I would like to take this opportunity, both as a private citizen and as the state director for my organization, to comment on the feasibility of implementing these proposed regulations. 

This issue should be decided based on real medical concerns and not from any ideological standpoint and that does not appear to be the case thus far.

Respected medical testimony has been offered to show that these regulations are unnecessary and pose an undue burden on facilities that offer a safe and legal service to women. Furthermore, if the proposed regulations were being applied from a purely medical/public safety standpoint, other facilities, such as those offering cosmetic or oral surgery would be held to  the same standards and restrictions. However, this does not appear to be the case. That fact alone suggests that these regulations are "targeted" in the worst possible connotation of the word, and that their only real purpose is to limit access to a safe and legal service via the financial stranglehold they would impose. 

In closing, there is a real  and imminent danger in  limiting, or potentially removing the access that women in Virginia have to safe, carefully operated abortion services. The epidemic of potentially unsafe avenues women might be forced to avail themselves to has already begun and with  real and chilling results. This was the case before Roe v. Wade and it could be again, if clinics in Virginia are forced by burdensome and unnecessary regulations to close their doors. 

Brenda Seward

Virginia State Director, UniteWomen.org