October 3, 2024
Wisconsin Elections Commission
201 West Washington Avenue, Second Floor
Madison, WI 53703
Via email
2024 Post-Election Electronic Voting Equipment Proposed Guidelines and Procedures
Dear Members of the Wisconsin Elections Commission:
On behalf of Verified Voting, I submit these comments on the proposed 2024 Post-Election Electronic Voting Equipment Proposed Guidelines and Procedures, prepared for the October 4, 2024 Wisconsin Elections Commission meeting. Verified Voting is a nonpartisan nonprofit organization whose mission is to strengthen democracy for all voters by promoting the responsible use of technology in elections. We believe that the integrity and strength of our democracy rely on citizens’ trust that each vote is counted as cast.
Post-election tabulation audits provide an important check on voting system performance and provide crucial evidence that the ballots were tabulated correctly. We applaud the measures that Wisconsin has adopted in recent years to improve and expand its post-election voting equipment audits. Wisconsin took an important step in 2018 when it first moved to pre-certification audits.
We support the staff’s overall recommendation that the audit be completed prior to certification. We also appreciate the challenge of auditing elections when a recount, especially one statewide, is possible.
We would, however, encourage the Commission to maintain the audit as a pre-certification audit, especially if no recount takes place. The default audit completion deadline is November 25, but according to the proposed audit calendar, this deadline could shift if a statewide recount is possible. For instance, if the recount petition deadline falls after November 18 and no recount petition is received, the proposed audit procedures would require municipalities to submit their audit results one day after the state certification deadline on December 1. This seems like a missed opportunity. Even partial audit results could provide the Commission, and ultimately the public, with greater confidence in the accuracy of the election results.
Audits have value even when a recount takes place. In Wisconsin, audits generally
examine more contests, and they are conducted entirely by hand, unlike recounts. The materials do offer some suggestions regarding how to coordinate these two processes. For instance, some municipalities in the past have conducted an audit directly after a recount, as a means of ensuring chain of custody for the recount. Staff also suggest that recount results for a specific reporting unit could “count” towards a municipality’s audit, if the recount were conducted by hand. Since the selection of reporting units for audit is conducted on November 6, municipalities will have early notice of which reporting units, if any, they have selected for audit and could prepare accordingly.
Thank you for your consideration of these comments.
Respectfully submitted,
Chrissa LaPorte
Senior Policy & Technical Associate