Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]
Action Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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3/11/13  10:43 pm
Commenter: Katherine Hoffman

Certified Land Planner - grandfathering is the usual way for existing buildings.


I am a certified urban and environmental Planner of the American Institute of Certified Planners (AICP). "TRAP,” or "Targeted Regulation of Abortion Providers,” laws involve meeting new hospital standards that are excessive and highly unusual as well as being unnecessary to correct medical services. Historically such building changes are applied only for new structures whereas existing building are “grandfathered” in as they are, e.g., do not have the changes applied.

In June 2012 the Virginia Board of Health “grandfathered” existing clinics which was the right thing to do.  In September with the state’s attorney General threatening the individual members that the State would not back them if the case went to the Courts. Who can blame the individuals and their families put in such a position as it is likely this will end up in the Courts.  That does not make it right.

These TRAP building regulations do not provide for women’s good health as these regulations limit access by increasing costs where there was not a major problem to fix and for clinics which cannot afford the new building change costs, when they must close their clinics, then needed access is gone.  When access and care is decreased, not increased, women’s health needs are more poorly met; TRAP has nothing to do with safe health care.

These TRAP laws are arbitrary, as they do not also apply to dentists, oral surgeons, plastic surgeons and colon doctors.

These TRAP laws make it more expense for providing a whole list of aspects of comprehensive care while poor women need good affordable health care during and slowly as we come out of the Great Recession.  These clinics have been affordable care for cancer screenings, gynecological exams, prenatal care and sexually transmitted disease testing and treatment, family planning, prenatal care and even adoptions.

I ask and I urge you the individual members of the Virginia Board of Health to only approve new abortion regulations that are medically necessary to advance the public health. Regulations that are not jeopardize the health and safety of women in Virginia. TRAP or "Targeted Regulation of Abortion Providers,” law has nothing to do with the safe health services for women and everything to do with inappropriate religious and political efforts to “war” on women and take away their US constitutional right to an abortion.  Please do the right thing and vote down the TRAP law for both new and old clinics. At a minimum grandfather the existing clinic and their buildings so we keep what access we do have.

Thank you,

Katherine Hoffman

CommentID: 26522