The Constitution, ratified in 1789, provided for the creation and governance of a permanent home for the national government. Article I, Section 8, Clause 17, called for the creation of a federal district to serve as the permanent seat of the new national government and granted Congress the power To exercise exclusive Legislation, in all Cases whatsoever, over such District (not exceeding ten Miles square) as may, by Cession of particular States, and the Acceptance of Congress become the Seat of the Government of the United States.... Proponents of voting representation contend that the District's unique governmental status resulted in its citizens' equally unique and arguably undemocratic political status. Citizens residing in the District have no vote in their national legislature, although they pay federal taxes and may vote in presidential elections. Opponents often note that the Constitution grants only states voting representation in Congress. They argue that, given the District's unique status and a strict reading of the Constitution, no avenue exists to provide District residents voting rights in the national legislature other than a constitutional amendment or the statehood process, which could be achieve by statute. Issues central to the District of Columbia voting representation debate arguably revolve around two principles of our republican form of government: (1) the consent of the governed and (2) no taxation in the absence of representation. The debate has also involved questions about how to reconcile two constitutional provisions: one creating the District and giving Congress exclusive legislative power over the District (Article I, Section 8); the other providing that only citizens of states shall have voting representation in the House and Senate (Article 1, Section 2 and Section 3). Over the years, proposals to give the District voting representation in Congress have sought to achieve their purpose through constitutional amendment to give District residents voting representation in Congress, but not granting statehood; retrocession of the District of Columbia to Maryland; semi-retrocession, i.e., allowing qualified District residents to vote in Maryland in federal elections for the Maryland congressional delegation to the House and Senate; statehood for the District of Columbia; and other statutory means such as virtual-statehood, i.e., designating the District a state for the purpose of voting representation. In the recent past, Congress has restricted the ability of the District government to advocate for voting representation. Several provisions have been routinely included in District of Columbia appropriation acts prohibiting or restricting the District's ability to advocate for congressional representation. During the 10-year period between 1790 to 1800, Virginia and Maryland residents that ceded land that would become the permanent "Seat of the Government of the United States" were subject to the laws for the state—including the right to continue to vote in local, state, and national elections in their respective states—until the national government began operations in December 1800. One year after establishing the District of Columbia as the national capital, District residents began seeking representation in the national legislature. As early as 1801, citizens of what was then called the Territory of Columbia voiced concern about their political disenfranchisement. A pamphlet published by Augustus Woodward, reportedly a protégé of Thomas Jefferson, captured their concern: This body of people is as much entitled to the enjoyment of the rights of citizenship as any other part of the people of the United States. There can exist no necessity for their disenfranchisement, no necessity for them to repose on the mere generosity of their countrymen to be protected from tyranny, to mere spontaneous attention for the regulation of their interests. They are entitled to participation in the general councils on the principles of equity and reciprocity. Congress has on numerous occasions considered legislation granting voting representation in the national legislature to District residents, but these attempts have failed to provide permanent voting representation for District residents. During the 103 rd Congress (1993-1994), the District's delegate along with delegates from the territories of the Virgin Islands, Guam, and American Samoa, and the resident commissioner from Puerto Rico were allowed to vote in the Committee of the Whole under amended House rules. Although the change was challenged in court as unconstitutional, it was upheld by the U.S. District Court in Michel v. Anderson, and affirmed by the Court of Appeals. Nevertheless, the new House Republican majority repealed the rule early in the 104 th Congress. On January 24, 2007, the new Democratic majority of the House passed a rules change ( H.Res. 78 ) allowing resident commissioners and delegates to vote in the Committee of the Whole, during the 110 th Congress. Over the years, proposals to give the District voting representation in Congress have sought to achieve their purpose through a constitutional amendment, retrocession of part of the District back to Maryland, semi-retrocession allowing District residents to be treated like citizens of Maryland for the purpose of voting representation in Congress, statehood and virtual statehood that allow Congress to define the District as a state for the purpose of voting representation in Congress. Each is discussed below. The most often-introduced proposal for voting rights has taken the form of a constitutional amendment. Since the 1888 and 1889 resolutions, more than 150 proposals have been introduced that would have used a constitutional amendment to settle the question of voting representation for citizens of the District. The proposals can be grouped into six general categories: measures directing Congress to provide for the election of two Senators and the number of Representatives the District would be entitled to if it were a state; measures directing Congress to provide for the election of one Senator and the number of Representatives the District would be entitled to if it were a state; measures directing Congress to provide for the election of at least one Representative to the House, and, as may be provided by law, one or more additional Representatives or Senators, or both, up to the number the District would be entitled to if it were a state; measures directing Congress to provide for the election of one voting Representative or delegate in Congress; measures directing Congress to provide for voting representation in Congress without specifying the number of Representatives or Senators; and measures directing Congress to provide for voting representation in Congress for the District apportioned as if it were a state. The idea of a constitutional amendment was first suggested in 1801, by Augustus Brevoort Woodward, in a pamphlet entitled "Considerations on the Government of the Territory of Columbia." Although not a Member of Congress, Mr. Woodward, a landowner in the city of Washington, served as a member of the city council of Washington. His proposal to amend the Constitution would have entitled the District to one Senator and to a number of members in the House of Representative proportionate to the city's population. The proposal, which was never formally introduced, may be found in Appendix A . Woodward's pamphlets, which were published between 1801 and 1803, provided a rationale for his proposal arguing that the people of the Territory of Columbia do not cease to be a part of the people of the United States and as such are entitled to the enjoyment of the same rights with the rest of the people of the United States.... It is contrary to the genius of our constitution, it is violating an original principal of republicanism, to deny that all who are governed by laws ought to participation in the formulation of them. Woodward noted that the Senate represented the interest of sovereign states and that no state was disadvantaged due to its population because the Constitution granted each state an equal number of Senate votes. He acknowledged the distinction between the Territory of Columbia and states and argued that the Territory, whose residents were citizens of the United States, should be considered half a state and thus entitled to one vote in the Senate. With respect to the House of Representatives, Woodward simply contended that House Members were representatives of the people, and that the citizens of the Territory of Columbia were therefore entitled to representation in the House equivalent to their population and consistent with the democratic principal of "consent of the governed." It took another eighty-seven years before the first proposed constitutional amendment providing for voting representation in Congress for the District of Columbia was formally introduced by Senator Henry Blair of New Hampshire. During the 50 th Congress, on April 3, 1888, Senator Blair introduced a resolution identical in its intent to that of the Woodward proposal of 1801. The Blair proposal was submitted on behalf of Appleton P. Clark and was accompanied by a letter which was printed in the Congressional Record . On April 5, 1888, the Senate Judiciary Committee was discharged from considering the resolution. Senator Blair reintroduced a modified version of the proposed amendment, S.J.Res. 82, on May 15, 1888. During the 51 st Congress, Senator Blair reintroduced both proposals as S.J.Res. 11 and S.J.Res. 18. The Senate Committee on Privileges and Elections responded to both bills adversely. On September 17, 1890, Senator Blair addressed the Senate on the subject of the District of Columbia representation in Congress. His statement referred to many of the arguments in support of voting representation in Congress. It admonished the Senate for what the Senator characterized as the hasty disposition of the amendments he introduced, noting that This [the lack of voting representation in Congress for citizens of the District] is no trifling matter, and I verily believe that it constitutes a drop of poison in the heart of the Republic, which, if left without its antidote, will spread virus through that circulation which is the life of our liberties. In the years between 1902 and 1917, several bills proposed constitutional amendments entitling the District to two Senators and representation in the House in accordance with its population. Although the Senate District Committee held a hearing on S. J. Res. 32, in 1916, the Senate took no further action on the resolution. On January 27, 1917, Senator Chamberlain introduced S.J.Res. 196 in the 64 th Congress. The bill empowered Congress to recognize the citizens of the District as citizens of a state for the purpose of congressional representation.