May 25, 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]

Dear Ms. Bishton:

The Charlotte Lozier Institute (CLI) appreciates the opportunity to comment on the Department of General Services’ final stage of proposed changes to the Regulations for Capitol Square [1 VAC 30-100]. We join with others in requesting the reopening the proposed stage of the rulemaking process in order to further protect individuals’ and organizations in exercising freedom of speech and assembly under the Virginia constitution.

About CLI

CLI is a research organization devoted to high-level scientific and statistical analysis of issues bearing on the right to life and maternal well-being.  In this work, we rely on standards of excellence and the freedom of Americans to engage in inquiry and give-and-take with the public and public officials alike.

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

It has come to our attention that under the current proposed amendments to the Regulations for Capitol Square Section 1VAC30-100-50. Permit Process, subsection E, state: “Permitted events may last a maximum of one hour, with an additional 30 minutes to set up the event and 30 minutes to take it down.”  A variety of organizations have expressed concern that these limitations have a substantive effect on the right of peaceable assembly in Richmond and inhibit the free speech on important issues of the day.  CLI believes that this concern is valid and we urge the Commonwealth to allow a reasonable expansion of time for all groups seeking orderly access to the Capitol Grounds.

Conclusion

In order to successfully protect the rights to free speech and assembly via a permitted event on the Capitol Grounds in Richmond, it is imperative that the Department of General Services reopen 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, irrespective of issue or party.

Thank you for this opportunity to comment on the amendment to the Regulations for Capitol Square in its final stage. Please do not hesitate to reach out with any questions.

Sincerely,

Charles A. Donovan
President
Charlotte Lozier Institute