[1] There is a section on material omissions on petitions (20-50-20(A)) and a section on material omissions on petition signatures (20-50-20(C)). However, paragraph (D) combines nonmaterial omissions on petitions and petition signatures. Should these be in separate paragraphs to mirror paragraphs (A) and (C)? As it is written now, the nonmaterial omissions for petitions and petition signatures are grouped together.

[2] What if ditto marks, e.g., " ", are used instead of writing out the information? In particular, this occurs frequently in the address block, so what effect would ditto marks have on paragraph (C)(4)?

[3] Re: paragraph (D)(6) (and possibly other parts of the proposed rule), what if the person placing his/her name on the petition only writes his/her name in what would appear to be print, and not cursive? And what if it's on only one of the lines (especially the printed name line)? If it is an issue for the State Board of Elections, I am concerned about how to implement that because a "signature" is in the eye of the beholder, or signer, and one person's printing is someone else's cursive. The importance of resolving this issue is especially demonstrated by the fact that a party complaint in last year's election discussed whether petition signatures were truly "signatures," and I believe case law from other states was cited that a signature had to be in cursive. What is the standard in Virginia? This may need to be established.

[4] I suggest rewording the requirements in paragraph (E) as material omissions and placing them in paragraph (C). This would make the material omissions more straightforward and gather them together in one section.

[5] I am profoundly and deeply concerned about requiring voters to put their street type (as required in paragraph (E)(3) on the petition. This is unnecessary if we have the voter's name, house number, and street name. The street type is not necessary to qualify a voter as having properly signed the petition. Having this requirement is an overly burdensome and unnecessary requirement, and it will lead to disputes that needn't exist in the first place.

Concerns with 1 VAC 20-60-20, as amended, are as follows:

[1] In paragraph (B)(4), have the courts resolved the issue of being a legal resident of VIrginia in order to circulate petitions? I thought that they had decided that is not a constitutional requirement. Perhaps this is still up for appellate review.

[2] I have the same concerns about the voter printing his/her name as I discussed in the comments for proposed 1 VAC 20-50-20. I renew those same concerns with regard to 20-60-20, in particular, but not limited to, proposed paragraph (D)(4).

[3] With regard to paragraph (E), I have the same concern as I raised for proposed 20-50-20(E), namely that it should be reworked and placed with the other material omissions.