I fully and unequivocally support the proposed Regulations Governing the Practice of Physical Therapy regarding dry neeedling.

Physical therapists are very well educated in, among other topics, anatomy, pathology, physiology, neurology, sciences, clinical reasoning and decision making, rehab, biomechanics, and manual therapy, This makes them specialists in treating neuromusculoskeletal conditions.
PT's have in the neighborhood of 9000 hrs of education, which includes hundreds of hrs of supervised patient treatments during their internships.

Dry needling to treat myofascial pain and dysfunction is one of the many tools a physical therapist has in his/hers toolbox. It requires them to have thorough knowledge of anatomy, muscle function, and it requires precise palpation skills. During education, much emphasis is put on "safe and accurate" needling of the myofascial trigger points, and on complying with OSHA regulations. The results of this treatment are unparalleled and are lauded by many satisfied patients who experience much decrease in pain, much increase in function and much increase in their quality of life.

Other professions have their own clinical reasoning for the use of a needle to treat certain conditions, and all of them are using the needle in a vastly different fashion. If a physician uses a needle it is called medicine, if a dentist needles it is dentistry, if a vet needles it is veterinarian medicine, if an acupuncturist needles it is acupuncture, and when a physical therapist needles it is physical therapy.

One medical profession cannot control what another medical profession can or cannot do. That is regulated by the Board of that particular profession in each State. Especially not when a national organization of anther profession is urging all of its members to leave a comment on the Virginia townhall website to oppose a regulation in Virginia; a State in which they don't practice nor live. In addition, it is painfully clear and apparent that these members have no idea of the vast and extensive education physical therapists have, who are licensed in Virgina. The townhall website is open for public comments about the proposed regulations, and is not meant to be used as a forum for another profession to prevent physical therapists from practicing physical therapy.

As a physical therapist for 30+ years, I am teaching dry needling to deactivate myofascial trigger points for more then 10 years to many physical therapists, doctors, nurses, chiropractors, dentists, and acupuncturists.  All course participants agree that it is a unique treatment which requires a unique skill, and that it is not comparable to any other treatment.
The proposed regulations are well written to ensure proper education of the practitioner, it mentions that this treatment is not to be confused with a treatment done by another profession, and the proposed regulations ensure public safety.