SUPPORTING STATEMENT
A. JUSTIFICATION
1. Need for the Information Collection
The Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), 42 U.S.C. 1973ff, requires the Presidential designee (Secretary of Defense) to prescribe an official post card form, containing both an absentee voter registration application and an absentee ballot application, for use by the States to permit absent uniformed services voters and overseas voters to participate in general, special, primary and runoff elections for Federal office. The authority for the States to collect personal information comes from UOCAVA. The burden for collecting this information resides in the States. The Federal government does not collect nor retain any personal information associated with this form.
2. Use of the Information
The collected information will be used by State and local election officials in determining the eligibility of the uniformed services and overseas citizens who submitted the information as a request to register to vote or request an absentee ballot in that jurisdiction. Additionally, the collected information will be retained by the State and local election officials to provide election materials, including absentee ballots, to the uniformed services, their eligible family members and overseas voters during the form’s eligibility period provided by state law. No information from the Federal Post Card Application is collected by or retained by the Federal government.
3. Use of Information Technology
The Federal Post Card Application requires that the submitter sign the form prior to sending to the State or local election official. This signature is used by State and local election officials to verify the voter’s signature on subsequent voted ballots and other election materials. There is no provision for State and local election officials to use digital signatures as a substitute for the handwritten signature.
4. Non-duplication
The applicant is required to update and resubmit this information annually or as required by State law.
6. Less Frequent Collection
The applicant is required to update and resubmit this information annually, whenever they change their mailing address or as otherwise required by state law. If the information is not submitted annually or whenever they change their mailing address, the applicant may not receive ballots for elections for Federal office in that calendar year.
7. Paperwork Reduction Act Guidelines
This collection is consistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
a. On Monday, April 1, 2013, the Federal Register notice for the redesign of the Federal Post Card Application was published. It can be found on pages 19466 and 19467. Public comments were collected through Friday, May 31, 2013.
The majority of comments received regarded form usability. Of those, most liked the form as is and did not require any action. Some commenters asked for an online fillable form which is currently available along with an automated form completion assistant at the FVAP.gov website. These tools will be updated based on the final OMB approved Federal Post Card Application. Other comments unrelated to the form did not require changes.
The second largest grouping of comments came in asking for additional space on the form to help legibility of handwriting and the voter’s signature. As requested, FVAP added space to the signature area, lengthened the signature line, and increased font size for the affirmation. Block 4 of the form was restructured allowing more space for driver’s license number and the email address area in Block 5 was increased.
Comments requesting clarification of the Instructions section were all accepted and modifications made. A summary of comment topic groupings and actions taken, as well as every comment received and its corresponding comment ID can be found as two supplemental documents as part of the submission.
On Thursday, June 13, 2013, the 30 Day Federal Register notice for the redesign of the Federal Post Card Application was published. It can be found on pages 35605 -35606. Public comments were collected through Monday, July 15, 2013.
Compared to the 60 Day Federal Register comment period, the number of comments received was minimal and did not require changes to the form. The largest number of comments, three, requested formatting changes. The Affirmation section of the form was modified following the 60 Day comment period. The signature line was lengthened and space was added to the signature area. The size of this Block cannot be further expanded without removing space from another Block. Other requests such as updating our online resources do not affect the form.
The comment received requesting that we change the name of the form was discounted because Federal legislation requires FVAP to develop a Postcard Application.
b. The Services, Department of State and GSA were approached regarding the availability of requested information. The FVAP Post Election Survey and Election Assistance Commission surveys help identify the frequency of collection. FVAP stakeholders from overseas citizen groups and State and local election offices were contacted for original feedback on the 2011 Federal Postcard Application. Additionally, stakeholders were made aware that the form is available for usability testing during the Federal Register process. More information will be added after that time.
The intent to return language on the FPCA remains on the form due to the October 2008 National Association Secretaries of State (NASS) Survey of State Statues that shows the majority of States have intent as a prerequisite for obtaining a State ballot.
10. Confidentiality
The information is collected and retained by the individual States, counties and municipalities and is not in the possession of the Federal government.
11. Sensitive Questions
The respondent’s complete or partial Social Security Number is required to meet State voter registration requirements. Some States request, but do not require, the respondent to provide information regarding their race or ethnicity. This information is used by those States to provide information to the Department of Justice to comply with the Voting Rights Act, 42 U.S.C. §§ 1973 to 1973aa-6, or to determine the respondent’s eligibility to vote in some special elections.
12. Respondent Burden, and its Labor Costs
a. Estimation of Respondent Burden
Based on the number of ballots cast in the 2008 Presidential general election (as reported by the Election Assistance Commission) by UOCAVA voters, it is estimated that 1,200,000 citizens will use this form annually. It is estimated that the respondent will require 15 minutes to complete the form. Post election information from the 2012 Presidential general election is not yet available.
b. Labor Cost of Respondent Burden
The estimated burden cost is $6,381,000. The burden cost is estimated based on 1,200,000 individuals completing the form in 15 minutes at an hourly rate of $21.27. The hourly rate is the average hourly wage or salary rate for the American worker as published by the Department of Labor in their document, USDL-12-1124.
13. Respondent Costs Other Than Burden Hour Costs
14. Cost to the Federal Government
The information is not collected and processed by the Federal government. The cost of collecting and processing the information is borne by the individual State and local election offices as part of providing voter registration and election services to citizens claiming their state as legal residence.
15. Reasons for Change in Burden
Since the inception of this form in 1956, the form has not required OMB review under the Paperwork Reduction Act. Therefore, this existing collection of information, by State and local governments (not the Federal government) has been without an OMB Control Number and without identifying an annualized cost to the respondents.
16. Publication of Results
The information collection will not be published for statistical use, outline plans for tabulation, statistical analyses, and publication.
17. Non-Display of OMB Expiration Date
We are requesting approval to omit the expiration date. These forms are stocked by Federal and non-government agencies for distribution to and use by uniformed services, their eligible family members and overseas voters. If the form contains the OMB expiration date, voters may believe they will continue to receive absentee ballots beyond what is allowed by State law. This confusion would disenfranchise citizens.
Additionally, requiring the form to be revised and reissued on a triennial basis would incur unnecessary expense to agencies in cases where the previous versions of the form meet the requirements of UOCAVA. Further, information found on the form is still often accepted by States since all necessary information for voter registration or ballot request is provided. Voters who may only have access to an “expired” form may not realize they could use the form for State voter registration and ballot request purposes and be disenfranchised.
18. Exceptions to "Certification for Paperwork Reduction Submissions"
No exceptions to the Certification for Paperwork Reduction Submissions exist.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.
| File Type | application/msword |
| Author | Patricia Toppings |
| Last Modified By | Fred Licari |
| File Modified | 2013-08-08 |
| File Created | 2013-08-08 |