To Whom it May Concern:

I have made these comments many times in the past, but before these regulations are permanent, I would like to reiterate my objection to their implementation.

All health care providers should be regulated, but regulations should be based on health care needs, not politics. Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion. This is politics at its worst and women's access to health care is the price we will pay if you move forward with these regulations.

- As currently written, the requirements -- specifically the time and resources required to physically alter health centers for no medical reason are likely to increase financial barriers/hurdles for patients as well as reduce women's ability to find a health care provider.

- The current regulations require extensive, medically unnecessary and inappropriate renovations to meet building standards designed only for new outpatient surgical hospitals, not existing health centers.

-Women in Virginia need better access to affordable, high quality healthcare, not politically-motivated barriers. Regulations that genuinely protect the health and safety of patients are critical, however politically motivated barriers to service put more women at risk.

As soon as is appropriate, these regulations should be reviewed and rescinded or significantly revised to speak solely to the medical necessity and not politics.

All health care providers should be regulated, but regulations should be based on health care needs, not politics. Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion. This is politics at its worst and women's access to health care is the price we will pay if you move forward with these regulations.

As currently written, the requirements -- specifically the time and resources required to physically alter health centers for no medical reason are likely to increase financial barriers/hurdles for patients as well as reduce women's ability to find a health care provider.

The current regulations require extensive, medically unnecessary and inappropriate renovations to meet building standards designed only for new outpatient surgical hospitals, not existing health centers.

Women in Virginia need better access to affordable, high quality healthcare, not politically-motivated barriers. Regulations that genuinely protect the health and safety of patients are critical, however politically motivated barriers to service put more women at risk.

I am an obstetrician/gynecologist who has practiced in Virginia for almost 30 years.  While I do not and have never provided abortion services, I recall many adolescents and young women admitted to my residency hospital (Johns Hopkins, in Baltimore) with severe injuries suffered during illegal abortions.  These resulted in life-threatening complications that sometimes cost these women their ability to conceive again.  

The requirements in this legislation that involve structural changes to the buildings housing these clinics are blatently designed to limit or prohibit access to pregnancy termination.  This bill is part of a nationwide campaign to reverse the constitutionally protected rights designated by the Supreme Court's Rowe versus Wade ruling.  It is obvious that the original legislation and opinions voiced by the Virginia Attorney General have resulted in political pressure being brought to bear on the Board of Health that will not reduce the number of abortions in Virginia.  Instead, the result will be an increase in illegal abortions and the complications associated with those procedures.

Please act to insure that women in the Commonwealth of Virginia continue to have access to the safe, legal abortions currently being provided.

Again, I urge the Board to reconsider implementation of the TRAP regulations. 81% of the comments submitted during the previous public comment period OPPOSED these burdensome architectural regulations.

We the people of Virginia can see that these regulations as passed have been unfairly applied and will cause financial hardship for the targeted women's health centers. We have said so repeatedly. Please represent us as you have been entrusted.

Out patient clinics that perform abortions are just that - out-patient facilities - not hospitals. If the Commonwealth wants all such facilities to meet certain health and safety standards, then, as with most such issues, existing facilities are granfathered.    I don't see anyone requireing that my old car burn unleaded gas, have airbags installed, etc. etc. etc.
 

I am not giving up. The TRAP laws are medically unsound, misogynistic, and are just wrong. Get gov't out of dictating a decision that should be between a woman and her medical practitioner. There is no evidence to indicate that current facilities are inadequate to meet women's healthcare needs. Please stop this partisan, anti-women legislation.

Virginia Board of Health:

PLEASE, I'm begging you, please stand up for woman and girls over politics, for science over falsehoods. Before it's too late. We need you to stand up for the health of Virginians over the health of political careers.

The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the Commonwealth, further marginalizing young, low-income, uninsured, and minority women by decreasing their health care options. 

The regulations impose unnecessary, burdensome building requirements that are unrelated to the services health centers provide and have no proven medical benefit. These building requirements will reduce or eliminate patient access to health care and are designed to force women’s health centers to close.

The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.

The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Hundreds of medical professionals throughout the state have spoken against unnecessary, burdensome building requirements, calling on the Board of Health to rely on evidence-based medicine, not politics.  The evidence shows that Virginia’s women’s health care centers are safe, trusted providers. 

Please protect us. We rely on you.

Sincerely,

Heather Higgins

I am so ashamed of this state.   That such a blatantly political agenda could be used against the women of Virginia is disheartening.   I will continue to vote against any politician that supports any version of this, and I BEG the Board of Health to rescind the new regulations in the medical interests of the women of Virginia.

The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Hundreds of medical professionals throughout the state have spoken against unnecessary, burdensome building requirements, calling on the Board of Health to rely on evidence-based medicine, not politics.  The evidence shows that Virginia’s women’s health care centers are safe, trusted providers.

I have been a registered nurse for 35 years.  The action about to be taken in Virginia saddens me as a health care professional.  Limiting access will limit credible acceptable health care.  In the case of abortion, legal or illegal, women will have one if they make that choice.  Please do not send this country and the State of Virginia back to the back alley abortions of the past.  The only thing you will accomplish is the death of women from a procedure that done correctly has a greatly reduced risk.

Thank you for your consideration.

TRAP adds regulations that are medical unnecessary, expensive, and designed with no real objective other than preventing abortions of all types.  These regulations limit a woman's choice and have no place in our state.

It is essential as a matter of women's rights and autonomy that they continue to have access to reproductive health care. These regulations are completley unesseccary and only serve to make it more difficult for women to get the health care they need.

When these burdensome and unnecessary regulations go into effect, TRAP could force many of Virginia’s remaining women’s health centers to shut their doors, leaving thousands of women without access to essential reproductive care.

TRAP has absolutely nothing to do with protecting women’s health. Instead, these onerous regulations are designed to force the majority of women’s health centers in Virginia to close, and prevent Virginia women from exercising their constitutional right to safe, legal abortion.
 

Convicted rapists and abusers are given a slap on the wrist while their victims are forced by the state to bear their children.  Why are dentists being spared; they are allowed to administer anesthesia and to pull teeth without having to have wide hallways and other nonsense.  Women have a right to freedom of choice.  I'm old enough to have mourned a classmate who was forced by law to have an illegal abortion in the late 1940s.  Why would anyone WANT that to happen?

I am standing in support of health care for all women.  It is ridiculous that these individuals in the Virginia house and senate will not agree to allow women the right to choose for themselves whether to abort their fetus.  These women frequently are raped and when this results in a pregnancy, she should have the ability to immediately abort the fetus. I did not do this because I wanted to have my baby and she is now 45 years old.  But it should be the right of every woman to make that choice.

It is my strong belief that these regulations are a thinly veiled attempt to infringe on the rights of women to choose what happens to their bodies with regard to reproduction.  It is not in keeping ith the spirit of Wade v. Roe and the regulations should not be enforced.  Thank you for your consideration with this important matter.

Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion.  I have previously stated my strong opinion against these regulations.

I find it appalling that certain elected officials have used their hard-handed influence on the board of health to ensure that these new regulations get passed.  I thought these certain officials wanted less governent in people's lives.  I think the  hypocrisy  of their actions in this case is typical of their character.

Virginia women have suffered enough at the hands of Republicans. TRAP regulations have no place in the U.S. Its implementation will add more obstacles and burdens to women needing care. 

Fellow citizens:

It is patently obvious that the TRAP legislation is designed to end the provision of abortion services in Virginia. If the legislature wants to ban abortions, they should pass legistlation to do so. The type of foolish, behind the back, techniques that TRAP represents decrease people's belief in the ability of the Commonwealth to make informed choices on behalf of all Virginians. From what I can gather, there appears to be no medical justification for the regulations that TRAP will impose. I guess that someone could feel smugly pround that he or she was able to accomplish a goal (ending abortion in Virginia) without passing legislation that explicitly does this. But is that any way to govern?

Sincerely yours,

John B. Nezlek

Targeted Regulations of Abortion Providers is not protecting the health of women in Virginia. Access to safe medical procedures regarding reproductive health is a right women in all countries and certainly in the USA should have. With the enactment of this law, Virginia is presenting to the world how backward we have become regarding healthcare. Medical care should not be a  political issue or personal or Party agenda.To enact this law requires medical procedures despite proven medical facts saying they are unnecessary. 

Consider the financial burden on the States with this law. Clinics provide medical care at more reasonable costs than private medical offices and hospitals. Preventative health care saves the State money by reducing high-cost, critical, emergency care and hospitalizations. Closing licensed clinics will push women who cannot afford private doctor bills and may not even have health insurance at all, into emergency rooms. Emergency rooms CANNOT turn away patients. Therefore, patients are treated regardless of whether they can pay the expenses incurred for their care. If they have no means to pay these bills, the burden falls upon the State to pay. 

In the longer term, the State often pays for childcare, Medicaid, social services, food, shelter,  and other State-funded programs supporting families in need. Larger families require more services. What is the logic is preventing families from controlling their size? 

Please put aside Party morals regarding legal and safe abortion and consider the financial, medical, and societal consequences of taking away personal choice in a country founded on personal rights to freedom.

These regulations offer a different interpretation of the law, mandating extremely oppressive new structural requirements on health care facilities that have been shown to safely provide first trimester abortion services to Virginia women, especially when no other existing facitlity is required to meet those standards.ype over this text and enter your comments here. You are limited to approximately 3000 words.

The TRAP regulations are burdonsome and unnecessary. Abortion clinics are safe,  and it is a total distortion to contend that they are not!

This is the most most obvious way i have seen to nullify and negative the laws of the United States of America. It is interesting that those that say they believe in the consitution so much will find any way they can to circumvent it, if the current law does not appeal to them. I think if i am correct this type of thing is what directly lead to the Civil War. There are alot of us that are more partiotic to the country as a whole then any small state splinter group. I think you reconsider just becasue of that fact alone.

Frederick L. Schwartz SSgt. USMC (ret)

                                     FMF Force Recon 1979-85,90-93

The new regulations, which were approved by the Virginia Department of Health in April 2013, will prevent women from accessing safe, legal abortions by forcing clinics to close their doors.  When women can't access these services, which are a constitutional right, the result is an increase in poverty and a decrease in quality of life for women and their families.  Moreover, regulating safe abortion out of reach does nothing to stop abortion from actually happening - it simply forces women to seek unsafe, dangerous procedures instead.  No woman should die or face sterility from unsafe abortion procedures, but it happens when the needs and rights of women are not respected, as they are not in these new regulations.  In addition, the reality is that these clinics do far more than provide abortion services (which again, are a legal, constitutional right).  They actively prevent unwanted pregnancies by improving access to contraception, help women stay healthy during pregnancy, screen for various cancers, and provide well-woman exams.  These clinics should never be forced to function as hospitals because they are not hospitals.  It could not be more clear that the regulations are not aimed at protecting anyone's health - they are designed to eliminate women's access to safe, affordable healthcare, even if they are poor.  This is not about health, it's about controlling women and forcing subordination upon them by preventing them from making informed choices about their own bodies and health.  This is unacceptable.  Period.  In the coming months, we will work to restore every woman's right to make her own choices.  

I strongly oppose the adoption of these regulations.  They are not required by law and the Department of Health was pressured to drop an approach which exempted existing facilities.  These regulations will severely limit access of women in Virginia to important health services.

I urge you to reconsider these detrimental regulations.

Sincerely,

Debra Jacobson

The Targeted Regulations of Abortion Providers is an ill-advised, ideological move on the part of  Virginia Legislators that do not speak for a large percentage of Virginians. These regulations will close many women's medical centers that only provide a small percentage of their clientel with abotion care while hampering other women from obtaining breast exams, pap smears, STD detection and treatment, as well as Family Planning information and acess to Birth Control. It is still beyond my understanding how targeting these clinics is in the best interest of Virginia's women and families while other out-patient services such as cosmetic surgery or Dental Offices are left alone. Please reconsider your stance on this issue.

Viginia's women have a basic human right to control their own fertility.  To exercise this right they need unfettered access to reproductive products and services.  TARP will severely limit their legal right to abortion services.  Virginia was founded by enlitened men and women who believed in strong individual rights.  We should not turn back on our heritage; Virginia should not pass TARP.

Allow me to reiterate the opinions already stated:

All health care providers should be regulated, but regulations should be based on health care needs, not politics. Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion. This is politics at its worst and women's access to health care is the price we will pay if you move forward with these regulations.

As currently written, the requirements -- specifically the time and resources required to physically alter health centers for no medical reason are likely to increase financial barriers/hurdles for patients as well as reduce women's ability to find a health care provider.

The current regulations require extensive, medically unnecessary and inappropriate renovations to meet building standards designed only for new outpatient surgical hospitals, not existing health centers.

Women in Virginia need better access to affordable, high quality healthcare, not politically-motivated barriers. Regulations that genuinely protect the health and safety of patients are critical, however politically motivated barriers to service put more women at risk.

To TRAP, we opposed you before and we still oppose you. Stop denying women's rights to health care!

The regulations are unnecessary as women's health clinics in VA are safe.  The intent of these regulations is to force clinics that offer abortion services to close.  Many low income women's health and, indeed, their lives will be in danger without these clinics.  How will you feel when the first death due to a septic abortion is reported when a VA woman is unable to obtain a safe abortion in VA?  I am old enough to remember when this was a common occurance.  Why does this administration continue to fail to protect the health of women in VA?  That is your job.

Let women have control and make their own decisions over their bodies and whether have children or not.  This is not and should not be a political issue.

This TRAP law will do more harm than good for women who need access to basic affordable health care. Abortion is a tiny percentage of the services that Planned Parenthood and other clinics provide. The best way to reduce abortions is to provide access to contraception and sensible family planning. The best way to ensure healthy families is to manitain access to affordable pre-natal care.

81% of the comments submitted during the previous public comment period OPPOSED the burdensome architectural TARP regulations.

We the people of Virginia can see that these regulations as passed have been unfairly applied and will cause financial hardship for the targeted women's health centers. We have said so repeatedly. Please represent us as you have been entrusted.

Please reconsider implementation of the TARP regulations

It is distressing to see how women, especially poor women, are being disregarded in this unnecessary set of regulations for clinics that perform abortions.  These clinics are already highly regulated and safe.  The changes may reduce the number of safe, legal abortions, but will not stop women from ending unplanned pregnancies.  What will also be reduced is access to the countless other health care offerings that these clinics, particularly Planned Parenthood, make available to women from all walks of life.  I volunteer at a Planned Parenthood, specifically talking to women who are considering abortion.  Most often their choice to abort is because they want to have a safe, stable environment for the children they do have.  They know what they can handle and seldom make this decision without a lot of serious thought and heartache.  Please do not persist in this misguided pretense that this set of rules promotes health and safety.

TRAP is another example of legislating politics and not science. This has nothing to do with health and everything to do with catering to the loudest minority's insistence that their beliefs be imposed on others.

Listen to doctors. Listen to legal experts. Listen to the women who are asking that legislators use good sense and good science, not empty campaign rhetoric, when enacting new regulations.

We ask for smaller government. Stop wasting tax payer dollars on frivolous symbolic gestures that will improve your ratings, and save your pen for regulations that actually make a positive difference.

IT is time to give Women the respect they deserve.

Again, I urge the Board to reconsider implementation of the TRAP regulations. 81% of the comments submitted during the previous public comment period OPPOSED these burdensome architectural regulations.

We the people of Virginia can see that these regulations as passed have been unfairly applied and will cause financial hardship for the targeted women's health centers. We have said so repeatedly. Please represent us as you have been entrusted.

Stop playing politics with women's health. I opposed TRAP before, and I still oppose it now. It does nothing but further a harmful agenda. 

These regulations are clearly specifically targeted to make first-trimester abortions more difficult to obtain for precisely those women who can least afford them. There is no medical safety justification for them. There is, I understand, no precedent for imposing requirements retroactively on existing facilities, aside from there being no medical justification for imposing them on ANY facilities.

I am aware of at least one facility that has already closed, at least in significant part because of these regulations.

But far greater damage would be done by causing the closure of many clinics that provide so much more than just abortions. In particular, it has been suggested that such clinics are a major front-line defense against the spread of STDs. If true, causing the closing of such clinics will impose a far greater health risk and health care cost to all Virginians.

I was expressed opposition to these regulations previously. Now I am aware of yet another strong argument against them and am more opposed than ever.

Regulations should be based on health care needs, not politics. Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion.

As currently written, the requirements  are likely to increase financial barriers/hurdles for patients as well as reduce women's ability to find a health care provider.

The current regulations require extensive, medically unnecessary and inappropriate renovations to meet building standards designed only for new outpatient surgical hospitals, not existing health centers.

Women in Virginia need better access to affordable, high quality healthcare, not politically-motivated barriers. After working in public health for over 30 years in Virginia, I am dismayed by regulations that are anti-women.

The regulations imposed on Virginia abortion clinics are deceptive to the maximum, for their purpose is not to insure health of women using the facities, but to stamp out abortion rights.  You can have all the regulations you want, but accidents will still happen.  Accidents harmful to patients' health happen in the best hospitals.  The regulations on clinics that provide abortion services are way overboard especially because these clinics provide so many other services to improve womens' health, like cancer screenings.  So I strongly oppose these regulations.  They should be rolled back and not put in the service of the Republican candidate for governor.  Remember, the head of Virginia's health department resigned because she knew these regulations were wrothless except for narrow, ugly, crass political purposes.

These onerous regulations have absolutely nothing to do with protecting women’s health. Instead, they are designed to force the majority of women’s health centers in Virginia to close, and prevent Virginia women from exercising their constitutional right to safe, legal abortion. They should not be implemented.

 

Keep government out of women's bodies. No TRAP.

I believe this end-run around proper legislation to effect the agenda of abortion-rights opponents is an abuse of the law and should not be enacted. Women, regardless of their station in life, should be able to procure legal abortions and should not be subjected to this blatant attempt to limit or eliminate them.

Once again, it is time to support a woman's right to have control over her body and the government

needs to keep out of the VERY PRIVATE life of women citizens.  This outrageous ploy to ultimately

ban abortions by instituting unnecessary regulations at facilities needs to be stopped.   As a member

of Planned Parenthood and a supporter of a woman's right to choose, I ask the health department

to not institute proposed regulations.  Are we going back to the time of back alley abortions for those

who cannot afford to travel to a destination that allows legal abortions?   I had an aboartion many

many years ago and had no physical or mental trauma. Incidentally I had to travel to Switzerland

because they were not allowed in this country.   Only wanted children need to be brought into this world.

All health care providers should be regulated, but regulations should be based on health care needs, not politics. Targeted Regulations Against Abortion Providers have nothing to do with women's health and everything to do with limiting access to safe and legal abortion. This is politics at its worst and women's access to health care is the price we will pay if you move forward with these regulations.   Women should have freedom of choice

I continue to be appalled, frightened even, at the efforts by Virginia politicians to prevent abortions in Virginia and to close down clinics that serve the medical needs of women.  Where are the men who care for these women?  We need to hear from real men, not politicians.  I fear that on this issue, Virginia is moving to a Nazi like stance?  If women are prevented from making choices about their own body. what is next?  And who will be the next targets?