Comment on changes to voter registration and ballot forms for overseas and military voters

The Department of Defense (DOD) has changed two forms that military members and Americans living abroad use to register and vote. The changes would make it harder for local election officials to process the forms and send voters the correct ballots. Public Rights Project filed a comment in opposition.

DOD made the changes to the Federal Post Card Application (FPCA) and the Federal Write-in Absentee Ballot (FWAB) without giving public notice and without consulting local election officials who process these forms. The changes:

• Remove the option for U.S. citizens living abroad to indicate they’ve never lived in the U.S.
• Require voters to confirm they’ve read their state’s instructions without telling voters where to find them.
• List a U.S. passport as an identification option, even though election officials can’t verify passports and federal law doesn’t require one to register to vote.

Local election officials, not DOD, receive and process these forms. They decide whether someone is eligible, where they should be registered, and which ballot they should receive. Our comment explains how the changes are burdensome:

• Citizens who have never lived in the U.S. can no longer describe themselves accurately. Without this information, election officials will spend more time on follow-up correspondence, rejected applications, and calls from confused voters.
• The state instruction requirement could confuse voters and add to the workload of election officials who are already stretched thin. DOD provides no practical reason for the requirement.
• The passport option asks for information that officials can’t verify. It also adds confusion for election officials trying to implement ID requirements under the Help America Vote Act (HAVA), which does not account for passports.
• DOD offers no estimate of the time and resources these changes will cost election officials.

DOD didn’t follow the process the law requires to make these changes, and the forms only work when they give election officials the information they need to register eligible voters and send them the right ballot. The revisions do the opposite, and we urge DOD to withdraw them.

Read the comment.