Virginia Institute Action opposes SB196 - General registrars, instead of the courts, are best positioned to oversee this challenge process, since they are responsible by Virginia code to keep current and accurate voter registration lists. Additionally, this bill establishes new restrictions and changes to the challenge process that are not needed. We ask you to please oppose SB196.

Rather disappointed that I signed up to speak and they completely did not allow any comments from the public. SB196 (Oppose): The general public has a right and a duty under the constitution, and expressed in HAVA and NVRA, to be fully engaged in the elections process, and that includes their right to oversee, verify and validate voter rolls. - Removes the ability for voters to address issues with their registrar. (They are forced to go through 3 person court challenge) - Removes the ability to use public documents such as obituaries, etc. - As VA also does not release information to the public that has unique identifying information about individuals on it, there is no method by which a member of the general public could have the necessary documentation to use to challenge a voter. This law effectively cuts the public out of the process to verify and validate voter rolls. This is a depravation of the public right under color of law. - Is overly proscriptive as to how the courts (a seperate constitutional body) shall adjudicate any potential challenges. SB577 (Oppose): Why do we need special treatments and carve outs for this? I do not see a justification for this set of exemptions. SB606 (Oppose): While the concept of ERIC is not altogether objectionable, the ERIC organization has shown itself to repeatedly act in violation of its charter and in violation of VA disclosure laws. (a) While VA was a member, ERIC routinely provided PII information on VA citizens that it received from the state Health, DMV, and ELECT offices to left wing organizations in violation of VA privacy laws and in violation of their charter and ethical responsibilities to not have political bias. (b) ERIC was failing miserably to execute on its core mission: to find duplicate or errant records and help clean up state voter rolls. Instead ERIC focuses almost exclusively on identifying "Eligible but Unregistered" voters and aggressively pursuing them to register. Ask Susan Beales how many errant records were identified and removed via ERIC ... the answer is shocking small considering the money and support they are provided. (c) Multiple member states (including VA) attempted to address and correct these issues, and were unable to do so. That formed the justification for Susan Beales decision to withdraw from ERIC.

The League of Women Voters supports methods to improve the accuracy of Virginia’s voter list and to avoid improper disenfranchisement of valid voters. SB 196 would achieve this purpose. Registrars should not be in a position to hear challenges to a voter’s registration lodged by three other voters and the bill removes that authority. We urge the Committee to report this bill.

SB196 will not improve Virginia’s voter list maintenance activities and will not help rebuild public confidence in our elections. This bill prevents the general registrars from maintaining a complete and accurate registered voter list. Maintaining a complete and accurate RVL is required and is an essential part of the process to ensure elections are safeguarded, fair and legitimate. There is concern that the registered voter list (RVL) is not accurate. Holtzman Vogel’s pre-litigation notice analysis dated August 8, 2023 indicates that 101 Virginia counties and cities are in violation of Section 8 of the NVRA and ELECT’s response to the pre-litigation notice is not reassuring. Large amounts of documentation submitted to the general registrars to correct the RVL are also alarming and indicates an inaccurate RVL. Challenges should be allowed to the general registrar who is responsible for maintaining an accurate registered voter list. Bypassing the general registrar and requiring a petition to the Circuit Court is unnecessary and a waste of the court’s time. We should be asking why Virginia’s RVL is not accurate and taking action to ensure that it is accurate. This bill restricts the reconciliation with other states’ voter data to ensure the accuracy of the registered voter list, and it could permit the duplication of registration in more than one state. SB196 restricts ELECT’s ability to reconcile with the states that do not use the full social security number. Many states only use the last 4 digits of the registered voters’ security number, which is not a unique identifier. ELECT does not verify or reconcile that the registered voters’ social security number matches the name and date of birth with the Social Security Administration, which is extremely important to ensure only one person is registered to vote and to verify the accuracy of the information on the application. An accurate registered voter list cannot be maintained without this verification and reconciliation. This bill requires ELECT to utilize full social security numbers or reliably linked data fields to match records when ELECT does not know if their registered voter information is correct. Using reliably linked data fields and leaving no room for other documentation will create an inaccurate registered voter list. The general registrars should not cancel registered voters based on the documentation they receive. They should review the documentation and send confirmation letter(s) to the registered voter as needed. If the registered voter does not respond to the confirmation, they will be put in inactive status. They can still vote while inactive. Voting, updating or confirming their information will change them to active. If no action is taken after 2 general federal elections, the registered voter is canceled. If you really want to improve list maintenance, please have ELECT reconcile the RVL immediately with the SSA or the DMV to make sure the social security number is valid and the name and date of birth match the social security number. Please also take action to have ELECT resolve registered voters who have duplicate social security numbers or no social security number listed. Please oppose SB196. Stronger internal controls are needed in list maintenance but SB196, as written, will create more inaccuracies in the registered voter list.