Planned Parenthood Advocates of Virginia is a statewide advocacy organization that works to ensure individuals and families have the freedom, information, and ability to make their own informed reproductive choices.  We appreciate the opportunity to submit this public comment.    

In Virginia, there is not, and never has been, a proven, medically justifiable reason for regulating abortion providers like hospitals. Until 2011, abortion providers and their practices were regulated like other physician groups and their practices. With the passage of TRAP (“targeted regulation of abortion providers”) laws in Virginia in 2011, abortion providers, and only abortion providers, were singled out for targeted, politicized regulations and restrictions by the state. These targeted restrictions had only one aim – to restrict and ultimately eliminate access to abortion in Virginia. These restrictions can do this by shutting down women’s health centers where abortion is performed, preventing physicians from performing abortions in their offices, and preventing new women’s health centers from opening. These restrictions also stigmatize abortion patients and providers, manifesting the State’s disapproval of the fundamental right to abortion at every entry-point in care.  Meanwhile, there is no proven reason grounded in patient health and safety that the Virginia Department of Health should license only abortion providers and no other physician group or medical office, as a category of hospital. It is important to note that, while the authorizing statute requires that VDH regulate providers that perform five or more first trimester abortions per month as a category of hospitals, there is no requirement that VDH treat all categories of hospitals in the same way. 

In sum, we believe the licensing requirement and the TRAP statutes are unconstitutional, unduly burdensome, and medically unnecessary.