Reject proposed changes to voter registration form and regulation / guidance for registrars

I am opposed to the proposed changes to the voter registration form and the revised Regulation interpreting the new form.  These changes create problems that do not exist with the current form.  Legal and constitutional requirements for voter registration should always supercede political considerations. It is by no means apparent that ensuring unique, qualified, legal voter registrations was a paramount concern in suggesting these changes.

Examining the proposed changes raises the possibility that political motivations and concerns are overriding good government practices in no less than four areas, identified below.

QUALIFICATION AFFIRMATIONS - The new form indicates that the checkboxes concerning U.S. citizenship, felony convictions, and mental competency must be completed yet the revised Regulation instructs that they be treated as non-material omissions if left incomplete. This is contrary to the Code of Virginia and Virginia Constitutional requirements. A positive statement of citizenship, competency, and absence of felony convictions (or that rights have been restored) forces the applicant to address these issues individually.  If the applicant is found to be untruthful, there are firm grounds for prosecution.  Signing a revised, general affirmation statement covering these issues is not a valid substitute for specifically affirming an applicant’s status in these areas. It virtually eliminates any opportunity for prosecution of fraudulent applications.

SEX / GENDER - The new form makes marking one’s sex as male or female optional (another non-material omission).  What burden is created by requiring the applicant to state a sex?  Knowledge of the voter’s sex is useful to Election Officers checking in voters on Election Day, especially as names are not a reliable indication of whether a person is male or female and sex can distinguish a person from a neighbor of the same name.

SSN & MIDDLE NAME - The new regulation creates confusion about whether these elements are required, although they can be quite important in identifying an individual voter.  

PRACTICAL CONSIDERATIONS - General Registrars have noted that the new form is of a different size than the existing form, necessitating a change to filing methods. Further, the new form may lead to an increase in fraudulent registrations / registrations that are inconsistent with legal requirements in the Commonwealth of Virginia.  

The proposed changes to the voter registration form and the revised Regulation are unnecessary, do not promote the public interest, and should not proceed.