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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7/30/15  11:21 am
Commenter: Keith Damon, VA Republican State Central Committee 11th CD

Opposed to Changes to Voter Registration Form and Regulation
 

I am opposed to the proposed changes to the voter registration form and the revised Regulation interpreting the new form.  The implications of these changes were apparently not considered and create problems where none exist with the current form.  This suggests a political motivation for proposing these changes – “make it easier for people to vote” – without any consideration of either the legal (Code of Virginia and Virginia Constitution) requirements for voter registration or the practical administrative problems that would be created. 

 

The new form indicates that the checkboxes for U.S. citizenship, felony convictions and mental competency are required input yet the revised Regulation regards them as non-material omissions since the checkbox information is included in a revised affirmation statement to be signed by the applicant.  This “required vs. non-material omission” dichotomy is at best sloppy staff work but declaring them to be non-material omissions is counter to the Code and the Virginia Constitution requirements and eliminates significant safeguards against fraudulent registration.  A positive statement of citizenship, felony convictions and competency forces the applicant to address these issues.  If the applicant is found to be lying, there are firm grounds for prosecution.  Merely signing a revised (and usually unread) affirmation statement covering these issues is NOT a valid substitute and virtually eliminates any opportunity for prosecution of fraudulent applications.

 

Gender is to become a non-material omission.  Why is an indication of gender a burden on the applicant?  Names are not gender-specific and having knowledge of the gender is invaluable to Election Officers checking in voters on Election Day.  This appears to be more of a political-correctness change than a needed change.

 

The proposed handling to an applicant’s middle name and his social security number are not sensible or practical.  Both of these data items are important in identifying an individual voter.

 

Numerous General Registrars have noted here in the Town Hall that the new form is of a different size than the existing form and thus the original forms cannot be filed in existing filing cabinets.  This is again sloppy staff work to be unaware of this practical problem.  Of course, scanning of applications could potential eliminate this size problem but apparently not all jurisdictions have scanning capabilities.  Further, even with scanning is it good practice to discard the original documents?

 

The proposed changes to the voter registration form and the revised Regulation do not make sense.

CommentID: 41047