Tomorrow, June 15th is a big day. Tomorrow people will be gathering from across the state at an anonymous building in an unprepossessing suburban office-park to try to make a group of bureaucrats and political appointees understand how important it is to not wipe away 40 years of progress on women’s reproductive health as the result of a sneaky bit of legislative legerdemain back in 2011.

Tomorrow the Virginia Board of Health will rule on final adoption of the so-called TRAP regulations (Targeted Regulations against Abortion Providers). The new regulations are designed specifically to make it nearly impossible for women to get an abortion in Virginia while not actually making it illegal. See, they can’t overturn Roe v. Wade (yet), so at the state level they’ve taken to making it so hard to run a women’s health clinic that provides abortions that no one can do it. And it’s working! Around the country states are installing more and more outlandish and ludicrous hoops for clinic operators to jump through, and more and more clinics are closing. A generation of violent intimidation, indiscriminate bombings, arson and assassination haven’t worked, but a room full of bureaucrats might finally manage the job for these zealots. Tomorrow APV will stand with many other organizations, groups and individuals in opposing these medically useless, politically motivated regulations. We urge you to join us in our efforts to keep abortion safe, legal and AVAILABLE in the Commonwealth of Virginia. Attend the hearing, write and call everyone you know, get angry and stay angry and win or lose, start working the next day to make the people who push these awful rules pay at the ballot box. Below are APV’s comments on the TRAP rules before the Board of Health tomorrow. For more information about tomorrow’s hearing go to APVonline.org

The Alliance for Progressive Values strongly opposes the regulations before you governing licensure of abortion facilities. In approving these regulations you will be placing extremely cost prohibitive constraints on abortion clinics when abortion access in the Commonwealth is already limited.

Specifically, the draft regulations require women’s clinics to adhere to standards found in the 2010 Guidelines for Design and Construction of Health Care Facilities. In particular the Guidelines for Outpatient Surgical Facilities, otherwise called ambulatory surgical facilities. It is important to note that these guidelines were not intended for existing structures but meant to govern the construction of new facilities, especially hospitals. By arbitrarily linking women’s clinics and doctors’ out-patient surgical services that provide abortions with regulations designed for large hospital settings, the Department, with the backing of the Governor and Attorney General, is launching a concerted, targeted attack on women’s reproductive choice in Virginia under the guise of innocuous structural mandates. This is not only dishonest, but it is also potentially dangerous. These regulations will significantly limit women’s access to safe and legal abortions in much of Virginia and could lead to women being forced into difficult and dangerous medical situations such as carrying a life threatening pregnancy to term.

The proposed regulations have no basis in medical best practices and serve only to make it harder for women to gain access to this legal and safe procedure. In fact, your own advisory panel of medical experts found these regulations to be medically unnecessary; sadly their recommendations have been ignored.

It cannot be stressed enough that today first trimester abortions which make up 90% of all abortions are routine, safe and legal in Virginia. Currently abortion providers are covered under the same regulations as physician practices that perform certain other, and in some cases statistically more dangerous invasive procedures, including dental, ocular and plastic surgery (none of which are covered by the new regulations). There is no evidence that there is any need for a change. Worse still, if anti-choice advocates have their way in the future, the prescribing of emergency contraceptives would be treated as a form of abortion and doctors who proscribed the legal and safe prophylactic in their offices would also fall under these new restrictions.

It should also not be lost in the highly emotional debate over abortion, that many of the clinics that will be forced to close as a result of the new TRAP regulations also provide other much-needed services to women around the state including breast exams, PAP smears, STI testing, HPV inoculation and other routine but necessary treatments, often at low cost.

The Alliance for Progressive Values strongly opposes the new Department of Health regulations and urges they be rejected or at the least be seriously reevaluated and studied further so that the consequences of their implementation to women’s health in Virginia can be better understood. As presently constituted, these regulations set women’s health in Virginia back decades and add unnecessary risks and costs for no medically sustainable reason. These regulations have nothing to do with protecting women’s health and everything to do with proscribing women’s reproductive choices.