Thank you for this opportunity to comment. I have two main points to make, and I ask that the State Board of Elections consider these when reviewing the proposed regulation for adoption.

[1] Soliciting IDs at locations other than the Registrar's Office

The proposed regulation provides, in part, as follows: "General registrars may solicit applicants for voter photo identification cards at locations other than their offices. No general registrar shall be required to offer this service."

While there is some concern about voters who are disabled or homebound, I agree with this stipulation being in the final regulation. Voters who are homebound, disabled, or otherwise unable to go to their Registrar's Office to vote or obtain a photo identification are able to vote absentee and do not need to provide to photo identification when voting absentee (unless they are required by federal law to provide an identification). It is a disservice to to inform disabled, or other homebound, voters that they need a photo identification when they are not required to have an identification to vote absentee, and voting absentee would be more convenient to them. The law of Virginia currently provides the Annual Absentee Application, as well as absentee voting itself, to eligible voters, and state agencies, registrars, and electoral boards, should not be throwing up barriers to voters who are qualified to vote absentee. Leading people to believe that they need a photo identification when that is not necessary for absentee voting is misleading them about the laws of the Commonwealth.

Instead, a much better way of helping homebound or disabled voters is to inform them of the Annual Absentee Application, which is available under Va. Code 24.2-703.1. This Annual Application will allow them to receive ballots for the entire calendar year for any elections in which they are qualified to participate, including party primaries. Not only should eligible voters be informed of this Application by civic groups, registrars, and electoral boards, but the State Board of Elections should adopt a regulation requiring the Department of Elections to mail information about the Annual Absentee Application, every year, to all who voted absentee the previous year because they were ill or disabled (2A voters).

[2] Photo IDs should be obtainable only in the Registrar's Office where the voter is located

The photo identification should only be issued by the Registrar's Office where the voter resides. This is because that Registrar's Office has access to the records for that voter, and that Registrar's Office is able to make changes to the voter's record prior to issuance of a photo identification.

While there are workarounds that can be done that would allow one Registrar's Office to take the photo and begin the process even if the voter resides in another locality, the voter's information should be reviewed by the office where the voter resides. This additional step, if there later appears to be an issue with the voter's form or other information, may hinder or delay the voter's receipt of an acceptable form of photo identification.

Again, thank you for this opportunity to provide comment.