The current regulations do nothing to contribute to the safety of women. They are medically unnecessary, and creat a huge financial burden on womens' health clinics, which provide necessary care, such as cancer screenings, access to affordable contraception, as well as abortions. TRAP regulations target clinics which provide abortion case, despite the fact that there are many other outpatient procedures with much higher rates of complications than abortion, such as oral surgery and endoscopy, which are not subject to these expensive restrictions.

The American Congress of Obstetricians and Gynecologists has recently published a Committee Opinion on the importance of abortion access (http://www.acog.org/Resources-And-Publications/Committee-Opinions/Committee-on-Health-Care-for-Underserved-Women/Increasing-Access-to-Abortion), which includes a discussion about how TRAP legislation is harmful to women.  I urge the Commissioner and Board of Health to follow the recommendations of ACOG and rewrite these politicized restrictions so that they rely on evidence-based medicine. Rather than allowing political or ideologic forces to dictate medical care, regulatory action should be based on sound principles of public health and sound scientific data.