I am writing to express my opposition to the "emergency" outpatient abortion clinic regulations currently under review by the State Board of Health.  The proposed regulations have absolutely nothing to do with public health.  Rather, they are solely intended to shame women and increase the costs of a legal, Constitutionally-protected medical procedure.  

Among other things, the regulations would:

 - impose requirements, such as requirements for the number of parking spaces, that have absolutely no relation to the provision of medical services;

- single out, without any rational legal basis, one specific type of outpatient clinic for treatment as a hospital.  If the State Board of Health believes that Virginia's outpatient surgery centers are this dangerous, why aren't the regulations being applied to ALL outpatient clinics?  For example, fertility clinics provide invasive services.  So do clinics that perform numerous types of arthroscopic surgeries.  Why is the State Board of Health not promulgating nuetral, medically-based standards for all outpatient clinics?

- close health centers that provide a full range of health services.  The net effect of these regulation will be to put clinics that provide birth control, mamograms, STD treatment and first-trimester abortion services out of business.  Numerous families in the Commonwealth of Virginia already lack access to health care -- why is the State Board of Health actually working to further reduce access to services?

In sum, these proposed "emergency" regulations have no basis in standard medical practice.  They are unlikely to be upheld by the courts as they fail to meet even a "rational basis" level of scrutiny.  Promulgation of the regulations will only result in needless litigation expense for the Commonwealth and denial of necessary care for many men and women who currently utilize these health care facilities.

Accordingly, I respectfully urge the State Board of Health to reject these ill-advised and unnecessary regulation.

Respectfully submitted -

Christopher Day

1217 N. Quantico Street

Arlington, VA  22205