University administrators submitted a public comment to the Federal Register concerning the U.S. Education Department’s proposed changes to Title IX on Tuesday.

The University expressed concern over some of the changes but stuck with familiar rhetoric, saying it appreciated the proposal’s commitment to a fair process for both sides. The stance is emblematic of the delicate balance colleges seek to maintain when it comes to the enforcement of Title IX.

The Education Department’s proposal would overhaul the process colleges use to investigate reports of sexual assault and harassment. The rules, in their current form, would bolster the rights of those accused of sexual misconduct.

Many students and survivor advocates believe the rules would discourage and harm reporters of sexual misconduct. These concerns have been laid out in comments on the rules, which the Education Department has been receiving since late November.

Northwestern’s comment, signed by University President Morton Schapiro, cited both pros and cons of the proposed changes.

“Northwestern shares the Department’s stated commitment to providing a prompt and equitable process for all parties involved in sexual misconduct matters,” NU administrators wrote. “In many ways, these regulations demonstrate this commitment.”

However, the comment was largely critical. Administrators took issue with eight separate sections of the regulations, saying they “impose an unprecedented amount of control” over a school’s ability to develop procedures. They added that the changes would confer a high cost on the University and that “certain aspects of the proposed regulations would be unfair to all parties.”

The comment calls for the removal of provisions that would alter the process by which incidents of sexual misconduct are investigated, changes over which Sarah Wake, the University vice president for equity, previously expressed concern.

During a November Faculty Senate meeting, Wake outlined the terms of the potential changes with which she was uncomfortable, including a change in policy regarding university investigations of off-campus incidents, requiring that universities use a “single-investigator” model during resolution and the narrowed definition of sexual harassment.

In their comment, University administrators also condemned changes to the standard of evidence used in investigations that would conflict with current Illinois law.

NU students and organizations, including Associated Student Government, also submitted formal comments about the changes. ASG submitted its comment, which was critical of the proposals, on Sunday.

Correction: A previous version of this story misstated the time Northwestern submitted its Title IX comment. The comment was submitted on Tuesday, Jan. 29. The Daily regrets the error.

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