Virginia Regulatory Town Hall
Agency
Department of Elections
 
Board
State Board of Elections
 
chapter
Voter Registration [1 VAC 20 ‑ 40]
Chapter is Exempt from Article 2 of the Administrative Process Act
Action 2015 Voter Registration Application Regulation and Form Update
Stage Proposed
Comment Period Ended on 8/3/2015
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7/23/15  4:49 pm
Commenter: Rick Miller, General Registrar of Voters, Frederick County, VA

Comments on 2015 Draft Voter Registration Application
 

General

1. The draft form is hopelessly flawed and unworkable from a practical point of view.  If the current form must be changed, a better option would be to start with the 2014 draft proposed by the Voter Registration Application Workgroup.

2. If this is a two-sided form, where are we supposed to enter the data that we now put on the reverse of the alpha card?

3.  If the final document has blue background, it will be more difficult to copy and read. We do not see where any cost savings would occur.

Virginia Voter Registration Application Form Instructions

  1. Use direct address for sections, Address Requirements and Signature.  This change will make the two sections consistent with the other sections, which already use direct address.  It will also eliminate the awkward use of “her” in the second sentence of the Signature section.
  2. The first two sentences in the Instructions section seem contradictory; make it clear that the applicant has a choice about how to register.
  3. Address Requirements: Move the last sentence: A qualified protected voter …. To the Protected Voter Requirements section. Bold the word required
  4. The Signature section is confusing.  It seems to say that only registered voters who cannot sign the form must have a witness.  What is the rationale for not requiring a witness for someone’s mark who has not previously registered?
  5. The Bilingual Election Requirements Notice is missing.

Virginia Voter Registration Application

  1. Reformat the form so that Boxes 1 thru 7 fit within a 5” x 8” section, to serve as an alpha card for filing in registrar files.
    1. Eliminate the citizen check box in Box 1.  (The Affirmation in Box 7 makes this box redundant.  We have seen proposed instructions from DOE that we would not deny an application that failed to check the box.)
    2. Eliminate Box 5, because it is redundant and it is an unnecessary invasion of privacy, given that the Affirmation covers this Box and we would not deny the application that failed to answer the questions.
  2. Box 2: Protected Voter Code.  Replace “(If applicable)” with, “You must provide a PO Box within Virginia.”
  3. Box 2:  Delete the check box, “I am required or authorized to provide my mailing address.”
  4. Box 3:  Reword to “Please provide your daytime telephone number.”
  5. As formatted, Box 6 needs some serious rethinking.
    1. This information, including the applicant’s name, DOB, and SSN4, is listed in Box 7 of the present form.  Current procedures call for Registrars to detach and send Box 7 to out-of-state localities.  We will not be able to continue that procedure under the proposed formatting.  Also, Registrars will be forced to write in the applicant’s name, DOB, and SSN4 in the proposed Box 6.
    2. Alternatively, VERIS should capture the out-of-state information for new applicants.  DOE would then produce occasional reports of the information to disseminate to the other states.  This would relieve the Registrars of the wasteful and inefficient task of producing numerous small reports to other states. Many states already do this.
  6. Excellent improvement to add the label, “Today’s date,” before the date blocks in Box 7.

Proposed Revisions to Voter Registration Application Regulations

  1. A.2. What are the acceptable disabilities? Also state here that a witness needs to sign.
  2. B.9. The applicant must provide their SSN.  All US Citizens have a SSN.
  3. B.11. The applicant needs to check Box 1 about citizenship.  Most applicants will not read the affirmation before signing it.
  4. B.12. The applicant needs to check Box 5 about felons.  Most applicants will not read the affirmation before signing it.
  5. B.13. The applicant needs to check Box 5 about adjudication.  Most applicants will not read the affirmation before signing it.
  6. C.1.b. How does the applicant indicate that he has a middle name?
  7. C.1b. and C.2. These two sections are in conflict with each other.  If the Registrar contacts the applicant and they give their middle name the Registrar cannot put that information on the form and must deny the application.  If the Registrar cannot contact the applicant, the Registrar must accept the application. 
  8. D. Written authorization from the voter. Does this include misprints from DMV?
  9. F. and B.16. These two sections are in conflict with each other.  F. says if the registered voter with a disability only includes a mark in Box 7, then a witness must sign, but B.16. says if there is no witness signature in Box 7, the registration must be accepted.   
CommentID: 40549