Please do away with the TRAP regulations. They are an undue burden to women seeking legal and safe medical care. 

Women need to be in a situation where they make all the decisions amd there are people who can get them there.  Once you take away that, We might as well call ourselves Musline and wear the garb.

The BoH is in a unique position to stop the politically-inspired intrusion into our healthcare decisions.  Healthcare is a political issue but the decisions made in the patient-doctor relationship is not a political issue.  I am hoping that the BoH will do the right things.  Thank you

Please repeal the medically unnecessary laws created to limit abortions. Women should be allowed to make decisions with their DOCTORS, not politicians. Take this issue out of the political realm and repeal those targeted laws.

The recent changes in Virginia that limit access to medically safe abortions were dead wrong.

Please consider that:

1. Women have a right to terminate pregnancies, and very few do so lightly.

2. Only medically appropriate regulations should be applied to clinics that serve women.

Dear Board of Health members, I am strongly opposed to any further restrictions on any clinics run by Planned Parenthood. It is fairly obvious to me that they were imposed through the politics of certain groups who apparently don't understand Planned Parenthood's mission and practice. Please relax the elready burdensome restrictions on their ability to assist women across the Commonwealth with basic health services that otherwise they would not be able to obtain. Thanks, Walter Neuron.

I am concerned about the proposed changes in regulations that would further restrict access to abortion by the women of Virginia.

Our laws and regulations, especially those governing medical procedures should be based on scientific evidence.

Abortion is an extremely safe medical procedure. Less than 0.3% of abortion patients in the United States experience a complication that requires hospitalization.-based regulations that reflect the safety record and reality of first trimester abortion.

Nearly all U.S. abortions take place in nonhospital settings and data going back decades confirm the safety of these procedures.  According to the American College of Obstetricians and Gynecologists (ACOG), providing abortions in the context of private practice is entirely appropriate, as long as physicians who do so in their offices are equipped to handle any emergencies that arise.

The World Health Organization (WHO) also makes clear that abortions can safely be performed not only in outpatient clinics, but also in physicians’ offices. WHO guidelines state that regulation of abortion providers and settings “should be based on evidence of best practices and be aimed at ensuring safety, good quality and accessibility.”

These regulations are often purported to be for the safety of women.  Ironically, they will likely to lead to unsafe abortions as access is further restricted.  Please let medical experts and evidence be the guide for regulations, not religious philosophy.

More complicated procedures are being performed in dental offices.The regulations concerning abortion clinics appear to be politically motivated and have nothing to with protecting women. Health decisions should be based in science, not ideology.

I urge the Virginia Board of Health to amend the current TRAP requirements for facilities providing abortion services.

The current requirements under TRAP are overly burdensome and unnecessary for ensuring the safety and health of the women recieving abortions. It is obvious to laypersons and those currently or previously involved in building regulations and permitting that the requirements are highly unreasonable, as they impose arbitrary and capricious regulations not imposed upon other medical outpatient facilities.

While abortion is a socially controversial practice, it is and has been a medically safe procedure, conducted in outpatient facilities in Virginia for decades, since Roe v. Wade until the present. The imposition of TRAP requirements has in no way improved the safety of women. It has only resulted in overly burdensome facilities enhancement, specifically designed to eliminate their existance.

When the availability or cost of an abortion becomes limited, women desparate to abort will resort to dangerous options.

I laud the Virginia Board of Health in considering changes for amending TRAP requirements and urge consideration of eliminating them altogether.

I'm writing this comment to urge you to use evidence and fact over politics, intellect over the emotions of a few in power, for legislation concerning women's health. Please do not make a woman's body and her right at self-determination and seeking the best care possible in this great, rich nation of ours a political game.

Virginia Board of Health,  I am writing to encourage you to make evidence based decisions in your consideration of changes to the TRAP regulations.  It is hard to see how number of parking spaces or type of water fountain have a meaningful impact on patient safety, particularly when weighed against the negative impact of less access to health care.  I am also writing to suggest you consider whether applying these types of regulations to ALL health care facilities (e.g. oral surgeons or dermatologists perfoming procedures in their offices) would pass the common sense test.  If not, then it would seem these regulations have little to do with health.  Thank you for your time and careful consideration.

Curious that the very acronym TRAP is used to impose non medically based restrictions on Women's Health Care Facilities, rules that do trap them into extraordinary expenses and force many to shut their doors.  

Of course, the motivation is not safety but shutting down facilities that perform abortions.  Whether or not abortions are supported by lawmakers' religious beliefs is totally irrelevant.  We are a Commonwealth that separates state and religion.  Patient safety should be the sole consideration, not the kind of water fountains available nor the width of the halls.  Abortion is one of the safest medical procedures performed in the United States.  

I urge you to stick to evidence based regulations when monitoring women's health centers.   

Thank you for your service.

Eugenia Anderson-Ellis

A heartfelt thanks to the Board of Health, for it's vote to approve the Notice of Intended Regulatory Action. It is my hope that this wil lead to an amendment of Virginia's anti-medicine/anti-women and families TRAP restrictions for health clinics in this state. As a Virginia citizen, a woman, and a senior, my lifetime experience leads me to believe in the intelligence of women and the competence of their doctors, to make their own health and family planning determinations. I also believe, adamently, that as pro family citizens, we must support health clinics for women and children who need them, not shut them down. Thank you!.

I support evidence based regulation that reflect the safety record of first trimester abortion and I support women's health centers.

I am a religious leader, theologyand ethics educator and I am writing to ask the Board of Health to make its decisions for regulating Abortion Clinics in Virginia specifically, but all medical facilities based upon evidence of direct impact on safety and healthcare of patients.  Hallway sizes, specifications in water fountains, and other extraneous suggested regulaitons for facilities do not have direct impact upon the health and safety of patients.  

Please do not allow our state regulations to be quided by the TRAP regulations being proposed which will have negative outcomes for clinics currently operating in our state. 

Sincerely,

Rev. Dr. Faith B. Harris

Before depriving a significant proportion of women of their health care options, there must be proof that the changes improve the outcomes for users of the service, or that they prevent documented harm.

Changes made to the regulations for Women's Health Clinics last year were politically motivated and did not fulfill either of those requirements, and, indeed, had no relation to reality. The end result was that women's access to inexpensive healthcare was abruptly limited due to the religious objections of legislators and not for any actual detriment found in those facilities. In point of fact, no research was done and no facilities were inspected to provide any basis for the regulation changes.

Despite my perception that those leading this vote in the previous legislative session would prefer that a woman's role reverts to one of chattel, the women of this Commonwealth know otherwise and deserve to have their needs addressed with facts, logic and respect. Antiquated religious ideas have no place in our society.

Virginians need evidenced  based care not regulations that  are driven by political motives.

I suppport evidence based regulations that reflect the realities of abortion. I want regulations and rules based on medicine-not politics. If Virginia health centers were forced to close because of TRAP restrictions ,I would not be able to access the care I rely on. I AM NOT ALONE. Hundreds of thousands of VA women and families also rely on that care. That care includes preventative care,birth control,STI testing and treatment,cancer screenings and SAFE, legal abortion. You have a responsiblity to protect the public health of Virginians. Please uphold your responsiblity and protect Virginia women's health centers and the women and families they serve.

Please keep the regulations strictly about women's health. Keep religious preferences out of the equation. There is no reason the the "incorrect" type of water fountain is a risk. These clinics provide so many other services to women than abortions. When a clinic closes hundreds of women who desperately need health care cannot get the help they need. This is just plain wrong. I sincerely doubt that the people who oppose these clinics have ever wanted health care they could not get. Most of the women affected are poor the one who most need help. If some one does not want an abortion, she needent get one. Denying health care to others on the basis of one and one only type of treatment offered is bigotry of the worst sort. 

Abortion is one of the safest medical procedures performed in the United States, and TRAP restrictions aren’t really about women’s health and safety. Width of health center hallways, number of parking spaces, and certain types of water fountains have little impact on patient health. 

Pleae continue to support high quality health care in a safe and respectful environment. This includes compehensive gynecological procedures, including abortions.

We all know nothing is always 100% safe, but  abortions come close. The restrictions recently placed on providers are medically unnecessary and are geared simply to prevent women from doing what they think best for themselves and their families.

In addition, the clinics do a lot more than just perform terminations. They are the loci of much other necessary health care for women.

I urge you to consider only the evidence based information, to ignore politically motivated misinformation, and to make sure women in the Commonwealth have access to needed medical care.

We hope the Board will be certain any regulations regarding Women's Health Centers will actually be to benefit women and not be motivated by political interests. Wider hallways do not benefit women's health.

I hope that this new year will give women a voice and a choice. Please use scientific based information rather than religious or political reasoning when creating regulations for abortions. Roe vs. Wade gave women the right to choose a long time ago and politicians and religious groups continually try to chip away at the hard won right for women to choose. Of course abortions need to be performed in a safe environment. They have been safely performed for years. We can't go back to"'back alley" and "coat hanger" abortions when medical technology and science have advanced as much as they have. 

I urge you to Please be considerate of women's actual needs and keep open the facilities that we need. Obstruction of our rights is Not an option and we are counting on you, our elected officials, to keep Our Best Interests in mind Not political objectives that are all too frequently at odds with Our Rights.

Thank you,
Jolynn Loftus

Please eliminate the unnecessary proposed TRAP rules. Abortion is one of the safest medical procedures performed in the United States, and these proposed rules are obviously not about women’s health and safety. Width of health center hallways, number of parking spaces, and types of water fountains have little impact on patient health.

Medical facilities which provide abortion, by licensed physicians, do not need hospital physical structures. This is a safe medical procedure which has been accomplished millions of times. The number of negative emergencies is no greater than that of other outpatient procedures. Modern technology has made it even more safe than in the past. The width of halls, or number of parking spaces, is irrelevant to the safety of the procedure.

In a perfect society there would be no rape; all pregnancies would be planned. And abortion would be limited to non-viable fetuses or to save the life of the mother. Until that day, we need to prevent abortion by education and family planning. 

Please formulate regulations that result in evidence-based rules that provide a full spectrum of assistance for women's health. In addition, please eliminate (1) provisions that require unnecessary procedures meant to harass patients and (2) standards meant to shut down facilities that could otherwise provide needed services.

Thank you for your consideration.

Elinor Schwartz

Arlington, VA

Dear State Board of Health:

I support the proposed amendments to the regulations governing the operations and architectural requirements for abortion clinics in Virginia. I believe these amendments will align the regulations with other health facility regulations.

Sincerely,

Donald Phillips

The best way for your organization to know about healthy and without political and religious obstacles abortion procedures is to travel to Denmark, Holland, Sweden, and Norway, where women enjoy more rights when  compared to cumbersome abortion rules in Virginia.

Please approve the NOIRA to lessen political reasons for regulating health care.  Thank you.

Access to good health care should be made more available especially to working class and poor women.  Good health care includes the option of abortion, which should be decided by the woman with the help of her physician and anyone else she chooses to include her decision.  TRAP restrictions have nothing to do with women's health; they are solely to prevent abortions, even when to do so means that thousands of women will no longer have access to basic health having nothing to do with abortion.  TRAP retrictions are solely to hurt women and "keep them in their place."  TRAP should be voided immedaitely.

Get rid of the trap regulations!  Rules need to be evidence-based, not emotion-based.  

The science is in. Abortions are not dangerous. They are even safer than childbirth. New drugs make it even more safe. These medications can be, and are being  given in the home setting in other countries and some states. Women are not dying, nor having a lot of complications after abortions. 

The law already permits abortions as it permits each person's decision to have various  other procedures at outpatient clinics. Physicians set the standards and qualifications for medical procedures, backed up by plenty of research. With this in mind, why should politicians and the religious right have the power to prevent any woman's decision or need to have a safe abortion by passing bogus laws in the name of keeping women safe? Why does it matter if a hallway is 6 ft. wide? These regulations are not being required for other outpatient procedures. They are only being required to provide stumbling blocks to make it much harder for women to access their legal right to have safe medical care. These stumbling blocks have a seriously detrimental effect on the poor. 

Please  remove these bogus rules and allow women to make their own health care decisions with their medical doctors. 

Thank you,  Millie Kantner

These regulations are not medically necessary and may be dangerous as they force women to wait and/or travel to obtain an abortion.  They serve one purpose only - to close reproductive health clinics and impede a woman's right to terminate her pregnancy safely.  End them now - let's stop pretending they provide any safety measures.  

As a nurse and a woman I feel that regulations regarding first trimester abortions and in fact any medical procedure should be based on evidence not rhetoric that purports to provide protection for patients.  Health care has progressed based on the facts and findings of controlled scientific experiments.  Do not change the way healthcare is provided to satisfy others.  Thank you.  Joan Moore

i  support of evidence-based regulations that reflect the safety record and reality of first trimester abortion.

Since she said it so well, I would like to echo what Suzanne said earlier: "These regulations are not medically necessary and may be dangerous as they force women to wait and/or travel to obtain an abortion.  They serve one purpose only - to close reproductive health clinics and impede a woman's right to terminate her pregnancy safely.  End them now - let's stop pretending they provide any safety measures."

The regulations imposed by 12 VAC 5-412 and the 2010 Guidelines for Design and Construction of Health Care Facilities maintains a high medical standard that protects women.  Previously, two different abortion clinics, Nova Women's Healthcare Center and Hillcrest Clinic, caused several injuries through poor medical procedures and unsanitary conditions.  The regulations embodied in 12 VAC 5-412 not only assisted in closing those two substandard clinics forwever, but it also raised the medical stardards for all of Virginia's abortion clinics.  I urge you to protect Virginia's women by refusing to relax any of the regulations embodied in 12 VAC 5-412 and the 2010 Guidelines for Design and Construction of Health Care Facilities.     

The restrictions placed upon abortion providers in 12 VAC 5-412 have done much to protect women from poor medical procedures and unsanitary conditions. In fact, two substandard abortion facilities, Nova Medical Clinic in Fairfax County and Hillcrest Clinic in Norfolk, caused unnecessary injuries to women during such medical procedures. The Nova Clinic was particularly unsatisfactory as they had cases of women having to undergo emergency hysterectomies and hospitalization for multiple days. The restrictions imposed by 12 VAC 5-412 are there to protect the health and even the life of the woman undergoing the procedure. Even though this is a very common procedure and it is done on an outpatient basis, it is still surgery and basic standards are needed. Therefore, I urge you to maintain the restrictions embodied in 12 VAC 5-412 to include all the 2010 Guidelines for Design and Construction of Health Care Facilities.

As a previous poster commented:

"These regulations are not medically necessary and may be dangerous as they force women to wait and/or travel to obtain an abortion."

This is particularly true for women who are struggling to make ends meet. Lawmakers need to stop placing burdensome regulation on clinics in an attempt to circumvent women's constitutionally protected right to choose.

To the Virginia Board of Health, 

I urge you to appeal the TRAP regulations passed in 2013. The TRAP regulations were advanced and implemented in order to reduce access to abortion without actually challenging Roe v. Wade, which affirms that the right to privacy extends to a right to have an abortion. They do not, in any way, refer to medical standards, and were not intended to make the procedure safer.

If the Board has concerns regarding the safety of abortion or the suitability of Virginia's clinics, it has a duty to adopt regulations that explicitly address those concerns. If the Board choses to implement such regulations, I will support them wholeheartedly. 

In conclusion, I urge the Board to actually advance women's health, by rescinding TRAP and, if necessary, implementing new rules which are actually applicable to safety. 

As you consider revisions to TRAP regulations, I strongly urge you to place the highest priority on medically necessary and science based policies and procedures..

• I support the Board of Health’s decision to amend the medically-unnecessary restrictions designed to close safe, trusted women’s health care centers in Virginia. As a person who is deeply committed to ensuring that all Virginia women have affordable access to safe, legal reproductive health care, I applaud the Board of Health’s decision to stop letting politics drive decisions that affect women’s health.

• The restrictions on women’s health centers in Virginia are about denying access to abortion, period. Three of 21 women’s health centers in Virginia have been forced to close or stop providing abortion services, in part due to these medically-unnecessary restrictions.

• If the restrictions remain unchanged, additional health centers will close – cutting off access to preventative and critical health care for thousands of Virginia women. Now is your chance to fix these restrictions and keep Virginia women’s health centers open.

• We all agree on the importance of ensuring patient health and safety, but the restrictions on women’s health care centers in Virginia don’t do that. Medical experts, including Dr. Karen Remley, the former Virginia Health Commissioner, and the Virginia Chapter of the American College of Obstetricians and Gynecologists oppose these restrictions because it’s clear that the restrictions have nothing to do with patient safety and everything to do with inserting a politician between a woman and her doctor.

• I support the Board of Health’s decision to amend the medically-unnecessary restrictions designed to close safe, trusted women’s health care centers in Virginia. As a person who is deeply committed to ensuring that all Virginia women have affordable access to safe, legal reproductive health care, I applaud the Board of Health’s decision to stop letting politics drive decisions that affect women’s health.

• The restrictions on women’s health centers in Virginia are about denying access to abortion, period. Three of 21 women’s health centers in Virginia have been forced to close or stop providing abortion services, in part due to these medically-unnecessary restrictions.

• If the restrictions remain unchanged, additional health centers will close – cutting off access to preventative and critical health care for thousands of Virginia women. Now is your chance to fix these restrictions and keep Virginia women’s health centers open.

• We all agree on the importance of ensuring patient health and safety, but the restrictions on women’s health care centers in Virginia don’t do that. Medical experts, including Dr. Karen Remley, the former Virginia Health Commissioner, and the Virginia Chapter of the American College of Obstetricians and Gynecologists oppose these restrictions because it’s clear that the restrictions have nothing to do with patient safety and everything to do with inserting a politician between a woman and her doctor.

• I support the Board of Health’s decision to amend the medically-unnecessary restrictions designed to close safe, trusted women’s health care centers in Virginia. As a person who is deeply committed to ensuring that all Virginia women have affordable access to safe, legal reproductive health care, I applaud the Board of Health’s decision to stop letting politics drive decisions that affect women’s health.

• The restrictions on women’s health centers in Virginia are about denying access to abortion, period. Three of 21 women’s health centers in Virginia have been forced to close or stop providing abortion services, in part due to these medically-unnecessary restrictions.

• If the restrictions remain unchanged, additional health centers will close – cutting off access to preventative and critical health care for thousands of Virginia women. Now is your chance to fix these restrictions and keep Virginia women’s health centers open.

• We all agree on the importance of ensuring patient health and safety, but the restrictions on women’s health care centers in Virginia don’t do that. Medical experts, including Dr. Karen Remley, the former Virginia Health Commissioner, and the Virginia Chapter of the American College of Obstetricians and Gynecologists oppose these restrictions because it’s clear that the restrictions have nothing to do with patient safety and everything to do with inserting a politician between a woman and her doctor.

Tye over this text and enter your comments here. You are limited to approximately 3000 words.

Thank you for the Board of Health's decision to amend the medically unnecessary abortion clinic regulations. As they stand, the regulations have been used to force the closures of clinics that provide safe medical care to women who need it. Please use this process to ensure more health centers are not forced to close.

Forcing abortion clinics to close is immoral and places women in danger. While proponents of the onerous clinic regulations claim they care about women's health and safety, their true colors were on display at the most recent Board of Health meeting where men spoke and claimed they supported the regulation because they believe it's a man's job to make sure women do the right thing. Another man held a sign that said "abortion hurts women." Whether the speakers in favor of these regulations are man or woman, their real goal is to make abortion impossible to access in the Commonwealth by regulating the clinics out of existence. 

Contrary to claims and rhetoric, abortion is overwhelmingly safe. A recent study by the University of California at San Francisco looked at the entire health records of more than 50,000 women who had abortions in that state, and the rate of major complication was one quarter of one percent. 

Ensuring that health centers that offer the full range of reproductive care remain open is a necessary condition of equality and justice for women, whether women need or choose to have abortions themselves. As a Virginian and the mother of a baby girl, I request that you fix these restrictions so that the clinics can remain open.

I understand that Virginia wants to shut down health centers that provide reproductive services; yes, I do mean abortion-but think about this: If Republicans take away food stamps (Florida calls them SNAP), has taken or will take away expanded Medicaid or affordable health insurance; then women can't afford to have children. If you take away abortion providers, then have emergency contraception medicines available without cost, hinderance or restrictions from your state's religous leaders/menbers. Gone are the days where women are chattel or owned & governed like any kind of livestock-we women are humans! Unless you want women to start restricting your Viagra/other ED medications, and monitor your bodies as something to get under control-then please be ever so respectful to let women make their own reproductive choices. You have different ideas about abortion; just as you have a disagreement about a news article, but you don't fight to take away the First Amendment-so be it with reproductive choices. Since men are part of the problem, try getting other men to NOT get any women pregnant by saying 'a real man doesn't get a women pregnant/'knocked up'/or whatever other term being used these days, just to be a man. A real man would & shouldn't get a woman pregnant if she doesn't want her to abort his child'.  Just like boys & young adult & grown men should, no must, be told not to rape no matter what they need to not get any women pregnant-and be taught to 'pleaseure themselves' to respect all women by not taking a chance getting a woman pregnant, or making it solely her responsibility to 'deal with it afterwards'.