I recommend NOT to adopt the proposed regulations for the following reasons:

Our Officers of Election have one and only one important function on Election Day.  Conduct the Election by helping and qualifying voters to exercise their right to vote. 

Section B of the Proposal - Under the AG opinion in 24.2 - 604 this may only be done with written permission of the appropriate Electoral Board.  Before Election Day may work, but not on Election Day. 

Section C of the Proposal - What is practical?  These people assessing the polling place could just show up without any prior notification.  General Registrars are extremely busy trying to help their voters exercise their right to vote and get ready to conduct the election.

Sections D & E - Taking measurements and videos and photos will absolutely be disruptive on Election Day for our Officers of Election and our voters.

Section G - Our Officers of Election have enough to do to conduct the Election on Election Day.  Again it comes back to their one and only important function.  They do not have the time to faciliate the work of these accessibility observers.       

Let the General Assembly take up this issue and make this part of Virginia Election Law.

Thank you.