National: Verified Voting Comments On VVSG 2.0 v3

Download the letter here  June 22, 2020 TO: The United States Election Assistance Commission (EAC) Thank you for the opportunity to comment on the proposed Voluntary Voting Systems Guidelines (VVSG) 2.0. Verified Voting’s mission is to strengthen democracy for all voters by promoting the responsible use of technology in elections. Verified Voting applauds the diligent…

Delaware: Election Commission Quietly Fielded An Online Voting System, But Now Is Backing Away | Sophia Schmidt/NPR

Delaware briefly deployed a controversial internet voting system recently but scrapped it amid concerns about security and public confidence. Before the online option was shuttered, voters returned more than 2,700 ballots electronically — and those votes still will be counted, according to the state, along with conventional votes in the upcoming July primary. Delaware Election Commissioner Anthony Albence said the decision to stop using the cloud-based return option was made to protect public perception of the election. “We have had no problems with the system,” said Albence. “We have confidence in the system, but we want everyone to be fully confident in anything that we do.” The coronavirus pandemic has sent election officials nationwide scrambling for creative solutions to voting problems this year, but it’s becoming clear that there remains very little appetite for new internet voting platforms as part of that conversation. After NPR reported in April that three states were moving toward statewide pilot programs to allow voters with disabilities to return their ballots over the internet, two of those states have since backed away from those plans after intense criticism from the cybersecurity community.

Georgia: How Electronic Voting in Georgia Resulted in a Disenfranchising Debacle | Sue Halprin/The New Yorker

No one familiar with Georgia’s record of election administration was surprised to see another train wreck unfold during Tuesday’s primary. Lines were so long that some voters waited seven hours to vote. It was a monumental failure that—not surprisingly—occurred in predominantly African-American and poor neighborhoods. Part of the problem was the use of expensive, new voting machines, which could signal problems for the Presidential election, in November. On Tuesday, Georgians voted using thirty thousand new machines, called Ballot Marking Devices (B.M.D.s), which the state purchased last year for a hundred and seven million dollars, despite public opposition. When voters finally made it to the front of the line, they signed into electronic poll books (many of which malfunctioned) and were given a smart card loaded with the ballot for their district. They then inserted the card into the voting machine, the ballot popped up on a touch screen, they made their selections, and the machine printed out a summary of those choices.

National: How secure are electronic pollbooks and vote reporting tools? This new program aims to find out | Joseph Marks/The Washington Post

Voting machines get most of the attention when it comes to election security. But officials are now trying to tackle myriad ways adversaries could undermine U.S. elections aside from directly rigging ballots. A new pilot project run by a top cybersecurity nonprofit group and the Election Assistance Commission aims to look for bugs in the many other machines that hackers could exploit to throw an election into chaos, such as electronic poll books and systems for reporting unofficial election night results. Most states currently don’t have a formal process for ensuring they’re secure. “Most of our adversaries aren’t looking to affect the outcome of an election as much as they want to affect our confidence in that outcome,” Aaron Wilson, senior director of election security at the Center for Internet Security, which is running the project, told me. “All of these technologies could have a really big impact on voter confidence and in some cases on the vote itself.” A cyberattack that modified voter information in e-poll books, for example, could make it difficult or impossible for many people to cast ballots. An attack that changed election night results could create confusion about the winner and degrade faith in the real result.

National: “Catastrophe:” Elections experts fear what primary mayhem may mean for November | Melissa Quinn/CBS

With five months to go before tens of millions of Americans head to the polls, voting rights groups and elections experts who watched chaos unfold in states that recently held their primaries are sounding the alarm about what Election Day in November may hold, amid the coronavirus pandemic. “I’m concerned that if we’re already seeing failures happening during these lower-turnout primary elections, come November when turnout will be two to three times what it was, the problems will still persist and we’ll have catastrophic failure,” Michael McDonald, a political science professor at the University of Florida and expert on elections, told CBS News. While some states have been able to navigate the uncertain landscape brought by the coronavirus, others have seen their primaries plagued by long lines, technical snags and widespread confusion. In Georgia and Nevada, voters waited in line for hours to cast their ballots because of the consolidation of polling locations and a shortage of poll workers, who are typically older and who opted to stay home to protect themselves and their health.

National: States failed to get absentee ballots to thousands of voters in recent primary elections, signaling problems for November | Marshall Cohen and Kelly Mena/CNN

As Washington, DC’s June 2 primary approached, Matthew Miller and Nima Sheth, married professors who live in the District, decided to vote absentee. With elderly, immunocompromised parents at home, plus a 1-year-old baby, it felt like the safest choice in the age of coronavirus. So, they submitted requests for absentee ballots on the last day of eligibility, a week before the primary. They got a confirmation email from the DC Board of Elections. But Miller’s ballot never arrived, and Sheth’s ballot was sent to the wrong address. Neither ended up voting. “It wasn’t a risk we were willing to take, at least for the primary,” Miller said, “Though November might be a different story. You just don’t think something like this could happen in a country like America, where, if you follow the rules, you should be able to vote.” Miller and Sheth are among tens of thousands of voters who didn’t get their requested absentee ballots in recent primaries, including in the battleground states of Georgia and Wisconsin. In Maryland, where all registered voters were automatically supposed to get ballots in the mail, about 160,000 ballots, roughly 5% of those sent out, weren’t delivered, officials say.

National: Georgia shows why November’s election could be chaos | Timothy B. Lee/Ars Technica

There’s broad agreement that last week’s primary election in Georgia was a fiasco, with voters reportedly waiting as long as five hours to cast a ballot. Democrats accused Georgia Republican Secretary of State Brad Raffensperger of bungling the statewide rollout of new election technology. Some went further, suggesting that the problems—which were most severe in Democratic areas—were a deliberate Republican strategy. “What happened in Georgia yesterday was by design,” former presidential candidate Hillary Clinton tweeted last Wednesday. “Voter suppression is a threat to our democracy.” Republicans have responded by blaming officials in Democratic-leaning urban counties where the problems were the worst. County officials in Georgia are responsible for many day-to-day details of an election, including selecting polling places and recruiting poll workers. Raffensperger singled out officials in Fulton and DeKalb Counties—liberal jurisdictions in the heart of the Atlanta metro area. “Every other county faced these same issues and were significantly better prepared to respond so that voters had every opportunity to vote,” Raffensperger wrote in an election-day statement.

National: COVID endangers the volunteers who make your vote count | Pat Beall and John Moritz/USA Today

Lost in the broader chaos of Georgia’s recent statewide election was a previously unreported incident that highlights a concern for every state planning for the November general election: Just 48 hours before Georgia’s June 9 election, a poll worker in Jackson County tested positive for COVID-19. Emails obtained by USA TODAY show Jackson County elections supervisor Jennifer Logan told election board members that, on the advice of an election official in Georgia Secretary of State Brad Raffensperger’s office, they were not required to tell the public anything. The official’s argument was that “due to the continuing health crisis, everyone knows the risk that they take when they go out in public…and they are making that choice,” the email states. Logan did not respond to written requests for comment, and it’s unclear whether other Jackson County poll workers were notified that one of their colleagues had tested positive for the novel coronavirus. In a statement, a Raffsenberger spokesman said counties had been advised only to make their own decisions after talking to health officials and their own legal counsel.

Alabama: Judge allows curbside voting in Alabama; loosens absentee ballot requirements in 3 counties | Brian Lyman/Montgomery Advertiser

A federal judge loosened absentee voting requirements in a handful of Alabama counties and allowed counties to set up curbside voting ahead of the July 14 runoff election. In a 77-page ruling Monday, U.S. District Judge Abdul Kallon suspended a witness requirement for absentee ballots cast in Jefferson, Mobile, and Lee counties; suspended a photo ID requirement for voters aged 65 or older or with a disability for absentee voting in those counties, and allowed counties that want to set up curbside voting as a way of protecting voters from the outbreak from doing so. The Southern Poverty Law Center; the NAACP Legal Defense Fund, and the Alabama Disability Advocacy Program filed suit on May 1 on behalf of several plaintiffs with health issues who said existing absentee voting requirements put them at risk of contracting COVID-19 and amounted to an unconstitutional burden on their right to vote.

Alaska: State plans to mail absentee ballot applications to seniors, prompting calls to send them to all Alaska voters | Andrew Kitchenman/Alaska Public Media

Lt. Gov. Kevin Meyer has announced a plan to mail absentee ballot applications to Alaskans ages 65 and older. Some lawmakers and voting advocates are concerned that this would create unequal access to those who don’t automatically get ballot applications. During an online town hall on Thursday, Meyer described why the Division of Elections will be mailing absentee ballot applications to all registered voters who are 65 and older: They have a greater risk of getting COVID-19. “That is a very vulnerable group,” said Meyer, a Republican. Meyer said the state Division of Elections is hearing it directly from seniors who have worked at the polls in the past. “A lot of these people right now are reluctant to commit, because they’re worried about the virus, or the pandemic,” he said. “And they should be, and if they’re not comfortable, we don’t want them to come out.” Meyer said the state is encouraging voters to request absentee ballots or to vote early to reduce the lines on election day. Some think the state should go further, and send the applications to all registered voters.

California: Los Angeles County has found the cause of its hourslong poll lines. It wasn’t the new voting machines. | Kim Zetter/Politico

The hourslong wait times that snarled the March 3 primary in Los Angeles County stemmed from malfunctions in the electronic tablets used to check in voters at the polls, according to an unpublicized county report that adds to questions about the nation’s readiness for November. The report concludes that these devices — known as electronic poll books — and not the county’s new $300 million voting machines were the source of those delays. Although the voting machines also had problems, the report faults inadequate planning, testing and programming of the poll books that workers used to check in voters and verify that they’re registered — technology that has also been implicated in this month’s meltdown at the polls in Georgia’s primary. Electronic poll books store a copy of the county’s voter registration list and automatically update that list as each voter checks in. Because Los Angeles County did not have backup paper copies of the voter list, poll workers were not able to check in voters when the devices failed, leading to long lines. The hourslong wait times that snarled the March 3 primary in Los Angeles County stemmed from malfunctions in the electronic tablets used to check in voters at the polls, according to an unpublicized county report that adds to questions about the nation’s readiness for November. The report concludes that these devices — known as electronic poll books — and not the county’s new $300 million voting machines were the source of those delays. Although the voting machines also had problems, the report faults inadequate planning, testing and programming of the poll books that workers used to check in voters and verify that they’re registered — technology that has also been implicated in this month’s meltdown at the polls in Georgia’s primary. Electronic poll books store a copy of the county’s voter registration list and automatically update that list as each voter checks in. Because Los Angeles County did not have backup paper copies of the voter list, poll workers were not able to check in voters when the devices failed, leading to long lines. The findings about the March primary, which Los Angeles County quietly posted to its website recently, have not previously been reported.

California: Los Angeles County Claims Elections Will Be Smoother, Voters Aren’t Convinced | Nathan Solis/Courthouse News

Just weeks before health orders effectively shut down the nation due to the novel coronavirus, Los Angeles County voters waited for hours to cast their vote in the March primary election. What should have been the public introduction of a new $300 million voting system turned into a public stumble. An independent review of the election system released Friday details issues with computer tablets used to check-in voters at polling places, improperly trained staff and poor communication. The ePollbook, an iPad-like tablet meant to check-in voters, was unable to sync with the county’s voter database, according to a summary of the independent report. The county announced the findings of the independent review on Friday, but the summary released to the public is dated from earlier in the month. A spokesperson said the county would not release the full document to the public because the report “contains confidential information prepared for the Board of Supervisors and intended to safeguard and improve the voting system and the technology that supports it.”

California: Legislature enacts November mail-ballot law — with surprising GOP support | Jeremy B. White /Politico

Gov. Gavin Newsom on Thursday bolstered his plan to mail every voter a ballot for the November election by signing legislation that passed earlier the same day with support from several Republicans, belying monthslong criticism of absentee voting from President Donald Trump and other GOP leaders. Newsom had already ordered county elections officials to send all eligible Californians ballots in an effort to prevent the general election from becoming a coronavirus health hazard. But that directive has drawn multiple legal challenges — including from the California Republican Party — so enshrining the all-mail mandate in statute puts it on stronger legal footing. By signing Assembly Bill 860 into law, Newsom defused the principal legal argument against the universal vote-by-mail argument. Plaintiffs argued he had exceeded his authority by implementing a sweeping change to election management without consulting the Legislature. California elected officials wanted to avoid a situation like Wisconsin’s April primary, which saw long lines potentially expose voters to other people for long periods. Assemblymember Marc Berman (D-Palo Alto) said AB 860 would prevent Californians from being effectively disenfranchised. California Secretary of State Alex Padilla also supports the measure.

Delaware: Election officials back out of mobile voting weeks before primary | Benjamin Freed/StateScoop

Delaware election officials backed off a plan to offer an online ballot-return method to voters in its primary next month, citing a recent report from security experts that found that the platform being used is vulnerable to hacking that could expose or manipulate how a person’s ballot was cast without being detected by either voters or the vote counters. The platform, OmniBallot, allows election administrators to send ballots to hard-to-reach voters, like deployed military members, civilians living abroad and voters with disabilities, giving them the option to return their completed ballots through a variety of methods, including postal mail, email and fax. But Delaware was also one of a handful of states that planned to test out OmniBallot’s ability to transmit ballots online, which raised concern with some election security analysts who argue that the internet is a dangerous venue for voting. In a June 7 paper, J. Alex Halderman, a computer scientist at the University of Michigan, and Michael Specter, a doctoral student at the Massachusetts Institute of Technology, wrote that OmniBallot “is vulnerable to vote manipulation by malware on the voter’s device and by insiders or other attackers” who can compromise software made by OmniBallot’s developer, Democracy Live.

Georgia: Elections head seeks changes to avoid lines in November | Mark NiesseBen Brasch/The Atlanta Journal-Constitution

Calls for monumental changes to Georgia’s elections arrived Wednesday, with elected officials from both parties demanding more voting locations, shorter lines and a management overhaul in Fulton County, where voters experienced the longest waits. The proposals came after a debacle in Georgia’s June 9 primary that left some voters in line for hours because of precinct closures, voting machine problems and complications stemming from the coronavirus pandemic.These efforts are meant to avoid a repeat of those issues in November’s presidential election, when three times as many in-person voters are expected. Turnout could exceed 5 million voters. In separate events, Republican Secretary of State Brad Raffensperger and Democratic legislators from Fulton heaped blame Wednesday on the county’s elections office. Fulton voters crammed into precincts with few voting machines and a shortage of trained poll workers. Other parts of the state also had problems, especially in densely populated areas with high turnout, but 70% of the problems statewide occurred in Fulton, Raffensperger said.

Kentucky: State braces for possible voting problems in Tuesday’s primary amid signs of high turnout | Michelle Ye Hee Lee /The Washington Post

Fewer than 200 polling places will be open for voters in Kentucky’s primary Tuesday, down from 3,700 in a typical election year. Amid a huge influx in requests for mail-in ballots, some voters still had not received theirs days before they must be turned in. And turnout is expected to be higher than in past primaries because of a suddenly competitive fight for the Democratic Senate nomination. The scenario has voting rights advocates and some local elections officials worried that the state is careening toward a messy day marked by long lines and frustrated voters — similar to the scenes that have played out repeatedly this spring as the novel coronavirus pandemic has disrupted the 2020 primaries. Because of a shortage of workers willing to staff voting sites during the health crisis, each of the commonwealth’s 120 counties is opening a very limited number of polling locations. The two largest counties will have just one in-person location each. On Thursday evening, a federal judge rejected an effort to add polling places in the state’s largest counties, citing a legal standard discouraging last-minute court intervention in election procedures. That means Jefferson County — the state’s largest, home to 767,000 residents and the city of Louisville — will have as its sole polling location a convention and expo center where voting booths have been set up about eight feet apart in a cavernous hall. About 1 in 5 residents in the county is African American, the largest black population in the state.

Michigan: Judge won’t immediately stop Benson’s mailing of ballot applications | Beth LeBlanc/The Detroit News

A Michigan Court of Claims judge denied a request Thursday to halt Secretary of State Jocelyn Benson’s mailing of absentee ballot applications to all registered voters ahead of August primary and November general elections. Nevin Cooper-Keel, Yvonne Black and serial litigant Robert Davis argued Benson was barred from sending the applications by state law and court precedent prohibiting elected officials from mailing unsolicited absentee ballot applications. But Judge Cynthia Stephens argued those rules don’t reflect the loosened voting restrictions enacted under a voting rights initiative approved by voters in 2018. And those cases, Stephen said, only spoke to “local elections officials,” not the secretary of state. “…there is some support for the notion that she possesses superior authority as compared to local election officials,” wrote Stephens, an appointee of Democratic former Gov. Jennifer Granholm.

Minnesota: Minnesota waives absentee ballot witness signature mandate | Steve Karnowski/Associated Press

Minnesota will waive its witness requirements for absentee ballots for the statewide primary election in August under the settlement of two lawsuits sparked by the health threat from the coronavirus pandemic. The lawsuits were filed by political arms of the League of Women Voters of Minnesota and the Minnesota Alliance for Retired Americans. A Ramsey County judge signed off on the consent decree with the retirees Wednesday while a federal judge scheduled a hearing for Thursday on the league’s case. Republican lawmakers complained that Democratic Secretary of State Steve Simon overstepped his authority by settling. “The lawsuits and agreements are a flagrant abuse of the courts and complete runaround of the Legislature,” they said in a statement. Under the settlements, Simon agreed that mailed-in absentee ballots for the primary will be accepted even if they don’t have witness signatures, and that ballots received within two days of the Aug. 11 primary date will be accepted as long as they’re postmarked by Election Day. Minnesota usually requires that the witness be a registered voter or notary public.

Voting Blogs: New Jersey agrees No Internet voting in July, vague about November | Andrew Appel/Freedom to Tinker

A formal settlement agreement has been submitted to the NJ Superior Court regarding online ballot access in the 2020 elections. On May 4, 2020,  New Jersey’s Division of Elections was caught trying to adopt vote-by-Internet on the stealth, even though the law forbids it.  That is, not only is Internet voting inherently insecurable, there’s a 2010 Court Order still in effect that says, “computers utilized for election-related duties shall at no time be connected to the Internet.”  That’s based on the New Jersey Superior Court’s finding that “As long as computers, dedicated to handling election matters, are connected to the Internet, the safety and security of our voting systems are in jeopardy,” in the case of Gusciora v. Corzine. Penny Venetis, attorney for the Gusciora plaintiffs, filed a motion (in early May) with the Court, to make the State abandon its plans for online voting, on the basis that receiving ballots e-mailed or uploaded on the Internet clearly violates this order.  The Court ordered the parties to reach a settlement by June 8, or report their separate positions.

New York: From COVID precautions to result delays: What to expect for Tuesday’s primary | Paul Liotta/SIlive

New Yorkers will head to the polls Tuesday for a unique primary in the era of social distancing. Safety precautions, similar to what’s been seen throughout the coronavirus pandemic, will be in place at polling centers across the city, some of which opened Saturday for early voting. According to the New York City Board of Elections, precautions include floor markers to encourage social distancing, antiviral wipes for use as needed, and masks available to voters who need one — face coverings are a requirement for voters. Polling sites will be open from 6 a.m. through 9 p.m. on primary day, but much of the voting will have already occurred with early voting and absentee ballots. As of Thursday morning, 3,814 of Staten Island’s 291,727 active registered voters had already taken advantage of their early voting options, according to unofficial data from the city BOE and voter enrollment data from the state.

North Dakota: After high turnout in pandemic primary, should mail-only voting be North Dakota’s new normal? | Adam Willis/The Dickinson Press

Roughly 158,000 North Dakotans voted in the recent June election, a strong turnout in a historic primary that relied solely on mail-in ballots. Vote-by-mail surged to the fore of national politics this primary season as the coronavirus pandemic had state governments scrambling to restructure their election systems. The outcomes were disastrous in several states, but North Dakota’s move to a completely vote-by-mail election stands out as a relative success. Not only did vote-by-mail reduce the risks for COVID-19 transmission in North Dakota, it also drew some of the highest voter turnout in state history. Among North Dakota primary elections, only 2012 saw higher numbers, with over 175,000 ballots cast. This month’s turnout prompts the question: Should North Dakota join a small group of states that vote exclusively by mail? Nationally, there are several kinds of vote-by-mail systems. Five states, Washington, Oregon, Utah, Hawaii and Colorado, have switched to universal vote-by-mail elections in which the government mails ballots to every registered voter. California recently passed its Voter Choice Act, which gives counties the option to mail ballots to voters while maintaining in-person polls. North Dakota’s mail-in system requires a few more steps. Here, voters must fill out a ballot application to receive their mail-in ballot, and the decision to automatically mail applications to voters is made on a county-by-county level.

Pennsylvania: NAACP sues state for changes to election law before November’s election | Jonathan Lai/Philadelphia Inquirer

The Pennsylvania NAACP sued the state Thursday demanding an overhaul of the electoral system before November because, it said, the system in place for the June 2 primary was not equally accessible and disenfranchised black and Hispanic voters. Among the changes the civil rights group seeks are stricter limitations on how many polling places a county can close, better notice of changes to locations, in-person early voting, automatic sending of mail ballot applications to all voters, and universal use of hand-marked paper ballots at polling places. To adapt to the coronavirus pandemic in the primary, voting places were sharply limited in many counties and officials were overwhelmed by applications for mail ballots and not able to process them quickly. The changes the group is seeking are necessary, it said, because most epidemiologists expect the pandemic to continue in the fall. On June 2, voters who went to the polls had to risk their lives and health — while those who tried to vote by mail were not always able to do so, the NAACP Pennsylvania State Conference said. “As the primary election made clear, many Pennsylvanians have been burdened by the hardships of voting in a pandemic under Pennsylvania’s current scheme. Still, these burdens were not, and in the future will not be, shared equally among Pennsylvania voters. … [W]hile some voters can vote burden-free, African-American and Latino voters are more likely to face an unacceptable and unnecessary risk to their lives and health,” the suit reads.

Texas: Democrats ask U.S. Supreme Court to weigh in on voting by mail | Alexa Ura/The Texas Tribune

After a series of losses in state and federal courts, Texas Democrats are looking to the U.S. Supreme Court to expand voting by mail during the coronavirus pandemic. The Texas Democratic Party asked the high court Tuesday to immediately lift the 5th U.S. Circuit Court of Appeals’ block on a sweeping ruling that would allow all Texas voters who are seeking to avoid becoming infected at in-person polling places to instead vote by mail. Early voting for the July 14 primary runoff election begins June 29. The fight to expand who can qualify for a ballot they can fill at home and mail in has been on a trajectory toward the Supreme Court since Texas Democrats, civil rights groups and individual voters first challenged the state’s rules months ago when the new coronavirus reached Texas. Under existing law, mail-in ballots are available only if voters are 65 or older, cite a disability or illness, will be out of the county during the election period or are confined in jail.n “Our constitution prevents our government from discriminating against voters due to age. Especially during this pandemic, why should we be penalized for being under age 65?” said Brenda Li Garcia, a registered nurse in San Antonio and plaintiff in the case, during a virtual press conference announcing the appeal to the Supreme Court. “To protect a certain group and to give only certain ages the right to vote by mail is arbitrary, discriminatory and unconstitutional.”

Utah: Elections director outlines voting changes, prepares for primary | Sahalie Donaldson/Deseret News

With laws locked in place altering voting practices to account for COVID-19, Utah’s upcoming June 30 primary election will be unlike any that has preceded it. Justin Lee, the state’s director of elections, swiftly walked through the changes with Utah lawmakers Tuesday afternoon during a meeting of the Legislature’s Government Operations Interim Committee. Discussion on the changes was brief, and Lee urged lawmakers and their constituents to remember that patience, while difficult, is going to be key working forward. “Everyone is going to need to be very patient with election results,” Lee said. “They are going to be a little bit slower, they are going to be a little bit longer, and in close races as we’ve seen in the past, we may not have final results or even definitive breaks between candidates for a couple of weeks after Election Day.” The delay is connected to a couple of changes largely implemented through laws passed during the April special session in HB3006.

Wisconsin: Elections Commission approves sending 2.7 million absentee ballot request forms to voters | Patrick Marley/Milwaukee Journal Sentinel

State election officials signed off Wednesday on a plan to send absentee ballot request forms to most registered voters despite a last-minute push by a Republican lawmaker to halt the effort. The Wisconsin Elections Commission, which consists of three Republicans and three Democrats, unanimously agreed to send 2.7 million registered voters forms they can use to have absentee ballots sent to them for the Nov. 3 presidential election. No one will be sent an actual absentee ballot unless they specifically ask for one. Ahead of the vote, GOP Rep. Rick Gundrum of Slinger called the $2.25 million plan too costly and said it could lead to voter confusion. In a letter, he asked the commission to let each community decide for itself how it wants to handle absentee ballots. “Municipal clerks are more acquainted with each of their respective communities and are better suited to handle absentee ballot requests in the manner in which they have in place,” he wrote in the letter.