As a member of the American Institute of Certified Planners (AICP) I am aghast. It is usual to “grandfather” existing buildings when changing building standards, e.g., to not hold the older buildings to new standards that were not in place when the buildings were originally built.  If “grandfathering” is the general building regulations approach, then why in this case is it that these regulations proposed are to apply the very newest hospital standards to the mostly business offices that happen to involve women’s health clinics, but my dentist who does oral surgery, my colon doctor in their offices are not included?!?  That is because these regulations appear to be arbitrary and capricious and unreasonable.  Perhaps these regulations will be taken to court if these regulations are passed.

These women’s health clinics are likely to issue more pills these days than to do surgical procedures. That is especially if one considers that such clinics include in their services: sexual disease screening, pap screening, birth control, counseling  … and some times adoption and abortions. Also consider that the majority clinics provide the abortion services only in the first trimester.  Therefore these “emergency” and now proposed “regulations for licensure of abortion facilities [12 VAC 5-412]” are not needed.  Therefore this is clearly an imposed political agenda and not based on the health and safety of the public.

It is appalling that the Board of Health membership is said to have been partially changed by Governor McDonnell so the Board would vote to recommend such regulations and that Attorney General Kenneth Cuccinelli who has advocated these outrageousness ideas for years is said to have imposed his version to be the temporary “emergency” and latest regulations recommended.

These regulations are NOT needed to protect the health and safety of women, but are regulations that are extremely expensive burdensome government intervention that may cost thousands or millions of dollars and may create the opposite by financially forcing closures. These regulations are likely to endanger women’s access to locally needed reproductive health and safety across the state. The statistics are 98% of women use birth control and for some they have failure of method, usage, or worse by being forced against their will become pregnant.  Women can decide as they are allowed to under the law of the United States of America to continue to carry a pregnancy to term or to have an abortion.  Statistically their health outcomes are said to be some 7 times safer to have an abortion.  It is unreasonable that a woman should be forced to be delayed or to travel long distances for her affordable and safe reproductive health and services as a result of the said regulations.

In Virginia women’s health clinics have an excellent record of providing high-quality, safe services; I have not heard otherwise.  The politics of these regulations appear to have the simple purpose make it as difficult as possible to obtain a first-trimester abortion in Virginia and ultimately to shut down such clinics and access to abortion.

I oppose and condemn these proposed “regulations for licensure of abortion facilities [12 VAC 5-412]” as they are not needed for the health and safety of women.  This travesty is not about safety but about putting clinics out of business by imposing huge financial regulatory burdens --- so much for cutting government regulation and keeping government out of individual’s lives that we hear so often in politics these days. I strongly recommend that these regulations not be passed and enacted.

Sincerely,

Katherine Hoffman