The undersigned are a collection of good-government, disability rights, civil rights, and voting rights groups that work to protect the right of every eligible American to vote. We
write now urging you to immediately withdraw your letters addressed to the chief elections officers in Kansas, Georgia, and Alabama permitting changes to the federal voter registration
form and to ensure that the instructions on the form reflect governing law and policy prohibiting the requirement of documentary proof-of-citizenship with the form.
Such changes – which unlawfully permit a handful of states to require documentary proof of citizenship in addition to the sworn attestation under penalty of perjury – run afoul of
present Election Assistance Commission (EAC) policy and procedure and are inconsistent with recent court cases. The EAC has previously addressed this very matter and declined to
make the change on documentary proof that you recently authorized. EAC Vice-Chair Thomas Hicks, one of the Commissioners to whom you report, has deemed your recent
communication a “unilateral” move amounting to a “material” change.i Any material change must be adopted by a quorum of the Commissioners after notice and public comment, as
required by the Administrative Procedures Act, the Help America Vote Act, and the National Voter Registration Act. That has not occurred here.