I suggest reviewing 1 VAC 20-60-20 to ensure that the material and nonmaterial omissions rules are comparable to those for candidate petitions. In particular, 20-60-20(E)(2) may need to be changed so that the procedures in 20-60-20 are similar to those governing candidate petitions.
Also, there should be a section in 20-60-20 that clearly states that the provisions of 20-60-20 are subordinate to more particular provisions in city, town, and county charters that pertain to referendum petitions.