Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations for Licensure of Abortion Facilities [12 VAC 5 ‑ 412]
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7/29/14  9:01 pm
Commenter: Rhonda Hening Davis, Alliance for Progressive Values

Repeal TRAP laws in Virginia
 
Dear Board of Health:
Please repeal the TRAP laws that were put into place last year. The regulations unfairly targeted women's clinics--clinics that provide many services essential to women's health in Virginia. These regulations were politically motivated, and were specifically written in order to close clinics that provide abortion services . 
If, in fact, the authors of these regulations were so worried about the architectural structures of the buildings in which outpatient surgeries are performed, they should have also included plastic surgery clinics and orthodontic or dental clinics as well. Why are women's health clinics the only ones targeted in the regulations, when so many other Virginians are potentially affected? The reason is because they wanted to make women's access to safe abortions virtually non-existent, not because they cared about the safety of women. 
The regulations focused upon architectural structures that have not failed the clinics in the past, and will not likely fail them in the future, to perform much needed services to women of all backgrounds and of all socio-economic statuses. Several Virginia clinics have already closed, unable to upgrade structures and provide the parking spaces necessary to adhere to the regulations. For every clinic that closes, many women will lose access to any women's health care. These clinics provide much more than abortion services. 
I am asking the Board of Health to vote rationally, and not politically, regarding the regulations. The Board had already voted the "grandfather clause" into the regulations, but it was shot down by a politically charged Attorney General, who literally threatened the Board with no legal support if they didn't support the regulations as they had been written. 
Attorney General Ken Cuccinelli lost the gubernatorial race in Virginia last year, because women came forward to vote. Women want affordable, accessible health care, and they want their health decisions to be between themselves and their doctors. They do not want legislators in their examining rooms.  
The Board of Health exists to provide the best care for their constituents. The width of a hallway or the number of parking spaces in a lot do not make women's healthcare facilities any more dangerous than they do any other outpatient surgery clinic. 
You have been placed in your position based on your knowlege and expertise in health care in Virginia. Please stay true to your convictions, based on the Hippocratic oath. You know that abortions are often necessary. They are not "just a form of birth control."  You know that women's, in fact, mothers', health depends upon these regulations. The waiting periods must also be repealed. They do nothing but add expense and stress to an already stressful procedure. They do nothing to make women more safe. If anything, waiting periods can make procedures less safe. 
Please consider this topic carefully. The regulations are not health-based. They are politically based. You are in your position to provide a health-based decision. Please do not allow politically based threats to influence your decision. Your public will support you.
Sincerely, 
Rhonda Hening Davis
 
CommentID: 34384