This comment is submitted on behalf of Advancement Project, a national, non-partisan, non-profit racial justice organization that advocates on behalf of voters of color.

Advancement Project agrees with other commenters who noted that the proposed changes are unnecessary.   The omission of a generational suffix and a street identifier are both inconsequential and may result in the rejection of an otherwise valid absentee ballot.  In light of the existence of a list of voters who have requested absentee ballots against which a returned ballot can be matched, and a VERIS generated label with the voter’s name and address affixed to the return envelope, these two errors on the handwritten envelope are not material.

Advancement Project notes that the proposed regulation would create two different classes of voters.  Voters who are registered with a generational suffix, but do not live in a household with voters of the same name, would not risk having their ballot rejected if they omit the suffix.  Other voters who registered with a generational suffix who do live in a household with voters of the same name would risk being disenfranchised because of the same omission.  

Similarly, homeless voters, as permitted by Virginia law, may have registered using the address of a shelter, a church, an agency, or an address used in the last sixty (60) days.  Thus, homeless voters are more likely to inadvertently omit the street identifier or record it incorrectly because they may be less familiar with the purportedly correct street identifier. 

Because the electoral board has other methods to verify the identity of the voter who submitted the absentee ballot, the risk of disenfranchisement outweighs any need either for the generational suffix or the street identifier. The proposed changes would condition the counting of absentee ballots on arbitrary standards that unduly risk disenfranchising voters. Advancement Project urges the Board not to adopt the proposed language regarding generational suffixes and street identifiers.