Hi Fred,
If PayPal Website Payments Standard is selected as your Primary Gateway, when checking out the cart skips step 2 of the checkout which is the page so the Payment Methods available are controlled via PayPal. That being said, I don't think PayPal Standard supports the ability to checkout using a check.
As a possible solution, you could select "Manual" as your primary gateway then enable the "Show PayPal Checkout Option". This will allow you to choose between the Check Payment Method and PayPal on Step 2.
Hope this helps!
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