Connecticut RLA Working Group, 2nd Meeting

On Wednesday, the CT RLA (Risk Limiting Audit) Working Group held its second meeting and firmed up plans for the 2021 prototype audits. Below is a video of the meeting and an email I sent the Chair Gabe Rosenberg and the chief scientist from UConn, Alex Russell.

Watch here:
https://www.youtube.com/channel/UCzakPMlj0LigvokDrkgiDVw/live

I have watched both meetings of the RLA Working Group and have several Suggestions and comments…

On Wednesday, the CT RLA (Risk Limiting Audit) Working Group held its second meeting and firmed up plans for the 2021 prototype audits. Below is a video of the meeting and an email I sent the Chair Gabe Rosenburg and the chief scientist from UConn, Alex Russell.

Watch here:
https://www.youtube.com/channel/UCzakPMlj0LigvokDrkgiDVw/live

****************************************************

Gabe, Alex,

I have watched both meetings of the RLA Working Group and have several Suggestions and comments.

As you may or may not know, I have been involved in post-election audits and audit laws in CT and nationally since 2007. Since 2009 I have been involved in what become known as RLAs. I was a catalyst in causing a meeting in early 2010 in D.C. and in securing invitations to three officials from CT who attended. After that meeting, they took the lead in initiating what became the UConn Audit Station. I was involved in the planning of the Colorado RLAs and planning, executing, and reporting on the Rhode Island RLA pilot. I was an observer at the Fairfax City RLA demonstration, which I used as a basis to suggest improvements for the RI pilot.

  • I complement all involved on the successful development of the UConn Audit Station. And the significant improvements in it in the last couple of years. It can save CT hundreds of thousands in an RLA.  Note: That all the experts recommended a Ballot Comparison Audit for RI, yet due to the extreme cost of ES&S central count scanners, the RI Board of Elections chose Batch Comparison Audits.
  • QR codes: The use of QR codes on ballots (mainly on printed ballot marking device ballots) has raised huge integrity and transparency concerns. The concern is that they are not human readable/verifiable for auditing. I would suggest a)the QR code labels also included printed sequence numbers etc. of what is in the QR code and b)the QR code be readable to show that same information by a standard smart phone QR code reader. I would also suggest you assume that QR codes do not need to be scanned in order, to facilitate multiple people/groups putting on stickers and that some stickers will be broken, misapplied, or otherwise discarded in the process.
  • Are you aware of the recent guidance for the U.S. DOJ that all election materials should be preserved for 22 months for Federal Elections. So things like CVRs, images, paper and computer records (Arlo records) must also be preserved?  Since this is not a Federal election the letter does not apply, yet it would be a good practice to do the same for 6 months for other elections as well.
    https://www.justice.gov/opa/press-release/file/1417796/download
  • I would have liked if ABs were included in the prototypes. Also note that there has been no recognition of the need to account for originally hand counted and EDR ballots in an actual RLA.
  • Two Transparency Requests: I hope you will consider giving at least a week’s notice of the date, time and place of any RLA prototypes, such that there is an opportunity for observers to attend. I would also suggest, like RI, live video stream(s) of the RLAs showing the whole space, so that the pubic can in that way observe the whole process and additional streams showing the details of ballot comparisons, ballot security, and data entry into Arlo (or other software).
  • Two Small Comments on the Slides: a) National experts have consistently said that there are three RLA methods, yet they include Batch Comparison Audits and view Full Recounts as a possible final round of all the other types of RLAs. b) I believe it is incorrect to state that “All previous pilots have considered single precincts”. As the person planning and leading the RI Batch Comparison Audit, I can state that it included multiple precincts. I also checked with my colleagues more involved in Colorado and they confirmed that Colorado pilots always included multiple precincts.
  • Going forward, a) I believe that the biggest challenge in conducting an RLA for CT is the town-by-town structure of elections. I would be a strong advocate for the idea of a small number of sites across the state for scanning with the Audit Station, with trained officials responsible for the Audit Station and guiding local officials in the rescanning process. b) Instead of QR stickers, perhaps a device or scanner could be acquired/developed to print QR codes on an appropriate place on ballots – stickering the whole state would be quite an expensive, time-consuming process.

Finally, while I am a supporter of RLAs, they are not a panacea, In my opinion, in many instances they have been oversold as easy and they are all that is necessary to prove that elections are OK. I am not aware of any state laws for RLAs that I or most would  consider good, even as far as they go.  Often they leave it to an official to choose contests to audit, leaving the suspicion that they made political decisions, where also they often choose uninteresting high margin contests to make the RLA easier. Similarly they often require the auditing of one or two contests, which says nothing about other contests. Doing Ballot Comparison RLAs has the advantage that with marginally more work all large contests can be audited (in CT, statewide and Congressional Races are most suited to RLAs).

RLAs are not well suited to municipal contests in CT, as your statistical table shows. RLAs do not provide much insight into errors. So, there is a place for the batch audits now done in CT. There is also a need for eligibility audits – are the checkoffs accurate? Are those checked actually qualified to vote? Are absentee ballots signed correctly, signatures accurately adjudicated? Etc. Especially in CT there is a need for audits of ballot security, which according to the experts are a prerequisite to trusted, useful RLAs.

Perhaps you would share this letter with the entire membership of the Working Group.

Thanks,

Luther Weeks
Executive Director, CTVotersCount and Connecticut Citizen Election Audit

September 2021 Audit Drawing

This year’s drawing was different. Based on the law passed this year it finally included centrally counted absentee ballots, an item we have been requesting since 2008. We thank Secretary Merrill for initiating the change this year. Better late than never!

This year’s drawing was different. Based on the law passed this year it finally included centrally counted absentee ballots, an item we have been requesting since 2008. We thank Secretary Merrill for initiating the change this year. Better late than never!

RLA Working Group holds its first meeting.

This spring there was a bill to initiate a Risk Limit Auditing Working Group. I testified in favor of the concept and suggested several changes to the bill. A similar bill was passed near the end of the session. Last week the group began its work. Here is a video of the meeting:
https://www.youtube.com/watch?v=UhH4JVYcaso

Here is the bill passed by the General Assembly: https://cga.ct.gov/2021/ACT/PA/PDF/2021PA-00002-R00SB-01202SS1-PA.PDF (The RLA section is on page 156.)

The meeting lasted about an hour, primarily consisting of an introduction to RLAs by Alexander Russell from UConn.  Assisted by Ben Fuller also from UConn.  Also in the group was Brian Macdonald, a statistician from Yale.

I am only familiar with the Chair Gabe Rosenburg, Alex Russel, and one of the registrars of voters in the group. There was no published agenda or list of members. The members were listed by the Chair at the beginning of the meeting. I could be wrong, yet as far as I know none of the members of the group have any experience observing or participating in RLAs. A far cry from RIs plan which included experienced experts from around the country and took much more time and effort that seems to be possible here…

This spring there was a bill to initiate a Risk Limit Auditing Working Group. I testified in favor of the concept and suggested several changes to the bill. A similar bill was passed near the end of the session. Last week the group began its work. Here is a video of the meeting:
https://www.youtube.com/watch?v=UhH4JVYcaso

Here is the bill passed by the General Assembly: https://cga.ct.gov/2021/ACT/PA/PDF/2021PA-00002-R00SB-01202SS1-PA.PDF (The RLA section is on page 156.)

The meeting lasted about an hour, primarily consisting of an introduction to RLAs by Alexander Russell from UConn.  Assisted by Ben Fuller also from UConn.  Also in the group was Brian Macdonald, a statistician from Yale.

I am only familiar with the Chair Gabe Rosenburg, Alex Russel, and one of the registrars of voters in the group. There was no published agenda or list of members. The members were listed by the Chair at the beginning of the meeting. I could be wrong, yet as far as I know none of the members of the group have any experience observing or participating in RLAs. A far cry from RIs plan which included experienced experts from around the country and took much more time and effort that seems to be possible for this Connecticut team (RI Study Report)

Russell’s slides were a reasonable introduction to RLAs. I found three things curious:

  • He listed three types of RLAs. One was full hand counts usually not listed and omitted from the list was the usually included Batch Comparison Audit.
  • He indicated that creating a ballot manifest requires a complete hand count of the number of ballots. That is usually not required, although very accurate it would be quite a task to hand could all the ballots in every town for a state-wide RLA.
  • His plan seems to be to rescan each ballot with the UConn Audit Station would additionally involve stickering each ballot with a QR Code. Once again usually not required, although very accurate quite a task stickering all the ballots in every town for a state-wide RLA.

With their next meeting to be scheduled for early October, they have a lot to accomplish.

Here is my testimony from last year, my concerns and suggestions still stand: (My Testimony)

Summary Recommendations:

  • Consider doing what CO, VA, RI and perhaps what every other state that has
    prototyped or implemented RLAs have done: Convene a team of election officials, and
    volunteer national experts to help plan a prototype, bring tested software (typically available
    at no cost) to the table to provide tested statistical calculations and public verifiability. And
    then report on the results and recommend methods and changes necessary in the law.
    Such a group could report to the Task Force such as the Rhode Island RLA Group reported
    to the RI Board of Elections.
  • Do not limit the prototype to 5 to 10 largely redundant municipal RLAs
  • Move the prototype(s) to the 1st half of 2022. That will give sufficient time to plan the
    prototype(s). It will provide more access to statistical experts and those with experience with
    RLAs to participate.
  •  Move the reporting deadline to Jan 2023 to provide more time to absorb the lessons of the
    prototype, to consider all the issues necessary to implement actual RLAs, and to detail the
    changes necessary in the law.

See my detailed testimony for reasoning behind these recommendations.

Study: The Price of Voting (Machines) – Valuable, Timely, and Facinating

Last week, I moderated a discussion featuring the authors of The Price of Voting, a study of what jurisdictions actually pay for voting machines.

The study is a great contribution to jurisdictions, including states like Connecticut, that are considering evaluating voting machines.

Five quick conclusions that I find relevant to Connecticut:

  1. If you are not getting about a 20% discount, you are paying too much…

Last week, I moderated a discussion featuring the authors of The Price of Voting, a study of what jurisdictions actually pay for voting machines.

Five quick conclusions that I find relevant to Connecticut:

  1. If you are not getting about a 20% discount, you are paying too much.
  2. Most voting machines cost about the same, so you might be able to pick the most suited if all bids are actually competitive.
  3. Connecticut should plan on about $12,000,000 for the initial purchase and about 10% of that per year for maintenance.
  4. There are also costs beyond the initial purchase and subsequent maintenance.
  5. Plus Connecticut may spend an additional $5,000,000 for initial purchase of a machines intended for those with disabilities, and perhaps $3,000,000 for initial purchases of ePollbooks.

Valuable, timely, and fascinating.

It seems that most jurisdiction pay about 20% off. What about those that paid more, far more? Did officials get too enamored of one solution? Did vendor sales staff get too close to the officials making the decisions? Were too many officials former vendor employees?

Beyond equipment maintenance the ongoing costs are: payments to vendors for expensive proprietary ballot paper based on claims that other papers will not do; ballot printing; ballot programming; and other services provided by the vendor(s) in managing the election which are outsourced from officials.

S1 Tempers “For the People Act” Impact on Connecticut

As we pointed out earlier, H1, the House version of the “For The  People Act” would have a large impact on Connecticut’s elections.

Recently there was a new Managers’ Amendment in the Senate, S1 https://www.rules. senate.gov/imo/media/doc/Klobuchar%20Substitute%20S1.pdf

We have reviewed the new version and are pleased to report that there are many improvements that would ease its impact on Connecticut election officials, yet the impact remains significant.

Among the changes:

As we pointed out earlier, H1, the House version of the “For The  People Act” would have a large impact on Connecticut’s elections.

Recently there was a new Managers’ Amendment in the Senate, S1 https://www.rules. senate.gov/imo/media/doc/Klobuchar%20Substitute%20S1.pdf

We have reviewed the new version and are pleased to report that there are many improvements that would ease its impact on Connecticut election officials, yet the impact remains significant.

Among the changes:

  • It now leaves a single day between early voting and election day and does not require early voting on election day. Still just a single day to print updated voting lists and load ePollbooks is very short – especially if there is a natural disaster or internet outage – just when you need those printed voter lists the most.
  • It now reduces the requirement for 20 days delay in results for accepting and curing absentee ballots to 10 days. Yet, that is not enough to save Connecticut from two elections, with two deadlines each even year, until we pass a Constitutional Amendment to conform state elections to federal election deadlines. Its complicated. Unfortunately the Elections Committee apparently did not get the urgency in my testimony.
  • It also removed the requirement for absentee balloting signature checking.
  • For smaller jurisdictions it eased some of the requirements for Election Day Registration and early voting – it seems that these will help large-area, small-voter rural areas more that Connecticut small towns.
  • It postponed many of the deadlines and provided an option for a state to apply for exemptions for a few years in some cases.
  • It also eased impossible requirements for support of those with disabilities. Some are good, but removing grants for research are disappointing.
  • It also removed grants for Risk Limiting Audits, that is not bad since it made Risk Limiting Audits mandatory.
  • Overall it included many of the changes recommended by the State Audit Working Group, which I moderate. We held sessions with staffers of four Senators on the Rules and Administration committees: Senators Klobuchar, Merkley, Feinstein, and Padilla Embarrassingly, to me, Sen Blumenthal on the Administration Committee did not respond to calls to meet with his staff.

It would remain a huge scramble for the State to meet all the deadlines and for local registrars to double to quadruple (depending on size) their work and budgets for each election.

Testimony on two more election bills: RLAs and Internet Voting

H.B.6325 was a second bill similar to an earlier on that proposed a task force for Risk limiting Audits (RLAs). My detailed testimony only changed a little bit. For the previous bill, I only testified on paper. For this bill I spoke, especially giving my answer to a legislators question of another on another bill. I’m glad I had a few days contemplate an answer: “How would you explain RLAs to forth graders?”

That is a good question: Risk Limiting Audits are intended to confirm that elections are correctly counted and totaled or to correct incorrect results…

  H.B.6325 was a second bill similar to an earlier on that proposed a task force for Risk limiting Audits (RLAs). My detailed testimony only changed a little bit. For the previous bill, I only testified on paper. For this bill I spoke, especially giving my answer to a legislators question of another on another bill. I’m glad I had a few days contemplate an answer: “How would you explain RLAs to forth graders?”

That is a good question: Risk Limiting Audits are intended to confirm that elections are correctly counted and totaled or to correct incorrect results. Over a 10-year period, Connecticut has about 20,000 election contests. For instance, if 20 of those contests were incorrectly decided due to error or fraud, rigorous Risk Limiting Audits which examine all 20,000 contests would correct at least 19 of the 20.

After several hiatus an Internet voting bill is being proposed, one of 28 sections. It also included a flawed proposal for curing absentee ballots rejected for signature issues etc. S.B.5 was patterned after systems that have failed independent security studies, spectacularly.

Testimony on two Elections Bills

 

Earlier this week we testified on two elections bills.

First a bill for a Task Force to provide a prototype and recommend state laws for Risk Limiting post-election Audits (RLAs). See our testimony and that of the inventor of RLAs, Philip Stark, and John Marion of RI. Phil and I disagree just a bit on our recommendations. I find November is just not the best time to do a prototype and then providing less that two months to make recommendations to the General Assembly is not enough time. Here is all thee testimony <read>

Then on a long bill with several election changes recommended by the Secretary of the State. We had comments on two sections: We asked that two officials empty drop boxes and sign logs listing their content. Also a reform we have been requesting for a long time – including central count absentee ballots and Election Day Registration ballots in post-election audits <testimony>

 

Earlier this week we testified on two elections bills.

First a bill for a Task Force to provide a prototype and recommend state laws for Risk Limiting post-election Audits (RLAs).  See our testimony and that of the inventor of RLAs, Philip Stark, and John Marion of RI. Phil and I disagree just a bit on our recommendations. I find November is just not the best time to do a prototype and then providing less that two months to make recommendations to the General Assembly is not enough time. Here is all thee testimony <read>

Then on a long bill with several election changes recommended by the Secretary of the State. We had comments on two sections: We asked that two officials empty drop boxes and sign logs listing their content. Also a reform we have been requesting for a long time – including central count absentee ballots and Election Day Registration ballots in post-election audits <testimony>

Testimony on Early Voting/Absentee Voting Constitutional Amendments

On Monday, the Government Administration and Elections Committee will hear testimony on bills to modify Connecticut’s Constitution for Early Voting and No-Excuse Voting. Meanwhile another Constitutional Amendment or change is advisable to pave the way for related and unrelated voting changes which Connecticut may desire or may be forced upon Connecticut by H.R.1. My testimony is below and <here in .pdf>

H.J.58, H.J.59 – Needed – A Further Critical Change to the CT Constitution

Chairs, members of the Committee, and Connecticut voters, my name is Luther Weeks, Executive Director of CTVotersCount, a computer scientist, and a Certified Moderator since 2008. I also lead one national group and participate in another that discuss, evaluate, and regularly propose changes to state and Federal election laws.

As you are contemplating amendments to the Connecticut Constitution for elections, we need to go just a bit farther than the changes now in H.J.59. Just a few more words would make a great difference going forward. The additional changes would remove deadlines for reporting state contest results that are now baked into our Constitution. These same deadlines would remain in effect, in law, yet easier to change in short order should that become necessary.

Why are these changes critical?

There are at least four reasons why these deadlines may need to change quickly in the near future. Not removing them as soon as possible in our Constitution would cause significant problems and limitations, while waiting for another years-long amendment process to change them…<more>

On Monday, the Government Administration and Elections Committee will hear testimony on bills to modify Connecticut’s Constitution for Early Voting and No-Excuse Voting. Meanwhile another Constitutional Amendment or change is advisable to pave the way for related and unrelated voting changes which Connecticut may desire or may be forced upon Connecticut by H.R.1. My testimony is below and <here in .pdf>

Portions in bold are those that I intend for my oral testimony:

H.J.58, H.J.59 – Needed – A Further Critical Change to the CT Constitution

Chairs, members of the Committee, and Connecticut voters, my name is Luther Weeks, Executive Director of CTVotersCount, a computer scientist, and a Certified Moderator since 2008. I also lead one national group and participate in another that discuss, evaluate, and regularly propose changes to state and Federal election laws.

As you are contemplating amendments to the Connecticut Constitution for elections, we need to go just a bit farther than the changes now in H.J.59. Just a few more words would make a great difference going forward. The additional changes would remove deadlines for reporting state contest results that are now baked into our Constitution. These same deadlines would remain in effect, in law, yet easier to change in short order should that become necessary.

Why are these changes critical?

There are at least four reasons why these deadlines may need to change quickly in the near future. Not removing them as soon as possible in our Constitution would cause significant problems and limitations, while waiting for another years-long amendment process to change them.

Reason #1: The U.S. Congress is contemplating H.R.1[1]  which if passed in its current form, would mandate no-excuse absentee voting for Federal contests, including allowing ballots post-marked by election day to be counted, if received, within a minimum of 10 days after election day. And subject to “curing”[2] for a minimum of 10 ten days after that.

If H.R.1 or a similar Federal law were to pass, it would only apply and override our Constitution for Federal races, then in even-year elections Connecticut would be faced with two election deadlines, one for Federal elections, and another for state elections, likely requiring two ballot designs per district. Ballots would have to be segregated, with some counted and declared within the currently mandated 10 days and others accepted, cured, and added in 20 days later, with the possibility of two sets of recanvass deadlines etc. To do what we do now within 10 days after an election, under H.R.1 would take at least 30 days! Not something that could be completed before early December.

Reason #2: If our Constitution is amended to provide for no-excuse absentee voting, presumably there will be calls for the same things in H.R.1, i.e. accepting ballots post-marked by election day, followed by curing.That would be impossible for state offices until and unless the Connecticut Constitution were to be amended as recommended here.

Reasons #3 and #4 are Ranked Choice Voting and Risk Limiting Audits. If either were to be implemented in Connecticut, they would require days and sometimes weeks longer than the current limit of 10 days – even longer if they were combined with H.R.1:

Reason #3: If Connecticut were to institute Ranked Choice Voting, in some cases it could take days to a few weeks to determine initial results, followed by days or weeks of recanvassing. Those time requirements would be impossible for State offices without this change to the Constitution.

Reason #4: If Connecticut were to institute Risk Limiting Audits (RLAs), by definition RLAs, must be coordinated statewide, completed before certification, may take several rounds, and can sometimes take several days for the last round, as they did in Georgia this past November. That would be impossible without these changes.

The changes I suggest are based on those already in H.J.59, plus the ones in bold and larger type below:

Section 9 of article third of the Constitution is amended to read as follows:

Sec. 9. At all elections for members of the general assembly the presiding officers in the several towns shall [receive the votes of the electors, and] count and declare [them] the votes of the electors in open meeting. The presiding officers shall make and certify duplicate lists of the persons voted for, and of the number of votes for each. One list shall be delivered [within three days to the town clerk,] and [within ten days after such meeting,] the other shall be delivered [under seal] to the secretary of the state.

Section 4 of article fourth of the Constitution is amended to read as follows:

Sec. 4. [At the meetings of the electors in the respective towns held quadrennially as herein provided for the election of state officers, the presiding officers shall receive the votes and shall count and declare the same in the presence of the electors] The votes at the election of state officers shall be counted and declared in open meeting by the presiding officers in the several towns. The presiding officers shall make and certify duplicate lists of the persons voted for, and of the number of votes for each. One list shall be delivered [within three days] to the town clerk, and [within ten days after such meeting,] the other shall be delivered [under seal] to the secretary of the state. The votes so delivered shall be counted, canvassed and declared by the treasurer, secretary, and comptroller[, within the month of November]… that currently even without being limited by our Constitution, all contests in Connecticut are similarly limited by law. The clauses in the Constitution above only apply to State Contests.

At this time, H.J.59 cannot be changed. There are two courses going forward 1) Place the additional changes in H.J.58 or 2) Create an additional amendment with only these changes. I recommend placing the additional changes in H.J.58, rather than as a separate amendment which would likely confuse voters.

Please consider the urgency of making these critical changes in Connecticut’s Constitution. 

Thank you    

[1] U.S. House Resolution 1 https://www.congress.gov/bill/117th-congress/house-bill/1/text

A bill that would mandate many changes for Federal elections nationwide by 11/2022 with some by 1/2020, including accepting absentee ballots for 10 days after election day if post-marked by election day followed by 10 subsequent days for “curing” them. It would also mandate at least 15 contiguous days of in-person early voting including on election day.
For more analysis of H.R.1, see: https://ctvoterscount.org/whats-the-matter-with-h-r-1-part-1/

[2] Curing – Processes by which voters are notified of errors in mail-in ballots in signatures, envelope protocols etc. and provided a period for correcting such errors.

 

What’s the matter with H.R.1, Part 3

Last week in<Part 1> we covered our three greatest concerns with the election administration portions of H.R.1: U.S. House Resolution 1, “For the People Act of 2021” <read H.R.1> and then in <Part 2> we covered our minor concerns which alone would argue against the bill as currently written. In this final installment we will cover what is good about the election administration areas of the bill. (We have refrained from commenting on the rest of the bill which concerns campaign finance reform, gerrymandering, and other issues which we generally do not cover and lack expertise to comment on in detail, other that we are sure that they, like the entire bill, are well-intended).

What is good about election administration in H.R.1?…

What can be done to make election administration portions of H.R.1, more acceptable, short of eliminating all the areas of our concern?..

Last week in<Part 1> we covered our three greatest concerns with the election administration portions of H.R.1: U.S. House Resolution 1, “For the People Act of 2021” <read H.R.1> and then in <Part 2> we covered our minor concerns which alone would argue against the bill as currently written. In this final installment we will cover what is good about the election administration areas of the bill. (We have refrained from commenting on the rest of the bill which concerns campaign finance reform, gerrymandering, and other issues which we generally do not cover and lack expertise to comment on in detail, other that we are sure that they, like the entire bill, are well-intended).

What is good about election administration in H.R.1?

  • It prohibits excessive requirements for authenticating absentee ballots such as the requirements that they be witnessed by one or two people.
  • It provides grants for the development of voting equipment for those with disabilities.
  • It provides grants for Risk Limiting Audits (RLAs), although the definition of RLAs and requirement for grants should be improved to require more transparency, public verifiability, and require that races to audit not be chosen by partisan bias or based on expediency after results are known. It could also offer grants for ballot security and other, so called, process audits.
  • It provides funds for replacing equipment that is over ten years old. We wish that those grants were limited to systems which require hand-marked paper ballots and one ballot marking device per polling place, and cover only VVSG/EAC certified equipment.
  • It adds ePollbooks to the definition of voting systems, thus subjecting them to the Election Assistance Commission’s Voluntary Voting Systems Guidelines, subject to certification testing as well.

What can be done to make election administration portions of H.R.1, more acceptable, short of eliminating all the areas of our concern?

  • Overall the requirements should be spread over several years, perhaps 2022 through 2026 or 2028.
  • Absentee ballots should not be required to be accepted after Election Day, that one requirement adds 10 days to the election cycle, delaying results. Voters knowing the deadline can be expected to mail them earlier or get them to drop boxes in time.
  • Curing should be required only for ballots received 12 days before election day and processed such that letters go out no less than 10 days before election day and cured by election day. Mandatory curing requirements should be delayed until 2026.
  • Officials should not be responsible for voters receiving absentee ballots. Voters should be able to request absentee ballots in-person and receive them on the spot until 5 days or less before the election. Requests received by mail should be mailed back within 24 business hours.
  • Election Day Registration should only be required for election day. Voters should be able to register in-person five days or less before election day, and any mailed-in or on-line requests received by that date processed.
  • Considering that states like CA and CO have shown that only a small number of voters use early voting when no-excuse absentee voting is available, there should be no requirement for early in-person voting. At worst it should only be required for a minimum of 5 days in the two weeks before election day.
  • Chief election officials should only be required to step aside, when they are on the ballot and not running for reelection.
  • Drop box ballots should be counted like absentee ballots. Drop boxes should, at most, be required to be wheelchair accessible and to have instructions in braille.
  • Unrealistic requirements for all voters with disabilities to be able to vote independently and privately should be dropped or made realistic, based on the capabilities of commonly available VVSG/EAC certified equipment.
  • Enforcement provisions should also be made more realistic to protect pollworkers and election officials from excessive risk and harrassment.
  • The unrealistic requirement for voters never having to wait over 30 minutes in line should be removed or drastically changed.
  • Having IDs on ballots which can link them to voters should be prohibited, never required in any circumstance. IDs on envelops are acceptable.

That is all for now, unless there are further developments.