Category: National

What’s the matter with H.R.1, Part 1

H.R.1: U.S. House Resolution 1, “For the People Act of 2021”. It is a 790 page omnibus election reform bill supported largely by Democrats. There is a companion bill in the U.S. Senate.

It is endorsed by a huge number of good government groups. I wonder how many have read it in detail and understand its ramifications? Like many such bills it has some good provisions and some not so good provisions. I have read only those portions having to do with voting and election administration, about half the bill, pp78-407 – areas where I can claim a level of expertise. I have also spent hours with a team of experts reviewing those provisions in further detail.

Be careful what you endorse! All of this bill is well-intended, yet not all workable. 

In this 1st post I will concentrate on just three concerns that make it especially tough for states like Connecticut. Overall in its voting and election administration sections one could say it seems to be intended to make all states voting more like California and Colorado which encourage voters to vote by mail, while offering extensive early (in-person) voting, along with polling place voting.

First, overall its too much too quickly. Overall we estimate doubling to quadrupling election costs in our cities and towns...

H.R.1: U.S. House Resolution 1, “For the People Act of 2021” <read H.R.1> It is a 790 page omnibus election reform bill supported largely by Democrats. There is a companion bill in the U.S. Senate.

It is endorsed by a huge number of good government groups. I wonder how many have read it in detail and understand its ramifications? Like many such bills it has some good provisions and some not so good provisions. I have read only those portions having to do with voting and election administration, about half the bill, pp78-407 – areas where I can claim a level of expertise. I have also spent hours with a team of experts reviewing those provisions in further detail.

Be careful what you endorse! All of this bill is well-intended, yet not all workable. 

In this 1st post I will concentrate on just three concerns that make it especially tough for states like Connecticut. Overall in its voting and election administration sections one could say it seems to be intended to make all states voting more like California and Colorado which encourage voters to vote by mail, while offering extensive early (in-person) voting, along with polling place voting.

First, overall its too much too quickly. Most of its provisions apply to all Federal elections (Federal races*) starting with November 2022, others apply by January 2022. Most previsions apply to Federal elections, primaries, run-offs, and special elections. For a state like Connecticut, you will see that it will be ongoingly expensive and in the near term challenging to implement so much. Overall we estimate doubling to quadrupling election costs in our cities and towns.

Second, significant changes in absentee voting. H.R.1 would allow all citizens the opportunity to vote by mail, yet with significant additions that will be especially challenging for Connecticut. It will mandate that mail-in packets must be processed if they are postmarked by election day** and received within 10 days after the election. Then if such ballot packages are rejected (for instance without a signature), voters must be notified and given at least 10 days to ‘cure’ (correct) the problem. That might sound good and fair, however:

Currently Connecticut law requires all ballots to be counted, recounted, and finalized within 10 days of the election. For state races, that 10 day deadline is in the Connecticut Constitution. So, in November 2022 and thereafter for every even year, the deadlines for Federal races would have to change to about 30 days after the election. State laws and election procedures should be changed to account for all requirements and to correct all subsequent deadlines (i.e. swearing into office) to conform to those Federal requirements, at least for even-year and other Federal elections. That’s all tall order to complete in, at most, a year and a half. Yet there is more. Federal law can not override our Constitution for state contests, so every two years, until our Constitution is changed we would have to effectively run two elections, with two deadlines for accepting ballots, counting ballots, calling and completing recounts (actually recanvasses in Connecticut). Realistically the earliest a Constitutional amendment could pass would be 2024, to be in effect in 2026. Connecticut could keep some or all of our current laws and deadlines for municipal races, yet that would create additional challenges and confusion for voters and for officials. Plus for the Federal races there would be no-excuse absentee voting, yet under our Constitution only absentee ballots for those with excuses could be counted for all other contests. So that would likely require two absentee ballots, one type for those with excuses, and another for those without an excuse that has only the Federal races.

The law also makes election officials responsible for the delivery of absentee ballots to individuals requesting them five days or more before the election. What about the elderly person who cannot use the Internet who requests a ballot five days before? What is an election official to do, but deliver it by hand?

Third, gargantuan early voting requirements.
Background: Connecticut does not have in-person early voting. In the past proposed Constitutional amendments have allowed the General Assembly to mandate a maximum of five or eight days of early voting in a specified period prior to an election or primary. In California there are currently 11 days of early voting, even that seems to be overkill for California, where 70% of voters mail-in their ballots, 20% vote on election day, and just 10% vote on those 11 days of early voting. Statistics are similar in Colorado.

H.R.1 would mandate a minimum of 15 days of early voting, not just any days, but each of the 15 days before election day and election day itself. It would mandate at least 10 hours a day of early voting, with all days required to be the exact same hours. And that early voting must use the same methods as election day voting, e.g. check-in lines, scanners, etc. So even the smallest, single polling-place towns in Connecticut would have to staff an early voting site for 15 days, with a minimum of six pollworkers, before election day and on election day. By my estimates likely contributing to quadrupling election costs  for some towns, in an already busy period for registrars and clerks. Perhaps ‘only’ tripling costs for mid-size municipalities, and ‘only’ doubling them for large cities. Another implication is that because early voting hours must be the same every day, early voting could not be open early some days, late other days, and vary for weekend days. Finally, if you desire to use an early voting location to double as an election day polling place that would mean all early voting hours would need to be from 6:00am to 8:00pm – most small one-polling place towns would find it easier to have two venues open on election day rather than do 15 days of 6:00am to 8:00pm. Staffing 15 days of 10 hour (actually 12 hours for staff) early voting would seem to require at least three crews plus registrars and clerks available.

This is perhaps the bulk of the work, yet not the end of H.R.1 and requirements that seem to have been written without the benefit of consulting those who have to implement them. Read <Part 2> and <Part 3>.

*We try to use ‘race’ when we mean a race for office and ‘contest’ when we mean both a race or a question on the ballot. When it comes to Federal elections, there are only races.

** For the most part when we use ‘election’ in this post we mean election, primary, run-off, or special election.

To trust our elections we need evidence, enough evidence

A recent article in Barons by respected scientists: Elections Should be Grounded in Evidence, Not Blind Trust 

Here’s what an evidence-based election would look like:

  • Voters hand-mark paper ballots to create a trustworthy, durable paper vote record. Voters who cannot hand-mark a ballot independently are provided assistive technologies, such as electronic ballot marking devices. But because these devices are subject to hacking, bugs, and software misconfiguration, the use of such ballot-marking devices should be limited.

  • Election officials protect the paper ballots to ensure no ballot has been added, removed, or altered…

A recent article in Barons by respected scientists: Elections Should be Grounded in Evidence, Not Blind Trust  <read>

Here’s what an evidence-based election would look like:

  • Voters hand-mark paper ballots to create a trustworthy, durable paper vote record. Voters who cannot hand-mark a ballot independently are provided assistive technologies, such as electronic ballot marking devices. But because these devices are subject to hacking, bugs, and software misconfiguration, the use of such ballot-marking devices should be limited.
  • Election officials protect the paper ballots to ensure no ballot has been added, removed, or altered. This requires stringent physical security protocols and ballot accounting, among other things.
  • Election officials count the votes, using technology if they choose. If the technology altered the outcome, that will (with high confidence) be corrected by the steps below.
  • Election officials reconcile and verify the number of ballots and the number of voters, with a complete canvass to ensure that every validly cast ballot is included in the count.
  • Election officials check whether the paper trail is trustworthy using a transparent “compliance audit,” reviewing chain-of-custody logs and security video, verifying voter eligibility, reconciling numbers of ballots of each style against poll book signatures and other records, and accounting for every ballot that was issued.
  • Election officials check the results with an audit that has a known, large probability of catching and correcting wrong reported outcomes—and no chance of altering correct outcomes. The inventory of paper ballots used in the audit must be complete and the audit must inspect the original hand-marked ballots, not images or copies.

None of these steps stands alone. An unexamined set of paper ballots, no matter how trustworthy, provides no evidence. Conversely, no matter how rigorous, audits and recounts of an untrustworthy paper trail provide no evidence that the reported winners won. Auditing or recounting machine-marked ballots or hand-marked ballots that have not been kept secure can check whether the reported outcome reflects that paper trail, but cannot provide evidence that the reported winners won.

We completely and enthusiastically agree.

One more time: Hand Marked Paper Ballots, protected and exploited

Our Longtime Editorial Opinion

We hear a lot about protecting voting equipment and paper ballots. We talk a lot about both as well. They are not equal!…

Today an article in Freedom to Tinker echoing our opinion: ESS voting machine company sends threats

Our Longtime Editorial Opinion

We hear a lot about protecting voting equipment and paper ballots. We talk a lot about both as well. They are not equal!

It is good to protect machines from tampering; good to test machines; and good to preserve them for post-election forensic analysis; yet, ultimately they cannot be fully protected and error free. They cannot be preserved for extended periods, they are needed for the next election.

Paper ballots are also ‘hackable’ by good old fashioned replacement, destruction, or alteration; yet they can be well protected by strong security measures and audits of security compliance. They must be exploited by sufficient, transparent, publicly verifiable audits and recounts.

Today an article in Freedom to Tinker echoing our opinion: ESS voting machine company sends threats  <read>

The ExpressVote XL, if hacked, can add, delete, or change votes on individual ballots — and no voting machine is immune from hacking. That’s why optical-scan voting machines are the way to go, because they can’t change what’s printed on the ballot. And let me explain some more: The ExpressVote XL, if adopted, will deteriorate our security and our ability to have confidence in our elections, and indeed it is a bad voting machine. And expensive, too!

The main point of the article is that ES&S is using false claims made against Dominion to intimidate others, making accurate, indisputable, scientific claims:

Apparently, ES&S must think that amongst all that confusion, the time is right to send threatening Cease & Desist letters to the legitimate critics of their ExpressVote XL voting machine. Their lawyers sent this letter to the leaders of SMART Elections, a journalism+advocacy organization in New York State who have been communicating to the New York State Board of Elections, explaining to the Board why it’s a bad idea to use the ExpressVote XL in New York (or in any state).

ES&S  machines, as far as we know, are no more or less vulnerable than other brands, however, the company exposes its lack of integrity by its unfounded intimidation.

Elections Should be Grounded in Evidence, Not Blind Trust

Commentary in Barron’s this week Elections Should be Grounded in Evidence, Not Blind Trust <read>

Even though there is no compelling evidence the 2020 vote was rigged, U.S. elections are insufficiently equipped to counter such claims because of a flaw in American voting. The way we conduct elections does not routinely produce public evidence that outcomes are correct.

Commentary in Barron’s this week Elections Should be Grounded in Evidence, Not Blind Trust <read>

Even though there is no compelling evidence the 2020 vote was rigged, U.S. elections are insufficiently equipped to counter such claims because of a flaw in American voting. The way we conduct elections does not routinely produce public evidence that outcomes are correct.

Furthermore, despite large investments since 2016, voting technology remains vulnerable to hacking, bugs, and human error. A report by the National Academies into the 2016 election process concluded that “there is no realistic mechanism to fully secure vote casting and tabulation computer systems from cyber threats.” The existence of vulnerabilities is not evidence that any particular election outcome is wrong, but the big-picture lesson from 2020 is that ensuring an accurate result is not enough. Elections also have to be able to prove to a skeptical public that the result really was accurate.

We need evidence-based elections: processes that create strong public evidence that the reported winners really won and the reported losers really lost, despite any problems that might have occurred. Every step in election administration—from technology choices to voter eligibility checks, physical security, the canvass, and audits—should flow from that requirement…

Here’s what an evidence-based election would look like:

  •  Voters hand-mark paper ballots to create a trustworthy, durable paper vote record. Voters who cannot hand-mark a ballot independently are provided assistive technologies, such as electronic ballot marking devices. But because these devices are subject to hacking, bugs, and software misconfiguration, the use of such ballot-marking devices should be limited.
  • Election officials protect the paper ballots to ensure no ballot has been added, removed, or altered. This requires stringent physical security protocols and ballot accounting, among other things.
  • Election officials count the votes, using technology if they choose. If the technology altered the outcome, that will (with high confidence) be corrected by the steps below.
  • Election officials reconcile and verify the number of ballots and the number of voters, with a complete canvass to ensure that every validly cast ballot is included in the count.
  • Election officials check whether the paper trail is trustworthy using a transparent “compliance audit,” reviewing chain-of-custody logs and security video, verifying voter eligibility, reconciling numbers of ballots of each style against poll book signatures and other records, and accounting for every ballot that was issued.
  • Election officials check the results with an audit that has a known, large probability of catching and correcting wrong reported outcomes—and no chance of altering correct outcomes. The inventory of paper ballots used in the audit must be complete and the audit must inspect the original hand-marked ballots, not images or copies.

None of these steps stands alone. An unexamined set of paper ballots, no matter how trustworthy, provides no evidence. Conversely, no matter how rigorous, audits and recounts of an untrustworthy paper trail provide no evidence that the reported winners won. Auditing or recounting machine-marked ballots or hand-marked ballots that have not been kept secure can check whether the reported outcome reflects that paper trail, but cannot provide evidence that the reported winners won…

outsourcing audits, as Georgia did after the November vote, may prevent such process improvements. It is the responsibility of election officials (and not a third party) to ensure and demonstrate that the paper trail includes no more and no less than every validly cast ballot, and that the reported result is what those ballots show.

We note that, to us, ‘Outsourcing’ audits is a distinct concept from ‘Independent’ audits. Outsourcing implies turning all responsibly over to a hired vendor or entity dependent on election officials for funding. Independent auditing means assigning responsibility for the audit, or at least assessment and oversight of the audit to an entity independent of election officials.

How Far Have We Come Since 2016?

Have not posted much since the Election, there has been plenty of true and false information to read from all sources. Time now for a little perspective.

Recall 2016, when Jill Stein and others demanded recounts and audits in MI, WI, and PA. They were largely thwarted by officials. Little was possible in PA with no paper records of votes to count. Potential Russian hacking of epollbooks across a county in NC which was never credibly investigated. Government conclusions that there was no evidence that election systems were hacked, without checking for any. Those involved in the recounts/audits, such as the were, conclude that the saw not evidence of hacking. Yet the government acknowledged there were 18 states with attempts (often mis-characterized as 21 attempts) at accessing voter lists. To many, including yours truly, Georgia represented the most questionable state with Secretary of State Kemp on the ballot for Governor, vulnerable, critical election data left on a server before the election – destroyed by officials precluding forensic analysis, voter purges, and no paper records of votes.

We have come quite a way since then in the 2020 election…

Yet we have much farther to go:..

Have not posted much since the Election, there has been plenty of true and false information to read from all sources. Time now for a little perspective.

Recall 2016, when Jill Stein and others demanded recounts and audits in MI, WI, and PA. They were largely thwarted by officials. Little was possible in PA with no paper records of votes to count. Potential Russian hacking of epollbooks across a county in NC which was never credibly investigated. Government conclusions that there was no evidence that election systems were hacked, without checking for any. Those involved in the recounts/audits, such as the were, conclude that the saw not evidence of hacking. Yet the government acknowledged there were 18 states with attempts (often mis-characterized as 21 attempts) at accessing voter lists. To many, including yours truly, Georgia represented the most questionable state with Secretary of State Kemp on the ballot for Governor, vulnerable, critical election data left on a server before the election – destroyed by officials precluding forensic analysis, voter purges, and no paper records of votes.

We have come quite a way since then in the 2020 election:

  • Georgia and Philadelphia now have new Ballot Marking Devices providing paper records for recounts.
  • Georgia has a Risk Limiting (tabulation) Audit (RLA).
  • Georgia by RLA and Philadelphia by recount, counted their paper ballots by hand.
  • Georgia also by recount used machines to recount them all.
  • Georgia officials, mostly Republican, defended the claim that Biden won. Even Governor Kemp.
  • Other mostly Republican states defended Biden’s win.
  • The Government beefed up cyber defenses and monitoring.
  • Online media improved their monitoring and response to false information.

Yet we have much farther to go:

  • We need Voter-Marked Paper Ballots everywhere. Despite claims to the contrary, Ballot Marking Devices do not provide voter-verified ballots. Tests and observations clearly demonstrate that about 90% of voters make no effort to check their ballots, that many who try fail to check well, and most officials would understandably not believe them if they complain.
  • Many RLA laws, like Georgia’s, are inadequate and poorly written. They like many audit laws fail to come close to the Principles and Best Practices for Post-Election Audits. They don’t specify enough details/requirements for RLAs. They mis-state RLAs. They allow election officials to pick races for audit after the fact, all but encouraging picking races with large margins, rather than close races.
  • Georgia’s RLA was really a complete hand recount. Much more valuable than a RLA.
  • Georgia’s hand recount did not count. That is why the official recount was machine recount, an extra waste of time. An adequate RLA law could eliminate the need for machine recounts and result in a full hand recount only when necessary – like it was in Georgia this year.
  • Georgia’s hand recount was not well planned, and not transparent. We can applaud the recount and the hard work involved, yet next time there should be detailed procedures published in advanced, oversight to be sure those procedures are followed, and transparency – observers were unable to see and verify results sheets, compare results to original batch totals, and see that the correct numbers were entered into the results accumulation system, designed for an RLA and not a full recount.
  • The audits and recounts only covered vote Tabulation. Full audits should include transparent audits of the chain-of-custody, eligibility, and other aspects of election administration.
  • Many of these same issues apply to other close states this year and to many other states as well.

Once again, we applaud officials who did exemplary work in trying conditions, especially those defending results they would have had otherwise.

In a future post we will go over some of these issues in more details, comparing to the standards in the Principles and Best Practices.

 

 

New Paper: Evidence Based Elections

A new paper by Andrew Appel and Philip Stark: EVIDENCE-BASED ELECTIONS:CREATE A MEANINGFUL PAPER TRAIL,THEN AUDIT  Provides a thorough description of how the public can be assured of election outcomes, in spite of hack-able voting equipment.

The bottom line: The only reliable method available is Voter-Marked Paper Ballots, with strong security for the ballots, followed by sufficient post-election audits. Other technologies, including Ballot Marking Devices and Internet voting are insufficient.

Anyone interested in trustworthy elections should read this paper – especially those who think that expensive Ballot Marking Devices should be trusted. And those who think it is impossible to use technology to count votes accurately.

A new paper by Andrew Appel and Philip Stark: EVIDENCE-BASED ELECTIONS:CREATE A MEANINGFUL PAPER TRAIL,THEN AUDIT  <read> Provides a thorough description of how the public can be assured of election outcomes, in spite of hack-able voting equipment.

The bottom line: The only reliable method available is Voter-Marked Paper Ballots, with strong security for the ballots, followed by sufficient post-election audits. Other technologies, including Ballot Marking Devices and Internet voting are insufficient.

Anyone interested in trustworthy elections should read this paper – especially those who think that expensive Ballot Marking Devices should be trusted.

The vulnerability of computers to hacking is well understood. Modern computer systems, including voting machines, have many layers of software, comprising millions of lines of computer code; there are thousands of bugs in that code. Some of those bugs are security vulnerabilities that permit attackers to modify or replace the software in the upper layers,so we can never be sure that the legitimate vote-counting software or the vote-marking user interface is actually the software running on election day. One might think, “our voting machines are never connected to the Internet, so hackers cannot get to them.” But all voting machines need to be programmed for each new election: They need a “ballot-definition file” with the contests and candidate names for each election, and lists of the contests different voters are eligible to vote in. This programming is typically done via removable media such as a USB thumb drive or a memory card. Vote-stealing malware can piggyback on removable media and infect voting machines—even machines with no network connection. There is a way to count votes by computer and still achieve trustworthy election outcomes. A trustworthy paper trail of voter selections can be used to check, or correct, the electoral outcomes of the contest in an election…

If a BMD is hacked and systematically steals 5% of the votes in one contest and only 7% of voters inspect their ballots carefully enough to notice, then the effective rate of vote-theft is5% ?93% ,or 4.65%;this is enough to change the outcome of a moderately close election. The same analysis applies to a DRE+VVPATsystem.One might think:“not everyone needs to carefully verify their ballots;” if only 7% of voters carefully inspect their ballots, they can serve as a kind of “random audit” of the BMDs. But this sentiment fails to hold up under careful analysis…

in our hypothetical scenario in which a hacked BMD steals 5% of the votes, and 7% of voters carefully inspect their ballots (and know what to do when they see a mistake), then7% ?5% ofvoters will alert a pollworker; that is, 1 in every 285 voters will claim their paper ballot was mismarked—if the voters do not assume it was their own error. The BMD would successfully steal “only” 4.65% of the votes.One might think:“but some voters caught the BMD cheating, red-handed.” But nothing can be done. It is a rare election official who would invalidate an entire election because 1 out of 285 voters complained.

“Delay” is a dirty word

WhoWhatWhy podcasd interview with Professor Ned Foley  <listen>

Ned is the leading legal expert on our presidential election system and how our country reacts to close elections.

In the second half of the interview he makes the point that counting votes after election day and waiting for certified results is a part of the process. He makes the point that the media and everyone else should avoid using the word ‘delay’ to describe results that are not complete on election night – they never are.

WhoWhatWhy podcasd interview with Professor Ned Foley  <listen>

Ned is the leading legal expert on our presidential election system and how our country reacts to close elections.

In the second half of the interview he makes the point that counting votes after election day and waiting for certified results is a part of the process. He makes the point that the media and everyone else should avoid using the word ‘delay’ to describe results that are not complete on election night – they never are.

4th of July Suggestion

As we often do, a suggested reading for the 4th of July weekend.  Today it seems the Constitution is under assault from all sides, with an administration assaulting the rule of law and civil rights advocates identifying its fundamental flaws. Lets refresh ourselves on our purer, more basic rights.

This weekend is a great time to [re-]read the Declaration of Independence. We find it very inspiring to read it sometime around the 4th of July each year.  As we have discussed before, some believe that the right to vote is more fundamental than the Constitution. Here is a link to a copy for your reading <Declaration of Independence>

The Declaration of Independence asserts our rights to determine and change our form of government – without voting integrity we lose that most fundamental of rights.

“The right to vote… is the primary right by which other rights are protected” – Thomas Paine

As we often do, a suggested reading for the 4th of July weekend.  Today it seems the Constitution is under assault from all sides, with an administration assaulting the rule of law and civil rights advocates identifying its fundamental flaws. Lets refresh ourselves on our purer, more basic rights.

This weekend is a great time to [re-]read the Declaration of Independence. We find it very inspiring to read it sometime around the 4th of July each year.  As we have discussed before, some believe that the right to vote is more fundamental than the Constitution. Here is a link to a copy for your reading <Declaration of Independence>

The Declaration of Independence asserts our rights to determine and change our form of government – without voting integrity we lose that most fundamental of rights.

“The right to vote… is the primary right by which other rights are protected” – Thomas Paine

Comments on new Federal Voting Systems Guidelines

Last week I submitted comments for the State Audit Working Group on the proposed (Voluntary Voting Systems Guidelines) VVSG 2.0 standards which will define future voting system standards. Looking over all the submissions, ours were likely the most extensive detailed comments submitted. In total our submission was about three hundred and fifty pages!

By far the largest number of comments were from disability rights groups and individuals supporting their positions, many redundant. Access for the disabled is one of the most controversial and critical issues.

There are other issues with the proposed guidelines. The proposal is a far from a finished product, with wide-ranging comments. It will be a huge task to complete them, far more challenging to complete well.

Last week I submitted comments for the State Audit Working Group on the proposed (Voluntary Voting Systems Guidelines) VVSG 2.0 standards which will define future voting system standards. Looking over all the submissions, ours were likely the most extensive detailed comments submitted. In total our submission was about three hundred and fifty pages!  You might consider reading the cover letter and then the Glossary Comments which have their own cover letter. In all, we spent over 200 hours developing and agreeing upon our comments. We were pleased to have thirteen signers and endorsements in comments from others groups : <SAWG Comments>

In all there were seventy-seven comments from various voting integrity, vendor, disability rights groups, and individuals <All Comments>

By far the largest number of comments were from disability rights groups and individuals supporting their positions, many redundant. Access for the disabled is one of the most controversial and critical issues. Many argue that everyone should vote on exactly the same voting machines so that all have equal access. There are several problems with this argument which would have us all vote on BMDs (Ballot Marking Devices): BMDs are not fully developed to meet the needs of the disabled, they need lots of work; Despite voting on identical machines, BMDs provide multiple interfaces for those with various disabilities , leaving voters not actually voting the same way anyway; BMDs cost about four times what a combination of a single BMD per polling place with VMPB (Voter Marked Paper Ballots) for most voters; BMDs do not serve some voters with disabilities  who cannot use them but can use paper ballots; BMDs are often the cause of the long lines we see in Georgia, Pennsylvania and elsewhere – almost non-existent in CT which has the single BMD and VMPB model; those long lines hurt the vast majority of those with disabilities who have issues with walking and standing in line for hours. I would favor investing the savings in BMD research and preparing to replace that one BMD per polling place as better solutions are developed. For some interesting comments on the challenges of the disabled that do not take the standard advocacy line, read the comments from <Marybeth Kuznik>, <Noel Runyan>, and <Harvie Branscomb>.

There are other issues with the proposed guidelines: They spend too little on vote-by-mail equipment; fail to fully recognize early voting; are too detailed in some areas and sketchy in others; provide for unsafe Recallable Ballots; and as vendors point out are often too prescriptive and expensive to implement. The proposal is a far from a finished product, with wide-ranging comments. It will be a huge task to complete them, far more challenging to complete well.