1)  Irrespective of the polarized viewpoints regarding the morality, legitimacy, or constitutionality of abortion, there is no question about the fact that the "procedure" in question is a surgical one that poses medical risks to the patient. 

2) The existing body of state regulations that apply to facilities conducting medical procedures on human (and even animal) patients would strongly suggest that the state feels obliged to ensure a baseline of health, cleanliness, and safety standards are maintained throughout the state to protect citizens undergoing medical procedures.  

3) Therefore, the only logically consistent course for the state to take would be to either consistently apply such basic standards across medical enterprises or uniformly dismantle them.  Any other course would be arbitrary and capricious.  

4) The body of evidence from many years of abortion center inspections in Virginia offers a sordid litany of violations that have placed women's bodies and lives at risk.  So clearly, there is a problem here.  

5) That undeniable reality would suggest that between the two logically consistent options the state faces, the one the state OUGHT to take is that which applies and enforces the same standards to abortion centers that apply to other medical practices across the state.  Abortion centers should not be afforded ideologically-driven exemptions.  

Therefore, I recommend the following:

 - Require annual inspections on abortion facilities instead of biennial

- Reinstate all of the health and safety measures the Board unlawfully weakened during its last amendment process.

- Remove the ability of the Commissioner to grant permanent variances

- Reinstate the ability of the department to deny, suspend, or revoke the license to operate an abortion facility for violating "any provision of Article 1 (§ 32.1-123 et seq.) of Chapter 5 of Title 32.1."

- Reinstate the requirement that the abortion facility ensure that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion.

- Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.

- Reinstate the reasonable design and construction standards that provided for things such as hallways wide enough to carry patients out on stretchers in cases of emergency

Thank you for your consideration. 

J. Clough