30 Day- Supporting Statement A - National Mail Voter Registration Application

Supporting Statement A:

U.S. Election Assistance Commission

National Mail Voter Registration Form

A. Justification

1. Explain the circumstances that make the collection of information necessary.

Section 6 of the National Voter Registration Act of 1993 (“NVRA”) required the Federal Election Commission (“FEC”) to provide states with a National Mail Voter Registration Form. Section 802 of the Help America Vote Act of 2002 (‘‘HAVA’’) transferred the FEC’s responsibilities (including statutory authority regarding regulations) to the U.S. Election Assistance Commission (“EAC”). The primary use of this application is for U.S. citizens to register to vote, to update registration information due to a change of name, make a change of address or to register with a political party by returning the form to their state election office. The EAC makes this form available for 3^rd party use and does not collect any information.

The proposed form is necessary for the EAC to fulfill its mail registration duties as outlined in Section 6 of the NVRA.

2. Indicate how, by whom, and for what purpose the information is to be used.

The National Mail Voter Registration Form will be made available to U.S. citizens on the EAC website at https://www.eac.gov/voters/national-mail-voter-registration-form. The downloadable form is available in 20 languages, including English, and intends to increase the availability of opportunities to register to vote. It provides the user of the form with state-specific instructions on how to complete the form, provide their signature and send to their respective state by postal mail.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

The EAC has made the National Mail Voter Registration Form available for download on its website. It is a fillable PDF which can be completed online, and then printed out. In addition, the form can also be printed out and then completed by hand.

4. Describe efforts to identify duplication.

One of the responsibilities transferred to the EAC under Section 802 of HAVA is the development and maintenance of the Federal voter registration form. The EAC is therefore the only entity that develops and maintains the Federal voter registration form.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This form does not have an anticipated impact on small businesses or other small entities. When creating the form, effort was made to only request the minimum amount of necessary information in order to register a voter.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the EAC does not provide this form for states’ use, it may be unable to comply with its statutory requirements under HAVA (52 U.S.C. 21131) and NVRA (52 U.S.C. 20508).

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

There are no special circumstances applicable to this form.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside DOE.

The Federal Register notice (86 FR 51347) announcing the 60 Day Public Comment period was published on September 15, 2021. Public comments were accepted until November 12, 2021. No comments were submitted during the 60 day period.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

The EAC does not provide any payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

The potential number of respondents is approximately 2,500,000. The frequency of a response is 1.0 (once, annually). The annual hour burden would be 291,667 hours.

This burden was estimated by taking the total number of registrations forms submitted by mail, fax, email, or registration drives in the country over the two-year period covered by the EAVS Report that is submitted to Congress (approximately 15 million), and dividing that number by 2 to get the annual amount of registrations (approximately 7.5 million). Once the annual number of registrations was determined, it was then estimated that approximately 1/3 of those registrations were completed using the NVRA form. The final number arrived at for the annual number of responses was 2,500,000.

Subsequently, it was estimated that it takes approximately 7 minutes for a person to fill out a Federal voter registration form. This time was arrived at by estimating the amount of time it takes an individual, of various ability levels, to complete the Federal voter registration form. Taken into account was an individual’s completion of the form through various means, including via electronic means, by hand, through the use of a screen reader, etc.

Using 7 minutes as an estimate, which is 0.11666667 of an hour, it was calculated that the annual time burden is 1,166,667 hours.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.

There is no cost burden associated with this form as states would be required to process voter registration applications irrespective of the existence of the proposed EAC regulations.

14. Provide estimates of annualized cost to the Federal government.

The annualized cost to the Federal government is $8,267. The cost was calculated by taking the three-year average of translation costs between the years 2019 and 2021.

15. Explain the reasons for any program changes or adjustments reported in Items 13 (or 14) of OMB Form 83-I.

Not applicable.

16. For collections whose results will be published, outline the plans for tabulation and publication.

Not applicable.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.

Not applicable to this collection.

18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I.

1. The EAC does not request an exception to the certification of this form.

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