Thank you for the opportunity to comment on the proposed rules.  The question should not be if dry needling is safe to be performed by PTs.  Past experience in the state of Virginia shows us that dry needling has been performed safely by PTs for years.  How many complaints and disciplinary actions have been received/taken by the Board over the last 10 years due to dry needling?  Regulations are about public protection; if there is no public protection worry, than there is no need to decrease access to a very beneficial service.  Dry needling was an amazing part of both mine and my husband's PT plan.  It was not the only treatment, but it definitely helped both of us immensely and I feel our progress would not have been as successful without it.  We are military and now live in a state that does not have dry needling and we have traveled back to Virginia to receive this treatment because it was so beneficial. I encourage the Board to focus the regulations on clarifying what PTs need in order to perform dry needling, now whether or not they can.  That answer has already been given.  I also encourage the Board to look at what PTs have been required to have in the past, how well that has protected the public, and not make significant changes if the goal of public protection has been met.