These data contain selected census tract level demographic indicators (estimates) from the 2015-2019 American Community Survey representing the population density by square mile (land area).

This is a comment on the preliminary Congressional Commission redistricting map. Along with providing feedback on that map, it offers a draft alternative that better meets the criteria of the Colorado Constitution. As background, I participated in redistricting initiatives in South Bend, Indiana, in the mid-1980s and for Indiana legislative seats after the 1990 census. I didn’t engage with redistricting during the rest of my 20-year military career. After retiring, and while serving as Public Trustee for El Paso County, I participated in redistricting efforts at the county and city level. I also stood for El Paso County Clerk in 2010. I have lived in Colorado since 2000. The draft alternative map is created using Dave’s Redistricting App (DRA) and can be found at https://davesredistricting.org/join/346f297c-71d1-4443-9110-b92e3362b105. I used DRA because it was more user-friendly in that it allows selection by precinct and by city or town, while the tool provided by the commission seems to allow only selection by census block (or larger clusters). The two tools also use slightly different population estimates, but this will be resolved when the 2020 data are released in August. These comments acknowledge that any map created using estimated populations will need to change to account for the actual census data.

Description of Draft Alternative

    My process started by

identifying large-scale geographic communities of interest within Colorado: the Western Slope/mountain areas, the Eastern Plains, Colorado Springs/El Paso County, the North Front Range, and Denver Metro. Two smaller geographic communities of interest are Pueblo and the San Luis Valley—neither is nearly large enough to sustain a district and both are somewhat distinct from their neighboring communities of interest. A choice thus must be made about which other communities of interest to group them with. El Paso County is within 0.3% of the optimal population, so it is set as District 5. The true Western Slope is not large enough to sustain a district, even with the obvious addition of Jackson County. Rather than including the San Luis Valley with the Western Slope, the preliminary commission map extends the Western Slope district to include all of Fremont County (even Canon City, Florence, and Penrose), Clear Creek County, and some of northern Boulder County. The draft alternative District 3 instead adds the San Luis Valley, the Upper Arkansas Valley (Lake and Chaffee Counties, and the western part of Fremont County), Park and Teller Counties, and Custer County. The draft alternative District 4 is based on the Eastern Plains. In the south, this includes the rest of Fremont County (including Canon City), Pueblo, and the Lower Arkansas Valley. In the north, this includes all of Weld County, retaining it as an intact political subdivision. This is nearly enough population to form a complete district; it is rounded out by including the easternmost portions of Adams and Arapahoe Counties. All of Elbert County is in this district; none of Douglas County is. The draft alternative District 2 is placed in the North Front Range and includes Larimer, Boulder, Gilpin, and Clear Creek Counties. This is nearly enough population to form a complete district, so it is rounded out by adding Evergreen and the rest of Coal Creek in Jefferson County. The City and County of Denver (and the Arapahoe County enclave municipalities of Glendale and Holly Hills) forms the basis of draft alternative District 1. This is a bit too large to form a district, so small areas are shaved off into neighboring districts: DIA (mostly for compactness), Indian Creek, and part of Marston. This leaves three districts to place in suburban Denver. The draft alternative keeps Douglas County intact, as well as the city of Aurora, except for the part that extends into Douglas County. The map prioritizes the county over the city as a political subdivision. Draft alternative District 6, anchored in Douglas County, extends north into Arapahoe County to include suburbs like Centennial, Littleton, Englewood, Greenwood Village, and Cherry Hills Village. This is not enough population, so the district extends west into southern Jefferson County to include Columbine, Ken Caryl, and Dakota Ridge. The northwestern edge of this district would run along Deer Creek Road, Pleasant Park Road, and Kennedy Gulch Road. Draft alternative District 8, anchored in Aurora, includes the rest of western Arapahoe County and extends north into Adams County to include Commerce City, Brighton (except the part in Weld County), Thornton, and North Washington. In the draft alternative, this district includes a sliver of Northglenn east of Stonehocker Park. While this likely would be resolved when final population totals are released, this division of Northglenn is the most notable division of a city within a single county other than the required division of Denver. Draft alternative District 7 encompasses what is left: The City and County of Broomfield; Westminster, in both Jefferson and Adams Counties; Federal Heights, Sherrelwood, Welby, Twin Lakes, Berkley, and almost all of Northglenn in western Adams County; and Lakewood, Arvada, Golden, Wheat Ridge, Morrison, Indian Hills, Aspen Park, Genesee, and Kittredge in northern Jefferson County. The border with District 2 through the communities in the western portion of Jefferson County would likely be adjusted after final population totals are released.

Comparison of Maps

Precise Population Equality
    The preliminary commission

map has exact population equality. The draft alternative map has a variation of 0.6% (4,239 persons). Given that the maps are based on population estimates, and that I left it at the precinct and municipality level, this aspect of the preliminary map is premature to pinpoint. Once final population data are released, either map would need to be adjusted. It would be simple to tweak district boundaries to achieve any desired level of equality. That said, such precision is a bit of a fallacy: errors in the census data likely exceed the 0.6% in the draft map, the census data will be a year out of date when received, and relative district populations will fluctuate over the next 10 years. Both the “good-faith effort†and “as practicable†language leave room for a bit of variance in service of other goals. The need to “justify any variance†does not mean “no variance will be allowed.†For example, it may be better to maintain unity in a community of interest or political subdivision rather than separate part of it for additional precision. The major sticking point here is likely to be El Paso County: given how close it seems to be to the optimal district size, will it be worth it to divide the county or one of its neighbors to achieve precision? The same question would be likely to apply among the municipalities in Metro Denver.

Contiguity
    The draft alternative map

meets this requirement. The preliminary commission map violates the spirit if not the actual language of this requirement. While its districts are connected by land, the only way to travel to all parts of preliminary Districts 3 and 4 without leaving the districts would be on foot. There is no road connection between the parts of Boulder County that are in District 3 and the rest of that district in Grand County without leaving the district and passing through District 2 in either Gilpin or Larimer Counties. There also is no road connection between some of the southwestern portions of Mineral County and the rest of District 4 without passing through Archuleta or Hinsdale Counties in District 3.

Voting Rights Act
    The preliminary staff

analysis assumes it would be possible to create a majority-minority district; they are correct, it can be done via a noncompact district running from the west side of Denver up to Commerce City and Brighton and down to parts of northeastern Denver and northern Aurora. Such a district would go against criteria for compactness, political subdivisions, and even other definitions of communities of interest. Staff asserts that the election of Democratic candidates in this area suffices for VRA. Appendix B is opaque regarding the actual non-White or Hispanic population in each district, but I presume that if they had created a majority-minority district they would have said so. In the draft alternative map, District 8 (Aurora, Commerce City, Brighton, and Thornton) has a 39.6% minority population and District 1 (Denver) has a 34.9% minority population. The proposals are similar in meeting this criterion.

Communities of Interest
    Staff presented a long list

of communities of interest. While keeping all of these intact would be ideal, drawing a map requires compromises based on geography and population. Many communities of interest overlap with each other, especially at their edges. This difficulty points to a reason to focus on existing subdivisions (county, city, and town boundaries): those boundaries are stable and overlap with shared public policy concerns. The preliminary commission map chooses to group the San Luis Valley, as far upstream as Del Norte and Creede, with Pueblo and the Eastern Plains rather than with the Western Slope/Mountains. To balance the population numbers, the preliminary commission map thus had to reach east in northern and central Colorado. The commission includes Canon City and Florence

The data shown is from US Census Bureau 2020 ACS Estimates, at the census block group level.

Home Owners’ Loan Corporation (HOLC) maps illustrated patterns of segregation in United States cites in the 1930s. As the causes and drivers of demographic and land use segregation vary over years, these maps provide an important spatial lens in determining how patterns of segregation spatially and temporally developed during the course of the past century. Using a high-resolution land-use time series (1937-2018) of Denver Colorado USA, in conjunction with 80 years of U.S. Census data, we found divergent land-use and demographics patterns across HOLC categories were both pre-existent to the establishment of HOLC mapping, and continued to develop over time. Over this period, areas deemed “declining” or “hazardous” had more diverse land use compared “desirable” areas. “Desirable” areas were dominated by one land-use type (single-family residential), while single-family residential diminished in prominence in the “declining/hazardous” areas. This divergence became more established decades after HOLC mapping, with impact to racial metrics and low-income households. We found changes in these demographic patterns also occurred between 2000 and 2019, highlighting how processes like gentrification can develop from both rapid demographic and land-use changes. This study demonstrates how the legacy of urban segregation develops over decades and can simultaneously persist in some neighborhoods while providing openings for fast-paced gentrification in others.

Dear Commission: Happy Independence Day holiday! I am a resident of Boulder County and have a deep background in GIS technologies and demographic mapping applications. I've been following congressional redistricting developments from the commission closely over the past couple weeks. It's pretty cool to be able to "get my map geek on" and create a map of my own (using Dave's Redistricting App and exported to GeoJSON format -- file attached) which adheres as closely as possible to the specifications of Amendment Y (particularly with respect to equal representation, not splitting political jurisdictions -- counties, cities, etc. -- and reflecting communities of interest). I also worked to be as responsive in my map as possible to many of the points raised in other public comments submitted to the commission thus far. I feel quite good about the result and would like to share that with you at this time. This map can also be viewed online at: https://davesredistricting.org/maps#viewmap::d45019ad-0d0e-41e1-8949-4325bd031b20 Highlights of the attached map are as follows: - Only 6 counties are split in this plan, fewer than the existing 2010 CD map (7 splits) or current CD preliminary plan (9 splits). The 6 splits are: * Teller * Adams * Arapahoe * Jefferson * Weld * Denver -- very minimally split just to necessarily shed extra population from the 1st CD - Partisan split of districts is well-representative of the state overall: * GOP districts: 2 solid (4th and 5th CDs), 2 tilt (3rd and 7th CDs) * DEM districts: 2 solid (1st and 2nd CDs), 2 lean (6th and 8th CDs) - Several cities/towns which are split between different counties are kept whole in single district -- e.g., Longmont and Erie fall across both Boulder and Weld counties and those are kept together in a CD (which is what necessitated the relatively small splitting of Weld County) - Variance in population between all 8 districts is <10 people - Sensitive to multiple ethnic/cultural, economic, and political/social communities of interest - Racial/demographic splits: * Hispanic population

20% in 3 districts (4th, 8th, and 1st CDs) * Black population >10% in 6th CD, ~10% in 1st CD * Overall minority population >30% in 2 districts (1st and 6th CDs), 25-30% in 3 additional districts (8th, 4th, and 5th CDs) - Two predominantly rural districts: * Western Slope (3rd CD -- tilt GOP) * Eastern Plains (4rd CD -- solid GOP) - New 8th CD allocated to north Denver metro-Boulder commuter crescent (northeastern Jefferson, Broomfield, and western Adams counties) and has a denser Hispanic community than other non-1st CD metro districts (i.e., denser than the 2nd, 6th, and 7th CDs) - San Luis Valley/SLV kept whole within 3rd CD - Arkansas River valley below Salida kept whole within 4rd CD - Continental Divide used as natural boundary between North-central districts (between 2nd and 3rd CDs) - CSU and CU maintained within 2nd CD (Boulder and Larimer counties are entirely within 2nd CD) Thank you for your service to our state and consideration of my submission. Sincerely, Laura J. Westerfield

Census tracts are small, relatively permanent geographic entities within counties (or the statistical equivalents of counties) delineated by a committee of local data users. Generally, census tracts have between 2,500 and 8,000 residents and boundaries that follow visible features. When first established, census tracts are to be as homogeneous as possible with respect to population characteristics, economic status, and living conditions. (www.census.gov)

I have two central concerns regarding the commission's draft map. Firstly, all of the districts are majority white despite the fact that about two fifths of the state's population is constituted by people of color. I think at least one district should be majority-POC in order to comply with the VRA. It is possible to draw such a district by combining the inner northern and eastern suburbs of Denver with the sections of Denver near the airport and on the northeast fringe of the city. As attachment C notes, these sections of Denver are closely intertwined with the inner suburbs given their geographic proximity and demographic similarity. While the commission argues in their memo that the white majority does not prevent minority groups from electing their candidate of choice in this area, their analysis only considers the results of general elections (i.e. whether a democrat or republican is elected). However, it is possible that cracking the concentrations of minority voters in this region (as the proposed map does) will prevent minority voters from electing their candidates of choice in primary elections. Notably, this region is currently divided between districts 1, 6, and 7. Over the past decade, across these three districts, there has only been one major party nominee of color (Casper Stockham) and no candidate of color has been elected in the general. Consolidating a larger share of minority voters into district 6 would ensure that voters of color have the power to nominate candidates of choice for the general election, including candidates of color. Second, I am concerned that this proposal disregards competitiveness. According to Amendment Y, the commission is supposed to try to maximize the number of competitive districts but most of these districts seem to be drawn to protect incumbents of both parties. I agree with others arguing for a map that includes three competitive districts along with two solidly republican districts and three solidly democrat districts. This is a fair split given that Colorado leans somewhat toward the Democrat party. I have drafted a map based on my comments: https://davesredistricting.org/join/9df1a608-6ba9-4bed-ae48-260310fbafb3. This map keeps communities of interest together, splits municipalities as little as possible, and performs better on compactness scores than the commission's draft map. Additionally, district 6 is 58.3% POC including 36.0% Hispanic/Latino (a higher share than in any district in the commission's map). The new district 8 also still has a relatively large share of Hispanic/Latino residents at 28.6% as it is somewhat similar to the district proposed by the Hispanic Chamber of Commerce. Overall the results of the 2018 Attorney General's Race for this map would be as follows: District 1: 73.0D-24.2R District 2: 62.0D-35.0R District 3: 50.3R-46.4D District 4: 61.6R-35.0D District 5: 58.0R-38.1D District 6: 61.0D-35.5R District 7: 48.7D-48.4R District 8: 48.6R-47.7D https://davesredistricting.org/join/9df1a608-6ba9-4bed-ae48-260310fbafb3

Based upon the Neighborhoods layer from Community Planning and Development. This layer is a duplicate of that layer, but with additional demographic information compiled from the 2010 US Census. Although every effort was made to ensure that blocks were assigned to their proper neighborhoods, due to geographic problems inherent in the original 2010 census block data, errors may exist. This data-set includes the housing and population data from redistricting file P.L. 94-171 of the 2010 census. The data-set does not contain data for any enclaves administered by other jurisdictions that are located within the City and County of Denver's boundary.

These data are the common data fields from the American Community Survey agreed upon by the Data Indicators GIS Subcommittee. The data source is Census Tract level data from the American Community Survey; 5 year average, years 2018-2022. The original census tract group boundaries have been adjusted to various Denver GIS data layers to increase the spatial accuracy of this data. Although every effort was made to ensure the accurate rectification of the data, due to geographic problems inherent in the original 2010 census block group data, errors may exist. The data-set does not contain data for any enclaves administered by other jurisdictions that are located within the City and County of Denver's boundary. This data is a sample, not a complete census. Data should be considered estimates and a margin of error table is located on the city network that can be used in conjunction with this dataset.

The Department of Transportation & Infrastructure (DOTI) developed the DOTI Equity Index to prioritize areas of need and capital allocation for projects. The Transportation Mobility Planning Division uses the Equity Index to determine Denver’s Priority Areas for Transportation Equity. The resulting data model uses a data-driven approach to evaluate areas of inequity by performing a weighted overlay analysis using demographic indicators that correlate with more historic disinvestment, which also indicates a higher reliance on active transportation and transit systems. The equity index is intended to be used with supplemental data to help provide a better overall picture for any given program. For example, the Vision Zero program will also use safety and vehicle crash data in unison with the equity index to help prioritize investment locations.The Equity Index is comprised of the following seven demographic characteristics:Race & EthnicityIncome & PovertyEducation LevelPopulations of Age 65+Households with No VehicleFemale Heads of HouseholdPeople with Disabilities