[VIDEO] Holt Legislative Redistricting 3rd Testimony


A third round of public comment began on May 2, this time on the revised preliminary maps. It was the first of two public hearings the Legislative Reapportionment Commission will hold to allow concerned citizens, like myself, an opportunity to provide the commission with feedback on these maps released on April 12.

The plan continued to make the same violations found in the Remanded Final Plan. This means there were issues regarding compactness, contiguity, and whole political subdivisions.

Watch me present my testimony in the video below. The entire 3 hour public hearing is available to watch online as well. Watch Part 2 of the Public Hearing on May 7 at 2pm. It will likely air live on the PA Senate Video Feed.

Remember it is not too late to share your thoughts with the Commission, even if you just want to let them know you concur with what I’ve shared. The public comment period ends on May 12. You may email them through the LRC contact page.

Below are my remarks offered that day that highlighted my full testimony (in the 3rd Holt Legislative Proposal PDF). It illustrates where the constitutional violations were found in the Revised preliminary plan and how they were avoidable.

My Remarks

I am here to take exception to the excessive number of avoidable political subdivision splits found in the Revised Preliminary Plan.

The Constitution is quite clear that political subdivisions should remain whole and only be divided if it is unavoidable in order to comply with other constitutional criteria. The meaning of absolute necessity only becomes obscure if one tries to alter the clear definition found in the English language: inevitable, unavoidable, compulsory, required.

This Commission should not redefine the English language. The meaning of absolute necessity is quite plain and should cause no debate. In any other field, this point would not even raise a doubt as to the self-evident meaning of the term.

The Constitution outlines four criteria that might make a division unavoidable in certain places:

  1. Equal Population
  2. Voting Rights Act
  3. Compactness
  4. Contiguousness

If the law is being upheld first and foremost by this Commission, then each political subdivision split in the Revised Preliminary Plan will be found unavoidable in order to comply with one of these rules. The Supreme Court agreed in its recent ruling when emphasizing the need to address the significant number of avoidable political subdivision splits present in the Remanded final plan.

As this Commission has acknowledged, there are avoidable subdivision splits in the Revised Preliminary Plan. So you are aware that subdivision splits were made that might have been avoided while still meeting constitutional criteria. My findings show that these excessive divisions are on a massive scale.

Before looking at the details of these findings, I should clarify a few points.

  • The split baseline is the number of splits automatically required by population. The Constitution requires that this Commission minimize how far they exceed the baseline in complying with the criteria of equality, contiguity, and compactness.
  • It is also important that we consider the total split count, which is calculated by subtracting the number of split subdivisions from the number of times subdivisions are split. This offers the most accurate overview of the split situation.
  • Lastly, it should be noted that there are multiple ways to achieve this end of constitutional compliance, as illustrated by the three Senate and two House maps submitted today.


Page 3 of your packet shows that the Senate portion of the Revised Preliminary Plan went 36 splits beyond the baseline, when it was only necessary to make 4 additional divisions.

Page 4 shows that these 32 avoidable divisions were not made to comply with constitutional equality requirements. Each of the three submitted Senate maps use a slightly lower population deviation while creating the same number of minority-majority districts and even creating a stronger Hispanic presence in Senate District 2 than what was proposed by this Commission.

Page 5 shows that they were not made to create compact districts. The compactness issues the Supreme Court raised regarding Senate District 3 were simply shifted to Senate District 2. Senate District 15, another district mentioned by the Court, also remains not compact. Even Azavea, using impartial compactness measures, found the district boundaries in the Revised Preliminary Plan to be “drastically less compact” than the evidence I submitted to the Supreme Court.

These additional divisions are not even justified on the non-constitutional consideration of the residence of incumbents. With only two additional total splits beyond the four I have proposed, all but one incumbent residence might be accommodated.


These same issues are also present in the House portion of the Revised Preliminary Plan.

Page 6 of your packet shows that the House portion of the Revised Preliminary Plan went a staggering 267 splits beyond the baseline, when it was only necessary to make 62 additional divisions.

These 205 avoidable divisions were not made to comply with constitutional equality requirements. Each of the two submitted House maps use a slightly lower population deviation while creating more minority-majority districts. Page 7 shows the minority-majority district details.

Page 8 shows an excessive number of divisions to municipalities – nearly 70 in the total split count. Residents of Ferguson, Lancaster Township, Lower Merion, Manheim, O’Hara, Phoenixville, Pittsburgh, Radnor, Ross, Salisbury, South Whitehall, and Upper Dublin offer a sampling of those taking the brunt of this violation.

Page 9 shows an excessive number of divisions to Wards– nearly 100 in the total split count. Residents of Radnor, Reading, Philadelphia, and Pittsburgh offer a sampling of those taking the brunt of this violation.

Page 10 shows that they were not made to create compact districts and offers an illustration of some of the more striking examples.

Page 11 shows that they were not made to create contiguous districts. There are 12 portions of districts that are not contiguous with the rest of their district. Two additional contiguous issues were addressed by the Commission in the Revised Preliminary plan by splitting voting districts. This was completely unnecessary as those contiguous issues might be addressed without harming any voting precinct, as illustrated in both House version maps submitted today.


The submitted maps are shown beginning on Page 13. They were created using the same method described in my previous testimony to this commission on Sept. 7. It puts population first by using county apportionment, and then extends this to municipalities and wards. Once population equality was achieved with the minimum number of splits, a minimal number of additional divisions were made to avoid discriminating against minorities.

Each version illustrates that this testimony does not advocate one way to draw the map. The multiple versions of each reflect that the same total split count might be reached by drawing districts in multiple ways.

First are the three Senate maps. Each illustrates the variety possible in choosing where divisions occur while achieving the minimum number of splits required for compliance with the law. Version 1 only divides the counties and cities that exceed the size of a Senate district. Next are the two House maps that illustrate the same concept.

Additional Considerations

Please remember that the constitutional directive to keep political subdivisions whole has an immediate and personal impact on the voice of residents throughout Pennsylvania.

It is allowable for this commission to place additional restrictions upon itself – beyond what are found in the constitution – provided they do not conflict with the constitution. Based on comments at the last public meeting, this commission has given itself the additional limitation of only moving seats of retiring members. But what if there is significant population loss in an area where there is no retiring member?

The clearest instance of this is in Philadelphia where seven Senators reside yet there is only population to fill out exactly six districts. Must this incumbent consideration take precedence over the people and our constitution? Must the surrounding areas be fragmented and divided, thus diluting the voice and representative say of the people in those areas?

Continuing with the Philadelphia example, we see in the Senate how the neighboring Counties suffer severe fragmentation as a result – Bucks and Delaware each split 1 extra way, Chester split 2 extra ways, and Montgomery split 3 extra ways. Similar instances might be found in the House plan.

This “divide and conquer” approach only serves to violate the constitutionally protected voice of Pennsylvania residents and the laws designed to ensure we have an equal and unified say in our state government. This is why our constitution must come first.

Preserving the integrity of political subdivisions was the way our founders chose to protect the voice of citizens while creating a natural checks and balances to political power. You have been granted the privilege of carrying out this sacred trust on behalf of the people.

The Supreme Court affirmed the significance of the constitutional requirement to respect political subdivisions. They wrote “that the 2011 Final Plan is contrary to law premised on the existence of a significant number of political subdivision splits that were not absolutely necessary”.

Absolute necessity matters. 303 represents a significant number of avoidable splits when compared to 66. I can only conclude that this Revised Plan, rather than first serving the citizens and upholding our constitution, needlessly continues to sacrifice our constitution on the altar of incumbent preferences.

Our constitution must not be compromised. This means that counties, municipalities, and wards must remain whole unless keeping another constitutional rule makes dividing them unavoidable.

I, along with several of my fellow petitioners, respectfully request that you address these exceptions in the Final plan.

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Amanda began delving into the subject of redistricting in October of 2010 on her quest to know why. Helped by a love of puzzles, attention to detail, and a great deal of persistence, her efforts eventually led her to a historic victory before the Pennsylvania Supreme Court. She documents her journey at AmandaE.com, inspiring others through numerous presentations across the state. The recipient of several honors, her work has also been featured in every major Pennsylvania newspaper, making headline news in Pittsburgh and Philadelphia.

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