May 24, 2022

Rhonda Bishton, Director's Executive Administrative Assistant

Department of General Services

1100 Bank Street

Suite 420

Richmond, VA 23219

Via Electronic Filing at https://townhall.virginia.gov/ 

RE: Regulations for Capitol Square [1 VAC 30 ? 100]

Reopening of Proposed Stage of Regulations for Capitol Square [1 VAC 30 ? 100] Rulemaking

Dear Ms. Bishton, 

I appreciate the opportunity, as a resident of the Commonwealth of Virginia, to on the Department of General Services’ final stage of proposed changes to the Regulations for Capitol Square to request the reopening of the proposed stage of the rulemaking process in order to further protect individuals’ and organizations in Virginia’s freedom of speech.

Under the current proposed amendments to the Regulations for Capitol Square, permitted events may only last a maximum of one hour, with 30 minutes to set up the event and 30 minutes to take it down. It is in the interest of individuals and organizations in the Commonwealth of Virginia, wishing to practice their first amendment right to free speech in the U.S. Constitution, that the regulation is amended to include 1 hour of set up time, 1.5 hours of the permitted event time, and to keep the additional 45 minutes of time to take down the event set up at the end of the permitted event. The time allotted for set-up and a rally event is simply not enough time to set up baseline quality audio and visual equipment for a permitted event. 

In other states’ capitol grounds’ permitted event regulations, more time is given to event organizers to set up, execute the event, and breakdown equipment thereafter. In states such as California, Pennsylvania, and Connecticut, organizers have been able to set up at least 2 hours before an event begins. To successfully grant the right to free speech via a permitted event on the Capitol Grounds in Richmond, it is imperative that the Department of General Services reopens the proposed stage of the Regulations for Capitol Square [1 VAC 30 ? 100] rulemaking so that these proposed changes to the time allowed for set up, execution, and break down of a permitted event may be made. It is in the interest of protecting every Virginian’s first amendment rights.

Thank you for this opportunity to comment on the amendment to the Regulations for Capitol Square in its final stage. 

Sincerely,

Elizabeth McCauley