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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Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]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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3/29/13  12:49 pm
Commenter: Tannis Fuller, National Organization for Women - Charlottesville Chapter

We strongly urge that these regulations NOT be accepted as proposed


Dear Members of the Board of Health,
The Charlottesville National Organization for Women (CNOW) asks that you reject the proposed final regulations for licensure of abortion facilities, also know as ”Targeted Regulation of Abortion Providers,” or “TRAP.”
Accepting these regulations as proposed, which do not grandfather existing facilities and are not grounded in evidence-based medicine, will jeopardize the continued operation of an estimated 75% of abortion clinics in the Commonwealth of VirginiaThese requirements, which purport to be made with the best interests of patient safety in mind, do not affect outpatient surgery clinics that provide plastic surgery, colonoscopies and other surgical procedures that are proven more risky than abortion to patients. These regulations are not acceptable, nor good governance.
First trimester abortion is one of the safest medical procedures performed in the United States. The Guttmacher Institute shows that fewer than 0.3% of people undergoing abortions in the first trimester of a pregnancy experience complications that require hospitalization. There is no evidence to support that these regulations, as proposed, will make abortions any safer.
If 75% of abortion clinics close as a result of these regulations, abortion will, in fact, become less safe. Restricting access to abortion, by forcing patients to travel farther distances, and incur greater financial cost, will disproportionately affect poor and rural residents of the commonwealth, and will not reduce the incidence of abortion. It will delay the ability of a person to access it, and will likely increase the incidence of self-abortion, thereby actually increasing risk.
A study published in the journal Obstetrics and Gynecology in 2012 demonstrates that having a baby is 14 times more dangerous than having an abortion. Interfering with a person’s ability to have an abortion, and forcing them to continue with a pregnancy is actually more dangerous to the patient. These regulations are not about patient safety.
Furthermore, accepting these regulations sets a dangerous precedent for possible future regulations of other medical specialties. That would not be good policy and nor are TRAP regulations.
Your responsibility is to protect the public's health; these regulations are not about actual patient safety. These regulations are inappropriate political efforts to undermine the constitutionally protected right to abortion. Therefore CNOW urges you each as individual members of the Virginia Board of Health to only approve new abortion regulations that are medically necessary to advance the public’s health. To uphold that you must reject these regulations as proposed.
Thank you for your serious consideration of CNOW's comments and of your service and commitment to the citizens of the Commonwealth of Virginia.
CommentID: 27688