions cannot afford to take steps backwards in working to combat campus-based violence,” said Madison Lightfoot, Communications Specialist for the NH Coalition Against Domestic and Sexual Violence.

We encourage institutions of higher education, supporting organizations, allied professionals, students, and parents, to participate in the public comment period, which ends on January 30th.

The New Hampshire Campus Consortium Against Sexual and Interpersonal Violence is a statewide collaborative of New Hampshire colleges, universities, and professionals working collectively to develop and implement strategies to end interpersonal violence on NH’s campuses. The Consortium has participation from 22 NH colleges, both public and private, as well as the system office for the Community College System of New Hampshire, the New Hampshire Attorney General’s Office, and the New Hampshire Coalition Against Domestic and Sexual Violence and its member programs. For more information visit www.nhcampusconsortium.org

The New Hampshire Coalition Against Domestic and Sexual Violence is a statewide network of 13 independent member programs committed to ending sexual violence, domestic violence, and stalking, through direct services to victims, community education, and public policy advocacy. The NHCADSV and its 13 member programs do not discriminate based on gender, age, health status (including HIV-positive), physical, mental, or emotional ability, sexual orientation, gender identity/expression, socio-economic status, race, national origin, immigration status, or religious or political affiliation. For more information visit www.nhcadsv.org.