Committee Members:

I have reviewed the regulation and the accompanying documents.  I have scanned the comments to date.  I appreciate the emotion that this topic generates. I wish to address some arguments I have seen.

Regulation versus prohibition: These regulations control facilities that perform abortions, they do not prohibit abortions.

Cost:  I understand that the regulation may cause the facilities some expense to comply - however if they are already practicing measures to control infection, provide CPR, assess medical history, advise patients about the procedure and risks, allow access for emergency personnel (entrances and corridors to allow stretchers) - I am not sure of the magnitude of the cost. Some measures, such as modification to allow access are one time costs (like Americans with Disabilities Act modifications) - I am sure that the organizations involved are smart enough to figure financing options including grants and fund raising to solve their complaint. I do not accept the increased cost (if any) as a reason to reject the regulation.  

Science:  I read with interest several posting mentioning, but not discussing, the science involved.  I saw no citations in the postings that I read that indicate controlling infection, having CPR certified persons, qualified anaesthesiologist (if used), or checking patient history are somehow at odds with science or modern medical practice,  If their point about science is a reference to statistics - they too are uncited, and one must exercise care in the reporting and source. Regulations usually stem from a problem or potential problem.  The issue for some appears to be how much risk is acceptable in order to control costs for abortion providers (passed on to clients). That might be interesting if credible cost and risk data is available.  All posters seem to agree that unregulated abortions are problematic and should be avoided, so I believe the referenced science must support some level of regulation.  I see no scientific argument to reject the regulation. 

Quality Control:   Having written procedures is not an onerous task, merely sound management practiced in many fields.  I suspect that enterprising practicioners will develop a generic version of the required procedures/staffing document that others will be able to complete with minimal effort or expense. I do not understand objections to inspections - certainly many types of endeavors to include food preparation require/allow for frequent inspections.  Is an invasive procedure no less important?  Similarly record keeping is also sound business (and medical) practice.  I support the quality control/assurance aspects of the regulation.

Safety:  If these measures are not already being practiced, it seems like they should.  I do not see how they create a danger or increase risk.  If they are already practiced, then there is no debate.  I support the proposal based  on safety issues.  

Discrimination: The claim that these  regulations discriminate against poor, rural and minority citizens is not supported in any of the posts that I read.  On the contrary, why should rural or minority women receive treatment of less quality than others?  Why are the costs greater in rural areas to have a CPR trained person available or a facility with adequate hallways and doors?  Should not a non-english speaking woman receive an adequate explanation of the procedure in a language she understands?  Obviously abortions involve women, but I fail to see how enforcing higher (or as some would argue already in place) safety standards discriminates against them.  The argument that these standards are more strict than other out-patient facilities may be true. I do not know the comparability of those regulations or the associated risks of the procedures involved - but that is not the issue under consideration. (However, I am not sure why they only apply to facilities performing a certain number of abortions a month.  Safety issues apply equally to a single abortion as to multiple abortions, in my opinion).  I reject the discrimination argument.

Politics:  It is unfortunate that reasonable people on opposing sides often feel the need to demonize (I hope that is not too religious sounding) those who disagree.  Politics are emotional.  Some will oppose these regulations based on a political need to react to anything that might somehow lead to a lesser number of abortions, and a fear that they will eventually lead to prohibit all abortions.  Others simply because it is supported by social conservatives or persons of certain religious beliefs.  On the other hand, some do support it as a step to reducing abortions, or because it is opposed by social liberals/progressives. Persons/groups will typically lobby and contribute to officials that share their views. I agree with most comments that politics should not be the cause for accepting or rejecting the regulation.  The issue here is not about allowing or preventing abortions, not about conservative or liberal.  Nor is it about the beliefs, motivations, or character of those on either side of that argument.  The issue is do these regulations achieve their purpose?  Do they help or harm the citizens of Virginia?

in conclusion, I have reviewed the regulation and documents concerning the licensure issue.  I have scanned many of the postings, and I take the authors of the postings seriously - they are good citizens who spent the time to comment. I have attempted to rationally consider the arguments that I have seen. I suspect my review will not change the politics of any posters, but hopefully it may cause some additional thought  for them and for the committee.  Based on my review and consideration, I respectfully ask that you make these regulations permanent.