Public Comments

We like the Preliminary Congressional Map! We need to keep the 2 rural districts. The Southern District that has been proposed will silence the voice of one of the largest communities of interest, which is Agriculture/Rural colorado. We deserve the 2 representatives we have now. The southern district will give us NO Representation. The new representatives will come from ElPaso County and other large urban areas. Agriculture is the second largest economic driver of our state and our business is unlike any other business, so we need representatives that understand the complexities that we deal with. Please keep the 2 Rural Districts as seen in the preliminary map. Thank you.

Hi my name is Patty Lampman and I live in Elizabeth, CO in Elbert County. I am following up on a statement I submitted in April and wanted to offer additional thoughts after I’ve heard some of the statements shared over the past few weeks of hearings. During the Highlands Ranch hearing, there were many comments suggesting that Douglas County had no similarities with the Eastern Plains. I am here to tell you that is NOT true. As a former resident of Douglas County, I can tell you firsthand that there are a number of ties between Elbert County and Douglas County. First, as of 2018, Elbert County only had 2,786 jobs for its population of 26,000. Obviously, that means many of our residents travel out of the county for their jobs - mostly to Douglas County. While Elbert County is becoming more and more developed (we have a McDonald’s moving in soon!), we still rely on Douglas County for much of our shopping, medical care, transportation, and other essential services. For your reference, the average commute is just under 36 minutes. Clearly, we are a bedroom community of Douglas County. Second, Elbert County is home to the state’s largest wind project, Rush Creek Wind Project, which spans Elbert, Kit Carson, Lincoln, and Cheyenne. The largest group of turbines on the 95,000 acre piece of land is within Elbert County, and the entire project generated a 20% increase in wind energy when it came online in 2018. These turbines are manufactured in state, specifically in Douglas County, Windsor, and Pueblo. In each of these areas, different critical pieces of the turbine is created, turbines that end up on our land in Elbert at the Project. For this reason, Elbert is inextricably linked to Douglas County. Finally, Elbert County, like Douglas County, is a 2nd Amendment Sanctuary City. In 2019, the County Commissioners in Elbert County passed a resolution in response to the Red Flag Law passed by Jefferson, Arapahoe, and Denver Counties’ legislators. More than half of Colorado’s counties passed similar resolutions in response to this law - most of which are on the Eastern Plains or Western Slope. Zero metro-area counties are Second Amendment Sanctuary Cities. Please consider how challenging it would be to separate Douglas County from Elbert and the rest of the Eastern Plains. There are so many similarities and common interests that tie my county to Douglas, whereas it would be virtually impossible for a congressperson to represent metro counties along with Douglas County. Thank you, Patty Lampman

My husband and I have lived in Eagle County starting in 1996 part-time and in 2000 full time. We strongly oppose any redistricting that would make Eagle County a part of Boulder County. I lived in Denver for 30 years and my husband lived in Boulder for 2 years and we certainly know the difference in an urban and metropolitan area versus the mountain community of Eagle County. There is no valid or justifiable reasons that have been presented to warrant any change to our redistricting. Thank you!

Please accept the attached comments and proposed legislative redistricting maps on behalf of the Colorado Farm Bureau.

Please, please, please... Please keep the 2 Rural Districts as seen in the preliminary map. The rural areas of Colorado need to continue to have a voice. I am a native of Colorado for 70 years. Too much has changed. Rural is being pushed too hard now. Please do not make it any worse!

Dear Commissioners: I am writing to offer feedback on the approaches being discussed by the Commissions for addressing the constitution’s competitiveness requirements in drawing new congressional and state legislative districts. My background is as a political scientist, with a focus on election analysis and political methodology. I have spent much of the past fifteen years working with exactly the sort of data the commission is trying to analyze, in both academic settings and for political organizations, and I also teach courses in government and data science at Harvard and Northeastern. Currently, I am serving as a consultant for the National Democratic Redistricting Committee, and it is in that capacity that I provide this feedback. I addressed the Commissions during a public meeting on August 10th with regard to the topic of competitiveness generally, and elaborated on those comments in accompanying written feedback submitted through the Commissions’ website. In a follow-up question during that meeting, Commissioner Perez asked if the commission was doing something wrong. At the time, I did not have the necessary information in front of me to respond in detail, so I then addressed the Commissions again during the August 20th public meeting to provide more specifics. The comments below give an extended version of my remarks during that meeting. *On the Congressional Commission’s Approach to Measuring Competitiveness* The Congressional Commission recently adopted a measure of competitiveness which combines the results of 8 elections, going back to 2016. The fundamental problem inherent in that measure is that it focuses on the wrong outcome. The result is an approach to measuring competitiveness which is both out of alignment with the constitutional definition of competitiveness and also unnecessarily complex and overly subjective. By defining districts as competitive if they’re close to a 50% Democrat / 50% Republican split, you are optimizing for partisan balance, not competitiveness as Amendments Y and Z require. It is not clear how this measure fits the constitutional standard of a “reasonable potential” for a seat to change parties at some point in the next decade. The averaging of a hand-picked set of election results (the choice of which is inherently subjective and open to debate) is presumably intended to provide a proxy for the likely election outcome in future election cycles, but an extra step is required to turn this number into a measure of competitiveness: the determination of a threshold for closeness that indicates a district is “competitive”. This added step introduces another opportunity for subjective judgment. It might be possible to identify an appropriate cutpoint for closeness based on an equivalent analysis of data from prior to the last redistricting cycle. (This would be done by looking for a cutpoint below which more than 50% of new districts changed hands sometime between 2010 and 2020, while fewer than 50% of new districts above that point did so.) But to the best of my knowledge, no such analysis has been done, and I suspect that the necessary data to do such an analysis is not available. Without such an analysis, it is not possible to use the proposed measure to meet the constitutional requirements. What’s more, trying to make districts close to 50/50 is also problematic because Colorado is not a 50/50 state. You simply cannot make some districts more balanced without making other districts less so, which means that any balance achieved is artificial. In choosing to make some districts more competitive by creating such a balance, the commission is forced to diminish the influence of other voters by packing them into less-competitive districts than they would otherwise have. To the extent that the drawing of such districts may have a disproportionate impact on voters from particular racial or ethnic groups or other communities of interest, this could then bring the application of competitiveness into conflict with other redistricting criteria, which should in fact be given higher priority based on the requirements of Amendments Y and Z. This is not to say that the application of competitiveness is an unsolvable problem, only that the Commission’s current approach is not the right solution. This is why, in my prior testimony and written comments, I proposed an alternative measure which does not require such complex calculations or subjective determinations. That measure instead looks at the full set of federal and statewide election results in a proposed district over the previous decade. In that approach, we would categorize a district as competitive only if the voters of that new district favored both Republicans and Democrats across those elections, rather than supporting the same party in every election. This avoids the subjectivity and complexity of choosing a specific set of elections and a threshold for saying how close the elections must be to be called competitive. It simply looks to see whether, in the last decade, we saw an outcome (a change in the voters’ preferred party across elections) that would suggest a “reasonable potential” for the same outcome to happen in the next decade. (Please see my earlier submission for a more detailed discussion of this proposal.) *On the Legislative Commission’s Approach to Measuring Competitiveness* The Legislative Commission is still discussing its own approach to measuring competitiveness, and they have discussed many different alternative measures. Several of the measures are similar to that adopted by the Congressional Commission, and are subject to the same problems described above. But a number of the measures discussed take a different approach altogether, and I have even more serious concerns about those, owing to numerous fundamental technical flaws in how they are being constructed and calculated. During the Commission’s July 13 meeting of the Mapping and Quantitative Methods subcommittee, Dwayne Liller (the Commission’s analyst for measuring competitiveness) presented an analysis of precinct-level competitiveness, on the basis that districts with more balanced precincts are themselves more competitive. But this is not actually true: precincts are arbitrary administrative boundaries, not political jurisdictions, so their vote shares only matter in the aggregate. By this standard, we could make every district extremely “competitive” just by arbitrarily redrawing precinct lines to increase the number of competitive precincts, while leaving districts exactly the same. To illustrate the conceptual problem with this approach, imagine two districts, each with two equal-sized precincts. The first district has one precinct which is 100% Democrats and one which is 100% Republican. In the second district, both precincts are 55% Democrats and 45% Republicans. Because the precincts are equally sized, the first district is therefore 50% Democratic and 50% Republican, while the second is 55% Democratic and 45% Republican. Yet according to the approach of measuring precinct-level competitiveness, the first district is evidently not at all competitive, while the second is coded as extremely competitive (assuming that a 10-point margin is within the “competitive” threshold). This obviously makes no sense, and that is because the competitiveness of individual precincts is not actually indicative of the competitiveness of the district as a whole. Later in his presentation, Liller proposed a different approach, based on how much each precinct’s votes change from one election to the next. Yet again, this proposal is not actually a measure of competitiveness. At the precinct level, the volatility of votes from election to election only matters if the precincts are overwhelmingly shifting in the same direction (otherwise, they just cancel each other out in aggregate). But even at the district level, volatility only matters in close election: in a district that’s split 75/25, a swing of 20 points would not be enough to change the outcome, while a district that is 55/45 would only require a 5-point swing. As such, this a very weak proxy for competitiveness, and even further removed than the Congressional Commission’s approach from the requirements given in the constitution. Precinct-level measures are especially bad proxies for competitiveness because precinct boundaries often change between elections, making it hard or impossible to accurately calculate vote patterns or shifts at that level. And this brings us to the biggest problem in Liller’s proposals: that he doesn’t actually have or use the right data to do these analyses. Liller notes that he does not account for changes in precinct boundaries between elections, which means that data for any precinct that changed is going to be inaccurate. He also excludes precincts from his analysis which did not exist in every election. This makes his numbers less accurate, but even more importantly, it is a potential source of bias. That’s because precincts most often change in fast-growing areas, which are often home to sizable African-American and Latino communities, so the exclusion of these precincts could have a disproportionate impact on those communities’ representation in the redistricting process. So how common are these problems, and how big are the effects? Unfortunately, I cannot say with any certainty, because the data and analyses are not publicly shared; all of the conclusions herein are based only on the resulting slides and discussion in those meetings. And that leads to my final critique: not only is this process complicated and error-prone, but it is being done without the transparency needed for public scrutiny. Regardless of the measure ultimately adopted by the Commission, this information should be made available in order to ensure confidence in the redistricting process. --- So where do we go from here? To the congressional commission, I ask that you reconsider your approach and adopt a measure that better aligns with the constitution’s definition of competitiveness and avoids unnecessary complexity and subjectivity. To the legislative commission, I ask for you to do three things. First, ensure that all calculations are based on comprehensive and accurate data, without taking shortcuts. (If compromises or approximations do need to be made, the commission should be able to give clear information about where they apply and how they affect the final results.) Second, if that is not possible, then adopt a different measure that can be calculated accurately. And finally, publicly release all of the data used, along with enough documentation for others to reproduce the results. (This should include both analysis code and written documentation, with sufficient detail to allow an outside analyst to reproduce the results.) Thank you for your consideration, and I hope that my feedback is helpful to the commissions as they determine the best path forward. If it would be of interest, I would be happy to present to either or both of the commissions on these topics in greater detail, and answer whatever questions you might have. Sincerely, Andrew Therriault, PhD

To the Colorado Redistricting Commission, My name is Christine Howe and I live in area code 80481 in unincorporated Boulder County, between the communities of Ward and Jamestown. I am writing to express my concerns with the current redistricting map. I am asking you to keep the mountain communities of Boulder County east of the Continental Divide in Congressional District 2 rather than moving them to District 3. The mountain areas of Boulder County are communities of interest and work together to address common interests. We align with Boulder County, not the counties west of the divide. We have very little in common with those living on the Western Slope. We live, work, shop, recreate, and pay our taxes in Boulder County. Education here is provided by the Boulder Valley and St. Vrain Valley School Districts, while education west of the Divide is provided by other school districts. Public health is managed by the public health agencies of the county in which communities are located. Transportation needs are addressed through the Denver Regional Council of Governments and there is no public transportation to the Western Slope. Boulder and the mountain communities of Boulder County form a critical urban/mountain corridor with aligned interests, including environmental stewardship, conservation, recreation, and flood, fire, and wildlife concerns. Removing western Boulder County from its community of interest would have a negative impact on the ability of our communities to engage with our elected representatives and successfully advocate for the needs of our communities. I understand that population is a major consideration when drawing district lines. I realize that the districts need to be close to equal in population and perhaps this is the reason that this mountain area is being targeted for removal from District 2. I can’t imagine a worse demographic to move to District 3. Surely there is a better solution that could even out the numbers to satisfy this requirement and leave all of Boulder County in the same district. Please, please keep our community of interest whole as you review and finalize the proposed redistricting lines. Thank you for your consideration. (submitted by email 8/23/21)

Good day committee staff, This is a message is intended for the Mapping and Quantitative Methods Subcommittee and Map Analytics Committee. I am writing because I am unsure whether the redistricting staff has been following recent changes in the Census' new privacy efforts (see link). The changes are intended to ensure individuals cannot be identified in the public data. https://www.census.gov/programs-surveys/decennial-census/decade/2020/planning-management/process/disclosure-avoidance.html Numerous studies and tests have shown that the new differential privacy efforts are unwarranted and are potentially damaging to the quality of the 2020 Census data. One of the main opponents to this new policy is Steven Ruggles at the Minnesota Population Center (host of the Integrated Public Use Microdata Series, IPUMS). According to Ruggles and IPUMS, "The Census Bureau plans to release only 'differentially private' data from the 2020 Census. These data will have intentional errors added to nearly all statistics, including even total population of all geographic units below the state level". https://www.ipums.org/changes-to-census-bureau-data-products#dpit2020c The Census has proceeded with its plans despite the objections of users. My concern is that the 2020 Census data recently obtained for redistricting has was altered following this policy. Does the committee know if the data they obtained was subject to the new differential privacy policy or not? And if so, what guarantees are in place so that people know the numbers used for redistricting are correct? Thank you for your time and best of luck with this difficult task, Ernest Boffy-Ramirez Ernest Boffy-Ramirez, PhD Associate Professor CTT Department of Economics University of Colorado Denver & International College Beijing Research Affiliate IZA Institute of Labor Economics (submitted by email 8/19/21)

House District 38 and Senate District 32 have cut Erie off from its neighboring towns, Lafayette and Louisville, where we have a community of interest. Many Erie residents shop, attend church, have friends in these towns. These communities are suburban in their outlook and interests, not rural as Weld County is. These communities all relate to Boulder interests re open space, fracking, education, and community health. Many Erie residents work in Boulder, Longmont and Louisville in aerospace, research and pharmaceutical businesses. Many Erie residents are transplants from Boulder because of high housing costs there and have many ties to that city. I want a representative and senator that understands the concerns of our community. I like that all of Erie is being included in these districts and not split up as it has been in the past. Erie has no community of interest with Weld County and should not be included in a district with Frederick, Dacono and Ft. Lipton.

As a resident of Montezuma county and Cortez Colorado I strongly appose the 52 district proposal. Montezuma county and City of cortez have very different needs and demographics this plan just makes no sense. One more ranching and supporting community this plan has the potential and plan to strengthen one party over the other so we get false representation at the state level. Another playbook ploy of the democratic party that cannot win on merit. (submitted by email 8/19/21)