Although at the time Charles I gave this grant to Lord Baltimore Virginia was a Crown Colony and thus it could not be contended that he was giving away lands he had no power to cede since they already had been given to others, the Maryland-Virginia boundary became a subject of controversy as soon as the first Maryland settlers arrived, and has continued so until almost the present time. Indeed, one might say that the ghost has been laid only temporarily since echoes of the dispute appear in today's newspapers: "Maryland and Virginia Start New Round in Oyster War"--"Pentagon Area a No Man's Land." These headlines derive in a direct line from the grant of King Charles I to Calvert, Lord Baltimore, in 1632.[9] [9] Conway, _The Compacts of Virginia_, p. 8. To leave, for a time, the Potomac boundary of Arlington, let us turn to the narrowing of the boundaries of the landward side of the County. In the development of governmental administration, counties began to be created in Virginia in mid-17th Century. The area which became Arlington was successively in Northumberland, Westmoreland, Stafford, Prince William, and finally, Fairfax counties. (Map II.) Consequently, the history of land tenure and legislation for Arlington must be sought in the records of these counties for the relevant period. [Illustration: MAP II Development of Northern Neck Counties Drafted by W. B. Allison and B. Sims] Northumberland County was definitely created in 1648 by an Act of the General Assembly[10] which provided "that the said tract of land ['Chickcoun and other parts of the Neck of land between Rappahonock River and Potomack River'] be hereafter called and knowne by the name of the county of Northumberland...." [10] Hening, Vol. i, p. 352. Northumberland was first mentioned by name in an Act (IX) of February 1645, and sent its first representative to the Legislature for the session of November 1645. and was given power to elect Burgesses. A later Act[11] declared: "_It is enacted_, That the inhabitants which are or shall be seated on the south side of the Petomecke River shall be included and are hereafter to be accompted within the county of Northumberland." [11] Act III, October 1649. Hening, Vol. i, p. 362. Settlement was pushing north, however, and in July 1653, Westmoreland was carved out of the then existing Northumberland. It was decreed: "ordered by this present Grand Assembly that the bounds of the county of Westmorland be as followeth (vizt.) from Machoactoke river where Mr. Cole lives: And so upwards to the falls of the great river of Pawtomake above the Necostins Towne."[12] [12] Hening, Vol. i, p. 381.