July 19, 2024
U.S. Election Assistance Commission
633 3rd Street NW, Suite 200
Washington, DC 20001
Re: Document Number: 2024-13811
Request for Comment: Accessible Digital Form Filler Tool for the National Mail Voter Registration Form
The National Federation of the Blind, the transformative advocacy organization of blind people in the United States, appreciates the U.S. Election Assistance Commission reaching out and allowing us to provide comments to the Accessible Digital Form Filler Tool for the National Mail Voter Registration Form. Section 504 of the Rehabilitation Act of 1973 (“the Rehab Act”) and Title II of the Americans with Disabilities Act of 1990 (“The ADA”) prohibit discrimination on the basis of disability in services, programs, and activities provided by state and local government entities. This requirement extends to registering to vote both privately and independently.
Paper voter registration and absentee ballot request forms are inaccessible to blind voters. Due to the inherent inaccessibility of paper forms, blind and low-vision voters must complete these forms with assistance. Voters with print disabilities in jurisdictions that do not provide an accessible way to mark and return their voter registration form must sacrifice their independence and ask a sighted person and trust that person to mark the voter registration form as instructed. In addition, many online versions of these forms are inaccessible with screen-access technology. A 2015 report by the American Civil Liberties Union found that in 2014, only one state had an online voter registration form that was fully accessible. i Additionally, a 2020 audit of online absentee ballot request forms by Deque Systems found that forty-three states had forms that were not fully accessible.2ii Blind and low-vision voters have also expressed their frustration with having to print and sign the marked voter registration form. Many blind and low-vision voters have little reason to own a printer. Requiring a signature and the use of a printer creates a barrier, as non-electronic signatures are inaccessible for people with print disabilities. This same concept applies as the paper form must be addressed and mailed.
The National Federation of the Blind tested the accessibility of the accessible digital form filler tool. While we found the form to be accessible, the pdf that was generated is inaccessible. Specifically, the first page of the pdf lacks the required accessibility tags. This lack of accessibility inhibits the ability of a blind voter to verify their registration form.
We urge the U.S. Election Assistance Commission’s Accessible Digital Form Filler for the National Mail Voter Registration Form be provided in an accessible way for blind and low-vision voters to register to vote. Voter registration materials must be accessible for blind and low-vision individuals including the entire process of requesting, filling out, signing, verifying, and returning. Offering an accessible electronic voter registration process can provide blind and low-vision voters with an equal opportunity to privately and independently register to vote at home using a computer and their own access technology.
If the National Federation of the Blind can be of assistance in any way, especially by utilizing the nonvisual access to voting best practices and innovations we have developed over the past decades, please do not hesitate to contact us.
Sincerely,
Mark A. Riccobono, President
National Federation of the Blind
i American Civil Liberties Union. “Access Denied: Barriers to Online Voter Registration for Citizens with Disabilities.” January, 2015. Access Denied: Barriers to Online Voter Registration for Citizens with Disabilities PDF
ii Deque Systems. “Digital Accessibility in 2020 Election: Progress, But a Long Way to Go.” November 24, 2020. Deque Systems. “Digital Accessibility in 2020 Election: Progress, But a Long Way to Go.”