SENATE OF VIRGINIA

Committee Assignments:
RICHARD L. SASLAW Chair, Commerce and Labor
Majority Leader Education and Health
35th Senatorial District Judiciary
Post Office Box 1856 Finance & Appropriations
Springfield, Virginia 22151 Rules

December 15, 2021

Ms. Muriel-Theresa Pitney

Clerk of Court
Supreme Court of Virginia
100 N. 9th St, 5th Floor
Richmond, VA 23219

Dear Ms. Pitney:

Pursuant to the Court’s Redistricting Rule 4, the Virginia Senate Democratic Caucus
respectfully submits the following comments on, and proposed amendments to, the draft Senate
map released by the Court’s Special Masters on December 7, 2021.

To begin with, my colleagues and I want to thank the Special Masters for their diligent
efforts thus far. The Redistricting Amendment, its implementing legislation, and this Court’s
rules place a premium on transparency and public input in the redistricting process. By releasing
their draft maps early along with a detailed memorandum explaining their approach and data
regarding the draft districts, the Special Masters have given the public, along with the parties
specifically mentioned in Va. Code Ann. § 30-399(F), an opportunity to review and comment on
the draft maps, including to propose amendments that will ensure the maps ultimately adopted by
the Court comply with the governing laws and advance the goal of fair elections for Virginia
voters. In addition, the Court has created a robust public comment process by providing multiple
ways for the public to share their views on the important work of drawing new districts. It is in
this spirit that we submit the comments and proposed amendments below.

In summary, in recognition of the Special Masters’ reasonable approach in many areas,

we are not proposing any wholesale overhaul of their draft Senate map. Instead, the Senate
Democratic Caucus respectfully submits that certain districts in seven specific regions should be
modified to better reflect important communities of interest and other significant considerations
regarding the makeup of the Virginia Senate. Of particular note, the Special Masters’ draft
Senate map pairs the two longest-serving African American members of the General Assembly,
including the current Senate President Pro Tempore, in a single district. While we understand
that the Special Masters chose generally not to consider incumbent addresses or pairings, a map
that effectively expels at least one of these historic African American figures and civil rights
icons from the Virginia Senate will not help move the Commonwealth forward. We have
therefore proposed modifications to the draft Senate map that will avoid this unacceptable result
while simultaneously improving the preservation of well-recognized communities of interest in
the relevant regions. These and other proposed modifications, including to better preserve
college and university communities, are detailed below.

I. Hampton Roads

We appreciate the Special Masters’ recognition that the Senate districts in the Hampton
Roads region are “among the most difficult districts to draw in the commonwealth, as they
require a careful balancing of competing considerations based upon geography, community, and
race.” Memo from Special Masters to Supreme Court (Dec. 17, 2021) (hereinafter “Special
Masters Memo”). Respectfully, however, the Special Masters’ draft districts in this region
would do significant harm to African American representation and would divide, rather than
unite, well-recognized communities of interest.

Our proposed amendments to the Hampton Roads districts, shown in Figure 1 below, are
aimed primarily at unpairing two long-serving African American Senators who have overcome
tremendous challenges and racial discrimination to become historic and consequential figures in
our Commonwealth. Additionally, our amendments better respect the region’s main
communities of interest by uniting Norfolk with South Norfolk on the one hand and with the
Eastern Shore on the other, as well as keeping whole the suburban area of Virginia Beach. These
amendments recognize the historic connections binding the City of Norfolk to these two areas, as
well as the unity of economic and political interests that exist between them.

Figure 1. Proposed Amendments to Hampton Roads Districts1

1
In this figure and the others figures below, the color fields show Senate districts with our proposed amendments,
using the same district numbering as the Special Masters’ draft map. The red lines indicate the boundaries drawn by
the Special Masters that we have proposed changing. Submitted to the Court under separate cover are the shape
files and block assignment files for the entire statewide Senate map with all of our proposed amendments.

2
 A. Senators Lucas and Spruill Should Not Be Paired in a Single District

Due to the Special Masters’ decision not to consider incumbent addresses, the Special
Masters’ draft of the Hampton Roads districts inadvertently “double bunked” two heroes of
Virginia’s civil rights movement: Senator L. Louise Lucas and Senator Lionell Spruill, Sr.
Specifically, the Special Masters’ draft Senate District 18 combines northern portions of
Chesapeake (where Senator Spruill resides) with the southern half of Portsmouth (where Senator
Lucas resides).

Both of these respected legislators have overcome unimaginable hurdles in their personal
lives and political careers, including invidious racial discrimination, and both have contributed
immensely to improving the Commonwealth’s record on civil rights. Pairing them in a single
district, which would effectively expel at least one of them from the Senate, fails to respect the
unique role that each of these iconic figures has played and continues to play in the troubling and
evolving story of race relations in Virginia.

Senator L. Louise Lucas, the President Pro Tempore of the Virginia Senate, could not
go to school when she was a girl because Portsmouth’s school system was shut down by
segregationists engaged in the strategy of “Massive Resistance.” She became a mother at age 14,
and even after the Portsmouth schools were reopened she was not able to complete high school.
Despite these extreme obstacles placed in front of her as a result of racial discrimination, Senator
Lucas persevered. In 1971, she became the first female shipfitter at Norfolk Naval Shipyard.
From there, she rose to become the Command Federal Women's Program Manager at the
Commander in Chief, U.S. Atlantic Fleet (CINCLANTFLT) and Equal Employment Manager at
the Supervisor of Shipbuilding Conversion and Repair (SUPSHIP). Since leaving federal
employment, Senator Lucas has been a business owner, a civic leader, and a college professor.

While Senator Lucas has been an activist all her life, her career in politics formally began
in 1984 when she was elected as the first African American woman to serve on Portsmouth’s
City Council. She was elected to the Virginia Senate in 1991, where she has served with
distinction ever since. As one of just three African American women in the chamber, Senator
Lucas is a role model to generations of Virginians, especially African American women and
girls. Senator Lucas is both the first woman and the first African American to serve as President
Pro Tempore of the Virginia Senate. She serves as the Chairman of the Education and Health
Committee and is third in seniority on the Finance Committee. Her loss in the Senate would
deprive Virginia’s African American community of significant influence on a statewide basis.

Senator Lionell Spruill, Sr. was born one of 16 children in the era of segregation,
meaning his mother was denied access to a hospital. Because of a preventable mishap during
birth, Senator Spruill was born with serious hearing problems and a speech impediment that
rendered his speech unintelligible. He grew up in poverty, in a segregated school system with no
resources to help him overcome his impediment.

Despite these hurdles, Senator Spruill obtained a job with the phone company, which
paid for medical procedures that helped him hear and learn to speak. He began as a lineman and
worked his way up to installer, then technician. He first entered politics when he realized that
his hometown of South Norfolk was completely unrepresented in the leadership of the newly

3
merged City of Chesapeake. He ran and won as the first representative for South Norfolk on the
Chesapeake City Council. In 1993 he won election to the House of Delegates, where he served
with distinction until his election to the Senate in 2015. As the only African American man in
the Virginia Senate, Senator Spruill is, like Senator Lucas, a role model to generations of
Virginians. Senator Spruill is third in seniority among members in the majority on the
Commerce and Labor Committee, and is chairman of its Energy Subcommittee.

While some pairing of incumbents may be unavoidable, this particular pairing is both
harmful to minority representation in the Commonwealth and easily avoidable. By reuniting all
of Portsmouth in a single district that connects with Suffolk and additional counties to the west,
Senator Lucas would no longer be paired in the same district as Senator Spruill, giving both of
them the opportunity to continue their historic representation of minority opportunity districts.

B. Norfolk and Northeastern Chesapeake Form a Well-Recognized Community

of Interest, and Portsmouth Should Be Kept Whole

In addition to unpairing Senators Lucas and Spruill, our proposed amendments to Senate
Districts 17 and 18 better preserve communities of interest by undoing a jurisdiction split in
Portsmouth and combining the southern portion of Norfolk proper with the South Norfolk
community of City of Chesapeake. This is superior to the Special Masters’ configuration, in
which the southern portion of Portsmouth is lumped together with the northern portion of
Chesapeake in one district, while the northern portion of Portsmouth is sheared off into a
separate district.

Uniting the southern portion of Norfolk with the northeastern portion of Chesapeake in
District 18 would preserve a well-known community of interest. Indeed, the northeastern portion
of Chesapeake is officially known as “South Norfolk,” rightly reflecting its longstanding ties to
the City of Norfolk. See “South Norfolk Community,” City of Chesapeake Official Website
(accessed Dec. 14, 2021).2 This part of Chesapeake started as a “street car suburb” of Norfolk
and was incorporated into the City of Chesapeake in 1963. See Suzy Looman, “History of South
Norfolk,’ HistoricSouthNorfolk.com (July 5, 2021).3 The Special Masters appear to have
recognized the ties between Norfolk proper and South Norfolk in drawing House District 92,
which straddles both areas.

Modifying Senate District 18 to include South Norfolk and Norfolk would allow the
redrawing of District 17 to include the entirety of Portsmouth and undo a jurisdiction split, which
was one of the Special Masters’ primary objectives. Portsmouth, one of Virginia’s oldest
settlements, is a community of interest unto itself. Its residents have immense hometown pride.
For instance, the City hosts the annual Portsmouth Invitational Tournament, where college
basketball seniors play in front of NBA scouts. Many top basketball stars played in the
Tournament before successful pro careers, including Jimmy Butler, Scottie Pippin, Dennis
Rodman, and John Stockton. See Portsmouth Invitational Tournament, Wikipedia (accessed
Dec. 14, 2021).4 The City is also home to the African American Historical Society of
Portsmouth, which recently put up murals honoring the City’s Black history at the Portsmouth
2
Available at https://www.cityofchesapeake.net/communities/south-norfolk/community.htm
3
Available at https://www.historicsouthnorfolk.com/2012/07/05/history-of-south-norfolk/
4
Available at https://en.wikipedia.org/wiki/Portsmouth_Invitational_Tournament

4
Welcome Center. J. Reyes, “Portsmouth group hopes murals in city’s Welcome Center are first
step toward a more prominent display of African American history,” Virginian Pilot (Nov. 26,
2021).5 Keeping Portsmouth whole would also ensure that the entirety of draft House District 88
falls within Senate District 17, which better respects the “nesting” concept endorsed by the
Special Masters for state legislative districts. Special Masters Memo at 9.

In order to equalize population, our proposed District 17 drops most of the City of
Suffolk but retains the eastern portion of Southside, traveling along the Route 17 corridor. See
“Route 17 Arterial Preservation Plan,” VDOT (Sept. 1, 2020);6 see also Special Masters Memo
at 7 (defining communities of interest with respect to “travel arteries”).

C. The Eastern Shore and Norfolk Form a Community of Interest

We further suggest that Senate District 20 be modified such that the Eastern Shore is
joined with Norfolk, including just a small sliver of Virginia Beach where the Chesapeake Bay
Bridge Tunnel makes landfall. This is superior to the Special Masters’ configuration, in which
the Eastern Shore is joined primarily with Virginia Beach, taking just a small sliver of Norfolk.

With this amendment, the map would preserve the strong community of interest that
exists between the Eastern Shore and Norfolk. This community is reflected in the myriad
economic and cultural ties that connect these two areas. For example, as amended, District 20
would follow the “Eastern Shore Corridor,” which was designated a “Corridor of Statewide
Significance” and is centered on U.S. Highway 13. See “Eastern Shore Corridor,” VTrans2040
Multimodal Transportation Plan (2012).7 The Corridor centers on Norfolk as the “primary
population center” and connects it with “the sparsely populated counties of Northampton and
Accomack.” Id. Norfolk serves as a major “employment center” for the Eastern Shore counties,
as well as a transportation hub that is home to the region’s airport. Id. And Norfolk’s Old
Dominion University has a special relationship with Eastern Shore Community College and with
the Wallops Island Spaceport, both of which are important institutions on the Eastern Shore. See
Old Dominion University Partnership, Eastern Shore Community College Official Website
(accessed Dec. 14, 2021)8; “Wallops Spaceport partnership that includes ODU expected to have
role in new space station resupply project,” News@ODU (May 2008).9

Norfolk and the Eastern Shore also share significant political interests. Both areas of the
Commonwealth unfortunately have median incomes significantly below Virginia’s statewide
median. See Virginia Dep’t of Health, “Income and Poverty” (accessed Dec. 14, 2021)
(Statewide - $74,222; Accomack - $46,073; Northampton $47,227; Norfolk - $51,590). In
contrast, Virginia Beach’s median income is above the statewide median. Id. The poverty rates
tell the same story: Accomack, Northampton, and Norfolk all have poverty rates in excess of
20% while Virginia Beach’s poverty rate is less than 10%. See Virginia Dep’t of Health,

5
Available at https://www.pilotonline.com/history/vp-nw-fz21-portsmouth-welcome-center-historical-art-
20211126-rcd2xvckfndtrmscolukjets4u-story.html
6
Available at https://www.virginiadot.org/projects/hamptonroads/route_17_arterial_preservation_plan.asp
7
Available at https://businessdocbox.com/Logistics/115944865-Vtrans2040-multimodal-transportation-plan-
corridors-of-statewide-significance-needs-assessment-eastern-shore-corridor.html
8
Available at https://es.vccs.edu/about/projects-partnerships/odu/
9
Available at https://odu.edu/news/news-archive/2008/05/WallopsSpaceportp_10208#.YbUMfahKjmE

5
“Poverty” (accessed Dec. 14, 2021). Norfolk and the Eastern Shore also share similar challenges
with respect to education, with high percentages of students receiving free and reduced-price
school meals. See Virginia Public School Free/Reduced Lunch Participation Rate by County,
ZipDataMaps (accessed Dec. 14, 2021).10 These communities would be best served by a
representative in the Senate who can focus on their shared challenges, in particular on advocating
for measures that will help bring residents out of poverty.

The historical connections between the Eastern Shore and Norfolk further support joining
those communities rather than splitting them. For example, in the late 19th century, Cape
Charles, Northampton County’s largest town, was “planned as a hub for traffic flowing via
steamboat and barge to and from Norfolk.” W. Thomas, B.M. Barnes, T. Szuba, The
Countryside Transformed: The Eastern Shore of Virginia, the Pennsylvania Railroad, and the
Creation of a Modern Landscape, Southern Spaces (July 31, 2007).11 Before the service was
shut down, the Eastern Shore was connected to Norfolk by twice-daily ferry trips carrying “mail,
freight, cars, and passengers.” Clarence Lee Beebe, A History of the Chesapeake Bay Ferries to
Virginia’s Eastern Shore Prior to the Civil War (August 1954).12

For all these reasons, for the last 20 years, the Eastern Shore has been drawn with
Norfolk in Virginia’s Senate maps by caucuses controlled by both Democrats and Republicans,
and we urge the Court to continue that practice today.

Finally, with this amendment District 20 would include the entirety of the Special
Master’s proposed House District 94 without changes, advancing the Special Masters’ interest in
“nesting” state legislative districts. Special Masters Memo at 9.

D. Virginia Beach’s Suburban Community of Interest Should be Preserved

The suburban portion of Virginia Beach is a community of interest that should be

preserved in the Senate map. Our amended District 21 encompasses the entirely of Virginia
Beach’s more densely populated suburban zone. See Virginia Beach Comprehensive Plan,
Planning Area 1-1 (Nov. 20, 2018).13 This is superior to the Special Masters’ configuration,
which splits the suburban zone, pairing the northern part with the rural Eastern Shore and the
southern part of the suburban zone with the rural and undeveloped parts of Virginia Beach and
southern Chesapeake.

In order to equalize population, our amended District 19 picks up the majority of the City
of Suffolk, other than the Route 17 Corridor. This amendment preserves a community of

10
Available at https://www.zipdatamaps.com/counties/state/economics/map-of-public-school-free-reduced-lunch-
program-participation-for-counties-in-virginia
11
Available at https://southernspaces.org/2007/countryside-transformed-eastern-shore-virginia-pennsylvania-
railroad-and-creation-modern-landscape/
12
Available at https://scholarship.richmond.edu/cgi/viewcontent.cgi?article=1085&context=masters-theses
13
Available at
https://www.vbgov.com/government/departments/planning/2016ComprehensivePlan/Documents/Fall%202020%20
Update/CHAPTER%201_EntireChapterSections%2012-14-20%20MES.pdf

6
interest, as Suffolk is largely rural, and therefore a good match for District 19. See City of
Suffolk 2026 Comprehensive Plan at Figure 3-1 (2018 ed.).14

II. Greater Richmond

We commend the Special Masters for creating an additional minority opportunity district
in the greater Richmond area. As we explain below, it was demonstrated during the
Redistricting Commission proceedings that the Voting Rights Act of 1965 (“VRA”) requires the
creation of such a district. We respectfully urge the Court to recognize that the VRA requires the
drawing in this region of an additional district in which African Americans have the opportunity
to elect their candidate of choice, which the Special Masters have already done.15 And we
suggest only modest amendments to the Special Masters’ draft districts, namely minor
adjustments to the border between Districts 14 and 16 to better reflect communities of interest, as
shown in Figure 2 below.

Figure 2. Proposed Amendments to Greater Richmond Districts

A. The Voting Rights Act of 1965 Requires the Creation of an Additional

Minority Opportunity District in the Greater Richmond area

We commend the Special Masters for drawing an additional district in greater Richmond
that will allow the region’s African American citizens the opportunity to elect a candidate of
their choice (“minority opportunity district”), increasing the number of minority opportunity

14
Available at https://www.suffolkva.us/593/Chapter-3-Land-Use-Growth-Management
15
The Special Masters appear to have recognized this obligation. See Special Masters Memo at 22 (“Districts 13, 14
and 15 are minority opportunity districts. We forced ourselves to draw these districts within the constraints placed
on other districts: Compactness, minimization of county splits and attention to communities of interest.”). We also
agree with the Special Masters that the relevant inquiry under the VRA is not the literal number of “minority-
majority districts” but rather the number of districts “where minority groups are able to elect their candidates of
choice, either alone or in coalition with other groups.” Id. at 26-27.

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districts in this area from two to three. We write to emphasize that this feature of the Special
Masters’ draft map is in fact required by federal law.

The Supreme Court’s landmark opinion, Thornburg v. Gingles, sets out the criteria that,
if met, require the drawing of a district in which a minority population has the opportunity to
elect a candidate of that population’s choice. 478 U.S. 30 (1986). In particular, Section 2 of the
VRA requires the drawing of a minority opportunity district “[1] where the minority group is
sufficiently large and geographically compact to constitute a majority in a single-member district
and [2] is politically cohesive, and [3] where the majority votes sufficiently as a bloc to enable it
... to defeat the minority's preferred candidate.” Personhuballah v. Alcorn, 155 F. Supp. 3d 552,
565 (E.D. Va. 2016) (citing VRA and Gingles, 478 U.S. at 50-51).

Those criteria are met here. The Redistricting Commission received as part of public
submissions a map demonstrating that greater Richmond’s African American population is
“sufficiently large and geographically compact to constitute a majority” in an additional single-
member district. Personhuballah, 155 F. Supp. 3d at 565. We incorporate that map by reference
here. Record of the Virginia Redistricting Commission (accessed Dec. 14, 2021).16 This
evidence satisfies the first Gingles criterion. See, e.g., Wright v. Sumter Cty. Bd. of Elections &
Registration, 979 F.3d 1282, 1304 (11th Cir. 2020) (“The undisputed evidence presented showed
that Sumter County’s black residents could form a majority in at least one additional, single-
member district.”).

The second and third Gingles criteria are also met because there is at least some measure
of “racially polarized voting” within the Senate districts surrounding Richmond. See, e.g.,
Alabama State Conf. of Nat’l Ass’n for Advancement of Colored People v. Alabama, 2020 WL
583803, at *26 (M.D. Ala. Feb. 5, 2020) (“Racial bloc voting, also termed racially polarized
voting, is the linchpin of a § 2 vote dilution claim and the embodiment of the second and third
Gingles preconditions.”). The Redistricting Commission received evidence that racially
polarized voting exists in parts of this region of the Commonwealth. M. Palmer & B. Schneer,
“Racially Polarized Voting Analysis for the Virginia Redistricting Commission,” Record of the
Virginia Redistricting Commission (Aug. 31, 2021) (accessed Dec. 14, 2021).17 The report on
racially polarized voting submitted to the Commission found as much as a 20% gap between the
voting of patterns of whites and racial minorities in parts of this region. Id. at 5.

Because the three factors are met, Section 2 of the VRA requires the drawing of an
additional minority opportunity district in greater Richmond. We appreciate that the Special
Masters’ draft Senate map already satisfies this requirement, and we respectfully urge the Court
to confirm their work in this regard.

16
Available at https://www.virginiaredistricting.org/legdistricting/comments/plan/130/1
17
Available at https://virginiaredistricting.org/2021/Data/Publications/palmer_schneer_rpv_report.pdf

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 B. The Boundary Between Districts 14 and 16 Should Be Amended to Better
Reflect Communities of Interest

We propose adjusting the boundary between Districts 14 and 16 to keep the Hermitage
High School attendance zone together in the north, and to keep whole the community of interest
anchored on the University of Richmond in the south.

In the Special Masters’ draft map, the Hermitage High School attendance zone is split
between District 14 and 16. See Henrico School Locator, HCPS Official Website (accessed Dec.
14, 2021).18 The southeastern portions of the attendance zone are in District 14, while the school
itself and the attendance zone north of Parham Road are in District 16. Our amendment would
move the southeastern portion of the attendance zone into District 16, with the exception of one
precinct that is kept with District 14 in order to preserve the Chamberlayne community of
interest. See “Chamberlayne,” UVA Data, Map of Virginia Census Designated Places (accessed
Dec. 14, 2017).19 Chamberlayne has been recognized by the federal government as a “closely
settled, unincorporated community[y] that [is] locally recognized and identified by name.”
“Census Designated Places (CDPs) for the 2020 Census—Final Criteria,” 83 Fed. Reg 56290
(Nov. 13, 2018). Keeping this attendance area is important, as in suburban environments, high
schools are often the primary organizing and rallying point for community activity and a center
of community organization, and significant research has validated that unified community
schools build unified communities. See generally S. Bingler, et al., “Schools as Centers of
Community,” National Clearinghouse for Educational Facilities (2003).20 Hermitage High
School in particular plays a central cultural role as one of the oldest high schools in greater
Richmond, dating to 1936 when Virginia began to modernize its education infrastructure during
the New Deal. “Hermitage High School,” Wikipedia (accessed Dec. 14, 2021).21

Our adjustments to the border on the northern bank of the James River are designed to
preserve the community of interest centered on the University of Richmond. Located on the
border between Henrico and Richmond, the University is an economic and cultural hub for
Virginians residing in both localities. For instance, the University of Richmond has undertaken
detailed historical studies of the land to its west—the former Westham Planation—reflecting the
deep ties that connect the University to that part of Henrico, forming a single community of
interest. See L. Lee & S. Driskell, “Knowledge of This Cannot Be Hidden: A Report on the
Westham Burying Ground at the University of Richmond” at 8 (Dec. 2019).22 And the
connections between the University and the Westham neighborhood directly north of it are well
established. See, e.g., Westham Garden Club (“The Westham Garden Club was established on
May 25, 1943, to preserve and enhance the natural beauty of Westham, a neighborhood adjacent
to the University of Richmond and nestled in mature woodlands a short distance from the
historic James River.”).23 In this letter, the Senate Democratic Caucus is also requesting similar

18
Available at
https://henrico.maps.arcgis.com/apps/InformationLookup/index.html?appid=5651e3877c5243a19215f9a7fc7a4dc5
19
Available at https://www.arcgis.com/apps/mapviewer/index.html?layers=3a1fa38398a143b290099b65ea51d127
20
Available at https://files.eric.ed.gov/fulltext/ED539486.pdf
21
Available at https://en.wikipedia.org/wiki/Hermitage_High_School_(Virginia)
22
Available at https://equity.richmond.edu/about/foundational-work/inclusive-excellence/report-pdfs/burying-
ground-report.pdf
23
Available at https://westhamgardenclub.com/our-club/

9
changes that seek to consolidate communities of interest around Virginia’s major universities in
Blacksburg (Virginia Tech; Senate District 4) and Fairfax (George Mason; Senate District 37).
The Special Masters appear to have recognized the significance of university communities by
consolidating legislative districts around other major Virginia university communities such as the
University of Virginia (Senate District 11; House District 54), The College of William and Mary
(Senate District 24; House District 71), James Madison University (Senate District 2; House
District 34), Radford University (Senate District 5, House District 42), Virginia Commonwealth
University (Senate District 4; House District 78), Old Dominion University (Senate District 21;
House District 92), and Washington & Lee University (Senate District 3, House District 37).

III. West Central Region

We appreciate the Special Masters’ “attempt[] to place Roanoke, Salem and Blacksburg
in the same district, to reflect what some have reported as a community of interest.” Special
Masters Memo at 21. In particular, there is a strong community of interest anchored on
Roanoke/Salem at the eastern end and the Blacksburg suburbs on the western end. While the
Special Masters reported that they were unable to preserve this community in a single Senate
district “given equal population constraints,” id., it is in fact feasible to do so by moving the
Town of Blacksburg into District 4. As shown in Figure 4 below, our proposed amendments to
Senate Districts 4, 5, and 7 preserve this community of interest while staying within equal
population constraints. Our amendments also improve the compactness of these districts.

Figure 3. Proposed Amendments to West Central Virginia Districts

The single community of interest formed by the union of Roanoke/Salem and Blacksburg
is long established and well recognized. The two communities are joined by I-81, and many
residents commute between them each day. The region’s airport recognizes the community of
interest in its name: Roanoke-Blacksburg Regional Airport. See FlyROA.com (accessed Dec.
14, 2021). Virginia Tech has campuses in both Roanoke and Blacksburg, which are linked by
Smart Way Express, a dedicated bus service run by Valley Metro, free for Virginia Tech students
and staff. See Blacksburg-Roanoke Smart Way Shuttle, Virginia Tech Website (accessed Dec.

10
14, 2021).24 Virginia Tech’s facilities in Roanoke include the Fralin Biomedical Research
Institute at Virginia Tech, a Carilion partnership. And Virginia’s 2021 state budget provided for
$83.5 million to extend intercity rail service from Roanoke to Montgomery County, where it will
be used by many Virginia Tech students and staff. See E. Jones, “NRV to get Amtrak service;
Roanoke to get 2nd daily train,” WFIR News Talk Radio (May 5, 2021).25 In order to equalize
population in our proposed configuration, Christiansburg, a town with far fewer connections to
Virginia Tech than Roanoke, was moved into District 5.

Additionally, many of the region’s citizens testified eloquently before the Redistricting
Commission as to the web of connections that bind together these communities. See, e.g., Ex.
Public Comment West Central Region at 24, Records of the Virginia Redistricting Commission
(accessed Dec. 14, 2021),26 Testimony of Austin Pryor (“I am a resident of Roanoke City and
work for Virginia Tech and commute almost daily to Blacksburg down in the New River Valley.
I find great connection between the two areas of the Roanoke Valley and New River Valley …
These interest would be best represented by one State Senator to jointly represent both
communities.”); id. at 25, Testimony of James. B. McCloskey (“The Roanoke and New River
Valleys shar[e] multiple shared resources and values. In addition to the colleges and universities,
there [is] the huge medical community that blankets our region. Not just the Carilion and Lewis
Gale health systems but the joint efforts of Radford University Carilion and Virginia Tech
Carilion School of Medicine and Research Center the latter of which includes multi-disciplinary
project active on both the Riverside and Blacksburg campuses. This proposed change also
consolidates the entire Virginia Tech Community into one senate district similar to other
universities as described above. And, don’t forget the Roanoke-Blacksburg Regional Airport!”).

Our proposed amendments in this region have the added benefit of eliminating the part of
the Special Masters’ draft District 7 that crosses the Blue Ridge. The Special Masters were
correct to identify the Blue Ridge Mountains as “a natural dividing line for communities of
interest.” Special Masters Memo at 12. But in their draft Senate map, District 7 crosses the Blue
Ridge by traversing the border from Carroll and Grayson Counties and splitting Wythe County.
See “Wythe County,” Geology Mineral Resources Webmap, Virginia Energy (accessed Dec. 14,
2021).27 Our proposed amendments eliminate the split of Wythe County and preserve the Blue
Ridge Mountains as a dividing line, crossing them only at the Roanoke River Valley, one of the
range’s few “easy crossings.” Special Masters Memo at 12.

IV. Loudoun and Fauquier Counties

Districts 28, 31, and 32 should be modified to better reflect the region’s communities of
interest. As shown in Figure 4 below, we have adjusted the boundary between Districts 31 and
32 in two places to keep HOAs and school attendance zones together and to better reflect the
divergent political interests of the eastern and western portions of Loudoun County. And we
have adjusted the boundary between Districts 31 and 28 to keep Warrenton together with the

24
Available at https://parking.vt.edu/alternative/regional/blacksburg-roanoke-smart-way-shuttle.html
25
Available at https://wfirnews.com/news/nrv-to-get-amtrak-service-roanoke-to-get-2nd-daily-train.
26
Available at https://www.virginiaredistricting.org/2021/Data/ref/SubmittedComments/11-19-
21%20west%20central%20region%20input.pdf
27
Available at https://energy.virginia.gov/webmaps/GeologyMineralResources/

11
area directly to its south and to divide Fauquier County on a more intuitive line than the split
suggested by the Special Masters.

Figure 4. Proposed Amendments to Loudoun and Fauquier County Districts

The first amendment to the north is aimed at preserving the Belmont Greene community
of interest in a single district (District 31). Belmont Greene is a fast-growing and tightknit
community of homeowners, anchored on Belmont Country Club to the north and walking
distance to Stone Bridge High School to the south. It is part of the Stonebridge High School
attendance zone. See Stone Bridge High School 2021-2022 Attendance Zone.28 It is also a
Census Designated Place, meaning it is a “closely settled, unincorporated community[y] that [is]
locally recognized and identified by name.” “Census Designated Places (CDPs) for the 2020
Census—Final Criteria,” 83 Fed. Reg 56290 (Nov. 13, 2018); see also “Belmont,” UVA Data,
Map of Virginia Census Designated Places (accessed Dec. 14, 2021).29

The Special Masters’ draft Senate map divides this community in two: the bulk of the
homes are in District 31, with Stonebridge High School, the Belmont Greene Community Pool,
and the rest of the community in District 32. Our proposed amendment would keep Belmont
Greene together in District 31, and generally better preserve the Stone Bridge High School
attendance zone in a single district. Id.

Moving south, our second amendment is aimed at preserving the Brambleton community
of interest by keeping it entirely within District 32. Numerous public comments submitted to the
Court have requested this change. See, e.g., Comment of Ravi Balam, Interactive Proposed Map
(accessed Dec. 14, 2021) (“Brambleton should not be divided. It makes most sense for all of it
to be in 32nd as it is most like its northern, southern and eastern neighbors like Ashburn, Sterling
and S. Riding.”).30

28
Available at https://www.lcps.org/cms/lib/VA01000195/Centricity/Domain/27213/StoneBridgeHS21-22.pdf
29
Available at https://www.arcgis.com/apps/mapviewer/index.html?layers=3a1fa38398a143b290099b65ea51d127
30
Available at https://www.virginiaredistricting.org/legdistricting/comments/plan/514/1

12
 This amendment would better reflect the east-west division of Loudoun County, with
eastern Loudoun being more suburban and western Loudoun being more rural. See Loudoun
County Comprehensive Plan at 170 (2019).31 This rural-suburban division represents more than
just a change in zoning policy—the two areas of the county have many divergent political
interests. See, e.g., T. Baratko, “Chair Randall says people in eastern Loudon don’t understand
the west,” Loudoun Times (Oct. 19, 2016)32; R. Nelson, “A Tale of Two Counties,” Virginia
Living (Feb 2017).33 In the Special Masters’ draft map, District 31 is primary rural, except for
where it crosses Northstar Boulevard, the dividing line in Loudoun’s comprehensive plan
between rural and suburban areas of the County. See Comprehensive Plan at 170. Our
amendment would move the suburban precinct out of rural District 31 and unify it with District
32, which shares its suburban character.

Our final proposed amendment in this region joins the area of Fauquier County south of
the town of Warrenton with Warrenton proper in District 28. In addition to keeping Warrenton
together with its immediate surroundings, this amendment uses Route 211 as the boundary of the
jurisdiction split of Fauquier County. This “travel artery,” linking Warrenton and New Market,
is a more intuitive way to split Fauquier than the Special Masters’ configuration, which followed
Route 15 south and then Route 621 back north. See Special Master Memo at 7.

V. Greater Fredericksburg

District 27 should be modified, as shown in Figure 5 below, so that it picks up the fast
urbanizing areas around I-95 south of the City of Fredericksburg and gives up the rural areas in
the southwest of the district around Chancellor.

31
Available at https://www.loudoun.gov/DocumentCenter/View/152285/General-Plan---Combined-with-small-
maps-bookmarked
32
Available at https://www.loudountimes.com/news/more-chair-randall-says-people-in-eastern-loudoun-dont-
understand-the-west/article_e35a48ea-f05b-5cd6-be34-dc0530b3ba60.html
33
Available at http://www.virginialiving.com/culture/a-tale-of-two-counties/

13
 Figure 5. Proposed Amendments to Greater Fredericksburg Districts

The area south of Fredericksburg along I-95 lies between I-95, U.S. 17, and a VRE
Station, and has been zoned as “mixed use,” meaning that it is a “compact, walkable community
with a more dense development pattern.” Spotsylvania Comprehensive Plan at 6 (mixed used
definition), 19-20 (map) (amended 2018).34 This part of Spotsylvania, connected to the city by
U.S. 17, is also similar to Fredericksburg in that its development is served and anchored by a
VRE station that opened in November, 2015. K. Weir, “VRE to expand into Spotsylvania
County,” Washington Examiner (July 4, 2012).35 Before the opening of that station, 1,000
residents traveled from this area of Spotsylvania to Fredericksburg every day. Id. This station
attracts a similar type of employment and development pattern as Fredericksburg, as it serves
“commuters who [formerly] travel[ed] to Fredericksburg to catch the Washington-bound train.”
L. Lazo, “VRE Spotsylvania station to open Monday,” Washington Post (Nov. 15, 2015)36

This section of Spotsylvania County is therefore more similar in character and in political
interests to the City of Fredericksburg, and forms a community of interest, often referred to as
“Greater Fredericksburg.” But in the Special Masters’ draft map, Districts 25 and 27 divide up
this community of interest, with the urbanizing portion of Spotsylvania County included in
District 25, a predominantly rural district. The parts of District 25 making up the southern
portion of Greater Fredericksburg should instead be drawn into District 27 and included with
Fredericksburg proper.

To offset the increase in population, District 27 should give up the sections of

Spotsylvania County around Chancellor and the Chancellorsville Battlefield. These areas have
been zoned “low density residential,” “rural residential,” and “agricultural and forestall,”
Spotsylvania Comprehensive Plan, supra, at 19, and are likely to remain so given the presence of
the Chancellorsville National Battlefield and large sections of private land inside the battlefield

34
Available at https://www.spotsylvania.va.us/DocumentCenter/View/2119/Comprehensive-Plan-PDF
35
Available at https://www.washingtonexaminer.com/vre-to-expand-into-spotsylvania-county#.UHHSr66rgXg
36
Available at https://www.washingtonpost.com/news/dr-gridlock/wp/2015/11/15/vre-spotsylvania-station-opens/

14
with development restrictions. They thus form a community of interest with the other rural areas
included in District 25. The entire proposed District 25 has no VRE Stations, as VRE service
ends at the Spotsylvania Station.

We note that many Virginians testified in favor of a district substantially similar to our
amended District 27. See, e.g., Public Comment Northern Region at 39, Records of the
Redistricting Commission (accessed Dec. 14, 2021)37; id. 43; id. at 58; id. at 60 (“I share similar
concerns with the residents of the more developed Fredericksburg area, rather than those in rural
Spotsylvania.”); id. at 78.

VI. Virginia Peninsula

On the Virginia Peninsula, District 23 should be redrawn to include the entirety of both
Poquoson and Hampton, giving up portions of Newport News to District 24 to equalize
population and reduce the split of that locality.

Figure 6. Proposed Amendments to Virginia Peninsula Districts

Drawing District 23 in this way would preserve the community of interest that exists
between Hampton and Poquoson. This community is demonstrated by a shared geography, as
Poquoson and Hampton are the Peninsula’s two Atlantic facing localities. The two localities
also sit on opposite banks of the Back River, an estuarine inlet of the Chesapeake Bay. The U.S.
District Court for the Eastern District of Virginia recognized and validated this community of
interest in 2019 by adopting a special master-recommended remedial House of Delegates district
consolidating parts of Hampton and Poquoson together into one district. See Bethune-Hill v.
Virginia State Bd. of Elections, 368 F. Supp. 3d 872, 889 (E.D. Va. 2019) (adopting Remedial
Plan, Dkt. 355-3).

37
Available at https://www.virginiaredistricting.org/2021/Data/ref/SubmittedComments/11-19-
21%20northern%20region%20input.pdf

15
 There are also economic similarities between Hampton and Poquoson. Because of their
shared distinctive geography, for example, the two localities “developed as hubs for waterman
fishing and shellfishing in the Atlantic Ocean, Chesapeake Bay, and tidal rivers,” while other
regional localities developed into a commercial waterfronts. Virginia Working Waterfront
Master Plan at 71 (Sept. 2016).38 Today, in both localities, recreational boating plays a large
economic role. See M. Pizer, “Study values annual impact of Hampton boaters at $55M,”
Virginia Institute of Marine Science (Mar. 12, 2009); “Kayaking & Boating in Poquoson,”
Poquoson Official Website (accessed Dec. 14, 2021).

Redrawing Districts 23 and 24 as we suggest would keep this community of interest

together, and would allow more of Newport News to be in the same district, vindicating the
interest in “minimizing splits in counties and cities.” Special Masters Memo at 5. It would also
allow for the District 23 to contain the entirely of proposed House District 86, advancing the
Special Masters’ interest in “nesting.” Id. at 9 (Dec. 7, 2021). And, with this amendment, the
Newport News/Williamsburg Airport would be, as its name suggests, in the same district as both
Newport News and Williamsburg.

VII. Fairfax County

Consistent with other amendments we have proposed, Districts 36 and 37 should be

amended to preserve George Mason University as a community of interest, as shown in Figure 7
below and as advocated for other university communities above.

Figure 7. Proposed Amendment to Fairfax County

These minor change puts the entirety of George Mason University and its surrounding
neighborhoods into District 37. To equalize population, the commercial area around Fair Oaks
has been moved into District 36, which has the added benefit of keeping more of that Census

38
Available at
https://www.hrpdcva.gov/uploads/docs/7A_Attachment_Virginia%20Working%20Waterfront%20Master%20Plan.p
df

16
Designated Place together. See “Fair Oaks,” UVA Data, Map of Virginia Census Designated
Places (accessed Dec. 14, 2021);39 see also “Census Designated Places (CDPs) for the 2020
Census—Final Criteria,” 83 Fed. Reg 56290 (Nov. 13, 2018) (a Census Designated Place is
“closely settled, unincorporated community[y] that [is] locally recognized and identified by
name.”).

* * *

In closing, the Senate Democratic Caucus once again expresses our appreciation for the
diligent efforts of the Special Masters to this point, the Court’s adoption of a robust public
comment process with public hearings, and the prompt publishing and indexing of public
comments. Generally speaking, the Special Masters’ draft Senate map presents compact districts
that do a reasonable job reflecting the will of Virginia’s voters. Inevitably, however, the Special
Masters were not aware of certain local conditions unique to the Commonwealth, such as the
importance of avoiding the pairing of two senior African American senators and civil rights
icons, Senators Lucas and Spruill, in the same district. Nor were the Special Masters aware of
every particular of Virginia’s cultural geography. The Senate Democratic Caucus accordingly
has proposed a modest number of targeted changes to ensure that the Senate map tracks
Virginia’s communities of interest to the greatest extent possible while still respecting the many
other important factors that the Special Masters considered. We thank the Special Masters and
the Court for giving due consideration to our comments and proposed amendments, and to the
input of the public, following the release of the Special Masters’ draft maps.

Sincerely,

__________________________
Senate Majority Leader Richard L. Saslaw

CC: Speaker of the House of Delegates Eileen R. Filler-Corn

Senate Minority Leader Thomas K. Norment
House of Delegates Minority Leader C. Todd Gilbert

39
Available at https://www.arcgis.com/apps/mapviewer/index.html?layers=3a1fa38398a143b290099b65ea51d127

17