League of Women Voters Comments on Proposed Voter ID Rules



Raleigh, NC, July 11, 2019 – “The League of Women Voters of Wake County has long been concerned about the impact of requiring voters to present a photo ID in order to vote. Studies have shown that more than 200,000 registered voters in North Carolina do not have a form of ID that would be acceptable for voting. We urge the NC Board Elections to adopt rules that enumerate which IDs are acceptable, list the types of reasonable impediments, protect the privacy of IDs, and provide thorough and widespread education and training of voters and election officials,” states Marian Lewin. Voter Services Director for the League of Women Voters of Wake County.

  • Enumerate Which IDs Are Acceptable. We urge the NC State Board of Elections to enumerate the forms of photo IDs that are acceptable. At a minimum, we encourage the Board to include in the rules the list of acceptable IDs enumerated in SB 824, as well as any other forms the Board will find acceptable. In addition, we urge the Board to publicize widely the types of acceptable photo IDs, e.g., via public voter education forums, mailings, and on the county and state BOE websites. We also urge the Board to ensure that election workers are provided extensive training on the types of photo IDs that are acceptable. We are concerned that, without such clarity, public education, and training of election officials on the forms of acceptable photo IDs, confusion and long lines will prevail, resulting in voters becoming discouraged and not exercising their right to vote.

  • Specify Reasonable Impediments. We urge the Board to specify in these rules what constitutes a reasonable impediment. The rule governing reasonable impediments should be clear, straightforward, and widely understood by voters and election workers alike. We urge that the rules be clarified to specify the process for invoking a reasonable impediment and the steps that need to be taken. The process should be as streamlined as possible. At a minimum, we urge the Board to include in the rules the actual categories that will be included on the Reasonable Impediments Declaration Form checkboxes. Without such advance information, we are concerned that confusion during elections will prevail. We urge the Board to ensure that the rules governing reasonable impediments are clearly publicized to voters and to election officials, ensuring that all are aware of the delineated reasonable impediments.

  • Protect Privacy of IDs. The League is concerned about the privacy of IDs being sent through mail, sifted through at County Boards of Elections, copied, and, in the case of originals, returned again through the mail. For privacy concerns and to protect against identify theft, we believe it is critically important to maintain the confidentiality of the IDs within the County Boards. We urge stringent rules for County Boards’ handling of voter IDs, and ensuring that voter IDs are not public records, may not be shared or released, and must be maintained in a secure fashion from the time of receipt. We also urge the Board to educate the public that copies of IDs, not originals, be submitted to the Board. If a voter does not have the ability to make a copy of an original, the Board should urge that voter to utilize the reasonable impediment option instead. We are also concerned about public access to signatures. Although we recognize that signatures are prohibited from being copied, protections must be in place to prevent copying, e.g, via omnipresent cameras on cellphones, to protect potential identity theft and financial fraud.

  • Clarify Submission of Voter ID with Vote by Mail Ballots. If a voter fails to include an acceptable form of ID with the absentee ballot request form, the proposed rules provide that the Board must provide the voter with options, including “Attach[ing] to the absentee ballot container-return envelope the documentation necessary to comply with the identification requirements….” We urge the Board to suggest safer methods for including the ID. Attaching an ID to the outside of an envelope could create various potential risks to the voter, including privacy, voter fraud, ID theft, and financial fraud.

  • Voters Must Be Educated. Voter education on these new rules will be critical to avoid confusion, long lines, and ultimately disenfranchising voters who become frustrated with the process. We urge the Board to educate voters via educational forums throughout the state; provide mailings to voters; and post clear explanations on both the state Board and county Board websites. We also urge the Board and County Boards to work in close cooperation with voter groups in the state, e.g., the League, to educate voters.

  • Election Officials Must Be Educated and Additional Poll Workers Should be Hired. To avoid confusion, long lines, and frustration of voters as has occurred in other states that have implemented photo ID laws, election officials must be thoroughly trained on the new rules, particularly forms of photo IDs, what constitutes a reasonable impediment, and handling of provisional ballots. Election officials should be specifically trained on the proposed rule’s standard of review “most favorable to voter”. We also urge that the Board hire additional poll workers to handle implementation of the new rules, at least during the first two elections following implementation of the photo ID rules.

  • Rules and Education Translated into Other Languages. We urge the Board to include in the rules that all public-facing materials be translated into other languages, including, but not limited to Spanish.

  • Technical Correction on Provisional Ballots. There appears to be a contradiction in the proposed rule 08 NCAC 10B .0103 VOTING PROCEDURES as to who may vote a provisional ballot. In (d), last sentence following enumerated paragraph (5), line 9 on p. 2 of 3, the proposed rules states “No person shall be denied an option to vote a provisional ballot.” However, in (d), lines 35-37, p. 1 of 3, the proposed rule provides the judge the ability to make a determination as to whether a voter may cast a provisional ballot: “Based on information provided by the person the responsible judge shall determine whether or not the person may be eligible to vote.” We urge the Board to adopt the standard on p. 2 of 3, in favor of the voter.

League of Women Voters of Wake County President Dianna Wynn states that “the League remains concerned about the implementation of the voter ID law. We urge the Board to ensure that precinct workers and election officials are given adequate and timely guidance on the new rules. Following the elections in 2020, we hope the Board will evaluate and fine tune the process, as necessary, and report to the public on how the new voter ID law was implemented.”


Media Contacts:

Dianna Wynn, President

League of Women Voters of Wake County

919-271-4455 or lwvwakepresident@gmail.com


Marian Lewin, Voter Services Director

League of Women Voters of Wake County