BRAINTREE -- On behalf of the bishops of Massachusetts, the Massachusetts Catholic Conference (MCC) submitted a letter to the state Department of Elementary and Secondary Education (DESE) Aug. 17 opposing "very troubling and objectionable standards" in its proposed revamp of what will be taught in health classes across the state.

DESE is in the process of revising its Comprehensive Health and Physical Education Framework, a series of guidelines for health and sexual education that hasn't been updated since 1999. Some of the revised guidelines in the draft, which was approved by the Board of Elementary and Secondary Education and released for public comment on June 27, contradict Church teachings on abortion and human sexuality.

"My biggest concern is the fact that they're introducing topics related to sex education and gender to children at an age that is not appropriate in the opinion of the bishops," MCC Executive Director James Driscoll said in a phone interview Aug. 23.

The Massachusetts Catholic Conference is the public policy arm of the Catholic Church in Massachusetts and represents the bishops of the state's four dioceses.

If the DESE framework is approved, students between grades six and 12 (ages 11-18) would be taught how to prevent sexually-transmitted infections, "pregnancy options," and the "positive and negative consequences" of sexual activity. Of all the guidelines in the framework, this concerned Driscoll the most.

"What possibly could be positive about sexual activity at that age?" He wrote in his letter, addressed to DESE Assistant Director of Student and Family Support Kristen McKinnon. "Within the same age group, lessons about 'pregnancy options' would inevitably lead to discussions in the classroom about abortion as an option -- in the sixth grade!"

Driscoll also objected to the use of the word "genitals," references to same-sex parents, and gender stereotypes intended for pre-K to second grade students (ages 5-8).

"The MCC finds this material inappropriate for this age group," Driscoll wrote.

He also criticized the plan to teach children as young as eight years old about sexual reproduction, sexual orientation, and gender identity.

"Teachers would give a specific description of both biological sex and gender identity and how behavior or appearance does not define one's gender identity or expression," he wrote.

Driscoll wrote that parents, not schools, should be responsible for teaching children about sex "at a time, place, and age they deem appropriate for their children."

"Parents should be trusted by DESE," Driscoll wrote. "An approach of 'one size fits all' is not the solution."

Driscoll wondered whether, due to teacher shortages, sex ed would have to be taught by "teachers that are already overburdened and not properly trained in the field."

He wrote that parents and guardians should be informed about the content of the classes and be allowed to opt their children out with no consequences.

"Every child is a unique individual coming from different backgrounds, ethnicities, values, and family dynamics," Driscoll wrote. "They develop and mature on different timelines."

Better yet, he wrote, students should have to opt in if they want to take the classes.

Driscoll noted that the MCC stands "ready to discuss these matters more fully at your convenience and share different perspectives on the objectionable topics."

According to the DESE website, public comment on the framework will remain open until Aug. 28. Those who wish to comment can take an online survey at survey.alchemer.com/s3/6646350/Comprehensive-Health-and-Physical-Education-Framework-Public-Comment, email Kristen McKinnon at chpef@mass.gov, or send a letter to DESE (attention: Kristen McKinnon), 75 Pleasant St., Malden.

Driscoll encouraged those opposed to the guidelines to submit comments.

"They should make their voices heard," he told The Pilot Aug. 23.

After Aug. 28, the framework will be revised "as appropriate" in response to public comment, then presented to the board for a final discussion and vote.

According to DESE, the framework "supports the design and implementation of comprehensive health and physical education programs that are inclusive, medically accurate and developmentally, and age-appropriate."

This includes instruction about "gender, sexual orientation and sexual health."

"The frameworks fail the very vision statement put forth by DESE and quoted above," Driscoll wrote. "These standards are not 'developmentally and age-appropriate.'"

The framework's development began in 2018 and involved a panel of 45 administrators, health educators, nurses, community-based providers, and public health experts. In his letter, Driscoll objected to the fact that, among the private and public organizations that consulted on the framework, no religious organization was asked to provide feedback.