Yeah but toilets and changing rooms aren’t for reproduction.

If you go entirely by who has a penis or not, at least you allow some post operative trans people to live freely, but I’m not going to be checking any genitals at the toilet door, nor doing any blood tests for that matter.

This guidance deliberately leaves trans people with two bad options: go in one toilet and be harassed or attacked for being trans or go in another and risk being attacked legally.