Comment Opposing Changes to the Federal Post Card Application and Changes to the Federal Write-In Absentee Ballot

Less than ninety days before a federal election, the Department of Defense (DOD) proposed amendments to the Federal Post Card Application (FPCA) and the Federal Write-In Absentee Ballot (FWAB), which were subsequently, and unlawfully, implemented by the Federal Voting Assistance Program (FVAP). Specifically, the Proposed Final Rules eliminate the following category from both the FPCA and FWAB: “I am a US citizen living outside the country, I have never lived in the United States.” As CLC's comment explains, the removal of this category is both substantively deficient under the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), will lead to voter confusion regarding who is eligible to vote in federal elections, and violates the Paperwork Reduction Act and Administrative Procedure Act.