Department of Small Business and Supplier Diversity Work Plan: 2nd Quarter (July 31, 2022)
Summary
A memo dated July 31, 2022 from Matthew James, Director of the Department of Small Business and Supplier Diversity, to Caren Merrick, Secretary of Commerce and Trade, with the subject Work Plan: 2nd Quarter. It reports on the Virginia Small Business Financing Authority (VSBFA), including a $3.5 million Economic Development Loan Fund project for a new production line for Axxor, North America in Danville's Ringgold Industrial Park. It also states that VSBFA awarded $103 million in grant funding under the RebuildVA Grant Fund and has been appropriated an additional $130 million in FY23. The 2022 Agency Work Plan follows the memo.
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“Department of Small Business and Supplier Diversity Work Plan: 2nd Quarter (July 31, 2022).”
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Glenn Youngkin
Governor COMMONWEALTH of VIRGINIA
Caren Merrick Department of Small Business and Supplier Diversity Matthew James
Secretary of Commerce & Trade Director
To: The Honorable Caren Merrick
Secretary of Commerce and Trade
House of Appropriations & Senate Finance Committees
From: Matthew James
Director, Department of Small Business and Supplier Diversity
Date: July 31, 2022
CC: Laura L. Wilborn, Division of Legislative Automated Systems
Subject: Department of Small Business and Supplier Diversity Work Plan: 2nd Quarter
We appreciate the opportunity to share with you the work that has been accomplished in the
second quarter of the year in relation to our 2022 Agency Work Plan. We are on track with the
majority of our goals and are meeting with our staff monthly to review performance. Many of the
goals are cumulative and we expect to reach our targets as the year progresses.
We are pleased to report, in this quarter, the achievements of the Virginia Small Business
Financing Authority (VSBFA). VSBFA is the Commonwealth’s business and economic
development financing arm. VSBFA offers programs to provide businesses, not-for-profits, and
economic development authorities with the financing needed for economic growth and
expansion throughout the Commonwealth.
During this quarter, VSBFA utilized the Economic Development Loan Fund (EDLF) to finance a
new production line for Axxor, North America in Danville’s Ringgold Industrial Park. The
project was $3.5 million dollars, which was the largest dollar volume project in the history of
VSBFA. This project allowed Axxor to retain 50 full-time positions and add 21 new jobs in
Pittsylvania County at an average wage rate of $45,000 per year with full benefits. VSBFA
provided a very low interest rate and no origination fees. VSBFA’s favorable financing
maintained Axxor in Danville against a bid to move the company to Michigan.
Overall, VSBFA’s financing created and maintained 323 jobs during the second quarter of 2022.
These jobs were primarily attributable to the EDLF program activity in Southwest Virginia.
VSBFA was ranked number seven in the nation by The Bond Buyer magazine as a result of
issuing six bonds totaling $2.4 billion.
101 N. 14th Street, 11th Floor • Richmond, Virginia 23219 • (804) 786--6585 • Fax (804) 786-9736
Additionally, VSBFA awarded $103 million in grant funding under the RebuildVA Grant Fund,
which was created to assist businesses with recovering from the impact of the COVID-19
pandemic. VSBFA has been appropriated an additional $130 million in FY23 to complete the
RebuildVA Grant Fund, which is anticipated to be fully exhausted by December 2022.
SBSD continues to provide assistance and support to Virginia’s small business community. We
look forward to updating you at the end of October 2022 on our progress and performance in the
third quarter of the year. We plan to continue to focus on different divisions within the agency
each reporting period to give you a holistic perspective on the work we are doing.
Thank you and please let us know if you have any questions on items not addresses in this report.
101 N. 14th Street, 11th Floor • Richmond, Virginia 23219 • (804) 786--6585 • Fax (804) 786-9736
Department of Small Business and Supplier Diversity
Agency Work Plan
January 1-December 31, 2022
Overview
Mission: Economic Growth and Development of Virginia’s Small Businesses
The mission of the Virginia Department of Small Business and Supplier Diversity (SBSD) is to serve
Virginia’s small businesses, by enhancing growth opportunities through increased revenue and job
creation that raises the standard of living of all Virginians.
Proposed: SBSD provides education and assistance; economic opportunity; and access to capital for
small businesses to enhance the economy of Virginia.
Agency Vision:
The Virginia Department of Small Business and Supplier Diversity (SBSD), formerly the Department of
Business Assistance, was formed to meet the needs of existing and new small businesses. Over the life
of the agency, the mission has expanded so that small, woman, and minority-owned businesses are
included in this vision. Then and now, the department separates these important functions from the
political process and ensure that all Virginia small businesses receive assistance to grow and prosper in
the Commonwealth through education, counseling, certification, and access to financing.
Agency Goals:
Statewide Goals Advanced by SBSD’s Strategic Goals, Objectives and Strategies
Be a national leader in the preservation and enhancement of our economy.
Engage and inform citizens to ensure we serve their interests.
Be recognized as the best-managed state in the nation.
Ensure that Virginia has a transportation system that is safe, enables easy movement of people and
goods, enhances the economy and improves our quality of life.
The goals listed above are statewide goals with many contributors in which SBSD plays a role. The
agency is committed to customer service, advocacy for small businesses, and support of other Virginia
state agencies. SBSD specific goals do not stand alone, but support the broader goals of the entire
Commonwealth.
Agency Goal I: Spur economic vitality through strategic investment of resources.
For the Department this means implementing strategies that assist small businesses to be more
competitive in a rapidly changing global economy.
Agency Goal II: Enhance the positive business climate in Virginia for small businesses as they
move through the business life cycle: formation, stabilization, and growth.
For the Department this means providing services designed to assist with the development and growth of
small businesses, as they are the economic engine of the Commonwealth.
1
Agency’s Objectives and Strategies for 2021
Agency Goal #1:
Spur economic vitality through strategic investment of resources.
Objective
Utilize agency resources to maximize the creation and retention of jobs within the
Commonwealth as well as growth for wealth maximization of our current small business
population.
Overall success toward meeting this objective will be assessed through the following measures:
Total number of jobs created and retained by all businesses from VSBFA capital access
programs (Work Plan Measure)
Total number of jobs created and retained by small businesses from VSBFA capital access
programs (Work Plan Measure)
Total number of jobs created and retained by small businesses in rural areas from VSBFA
capital access programs (Work Plan Measure)
Total private investment enabled for all businesses from VSBFA capital access programs (Work
Plan Measure)
Total private investment enabled for small businesses from VSBFA capital access programs
(Work Plan Measure)
Total VSBFA funds utilized for small businesses from VSBFA capital access programs (Work
Plan Measure)
Number of presentations to financial institutions, economic development and stakeholder
partners (Strategic Plan Measure)
Make available a pool of Small, Women, and Minority (SWaM) and Disadvantaged Business
Enterprise (DBE) certified vendors for local, state, and corporate/private entities (Strategic Plan
Measure)
Average number of days to process a Small, Women, and Minority (SWaM) certification
application (Strategic Plan Measure)
Support of service disabled veteran businesses through certification (Strategic Plan Measure)
Virginia Small Business Financing Authority (VSBFA)
Total number of Jobs Created and Retained by all businesses from VSBFA capital access
programs:
Staff will provide data quarterly on the number of jobs created and retained from VSBFA’s Loan, Credit
Support, Investment Grant and Bond programs. (Baseline 400; Goal 400)
Q1 104 10 2 76 16
Q2 323 271 35 17 0
YTD 427 281 37 93 16
2
Total number of Jobs Created and Retained by small businesses from VSBFA capital access
programs:
Staff will provide data quarterly on the number of jobs created and retained from VSBFA’s Loan, Credit
Support and Investment Grant programs (Bond program excluded). (Baseline 400; Goal 400)
Total R1 R2 R3 R4 R5 R6 R7 R8 R9
Q1 104 10 2 76 16
Q2 288 271 0 17 0
YTD 392 281 2 93 16
Total number of Jobs Created and Retained by small businesses in rural areas from VSBFA capital
access programs:
Staff will provide data quarterly on the number of jobs created and retained in rural areas from VSBFA’s
Loan, Credit Support and Investment Grant programs (Bond program excluded). (Baseline 150; Goal
200)
Total R1 R2 R3 R4 R5 R6 R7 R8 R9
Q1 10 10
Q2 271 271
YTD 281 281
Total Private Investment Enabled for all businesses from VSBFA capital access programs:
Staff will provide data quarterly on the total private investment enabled for all businesses from VSBFA’s
Economic Development, Cash Collateral, Loan Guarantee, Investment Grant and Bond programs.
(Baseline $7,500,000; Goal $10,000,000)
Total R1 R2 R3 R4 R5 R6 R7 R8 R9
$1,105,000 1,105,000
Q1
84,704,618 19,664,293 65,000,000 40,325
Q2
$85,809,618 $20,769,293 65,000,000 $40,325
YTD
Total Private Investment Enabled for small businesses from VSBFA capital access programs (new):
Staff will provide data quarterly on the private investment enabled from VSBFA’s Economic
Development, Cash Collateral, Loan Guarantee and Investment Grant programs (Bond program
excluded). (Baseline $7,500,000; Goal $7,500,000)
Total R1 R2 R3 R4 R5 R6 R7 R8 R9
Q1 $1,105,000 1,105,000
Q2 84,704,618 19,276,293 65,000,000 40,325
YTD $85,809,618 $20,381,293 $65,000,000 $40,325
Total Funds Utilized for small businesses from VSBFA’s capital access programs (new):
Staff will provide data quarterly on the funds utilized for VSBFA’s Microloan, Child Care, Economic
Development, Cash Collateral, Loan Guarantee and Investment Grant programs (Bond program
excluded). (Baseline $5,000,000; Goal $10,000,000)
Total R1 R2 R3 R4 R5 R6 R7 R8 R9
Q1 $496,250 276,250 25,000 170,000 25,000
Q2 4,675,244 4,520,000 55,244 100,000
3
YTD $5,171,494 4,796,250 25,000 $55,244 170,000 125,000
Total number of Presentations to financial institutions, economic development and stakeholder
partners:
Staff will provide data quarterly for the number of presentations made to VSBFA’s centers of influence
to advance its access to capital programs. (Baseline 150; Goal 600)
Total
Q1 246
Q2 192
YTD 438
SWaM Certification Division (SWaM)
Make available a pool of Small, Women, and Minority (SWaM) and Disadvantaged Business Enterprise
(DBE) certified vendors for local, state, and corporate/private entities
Staff will provide data quarterly on the number of currently certified SWaM and DBE businesses.
(Baseline 14,000; Goal 17,000)
Q1. SWaM = 14,788 DBE = 3,126
Q2. SWaM = 14,936 DBE = 3,152
Average number of days to process a Small, Women, and Minority (SWaM) certification application
Staff will provide data quarterly on the average number of business days to process a certification
application. (Baseline 86; Goal 60)
Q1. 50
Q2. 50
Support of service disabled veteran businesses through certification
Staff will provide data quarterly on the number of service disabled veteran small businesses certified.
(Baseline 250; Goal 750)
Q1. 691
Q2. 727
Agency Goal #2:
Enhance the positive business climate in Virginia for small businesses as they move through the
business life cycle: formation, stabilization and growth.
Objective
To provide services designed to assist with the development and growth of small businesses in
the Commonwealth.
4
Overall success toward meeting this objective will be assessed through the following measures:
Number of education and outreach activities conducted to assist Virginia small businesses
with strategic growth and development (Strategic Plan Measure)
Percentage of businesses that maintained or experienced growth in revenue as a result of
participating in the New Virginia Scaling 4 Growth Development Program (Work Plan Measure)
Number of businesses served through Business One Stop (Work Plan Measure)
Number of partners worked with annually to support Virginia small businesses (Strategic Plan
Measure)
Number of VDOT projects supported through vendor development and technical assistance
(Work Plan Measure)
Business Development and Outreach Services (BDOS)
Number of education and outreach activities conducted to assist Virginia small businesses with strategic
growth and development
Staff will provide data quarterly on the number of outreach events and/or activities held or
participated in annually. (Baseline 1,000; Goal 1,900)
Q1. 662
Q2. 1,081 YTD 1,743
Percentage of businesses that maintained or experienced growth in revenue as a result of participating in
the New Virginia Scaling 4 Growth Development Program
This data will be provided by Interise on an annual basis. (Baseline 30%; Goal 30%)
M1. n/a
M2. n/a
M3. n/a
M4. n/a
M5. n/a
M6. n/a
M7. n/a
M8. n/a
M9. n/a
M10. n/a
M11. 50%
M12. n/a
Number of businesses served through Business One Stop
Staff will provide data quarterly on the number of small businesses served through Business One
Stop. (Baseline 2,300; Goal 2,500)
Q1. 1,049
Q2. 1,999 YTD 3,048
Number of partners worked with annually to support Virginia small businesses
Staff will provide data quarterly on the number of partner organizations worked with to support
Virginia Small Businesses. (Baseline 100; Goal 220)
5
Q1. 93
Q2. 80 YTD 173
DBE Technical Assistance and Outreach (DBE Outreach)
Development of ready, willing, and able businesses prepared to support VDOT projects.
Staff will provide data quarterly on the number of VDOT projects supported through vendor
development and technical assistance. (Baseline 10; Goal 15)
Q1. 1
Q2. 1 (YTD – 2)
Sourcing and Compliance Division (SAC)
Work with procurement officials and businesses in the Commonwealth to strategically source small,
woman, and minority-owned (SWaM) participation on large dollar Commonwealth contracts
● Engage with procurement officials and businesses in the Commonwealth to strategically source
Small, woman, and minority-owned (SWaM) participation on large dollar Commonwealth
contracts (Baseline: 115 state agencies) (Goal: 115)
● Engage with Higher Education Institutions to strategically source SWaM vendors on university
procurements and contracting. (Baseline: 62 universities) (Goal: 31 - #submitting SWaM Plans)
● Identify and engage with prospects for the Small, Woman-owned, and Minority-owned
(SWaM) Program for sourcing and contracting opportunities (Baseline: 0) (Goal: 50)
To increase the discretionary SWaM spend of the identified top 5 agencies and HEIs
Baseline: 32.75% (Average actual FY21 spend) Goal: 33.75%
Audit Compliance and Corrective Action:
The Department of Small Business and Supplier Diversity has had eleven audits and performance
reviews and VSBFA has had five since FY15. The Joint Legislative Audit and Review Commission
(JLARC) review is complete. Their review commenced January of 2020 and concluded in September of
2020. The agency has addressed the majority of recommendations and expects to have all completed in
2021.
The agency audits/review recommendations are listed below:
6
DSBSD
Fiscal Year Agency Description Findings/Recommendations
FY20 APA Information Systems Security Audit Final Report In Process
FY20 JLARC Performance and Operations Review Post Certification Webinars to Agency Website
Implement Appeal Process for New Applicants
Update Denial Letters to Clarify Appeals Versus Waiver
Creation of Marketing Plan for BDOS
Posting of BDOS Events on Agency Website for On-Demand Viewing
Develop a Report on Necessary Updates to BOS to be Submitted to the GA
Develop Utilization Goals for each Loan Program
Track and Report Progress on Utilization Goals
Develop Loan Guidelines and Policies Around Risk Assessment
Develop Risk Assessment Tool
Annual Review of Risk of Loan Portfolio
Ensure Banks are Notifying VSBFA of High Risk Loans
Identify Timeframes for VSBFA Loan Application Processing
Prepare a VSBFA Plan to Address Risk Assessment and Loan Utilization Recommendations
Additional Support to Agencies on SWaM Goal Achievement
FY19 APA Internal Controls Review and Audit No findings
FY18 APA Procurement Review and Audit No findings
FY18 JLARC Incentive Review of SBJGF No findings for the agency, recommendation to the GA to look at wage rate
FY18 JLARC Fiscal Impact Statement Review for SB318 No findings, impact statement for DSBSD was deemed accurate
FY18 VITA Sensitive Systems Audit Provide role based security training to appropriate personnel
Develop a continuous monitoring program for vulnerabilities
Develop IT Security Plans for each application
Have users acknowledge policy adherence
FY17 Third Party Vendor ARMICS review to evaluate agency-wide and transactional internal controls Update and develop additional agency policies and procedures
Address need for additional staff
Establish budget tracking for the agency
FY17 OSIG SWaM Certification Performance Audit (Review Period FY16) Enhance Reporting of SWaM Compliance
Establish the population of agencies required to submit SWaM plan
Maintain historical SWaM Vendor Data
Perform a certification division compensation study
Research the feasibility in instituting a fee structure for certification
Update the certification officer training manual
FY17 APA Payroll Audit (Review Period FY16) Transmission of data between agency and PSB
Improve controls over terminated employees
Update and develop additional agency policies and procedures
Perform post certification activities
FY17 APA Internal Controls Audit (Review Period FY16) Update and develop additional agency policies and procedures
ARMICS not in compliance for FY16
Monitor IT contractor performance using VITA form
Review user access for internal applications
Commonwealth IT Security Audit
FY17 Third Party Vendor Independent Assessment of VSBFA Audits and Transfers as well as SBIG and SBJGF Agency should evaluate the capital requirement for SBJGF
Agency should market the SBJGF to differentiate from VJIP
FY16 JLARC Development and Management of State Contracts in Virginia Recommendation #3 - Assist with determining price reasonableness
Thirty recommendations provided only 4 pertained to DSBSD Recommendation #4 - Assist with determining if weighted criterion for SWaM needed adjustment
Recommendation #7 - Prioritize small business certification over W/M
Recommendation #8 - Send notifications to businesses ahead of expiration
VSBFA
Fiscal Year Agency Description Findings/Recommendations
FY18 JLARC Incentive Review of SBIG Recommendation #7 - Obtain metrics from grant recipients and collect industry codes
Recommendation #9 - VSBFA to review credit conditions, adjust programs as needed
Recommendation #10 - VSBFA to establish a minimum job requirement for LGP, CC, and SWaM Microloan
Recommendation #11 - VSBFA to monitor employment outcomes for LGP, CC, and SWaM Microloan
FY18 APA VSBFA Federal Grants Audit Increase policy and procedure creation for Economic Development Federal Loan programs
FY17 APA Annual Financial Review (Review Period FY16) No Findings
FY16 APA Annual Financial Review (Review Period FY15) No Findings
FY15 APA Annual Financial Review (Review Period FY14) Improve controls over financial reporting process
Strengthen controls over off-CARS disbursements
7
Agency Corrective Action Plan and Timeline listed below:
DSBSD
Fiscal Year Agency Description Corrective Action
FY20 APA Information Systems Security Audit
FY20 JLARC Performance and Operations Review Complete
Complete
Complete
Complete
Complete
In Progress
In Progress
Complete
In Progress
Complete
In Progress
In Progress
In Progress
In Progress
Complete
FY19 APA Internal Controls Review and Audit None
FY18 APA Procurement Review and Audit None
FY18 JLARC Incentive Review of SBJGF None
FY18 JLARC Fiscal Impact Statement Review for SB318 None
FY18 VITA Sensitive Systems Audit Complete
Complete
Complete
Complete
FY17 Third Party Vendor ARMICS review to evaluate agency-wide and transactional internal controls Complete
Budget Requests Submitted/No funding
Complete
FY17 OSIG SWaM Certification Performance Audit (Review Period FY16) Complete
Complete
Complete
Complete
Complete
Complete
FY17 APA Payroll Audit (Review Period FY16) Complete
Complete
Complete
Complete
FY17 APA Internal Controls Audit (Review Period FY16) Complete
Complete
Complete
Complete
Complete
FY17 Third Party Vendor Independent Assessment of VSBFA Audits and Transfers as well as SBIG and SBJGF Complete/Legislation was introduced
Complete
FY16 JLARC Development and Management of State Contracts in Virginia Complete
Thirty recommendations provided only 4 pertained to DSBSD Complete
Complete
Complete
VSBFA
Fiscal Year Agency Description Corrective Action
FY18 JLARC Incentive Review of SBIG Complete
Underway
Unable to implement/communication sent to JLARC
Complete
FY18 APA VSBFA Federal Grants Audit Complete
FY17 APA Annual Financial Review (Review Period FY16) None
FY16 APA Annual Financial Review (Review Period FY15) None
FY15 APA Annual Financial Review (Review Period FY14) Complete
Complete
8
Discussion Points:
The agency is committed to supporting small businesses by providing access to capital, opportunity
through state and federal certification, and growth through comprehensive development programs.
Since the merger of the Department of Business Assistance (DBA) and the Department of Minority
Business Enterprise (DMBE) to create the Department of Small Business and Supplier Diversity
(DSBSD) in FY15 the agency has flourished. Under the direction of new leadership, the two agencies
became one and shared goals and vision were established.
The first order of business, once the mission of the agency was solidified, was to develop the
infrastructure necessary to allow the agency to be successful. This required the build out of office space
so both agencies could work together as one cohesive unit. Next staffing needed to be addressed;
attracting new talent, addressing performance issues, and developing high potential employees was a
priority. Once infrastructure was in place then current programing and performance of that programing
could be evaluated. Strategic planning and SWOT analysis was completed and new performance
metrics were established. Through this planning effort new programing opportunities were identified and
the agency added the Virginia Scaling 4 Growth program and the Virginia Contractor’s Course to our
business development offerings.
By December 2022, we anticipate 13 more businesses graduated (July) with another 16 in the program
(starting August). Virginia is the first State government to offer this nationally renowned program. The
program is a six-month MBA (coined StreetWise MBA) style program designed to take businesses
through leadership, finance, and business management modules with their final capstone project being
the completion of a growth program that they can put into action upon graduation. Based on economic
impact data we have captured from our graduates, 61 percent retained or created new jobs. 50% of
graduates reported that they increased or maintained annual revenue. Virginia’s program has had such
great success that Interise, the national licensing organization, has used Virginia’s results as a model of
success for other participants and ranked the Virginia program as number 1 in the country.
The agency has also made tremendous strides as it relates to streamlining the SWaM Certification
process and in reducing time to process applications. In FY16, the agency was faced with a backlog of
over 2,000 applications and the average processing time for SWaM certification was approximately 120
business days. The agency identified strategies to manage the application volume and instituted new
technology to automate the process. As of FY18, the agency was able to clear the backlog and reduce
processing times to less than 60 business days. The average number of days to process a certification
application in the private sector is 90 business days; we are committed to providing a faster service to
our small businesses and at no cost.
In FY20, the agency finalized streamlining efforts to reduce the burden of certification to the business
owner. The agency finalized regulatory changes that reduced the amount of time a business must wait
to reapply after being denied certification from 12 months to six months. The agency implemented
changes that allowed more time for reapplication increasing the reapplication period from 90 days to 120
days. The agency implemented a streamlined recertification process that allows for an attestation of no
change allowing the business to submit less documentation when reapplying. We have held webinars
and certification labs statewide to assist applicants with the process. We have conducted outreach and
increased the number of certified service disabled veteran owned businesses by 121 percent since
FY18.
9
Average Days to Process SWaM Certification Applications
140
120
100
80
60
40
20
0
2016 2017 2018 2019 2020
The agency has also been successful in updating its technology to meet the needs and expectations of
the citizens of the Commonwealth. In 2017, the agency launched a new website as well as a new
certification application portal. The agency created an enhanced SWaM and DBE directory to assist
Commonwealth procurement officials with identification and location of certified vendors. DSBSD, in
2018, worked with nineteen state agencies to provide them with real time data feeds on SWaM
certification information. These feeds populate SWaM certification data into DGS’s eVA system, DOA’s
Cardinal system, VITA’s subcontractor portal and various institutions of higher education’s ERP systems.
The agency launched a new Expenditure Dashboard application in FY20, which contained enhanced
reporting, adjustment submission, and subcontractor submission capabilities. The agency has begun
work to enhance the Business One Stop application.
The agency has accomplished a great deal and appreciates the opportunity to highlight the work that has
been done and the work that will be accomplished in this upcoming reporting period. We stand ready to
continue our support of the small businesses of the Commonwealth. There are currently 745,886
businesses in Virginia, of which 99.5 percent are small businesses. Virginia small businesses employed
1.5 million people or 47.2 percent of the private workforce in 2013. Our small businesses are the
backbone of Virginia’s economy.
Appendix:
The agency will use the USDA definition of rural, which includes the following localities:
Accomack, Alleghany, Bath, Bland, Brunswick, Buchanan, Buena Vista City, Carroll, Charlotte,
Covington City, Cumberland, Danville City, Dickenson, Emporia City, Essex, Franklin City, Galax City,
Grayson, Greensville, Halifax, Henry, Highland, King and Queen, King George, Lancaster, Lee,
Lexington City, Louisa, Lunenburg, Madison, Martinsville City, Mecklenburg, Middlesex, Northampton,
Northumberland, Norton City, Nottoway, Orange, Page, Patrick, Pittsylvania, Prince, Edward, Richmond,
Rockbridge, Russell, Shenandoah, Smyth, Southampton, Surry, Tazewell, Westmoreland, Wise, and
Wythe.
The following localities have geographic areas within them that have been designated rural as well:
10
Amherst, Bedford, Campbell, Culpeper, Dinwiddie, Floyd, Franklin, Goochland, Nelson, Pulaski,
Rappahannock, Sussex, and Warren.
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