II. Comments on the test of the law

C. Some specific comments on the concrete articles on the new law on referendum.

4. Administration of referendums.

The Law grants the right to propose candidates for membership on TCs and PCs to the chairpersons of the regional councils and executive committees of the local councils or mayors. If those local authorities do not nominate commission members, then members are nominated by the head of the state Administration, who is appointed by the President. It is unclear from the law how candidates suggested by the nominating entities will be selected by the CEC or TCs. The procedure is not only extremely complex; it creates a risk of excluding from the membership in different referendum commissions  representatives of different political forces and civil society.