I write to oppose the proposed regulations that would require surgical-center style construction and fitting out for abortion facilities. The rather transparent aim of this regulation is to put abortion providers out of business when they can't renovate their facilities to achieve compliance. In so doing, the creators of this regulation believe they will thwart the performance of abortions in Virginia. This is under the guise of 'protecting women' or 'safety' for women.

As a midwife for over 35 years, I can tell you with confidence that the goal of thwarting abortions will not be realized in this manner. Here are some facts:

1. Women have ALWAYS - throughout history -  had abortions when they couldn't cope with having a baby.

2. Abortion, when carried out by providers with the knowledge and skills needed for safety, are orders of magnitude safer than carrying a pregnancy to term and giving birth. The major complication rate is extremely small, less than 0.5%. So there is no need to carry out extraordinary renovations for the slight chance of complications, nor is the rationale that tougher physical facility requirements will improve outcomes in any way believable.

3. Making it difficult for women to procure abortion, as the inevitable closure of clinics in the face of the propsed regulation will do, will only drive them to desperate measues such as self-inducing abortion or resorting to unskilled and dangerous practitioners. These are the abortions with high complication rates, including death.

I don't believe that what our state legislators and officials want is more women dying of pregnancy-related causes. So I would urge you to REJECT these absurd regulations

Thank you.

Maryann Long