I've responded. The questions are a bit odd - it just wants you to say whether you think the proposal is clear - its clarity isn't what I want to comment on!
I've said I think the proposed guidance places schools in an impossible position, and fails to give adequate support on how to handle the inevitable conflicts which will arise. It's a recipe for a lot of conflict, and leaves teachers/schools very exposed, I think. (Would be very interested to hear a teacher's perspective on this.)
So I focused on the fact that the guidance reiterates that RSE must be pluralistic (which is good, of course), but also encourages schools to use external specialist resources, without any guidance at all on how to select suitable resources. Most of the 'specialists' that schools might reasonably trust in this area (Stonewall et al) do not just promote a specific view of gender identity (which they're entitled to do) they also condemn other perspectives as hateful, and campaign to silence them. Using such resources can't possibly fulfil a requirement to be pluralistic. There needs to be criteria, and preferably a list of approved resources, to ensure that all resources used accurately represent a range of different views, don't indoctrinate children into a specific perspective, don't reinforce gender stereotypes or suggest that following/not following stereotypes might mean a child is transgender etc
The guidance also tells schools that "School policy should lay out themes and how potentially sensitive issues should be dealt with" but gives them no guidance on how they might do so. This sounds like a recipe for disaster.
I've also said I think parents need to have a right to see the resources used. (Some of the stuff dd has come home with so far has been quite off the wall, but it's quite challenging to work out what she's got from school, and what's instagram)