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 March for Life Education and Defense Fund 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] to request the reopening the proposed stage of the rulemaking process in order to further protect individuals’ and organizations in Virginia’s freedom of speech. 

About the March for Life Education and Defense Fund: 

The March for Life Education and Defense Fund (March for Life) is a 501(3) Nonprofit organization that seeks to promote the beauty and dignity of every human life by working to end abortion. We do this by uniting, educating, and mobilizing pro-life people in the public square. The March for Life is best known for its annual rally and march in Washington, DC on the anniversary of the Supreme Court decision of Roe vs. Wade. In preparing for our annual rally and march, the March for Life successfully coordinates with local authorities and permitting bodies to organize the largest annual human rights demonstration in the world.  

In recent years, the March for Life has begun its State March Program, in which we partner with state organizations that share the mission to unite, educate, and mobilize pro-life people in the public square in their very own capitals. The state marches mirror the national March for Life in that a 1-hour Rally takes place to educate and inspire pro-lifers in the capitol, followed by a march to peacefully call for pro-life policies at the state government level.  

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

Under the current proposed amendments to the Regulations for Capitol Square Section 1VAC30-100-50. Permit Process, subsection E, states: “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.” 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. We request that the Department of General Services reopens the proposed stage to comment for this amendment to the Regulations for Capitol Square [1 VAC 30 ? 100] Rulemaking. 

In partnering with a Virginia-based organization, The Family Foundation of Virginia, to organize a rally on the Capitol grounds to practice our right to free speech, it is our experience that 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. It is our desire to follow the rules and regulations of using the grounds on Capitol Square that are enforced by the Department of General Services. However, vendors that we have contracted for basic audio and visual needs have expressed that they need at least an hour to set up basic equipment.  

It is also our experience in other states, where we have organized rallies and marches in the State March Program, that we have been given a reasonable amount of time to set up, execute the event, and breakdown equipment thereafter. In states such as California, Pennsylvania, and Connecticut, in partnership with state-based organizations and vendors, we were able to set up at least 2 hours before the rally event began. After the 1-hour long rally concluded, the amount of time to break down equipment took between 45 minutes – 1 hour depending on the level of production in that particular event. In Virginia, given the current time constraints on a permitted event and other production rules, we only contract vendors for the most basic audio and visual set up to achieve our goal of uniting, educating, and mobilizing pro-life people in the public square in Virginia, and thereby practicing our right to free speech.  

Conclusion 

In order 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. Please do not hesitate to reach out with any questions. 

Sincerely, 

Erin P. Getz 

Director, State March Program 

March for Life Education and Defense Fund