Hello,

I am a citizen residing in the City of Richmond. This comment is in regard to the drafting of permanant regulations (originially emergency regulations as part of SB 942) relating to the operation of medical clinics that provide more than 5 abortions per month. I believe that the provision of these regulations requiring clinics to conform to standards outlined in the 2010 Guidlines for Design and Construction of Health Care Facilities within 2 years should be removed.

This provision will require expensive remodelling of clinics and is a completely impracticle expectation within the allotted time frame. The 2010 Guidlines for Design and Construction of Health Care Facilities explicitely states within the document that it is intended to facilitate best management practices in the construction of NEW FACILITIES. The stipulation that these guildelines would apply instead of the building code of Virginia is a violation of what the document was intended for and is also a very overburdensome expectation.

There has been no evidence that requiring practices to overhaul their facilities will improve the quality of care. Instead, renovation requirements will have one of three effects: 1) the facility will undrego costly renovations, passing on this cost to the consumer and raising the price of any and all services provided, 2) the facility will not be able to afford the renovations and will close, losing jobs and access to health care or 3) the facility will opt to stop offering abortion services.

Because of the lack of evidence that renovations will improve the quality of care, I believe it is likely that this provision was always intended to produce the third effect: to limit access to abortions. I think it is important that women seeking medical care for any reason have access to high quality services that emphasize safety, but that this provision is not at all necessary to guarantee good medical care.