OVERSIGHT HEARING ON THE ELECTION 

ASSISTANCE COMMISSION 

HEARING 

BEFORE THE

SUBCOMMITTEE ON ELECTIONS 

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ADMINISTRATION 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED TENTH CONGRESS 

FIRST SESSION 

HELD IN WASHINGTON, DC, MARCH 12, 2008 

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OVERSIGHT HEARING ON THE ELECTION ASSISTANCE COMMISSION 


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OVERSIGHT HEARING ON THE ELECTION 

ASSISTANCE COMMISSION 

HEARING 

BEFORE THE

SUBCOMMITTEE ON ELECTIONS 

COMMITTEE ON HOUSE 

ADMINISTRATION 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED TENTH CONGRESS 

FIRST SESSION 

HELD IN WASINGTON, DC, MARCH 12, 2008 

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(II) 

COMMITTEE ON HOUSE ADMINSTRATION 

ROBERT A. BRADY, Pennsylvania, Chairman 

ZOE LOFGREN, California 

Vice-Chairwoman 

MICHAEL E. CAPUANO, Massachusetts 

CHARLES A. GONZALEZ, Texas 

SUSAN A. DAVIS, California 

ARTUR DAVIS, Alabama 

VERNON J. EHLERS, Michigan 

Ranking Minority Member 

DANIEL E. LUNGREN, California 

KEVIN MCCARTHY, California 

S. ELIZABETH BIRNBAUM, Staff Director 

WILLIAM PLASTER, Minority Staff Director 

SUBCOMMITTEE ON ELECTIONS

ZOE LOFGREN, California, Chairwoman 

CHARLES A. GONZALEZ, Texas 

SUSAN A. DAVIS, California 

ARTUR DAVIS, Alabama 

KEVIN MCCARTHY, California 

VERNON J. EHLERS, Michigan 


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OVERSIGHT HEARING ON THE ELECTION 

ASSISTANCE COMMISSION 

WEDNESDAY, MARCH 12, 2008 

HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON ELECTIONS, 

COMMITTEE ON HOUSE ADMINISTRATION, 

Washington, DC. 

The subcommittee met, pursuant to call, at 3 p.m., in room 1310, 

Longworth House Office Building, Hon. Zoe Lofgren (chairwoman 

of the subcommittee) presiding. 

Present: Representatives Lofgren, Gonzalez, Davis of California, 

Davis of Alabama, McCarthy, and Ehlers. 

Staff Present: Liz Birnbaum, Staff Director; Charles T. Howell, 

Chief Counsel; Thomas Hicks, Senior Election Counsel; Janelle Hu, 

Election Counsel; Jennifer Daehn, Election Counsel; Matt Pinkus, 

Professional Staff/Parliamentarian; Kyle Anderson, Press Director; 

Kristin McCowan, Chief Legislative Clerk; Daniel Favarulo, Legislative Assistant, Elections; Matthew DeFreitas, Staff Assistant; 

Gineen Beach, Minority Election Counsel; Bryan T. Dorsey, Minority Professional Staff; and Ashley Stow, Minority Election Counsel. 

Ms. LOFGREN. Good afternoon, and welcome to the Subcommittee 

on Election’s oversight hearing on the Elections Assistance Commission. The purpose of the hearing will be to examine what the 

EAC has done to improve its policies and procedures since our first 

hearing last August and what the EAC has planned, leading up to 

the 2008 general elections. 

The EAC has been operational for 5 years. However, it is still 

having difficulties becoming a fully functioning agency. Although 

the EAC has made changes since our last oversight hearing, recent 

reports by the agency’s Inspector General are cause for concern. As 

we will learn today, the IG found that the EAC lacks policies and 

procedures in all program areas, from document, governance and 

accountability, short- and long-term strategic plans and performance goals to a clearly defined organizational structure. Additional 

reports also cite improvements needed in the management of travel 

expenses. 

Today we will also have the opportunity to discuss the just-released IG investigative report on the preparation of the voter fraud 

and intimidation report. This report was the subject of much interest, both by the public and this committee. I appreciate the time 

and effort that went into the report that we received today and 

that the initial request for the investigation came from the EAC 

commissioners themselves. 


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While the investigation does not reveal that any political motivation was behind the changes and delayed release of the report, it 

does disclose a poorly conceived and managed project. The investigation, coupled with the Inspector General’s testimony, provides 

clear evidence of the Commission’s lack of an effective organization 

and management structure. 

However, we are not here to simply discuss what is wrong with 

the EAC. We are to learn what corrective action the EAC has 

taken since our last hearing and the agency’s plans for the future. 

The EAC has received recommendations for change from the IG 

and has taken some steps toward developing sound goals, objectives, plans, policies and procedures. And that should be acknowledged, and I do acknowledge it. 

Unfortunately, we must now discuss whether those changes are 

enough and what role the EAC is capable of playing, particularly 

in light of what could be a very highly charged 2008 presidential 

election. 

So I look forward to hearing from our witness today, the IG as 

well as the commissioners. I thank them for being here, and look 

forward to seeing how we can work together to have a better system. 

At this point, I would turn to our ranking member, Mr. McCarthy, for his opening statement. 

[The statement of Ms. Lofgren follows:] 


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Mr. MCCARTHY. Thank you, Madam Chair. 

I just appreciate this hearing. One, I guess it is rather timely 

now, with the IG report coming out, finding no evidence to support 

allegations that the charges were made to the report due to improper reasons or political motivation. 

And I know this committee or Madam Chair had a number of lettered concerns, so I want to make sure we give enough time to answer all the questions that we need to go forward and see where 

corrections need to be made but also see where allegations were not 

true, at the same time, to be known for the public as well. 

We have a lot of different questions to move forward, but I thank 

the Madam Chair for holding the hearing. 

Ms. LOFGREN. I thank you, Mr. McCarthy. 

And we would now turn to Mr. Crider for your testimony. As you 

know, your full statement is made part of our official record. We 

would ask that your testimony consume about 5 minutes so that 

the members can have time to pose questions to you. And, at this 

time, we would welcome your testimony. 

STATEMENT OF MR. CURTIS CRIDER, INSPECTOR GENERAL, 

ELECTION ASSISTANCE COMMISSION 

Mr. CRIDER. Thank you, ma’am. 

Chairman Lofgren, Ranking Member McCarthy, members of the 

committee, thank you for the opportunity to discuss the activities 

of the Office of Inspector General of the U.S. Election Assistance 

Commission. 

In its year and one-half of existence, the I.G. Office, which currently consists of me and a contractor, has concentrated on two 

areas: use of Help America Vote Act funds by States and the internal administrative operations of the Commission. 

In addition, the Office of Inspector General has completed two investigations. Investigations were performed for the EAC by the Office of Inspector General for the Department of the Interior. 

And I would like to publicly thank the Department of the Interior Office of Inspector General, in particular Mr. Earl Devaney, 

the Inspector General, for his help and support in the last year and 

a half, in terms of helping my office get established and get it up 

and running. His support has been invaluable. 

The focus of my testimony is on the internal operations of the 

Commission. Pertinent audits covered Commission travel and Commission program and financial controls. The relevant investigation 

dealt with voter fraud report. 

The audit of travel: The objective of the audit was to determine 

whether travel was performed in accordance with Federal travel 

regulations, travel cards were properly controlled and used for only 

official purposes, and travelers paid their bills in a timely fashion. 

The audit found that the Commission did not follow Federal travel regulations in performance of travel. The audit identified errors 

in 91 percent of the travel packages—that is, authorizations and 

vouchers—examined. While the majority of the errors were minor, 

such as claiming taxes as a part of the lodging rate, some were 

more significant, such as traveling to a location that was not authorized or claiming a lodging rate that exceeded the authorized 

rate. 


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Overall, the mistakes demonstrated a need for independent controls and clear instruction on the preparation and approval of travel authorizations and vouchers, and for reviews of the accuracy of 

the travel charges. 

We also noted the need for procedures to ensure that international travel is essential to the EAC mission and employees receive compensatory time when traveling on their own time. 

Finally, we concluded that travel cards were adequately controlled and used for official purposes and that travelers generally 

paid their travel bills on time. 

We made four recommendations in July of 2007 to the Executive 

Director. One was to implement written procedures for conducting 

temporary duty travel; two, implement written procedures approval 

of international travel; modify the procedures for approval of travel 

funded by non-Federal sources; and implement written procedures 

for authorizing tracking of compensatory time. 

To date, none of the recommendations have been implemented. 

However, the Director of the Finance and Administration of the 

U.S. Election Assistance Commission has instituted an audit program of travel vouchers, where she reviews the travel vouchers and 

the authorizations to make sure that the travel charges are in accordance with the travel authorization and the claims are allowed 

by the Federal travel regulations. But there still is a lack of written policies and procedures. 

In addition, the EAC has provided travel training to its employees so that employees now know how to prepare travel vouchers. 

And I think those things have helped. But there still is a very 

strong need for written policies and procedures. 

The second review we did was assessment of the Commission’s 

program and financial operations. The purpose of the review was 

to identify the programs and administrative activities performed by 

the Election Assistance Commission and to assess for those programs the vulnerability of fraud, waste and abuse and areas of 

mismanagement. 

This assessment identified a need to immediately address longstanding and overarching weaknesses related to Commission operations. Specifically, the assessment disclosed that the Commission 

lacked: short- and long-range strategic plans, performance goals 

and measurements to guide the organization and its staff; an organizational structure that clearly defines the areas of responsibility 

and an effective hierarchy for reporting, especially between the 

Commissioners and the Executive Director—the staff needs to 

know who is in charge, and that is still a recurring problem at the 

EAC; appropriate and effective internal controls need to be established based on risk assessments; and policies and procedures in all 

program areas to document governance and accountability structure and practices in place. 

The report made 29 recommendations to improve the EAC operations. In response, the Executive Director has developed an action 

plan with milestones to address the issues identified in the report. 

The OIG plans to meet with the Executive Director on a monthly 

basis to assess where they are at, in terms of the corrective action, 

and try to make sure that the milestones are, in fact, met. 


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In terms of investigations, yesterday and today we issued the investigative report on the voter fraud report. In September 2005, 

the U.S. Election Assistance Commission hired two consultants to 

conduct a study on voter fraud and voter intimidation. In August 

of 2006, the consultants completed their work and provided it to 

the EAC for review. The EAC officials edited the report and publicly released a final version in December of 2006. 

Subsequent to the release, it was learned that the EAC final report differed from the consultants’ report, causing speculation that 

the report had been changed due to political motivation and other 

improper reasons. The consultants’ report read, ‘‘There is a widespread but not unanimous agreement that there is little polling 

place fraud.’’ The final version of the report, after editing by EAC 

officials, concluded in its executive summary that, ‘‘There is a great 

deal of debate on the pervasiveness of fraud.’’ When the difference 

was disclosed by the New York Times, the allegation was made 

that the Commission changed the report due to political reasons. 

We conducted the investigation at the request of Commission 

Chair Donetta Davidson, who asked for a review of the circumstances surrounding the voter fraud and voter intimidation research project. The investigation centered on four general areas: 

The hiring of the consultants, the consultant staff report, the 

changes to the draft report, and potential external influences on 

the report. 

Overall, the investigation found no evidence to support the allegation that changes to the report were made for improper reasons 

or for political reasons. Investigators did, however, disclose a poorly 

conceived and managed project. The investigation found there was 

confusion regarding the intended scope of the project, the intended 

use of the consultants’ draft report. In addition, the investigators 

found the EAC officials reviewing the consultants’ report believed 

that the report was poorly written and contained unsupported conclusions and, therefore, required substantial editing. This, coupled 

with the delays in the EAC beginning the editing process, caused 

the final report to be released 4 months after receiving the consultants’ draft. 

The investigators also made the observation that the voting 

fraud project and issues related to voter fraud were a highly 

charged political issue, and that the decision to edit the report 

without including the consultants for input, along with their data 

produced in the final report, undoubtedly fueled speculations raised 

by the opponents of the final report. 

In conclusion, the Commission lacks an effective management organizational structure. What it has been able to accomplish, in my 

opinion, is due to the drive of individuals and not the organization. 

The Commission needs to make substantial improvements in its 

operations. The basic components for a good, sound organization—

goals, objectives, plans, policies and procedures—still do not exist, 

despite 3 years of operation. 

Furthermore, it is imperative that the Commissioners define 

their roles and responsibilities and those of the Executive Director 

to ensure that management decisions are made in a consistent, 

timely and nonpartisan fashion. 


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This concludes my testimony, and I would be happy to answer 

any questions. 

[The statement of Mr. Crider and the IG report follow:] 


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Ms. LOFGREN. Thank you very much, Mr. Crider. 

I would note that ordinarily we have a little red light that goes 

on when your time is up, and it is not functioning today. But you 

were very terse, and we appreciate that. 

We will now go to our 5 minutes of questions. I think I will, 

when we get close to our 5 minutes, I will do my gavel so members 

can know that they need to wrap up. 

And we will start first with my colleague from California, a member of the subcommittee, Congresswoman Susan Davis, for 5 minutes. 

Mrs. DAVIS of California. Thank you very much. 

Thank you, Mr. Crider, for being here. 

I appreciate the fact that you raise the issue in the difference between the two versions. I am just wondering the extent to which 

did you feel that this was a pretty big edit or a not-so-big edit? And 

is there a way that the EAC might have been able to deal with this 

in a way that is a little more up-front? 

Mr. CRIDER. That is a politically charged question, in terms of 

the various versions, because—depending upon the reader and how 

they want to interpret the writing. 

Could the EAC have done better? Yes, they could have. Could 

they have involved the consultants in the revisions to the report? 

One of the issues that became involved here was that the consultants’ contract had, in fact, expired and that, when they delivered 

the product, the EAC took it and then started working with it. But, 

yes, we could have involved the consultants with the revisions to 

the report. 

But I think it goes back further, in terms of how the project was 

initially structured and how it was managed; that, even from the 

very beginning, I think there was confusion as to what was going 

to be delivered, how it was going to be delivered and what was 

going to be done with the product. 

And when you go back through the whole history of the project—

and I think that led up to this particular scenario—is that, when 

we got the product, we did not go back, as you would with any 

other contractor, and try to work with the contractor to get revisions to the product. 

The project was done under a personal services contract, which 

means that they were basically employees of the agency during this 

period of time, and their work then became the product of the 

agency—or the agency-only work product. 

So I think a number of things contributed to this, but, yes, they 

could have done better. They could have worked with the consultants, in terms of making the revisions and trying to make sure 

they understood why the revisions needed to be made. And I think 

that is where one of the biggest failings was, is that we didn’t go 

back and say, ‘‘Okay, this is why we need to make those changes.’’

Mrs. DAVIS of California. Clearly, I mean, the EAC is in a difficult position. But I am just wondering, what kind of pressure do 

you see that they actually do come under to deal with that pressure? 

Mr. CRIDER. I think I should let the Commissioners answer that 

question, because they are the ones that have to deal with that. I 


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don’t have to deal with it. So I think they would be the ones in the 

best position to answer that question. 

Mrs. DAVIS of California. What do you think Congress could do 

or should be doing to be more involved in this process? Is there 

anything that you see that is appropriate? 

Mr. CRIDER. I think the hearing today and things of this nature, 

where there is oversight, vigilance in terms of what the EAC is 

doing, and making sure that the EAC has sufficient resources to 

do the job that it needs to do, would all contribute toward a successful mission. 

Mrs. DAVIS of California. And when you take a look at other 

agencies like the EAC, how does it compare? 

Mr. CRIDER. We are extremely small in relationship to other Federal agencies. 

During the period of this study, the EAC was also under a personnel ceiling cap, is my understanding, where they could not hire 

people. So they had people trying to perform multiple jobs and multiple functions at the same time. 

That cap has now been removed, and the EAC is trying to hire 

people so that people can start performing the functions that they 

were hired to do, versus trying to do multiple jobs at the same 

time. 

Mrs. DAVIS of California. Thank you. I appreciate it. 

Madam Chair. 

Ms. LOFGREN. Thank you. The gentlelady yields back. 

I just realized that I invited you to give your testimony without 

properly introducing you to our audience. So if I may just divert 

for a moment, Mr. McCarthy. 

Mr. Crider, as we know, is the IG for the U.S. Election Assistance Commission and has been since August of 2006. He has 32 

years of auditing experience in the Federal Government and is a 

1975 graduate of Clemson University. He is also a certified public 

accountant and a certified internal auditor. And we are pleased to 

have him here today. 

And, with that, I would yield to the ranking member, Mr. McCarthy, for his 5 minutes of questions. 

Mr. MCCARTHY. Thank you, Madam Chair. 

I just got your IG report last night. I guess it is dated March 

10th. Looks rather thorough, 17 pages. I read through most of it. 

How many hours did you put into this audit? 

Mr. CRIDER. We contracted with the Department of the Interior 

Office of Inspector General to conduct the investigation. So I don’t 

know how many hours they put into it. If you would like that information, we can get it. 

Mr. MCCARTHY. Okay. If you can follow up, that would be very 

helpful. 

But I was wondering, after investigating all the circumstances 

surrounding the vote fraud and the voter intimidation research 

project, did you find any evidence of partisanship on the part of the 

EAC? 

Mr. CRIDER. No, we did not. 

Mr. MCCARTHY. Having gone through all of that, as well, did you 

find any evidence that Hans von Spakovsky influenced the content 

of the report? 


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Mr. CRIDER. He sent some e-mails to the Chair of the EAC at 

that particular point in time, and the Chair responded very strongly that he would not be a party to any deal-making, he would not 

be a party to any type of pressure or anything of that nature. So 

I think the EAC responded appropriately. 

Mr. von Spakovsky does not believe that he tried to unduly influence the project. But, like I said, I think the Chair of the U.S. Election Assistance Commission responded appropriately. 

Mr. MCCARTHY. Do you feel it is proper that people are able to 

e-mail and give input to the EAC? 

Mr. CRIDER. You have to have public input; you can’t operate in 

a vacuum. There is a very strong constituency out there. This is 

a very important arena that we work in. And saying people can’t 

e-mail or talk to people would not be appropriate, because I think 

you would have to have a wide base of people that you get ideas 

from and thoughts from and even criticism. So I think you do need 

that. 

Mr. MCCARTHY. Okay. I agree with you. I believe we should be 

very open. I believe e-mails give you greater accountability and 

give you greater input and give you continual education upon the 

subject. 

You had mentioned a little earlier about the staffing size and the 

multiple jobs. Do you find that was one of the major problems 

when it comes to some of the points you lay out about their need 

for greater bookkeeping? 

Mr. CRIDER. I think people were stretched very, very thin, and 

they were trying to do multiple things at the same time. And, in 

some cases, I think people may have been doing functions that they 

maybe should not have been. 

And that is just where you need to have enough people in order 

to segregate duties, to make sure that people do stay within their 

areas of expertise and can then perform the functions they were 

hired to do. 

Mr. MCCARTHY. How many more people do you feel the EAC 

needs to hire to be able to——

Mr. CRIDER. Right now I think they have hired seven people, to 

date, in the last 6 months. 

And I think the—one of the things that the EAC needs to do is 

to take a look at—which we recommended as part of our assessment report—is take a look at the skill sets that they currently 

have and what skill sets they need to acquire, as well as develop 

strategic plans, operating goals and procedures. 

Right now, they are sort of like a ship without a rudder. And 

they need to focus in on what the mission of the organization is 

and determine what level of resources they do need. So I cannot 

give you an answer—10 people, five people. I think the Commission 

needs to focus in on that and decide what its mission is and how 

they are going to go about doing it. 

Mr. MCCARTHY. Do you think a year is enough time to—some of 

the corrections you asked for in here—is enough time to achieve all 

of that by the EAC? 

Mr. CRIDER. I would like to think that some of them could be 

done a lot sooner than that. And that is one of the reasons why 


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we requested the action plan as a part of our assessment report, 

so that we can monitor and track. 

Some of the things are going to take an extensive period of time. 

This is not going to happen overnight. But I would think a year 

should be more than sufficient time for them to get the stuff done 

that we think they need to do. 

Mr. MCCARTHY. Okay. Well, I thank you for your time. 

And I yield back, Madam Chair. 

Ms. LOFGREN. Thank you. 

I would recognize Mr. Artur Davis, member of the committee, at 

this point. 

Mr. DAVIS of Alabama. Thank you, Madam Chairwoman. 

Let me, Mr. Crider, turn to, I guess, the part of the report that 

is probably of most interest to people who aren’t knowledgeable 

about all the weeds—that is, the portions related to Mr. von 

Spakovsky. 

As I understand it, he has been nominated for a position on the 

FEC, and there has been a significant amount of controversy 

around his nomination. Is that right? 

Mr. CRIDER. Yes, that is my understanding. 

Mr. DAVIS of Alabama. Did you—and I apologize, I did not have 

more time to read your report—but did you interview him in connection with preparing your IG report? 

Mr. CRIDER. Yes, he was interviewed. 

Mr. DAVIS of Alabama. And did you question him about this August 29, 2005 e-mail that refers to, quote, ‘‘a political compromise 

agreement’’? 

Mr. CRIDER. Yes, sir. 

Mr. DAVIS of Alabama. And did he—just give me some sense of 

what his response was to this notion of a political compromise 

agreement between DOJ and EAC. 

Mr. CRIDER. I am sorry, sir? 

Mr. DAVIS of Alabama. Could you give me some sense of what 

his reaction was to that language, ‘‘political compromise agreement’’? Did he share that characterization? Did he dispute it? What 

was his reaction? 

Mr. CRIDER. Mr. Davis, I don’t have the report right here in front 

of me. And I would prefer to provide you that information for the 

record, if you don’t mind. 

Mr. DAVIS of Alabama. Well, do you remember that? I mean, it 

seems like a fairly meaningful conversation. 

Mr. CRIDER. The Department of the Interior conducted the investigation for us, okay? 

Mr. DAVIS of Alabama. Okay. 

Mr. CRIDER. And we have copies of the interviews, and we have 

read the interviews, but it was over a period of time, and I don’t 

want to misquote. 

Mr. DAVIS of Alabama. Well, let me try to perhaps pick up where 

Mr. McCarthy left off. The question that might be of some interest 

to our colleagues in the Senate is, what is the appropriate level of 

engagement, if you will, between someone like Mr. von Spakovsky 

and the process that was going on at the EAC? Where do you draw 

that line, in the perspective of the Inspector General? 


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Mr. CRIDER. The Department of Justice is on several advisory 

boards by law, and so they do have input into a number of functions that the EAC performs by law. And, therefore, you know, that 

is what Mr. von Spakovsky was involved with. And, like I said, 

that is by law. 

Mr. DAVIS of Alabama. What about this notion of a, quote, ‘‘political compromise agreement.’’ I don’t have in front of me the authorizing statute for the EAC, but I suspect, if I looked at it, there 

would not be any reference to the EAC having the capacity to reach 

political agreements with the Department of Justice regarding its 

mission scope. 

Does that phrase, ‘‘political compromise agreement,’’ trouble you? 

Mr. CRIDER. Yes, it does. I think that the Chair of the U.S. Election Assistance Commission did respond appropriately and strongly 

that he did not make deals. I think that type of language would 

be very troublesome. 

Mr. DAVIS of Alabama. What does it say to you that Mr. von 

Spakovsky apparently thought it appropriate to make a deal? 

Mr. CRIDER. That there needs to be some clarification as to what 

roles people play, in terms of the advisory boards, and what input 

they need to have. 

Mr. DAVIS of Alabama. Have you provided a copy of your report 

to the United States Senate, which apparently is considering his 

nomination to be on the FEC? 

Mr. CRIDER. They have received the redacted version. 

Mr. DAVIS of Alabama. Okay. Can you explain to me why a redaction was necessary? 

Mr. CRIDER. The interviews were not provided as a part of the 

report, because there is information in there that is covered by the 

Privacy Act. 

Mr. DAVIS of Alabama. Is there anything that you came across 

in your report that you think might be relevant to Mr. von 

Spakovsky’s fitness to serve on the FEC? 

Mr. CRIDER. Not to my knowledge, no, sir. 

Mr. DAVIS of Alabama. Would you consider his veracity, or lack 

of veracity, to be relevant to his fitness to serve? 

Mr. CRIDER. That is not for me to decide. That is something that 

the Senate should decide when they take him up for confirmation. 

But we have his interview. 

Mr. DAVIS of Alabama. Do you remember if there were any credibility disputes or any differences of factual assertions between Mr. 

von Spakovsky and other individuals that were interviewed? 

Mr. CRIDER. No. I am not aware of any. 

Mr. DAVIS of Alabama. Okay. Meaning that there weren’t any or 

you just don’t remember if there were any? 

Mr. CRIDER. I am not aware of any. 

Mr. DAVIS of Alabama. Okay. Well, I don’t want to take a lot of 

time, because we are trying to move on to our second panel, but 

I think you get the thrust of the concerns that I am raising. I 

think, as Mr. McCarthy pointed out, there is a line, and then there 

is conduct that falls on the permissible side of the line. What I hear 

you saying is that Mr. von Spakovsky may well have crossed that 

line, if these statements are accurate. 


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And I am just struck again and troubled again by this notion of 

a political compromise agreement. If the EAC is going to render 

dispassionate opinions about how the election process is working, 

I don’t know if they can do that by reaching political compromises. 

It would seem that that is the task of this institution. 

And if I understand the boundaries correctly, the EAC’s role is 

to make recommendations, to objectively assemble facts. Then it is 

up to us to make the political assessment and up to us to forge a 

political compromise. 

Have I got that about right, Madam Chairwoman? 

Ms. LOFGREN. The gentleman’s time has expired. 

Mr. DAVIS of Alabama. Okay. Well, I will take that as meaning 

I got it right. I yield. 

Ms. LOFGREN. That little marimba is on my iPhone. I am using 

the timer here. 

I recognize the ranking member of the full committee, Mr. Ehlers 

of Michigan, for 5 minutes. 

Mr. EHLERS. Thank you very much. 

I appreciate you being here, Mr. Crider. 

I have just been reading the summary of what you found. Is it 

typical, when you do enter into a situation like this, that you find 

this many shortcomings in management and accounting? 

Mr. CRIDER. It is unusual to find this many. But you have to remember the EAC is a relatively new organization, and it is time 

for them to grow up and become a Federal agency like it is supposed to be. We can no longer use the excuse, ‘‘We are new.’’ Yes, we were concerned about the number of deficiencies we 

identified. And that is one of the reasons why we are going to be 

meeting with the Executive Director on a monthly basis, to try to 

monitor what is going on, because it is unusual. 

Mr. EHLERS. Yes, I find it appalling, because members of the 

EAC, by and large, have worked in government before. They know 

the stringent requirements of government accounting and management and so forth. And even though it is new, I thought there 

would be a structure set up that would handle these sorts of things 

and do it properly. 

Mr. CRIDER. A significant amount, especially when the EAC was 

first formed—and this is not a criticism of the individuals—their 

experience was more at the State level and not at the Federal level. 

And this is a Federal organization, and we have specific rules and 

things that we need to follow. And I think that is where some of 

the issues started to develop, is that they did not really understand 

how a Federal agency was supposed to operate and what all was 

involved. 

Mr. EHLERS. Okay. I served at the State level too, and I know 

the Federal requirements are very strict, but, in my case, I found 

the State requirements almost stricter, because it is a smaller 

body, reporters are more readily able to understand it, dig into it, 

and write nasty stories. Maybe that is not true in every State, however. 

So thank you. I just appreciate your comments. 

And that is all I have. I yield back. 

Ms. LOFGREN. The gentleman yields back. 

The gentleman from Texas, Mr. Gonzalez, is recognized. 


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Mr. GONZALEZ. Thank you very much, Madam Chairwoman. 

Mr. Crider, let me ask you—and I am only going to spend a couple of seconds on this, because it is of particular concern to us— were the actions taken by Mr. von Spakovsky appropriate or inappropriate? 

Mr. CRIDER. That is a judgment call, sir. And I am not necessarily—obviously, Mr. von Spakovsky feels that he was within 

his rights as a member of the advisory board. The Chair of the 

EAC pushed back. I don’t know if I can make that type of a judgment call. 

Mr. GONZALEZ. Because his complaint was both to form and to 

substance, is my understanding. He complained to the EAC as far 

as the hiring of the consultant Wang and said, ‘‘I don’t believe that 

what we have representing the Republican side’’—because, obviously, he saw that there was a Republican or Democratic side—was 

not sufficient to withstand the aggressive or assertive nature of 

Wang. So that’s the form part: ‘‘I don’t like how you are constituting your consultants.’’ And then, secondly, there was discussion about the substance, 

and that is, ‘‘We had a deal. We were going to conform what we 

had here at DOJ to fit more what you might be doing. But there 

was, more or less, a deal or a compromise.’’ It would seem to me, if I was on the Election Assistance Commission, that that is an overreach, that it would be inappropriate, at 

least from—obviously, I can ask members, the Commissioners and 

such, but I am just thinking you, in your capacity—have you seen 

that occur in any other setting? 

Mr. CRIDER. The advisory boards operate differently than maybe 

what I have seen in other places. And I think that is one of the 

things that the EAC will have to look at, in terms of what role do 

the advisory boards play and what influence should they have, if 

any, and how should that input then be used and generated and 

recorded so there is transparency. 

But the advisory boards—like you said, Mr. von Spakovsky was 

on the advisory board, and he did have knowledge of the project. 

And I think his input was actually sought, in a couple of cases, as 

all the members of the advisory board were. 

Mr. GONZALEZ. And I think basically what I am looking at is 

really the partisan nature of the inquiry, recommendation and interests, as expressed by him. 

Let me move to something else here. In a minute, we will have 

the individual members, and they can probably answer. But, you 

know, following up on what the ranking member was pointing out, 

as to whether this is an inordinate amount of deficiencies, if that 

is how we will refer to them, or areas of concern, but it seems to 

me that what you have is you have problems with process. Mandated studies and reports have not been submitted on due dates. 

You have problems with accounting, as far as the management of 

travel expenses, which may not be anything that is serious or that 

something untoward is happening—or delay in release of reports 

and such. But it seems to be that, just about at every level, there 

is room for improvement. 

But first I need to acknowledge something, and that is that the 

Commission really didn’t get a healthy headstart as a result of 


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Congress’s inaction at its very inception. I remember those days, 

when they didn’t have a place to meet, they didn’t have staff and 

so on. So it is not all their fault that they were a little behind, and 

I acknowledge that. 

Where do they go for that guidance to improve in all of these 

areas that, obviously, you find, not necessarily alarming, but, 

again, of concern. Because you have said it is a good thing to have 

oversight, but there is only so much that we are going to be able 

to do. 

What we do is look at reports and such and we say, ‘‘Look, you 

need to improve here, you need to improve there,’’ and then we just 

kind of let them go at it. But this is a unique, unique commission, 

with a very specific mission that is different and has never existed 

before, to be quite honest with you. 

So where do they go for their guidance? Where would you suggest, in these areas where, obviously, they need to improve? 

Mr. CRIDER. A lot of the things we are talking about here are 

routine operating policies and procedures and things that every 

Federal agency has. Every Federal agency has a travel policy. 

Every Federal agency has a property management policy. Every 

agency has a contracting policy. So you go to other Federal agencies and get the stuff that they have, and then you tailor it to fit 

your circumstances. 

There are contractors out there that specialize in A–123 work, in 

terms of establishing documenting and internal controls. So there 

are plenty of resources out there. We have gone to GAO for some 

guidance; Office of Management and Budget. So there are places 

out there that we can go and that we do need to utilize as an agency. 

Mr. GONZALEZ. Thank you very much, Mr. Crider. 

I yield back. 

Ms. LOFGREN. The gentleman yields back. 

I will now recognize myself for just a few minutes. 

On the report, what role has the general counsel for the agency 

played in drafting, editing and revising the investigative report of 

the vote fraud and intimidation and the study of the impact on 

voter identification? 

Mr. CRIDER. None. 

Ms. LOFGREN. None. 

Mr. CRIDER. They didn’t even see it. 

Ms. LOFGREN. So this was just completely separate. 

Mr. CRIDER. Completely independent and separate from the 

EAC. 

Ms. LOFGREN. Okay. Now, I am concerned that—I mean, there 

is the report itself, that the EAC, I want to emphasize, asked for. 

But there is the broader question of organization and efficacy of the 

agency. It sounds like we almost need, you know, ‘‘agency in a box’’

that you could put in place. I don’t know if that is available in the 

Federal Government. 

I am just wondering if you are satisfied with the action plan that 

the Executive Director prepared in response to your February 

audit? 

Mr. CRIDER. We are pleased with the action plan. And we will 

be monitoring it, as we go through it. And if additional things come 


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out of the implementation phase that need to be added to the action plan, we will work the Executive Director to add those to the 

action plan. 

Because there is no such thing as a complete cookbook for the 

Federal Government. You would think, with the number of new entities being established, that there would be some type of a manual 

or book to say, ‘‘Okay, this is what I need to do,’’ but there is not. 

At least we haven’t found it yet. 

But, no, we are pleased with the action plan. And, like I say, we 

will be monitoring that and adding things as we go through it, if 

we need to, to try to get to the place where the EAC needs to be. 

Ms. LOFGREN. Now, I understand that the GAO is at least considering a review of the agency similar to what they performed at 

one time for the Legal Services Corporation. 

Mr. CRIDER. We have talked to the GAO, and they do not have 

any plans to come in and do it at this point. But we have talked 

to them about doing a similar-type review. But they have not indicated their willingness to do it, at this point. 

Ms. LOFGREN. Okay. Let me just ask a final question, which is 

the—maybe it is not possible to answer. But, in your view, does the 

EAC rely too much on outside individuals and nongovernmental 

groups to determine its focus, or not? I mean, there is no, really, 

agency that is like them. But is that part of what has led to the 

disorganization, do you think? 

Mr. CRIDER. I think that is a contributing factor, but I can’t give 

you any evidence to support that other than my own observations. 

But I do think that the role that the advisory committees and panels play needs to be very clear and understood by everyone, and 

transparent so that everybody understands what is happening with 

those advisory panels. 

Ms. LOFGREN. So, in your judgment, if we have these advisory 

panels, there is value, obviously, in getting input, but there ought 

to be structure and accountability and minutes. And it shouldn’t be 

sending stray e-mails perhaps. But there ought to be action on the 

part of the advisory group itself or some structure that is transparent for individuals to provide input. 

Mr. CRIDER. In my opinion, yes. 

Ms. LOFGREN. Okay. 

I am not going to use the remainder of my time. I will thank you, 

Mr. Crider, for being here and for your service to the Government 

and to the country. 

And we may have additional questions for you. Members have up 

to 5 legislative days to submit additional questions. And we would 

ask you to respond promptly, if we are able to forward those to you. 

We will ask our next panel to come forward. 

Mr. CRIDER. Thank you, ma’am. 

Ms. LOFGREN. And while they are coming forward, I would ask, 

without objection, to enter into the record two letters, one from 

verifiedvotingfoundation.org and the other from Voters Unite, on 

the subject matter of this hearing for the record. 

[The information follows:] 


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Ms. LOFGREN. Our timer is not working, so I have my trusty—

maybe it will be fixed by the time we are through—but I have my 

trusty iPhone here, and it will go off when the 5 minutes are up. 

You all know our procedure. Your full written statements will be 

part of the record. We ask that your oral testimony consume about 

5 minutes, so the members can get to questions. 

We know each of you, but I would like to introduce you formally, 

so that the audience on the webcast and here can know who you 

are. 

First, I would like to introduce Commissioner Rosemary 

Rodriguez. Commissioner Rodriguez currently serves as Chair of 

the Election Assistance Commission. She was appointed in 2007 

and served as Vice Chair of the Commission during her first term. 

Prior to her work with the EAC, Ms. Rodriguez was president of 

the Denver City Council, director of boards and commissions for 

the mayor’s office, and a clerk and recorder for the city, as well as 

the County of Denver, for 5 years. 

We also have Commissioner Caroline Hunter, who currently 

serves as Vice Chair of the EAC. She has served on the Commission since 2007. And prior to her work with the EAC, Ms. Hunter 

was deputy director of the White House Office of Public Liaison; executive officer at the U.S. Department of Homeland Security Office 

of Citizenship and Immigration Services Ombudsman; and deputy 

counsel at the Republican National Committee, where she provided 

guidance on election law and the implementation of the Help 

America Vote Act. 

Next, we have Commissioner Gracia Hillman. Commissioner 

Hillman has served on the Election Assistance Commission since 

2003, where she was first Vice Chair in 2004 and then Chair in 

2005. Prior to her appointment with the EAC, Ms. Hillman served 

as president and chief executive officer of World Space Foundation, 

as well as a senior coordinator for international women’s issues at 

the U.S. State Department. Ms. Hillman also was a former executive director at the League of Women Voters of the United States, 

the Congressional Black Caucus Foundation, and the National Coalition on Black Voter Participation. 

And, finally, we have Commissioner Donetta Davidson. Commissioner Davidson has served on the Election Assistance Commission 

since 2005, where she served as chair in 2007. Prior to her work 

with the EAC, Ms. Davidson served as the Arapahoe County clerk 

and then Colorado Secretary of State, where she was president of 

the National Association of Secretaries of State and president of 

the National Association of State Elections Directors. Ms. Davidson 

also served on the Federal Election Commission Advisory Panel 

and board of directors of the Help America Vote Foundation. 

And we do welcome all of you here today and look forward to 

your testimony and our opportunity to have a dialogue. 

And, let’s see, what is the order? Since I introduced Ms. 

Rodriguez first, let’s hear from you, and we will go on in order. 


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STATEMENTS OF HON. ROSEMARY RODRIGUEZ, CHAIRWOMAN, ELECTION ASSISTANCE COMMISSION; HON. CAROLINE HUNTER, VICE CHAIR, ELECTION ASSISTANCE COMMISSION; HON. GRACIA HILLMAN, COMMISSIONER, ELECTION ASSISTANCE COMMISSION; HON. DONETTA DAVIDSON, 

COMMISSIONER, ELECTION ASSISTANCE COMMISSION 

STATEMENT OF ROSEMARY RODRIGUEZ 

Ms. RODRIGUEZ. Good afternoon, Madam Chair and Ranking 

Member McCarthy and subcommittee members. Thank you for inviting us to come back today. 

We are very pleased the Inspector General’s report is available 

today, because we know that many, many people in Congress and 

at the EAC and in the general public have been waiting for this 

report for, it seems like, a very long time. We are very grateful that 

it is out. 

Since our last hearing in your committee, our Inspector General 

assessed the EAC, and while I cannot say today that the agency 

is completely reorganized, or even organized, we are taking strenuous steps to improve operations. I appreciate the Chair recognizing our efforts in her opening statement. 

We are going to provide the Inspector General with monthly updates on our progress, and I would volunteer to provide those to 

this committee as well. 

Ms. LOFGREN. We would appreciate that. 

Ms. RODRIGUEZ. Okay, thank you. 

We are drafting regulations to govern FOIA, public meetings, 

grants, trade secrets and confidential business information, how to 

request testimony or information from EAC in third-party litigation, Privacy Act procedures, standards of conduct, and EAC’s policy of nondiscrimination. We expect to publish those in April. 

We are drafting travel policies and procedures. We established 

an electronic FOIA reading room. We are in the process of hiring 

a chief operating officer to help with our management shortcomings—admitted management shortcomings. 

After our employee cap was removed, we hired additional staff in 

critical program areas, like the Voting System Certification Division. All senior staff received cross-management training. 

We are going to implement the requirements of the Office of 

Management and Budget’s management controls. We are creating 

an EAC manual to document our governance and accountability 

structure. And, on Friday, we are going to spend an entire day in 

planning to improve our operations. 

I assure you, however, that all of these efforts to achieve internal 

improvements will not interfere with our assistance for election officials. 

Our priority message this year to election official is to prepare 

for a huge turnout: Have enough ballots, voting machines and poll 

workers; adopt a contingency plan. 

The Secretary of State for the State of Arizona is here today, Jan 

Brewer, and she assured us right before we came up here that Arizona is ready. 

The EAC has delivered tools and information, and other testimony will go into that in more depth. I am going to keep this very 


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brief and name three questions that I think we need to be prepared 

for and that I think you will be interested in. 

HAVA says that voting systems purchased with funds appropriated after 2007 must be fully accessible. What systems are considered accessible to individuals with disabilities? 

What is the role of the EAC clearinghouse? 

And Congress provided us with $115 million in new funds—

thank you—but can States use that money to replace touch-screen 

equipment? 

As Chair of the EAC, I assure you that the EAC will focus on 

its responsibilities under HAVA. We will fully inform the Congress 

and the public about our activities. 

Someone pointed out that we are a fairly young organization, but 

that it is really, Congressman Ehlers, no excuse for not being appropriately managed. And we intend to correct that. 

Thank you very much. 

Ms. LOFGREN. Thank you very much. 

Let me turn now to Commissioner Hunter, and invite you to give 

your testimony. 

STATEMENT OF CAROLINE HUNTER 

Ms. HUNTER. Thank you very much. Good afternoon, Chair 

Lofgren, Ranking Member McCarthy, members of the subcommittee. Thank you for asking us to be with you today. 

One of the EAC’s most important mandates under the Help 

America Vote Act is the adoption of the Voluntary Voting System 

Guidelines. The guidelines provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality, accessibility and security capabilities required of voting systems. 

HAVA transferred this responsibility from the FEC to the EAC. 

The EAC adopted its first version of the VVSG in 2005. And we 

are now in the midst of adopting the newest version of the VVSG, 

and we are calling that the next iteration. 

HAVA clearly defines the process for adopting these guidelines. 

The technical guidelines, development committee and NIST provide 

us with an initial draft. We then adopt a final version. We are 

doing that currently, under a public comment review. 

We have a public comment period that will expire on May 5th 

of this year. We are holding a variety of different roundtables with 

different advocacy groups, election officials, voting machine manufacturers and others. And we hope to get as many constructive 

comments from the public as possible, in making the very serious 

and difficult decision on which version of the Voluntary Voting System Guidelines to adopt. 

The newest version will likely be a complete rewrite of the 2005 

guidelines intended to address the next generation of voting systems. They contain new and expanded material in the areas of reliability and quality, usability and accessibility, security and testing. 

According to HAVA, as you know, adoption of the guidelines at 

the State level is voluntary. However, States may formally adopt 

the WVSG, making these guidelines mandatory in their jurisdictions. 


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We often get asked what value voluntary guidelines provide. The 

answer is simple: They provide a base level of conformity testing 

that election officials can rely on, if they choose to do so. States 

have the flexibility to apply the parts of the guideline that make 

sense in their jurisdictions or not to use them at all. 

The EAC is also operating the Federal Government’s first voting 

system certification program. And let me address two issues that 

come up frequently. 

One issue is the vendors paying labs directly. The EAC is not authorized to pay the labs. Any funds we collect must be turned over 

to the Treasury. To allow EAC to do this would require action on 

the part of Congress. And, as we have stated in the past, if Congress wishes to take this action, we stand ready to assist. 

The second issue I would like to mention today is that the Help 

America Vote Act did not give the EAC authority over voting systems that we have not evaluated. Right now we have approximately six systems within our certification program, but, as of this 

date, the EAC has not certified any voting system. 

So there are no EAC-certified voting systems in use today, and 

there likely won’t be in the 2008 election. Therefore, we don’t have 

any authority over the machines that are not certified by us and 

that are probably going to be used in this election. 

Thank you very much. 

Ms. LOFGREN. Thank you very much. 

Commissioner Hillman. 

STATEMENT OF GRACIA HILLMAN 

Ms. HILLMAN. Thank you. Good afternoon, Chairwoman Lofgren, 

Ranking Member McCarthy and members of the committee. 

On several occasions in 2007, this committee raised questions 

about EAC’s decision-making process as it pertains to our research 

and studies. We previously reported that, in May 2006, EAC began 

managing its large research contracts through GovWorks, which is 

a business unit of the Department of the Interior. This relationship 

provides us with Federal contracting expertise that we need. 

Additionally, EAC selects from GSA’s schedule of pre-competed 

vendors for our smaller contracts. And every contract is managed 

by an EAC staff person who has been trained in the management 

of Federal contracts. 

With respect to transparency, Madam Chair, EAC has taken 

three important steps since mid-2007. Our contractors and consultants continue their work until the final product is accepted by the 

Commission. We also receive periodic updates from staff and consultants at our public meetings. And draft research products are 

posted on our Web site. 

Additionally, we continue to work with our advisory boards to review their participation in our research, especially on the front end. 

But, Madam Chair, those and other steps haven’t made a dent 

in our ability to navigate the complexity of being a Federal Government agency. I know that this committee recognizes the many 

structural challenges we face, as do Senate Rules and our appropriations committees. And I recognize that EAC must match its 

commitment to change with tangible action. 


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Our work is significant and has national impact. We must expedite our efforts to improve the operations of our relatively young, 

now-adolescent agency. Yet, despite these challenges, EAC has directed its resources to assist State and local election officials. 

Within the last year, we have produced best-practice guides to 

help improve the administration of Federal elections. I will briefly 

describe two programs which provide this assistance and address 

specific interests of this committee. 

We frequently hear about election day problems caused by 

human error. Well, who are these humans who make these errors? 

Madam Chair, they are hard-working, honest people who volunteer 

to provide poll-worker service in their communities. These workers 

are America’s champions of democracy. They deserve the best 

training available so they can perform with excellence and accuracy. So, obviously, one urgent need is adequate numbers of highly 

trained poll workers. 

EAC has helped to tackle this challenge. You have before you 

EAC documents that provide effective and affordable practices for 

the recruitment, training and retention of poll workers. They are 

guides that look like this, and one in the notebook. And we ask 

that the material be submitted for the record. 

Ms. LOFGREN. Without objection, it will be accepted into the 

record. 

Ms. HILLMAN. Thank you. 

[The information follows beginning on page 124.] 

Ms. HILLMAN. Equally challenging for election officials is the effective design of voting materials. Ballot design flaws made frontpage news in 2000, in 2006, and again this year during the California presidential primary. To help with this challenge, EAC produced and distributed sample materials and best practices for effective designs. 

Ms. HILLMAN. Madam Chair and Members of the Committee, I 

call your attention to the easels in this room. They hold displays 

of sample ballot designs for optical scan and direct recording electronic voting systems. These and other materials were produced by 

EAC after a year of study and field testing. Through these materials, EAC has provided professional expertise at no cost to election 

officials. We have also saved them time and money by providing 

the materials in camera ready images and in different languages. 

Additionally, EAC will hold a ballot design workshop in April, and 

we are providing information to the History Channel on this and 

other topics as it produces a series on elections. 

Madam Chair, I will close by saying that I have worked for over 

30 years to ensure fair and equal access to the franchise. EAC can 

and must perform a critical role in ensuring access and accuracy 

despite its limitations under the Help America Vote Act. Having 

said that, I also know that Congress and the American voters must 

have confidence in EAC’s ability to efficiently and openly serve the 

public good. EAC’s success depends on the continued production of 

high quality and unbiased information. It depends on transparency 

and efficiency and it depends on your continued support. I look forward to answering your questions. Thank you. 

Ms. LOFGREN. Thank you very much. We would turn now to 

Commissioner Davidson. 


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STATEMENT OF HON. DONETTA DAVIDSON 

Ms. DAVIDSON. Thank you. Good afternoon, Chairwoman 

Lofgren, Ranking Member McCarthy and Committee. Let me start 

by saying I am glad the IG report is out and done. It confirms what 

we felt we all knew. There was no partisan influence. That is why 

I requested the report and that I had unanimous consent with my 

commissioners. In the review, you will see that I reached across the 

aisle and discussed my concerns about voter ID report with another 

commissioner. Our conversation was shared with third parties for 

the purpose I don’t know. And the information passed along was 

incorrect. I was concerned about voter ID report. For example, I 

felt that the statistics were not accurate. I will continue to urge to 

be transparent in our process across the board. And I will fully 

support and continue working with all of the commissioners because 2008 is going to be a very busy year. 

As the Chair said, due this year to anticipated increase in turnout contingency plans are very important. Increased turnout is a 

great problem to have. But it means having enough ballots, having 

enough poll workers and having enough equipment to support the 

turnout is what we have to have because the record numbers will 

be there. Secure, accurate and accessible elections are a complex 

process comprised of many moving parts and many people. Some 

of those people are involved only once a year. We hear a lot about 

whether voting systems can be trusted. In fact, any voting system, 

whether it’s a ballot box, whether it is an optical scan system, a 

touch screen, can be compromised if you have two things, knowledge of that system and access to that system. 

I’ve been an election official my entire career, and one thing 

never changes, whether voters use paper ballots or a touch screen 

details matter. It is very important that we make sure that our 

voting equipment is working properly as it is to have procedures 

and well-trained people to control access and maintain the equipment properly. That is why the EAC has produced what we like to 

call quick starts, as I hold up for your attention. And they have 

been delivered. I’m sure that you have them. We have done these 

management processes on several areas like polling place and voting centers, managing change in election office, media and public 

relations, absentee voting and voting by mail, acceptance testing, 

voting system certification, voting system security, poll workers, 

ballot preparation, printing and preelection testing, new voting systems and the contingency and disaster planning. 

The management material, as we call the quick starts, have been 

distributed to every election official throughout the Nation. In the 

very near future, we will have material to serve the elderly and the 

disability and long-term care facilities. Also, military voters and 

how to audit the entire election process. Also, our language accessibility program has produced Spanish glossaries of the election 

terms. Translated a large portion of our EAC Web site took Spanish and also had the registration form in the language. In May, we 

anticipate the EAC will offer a glossary in five Asian languages, as 

well as provide the Web site content and the form in those languages. All of the material that the EAC produces to help election 

officials are absolutely free. And we distribute them to everyone. 


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As a former election official who watched the formation and the 

evolution of HAVA very closely, the EAC is providing the type of 

information and assistance to the officials that we feel that HAVA 

definitely envisioned. I thank you very much and I look forward to 

your questions also. 

Ms. LOFGREN. Thank you very much, and thanks to all of you for 

your testimony today. 

[The statements of Ms. Rodriguez, Ms. Hunter, Ms. Hillman and 

Ms. Davidson follow:] 


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Ms. LOFGREN. We will now begin our questioning. And I would 

like to turn first to our colleague, Susan Davis, for any questions 

she may have for the commissioners. 

Mrs. DAVIS of California. Thank you, Madam Chair, and thank 

you to all of you for being here and for your service. I can tell that 

this is not easy. And I had asked the inspector general about the 

pressures that you may be under from vendors, from others. And 

I wonder if you could talk about that briefly and how you all deal 

with that. 

Ms. RODRIGUEZ. I will start. We have a fairly, I think, helpful ex 

parte policy so that vendors, we don’t really have direct conversations from vendors, and therefore they can’t really put any kind of 

pressure on us, which I’m grateful to have that policy in place. I 

certainly consult people. I have not experienced any kind of undue 

pressure to vote a certain way or anything, but I do seek input. I 

think it is a healthy part of our process to get different opinions. 

I have only been here a year and I have noticed that you can get 

sort of isolated in Washington, D.C. And so it is helpful. 

Whenever I go to a conference or travel, I try to meet, have a 

brown bag lunch and invite local voting activists in to—when I visited Secretary of State Brewer in Arizona, I had a meeting with 

about 150 interested Arizonans who wanted to talk about the political process. So I kind of seek that information. And I wonder if 

any of my colleagues want to chime in. 

Ms. HUNTER. Thank you. I agree with my colleague, Commissioner Rodriguez, that it is important to seek input from outside 

sources, and I think we all strive to do that. To tell you the truth 

I have been surprised at how little interest that there has been in 

the workings of the Commission on the part of the public. Our 

meetings are not terribly well attended, we don’t receive a lot of 

comment in my opinion. So we are sort of forced to seek that kind 

of input from the public, whether it is through conferences. Each 

of us does a number of public speaking engagements around the 

country to various State and local election officials and other 

groups. 

So I think it is extremely important that we hear from outside 

sources as long as we were aware of the positions from which they 

come. 

Mrs. DAVIS of California. Did you want to comment? I have a few 

other questions, too. 

Ms. HILLMAN. I will just say that there is a different kind of 

pressure. I personally have never been under any political pressure 

one way or the other, but this is a different kind of pressure. We 

operate in a two-year cycle. The election dates are set and we have 

to be ready to assist for those dates. The public has high expectations. And sometimes they go beyond what we are authorized to do. 

Plus there is a desperate need and probably a legitimate one for 

quick fixes. And you can’t do quick fixes in an election. So some of 

that pressure is, it is a different kind of political pressure, but unlike my colleague, I feel it just in reading e-mails and blogs and 

letters that people write. I know that there is an expectation that 

the Election Assistance Commission working with its partners is 

going to fix the problems. 


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Mrs. DAVIS of California. I wonder, one of the issues that you 

have to deal with, of course, is how you use some of the surplus 

HAVA funds. And there has been a question of whether or not 

those machines that were recertified, if they can’t be used, can 

those dollars be put into other kinds of machines that counties 

might be taking a look at? How have you been trying to work 

through that clarification of how those funds can be used? 

Ms. HUNTER. Are you asking someone in particular? 

Ms. RODRIGUEZ. I can talk about it. The EAC has previously instructed the States that they cannot use remaining HAVA funds to 

purchase equipment to replace equipment previously purchased 

with HAVA funds. And we have a request from a State now to do 

that. And I have placed on the table for consideration by the Commission on March 20th a revision to our policy that would allow it. 

We have asked GAO to give us an opinion on that by March 19th 

and they have agreed to provide that. And so we will very shortly 

have the opportunity for the Commission to—— Mrs. DAVIS of California. Is that for the State of California? 

Ms. RODRIGUEZ. It would apply to any State in that situation. 

Mrs. DAVIS of California. We are certainly in that position. I 

think it is about $78 million left. And much of that equipment, of 

course, was decertified. 

Ms. LOFGREN. The lady’s time has expired. The gentleman from 

California, the Ranking Member McCarthy is recognized for 5 minutes. 

Mr. MCCARTHY. Thank you, Madam Chair. I want to thank all 

the Commissioners for coming in and giving your testimony today. 

If I could ask Chair Rodriguez, you had brought up the Secretary 

of State from Arizona here too. Thank you for coming. But in the 

National Voter Registration Act, it requires the EAC to develop a 

mail voter registration. I know there are five or six States that are 

before you now that have requested some changes. Can you tell me 

where they are in that process and whether you have approved 

those yet? 

Ms. RODRIGUEZ. We have not approved them. We have, let’s see, 

I think we have had them in front of us for some time now. 

Mr. MCCARTHY. How long would that be? 

Ms. RODRIGUEZ. At least since December of 2007, at least 4 

months. The Commission has been wrestling with crafting a policy 

by which we would accept those changes or make those changes. 

And we have not—— Mr. MCCARTHY. Are all the States now the same then on this 

Web site? I mean, are all the voter registration items, every State 

the same? 

Ms. RODRIGUEZ. No, they are not the same. Every State has a 

State instructions portion, all of the States and the territories. 

Mr. MCCARTHY. Then why would we hold up changing these 

States? 

Ms. RODRIGUEZ. Because the EAC, in the transfer of the authority to amend the form from the FEC, we haven’t completed that 

transfer. We have started it. The FEC, as you know, is stagnant 

at this moment. We have not been able to come up with an interim 

policy that all four of us can agree on, or at least three of us can 

agree on. And so Commissioner Hillman has placed each of the 


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State changes on the agenda again on March 20th for our consideration State by State. 

Mr. MCCARTHY. I have real concerns with the elections so soon 

and you having this before you for so long. You had mentioned Secretary of State Jan Brewer. She has written testimony, and I have 

it, Madam Chair, to present unanimous consent. 

Ms. LOFGREN. Without objection, it will be entered in the record. 

[The statement of Ms. Brewer follows:] 


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Mr. MCCARTHY. That the EAC is unnecessarily disenfranchising 

voters using the Federal form by refusing to properly instruct them 

regarding State citizenship requirements. And I am wondering in 

the concept of the tenth amendment and States rights if they committed this to you, and you have had it before you a long time, is 

that the holdup, that you don’t agree with what the State wants 

to do, or I don’t quite understand. 

Ms. RODRIGUEZ. The EAC’s position on the Arizona citizenship, 

the documentary proof of citizenship requirement, is that there is— it simply isn’t—there is no place for it in the State instructions on 

the Federal form because there is reasons for that position. The 

Congress itself grappled with whether or not to require that when 

they wrote the—— Mr. MCCARTHY. But the State has passed a law is my understanding and they put this in 2 years ago. I understand you had 

studied this, but if the State and States rights has passed something to put on their voter registration and their mail and they 

have requested you to do it, I don’t understand the holdup. 

Ms. RODRIGUEZ. I see your point, and the Commission, there are 

a couple of members of the Commission who share your opinion, 

your position. However, it is not the consensus of the Commission 

that we should amend that. 

Mr. MCCARTHY. So then you agree with the Secretary of State 

that you are disenfranchising them by not acting, you are withholding their ability to change? 

Ms. RODRIGUEZ. In my opinion, the State of Arizona is 

disenfranchising their own voters. 

Mr. MCCARTHY. How is that? 

Ms. RODRIGUEZ. By requiring this documentary proof of citizenship. 

Mr. MCCARTHY. So you would say because you disagree with 

what the voters of Arizona have voted and asked for, you will not 

move it even though the States asked and the voters have asked 

for it because you personally disagree with it? 

Ms. RODRIGUEZ. No, I would not agree with what you just said. 

Mr. MCCARTHY. Then I apologize, but that is the way I was understanding the last thing that you just said, that the State was 

disenfranchising an elected official that the State has voted for 

this, asked for this, moved it on 2 years ago for you, and I am just 

understanding why we haven’t moved it forward? 

Ms. RODRIGUEZ. Well, it is still in the courts being argued. I am 

not the only person who has this opinion. I mean, this issue is 

being—is scheduled for trial. It is going to be heard on the merits. 

And when it is resolved, the Commission will——

Mr. MCCARTHY. So you want to wait until the trial is over to 

make a decision by the EAC? 

Ms. LOFGREN. The gentleman’s time has expired. 

Mr. MCCARTHY. If I can just have an answer to that question I 

will be done. 

Ms. RODRIGUEZ. Yes, I would like a court to interpret the appropriateness of that on the NVRA form. Yes, I want to know what 

a court would say. 

Mr. MCCARTHY. Madam Chair, I find a real concern with these 

answers. And I may request a minority hearing just based upon 


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this, nothing to do with you, Madam Chair, but just to get further 

beyond—— Ms. LOFGREN. Maybe if we don’t have votes we can have a second round. The gentleman from Alabama is recognized. 

Mr. DAVIS of Alabama. Thank you, Madam Chairwoman. I think 

all the Commissioners were present when I was questioning the Inspector General, so you know I have an interest in Mr. von 

Spakovsky, because he is a figure of some controversy right now. 

And there is a question as to whether he is the appropriate person 

to continue to serve or to serve on the FEC. 

Let me go to you Ms. Hillman, if I can, because you are referenced in one of these e-mails. Have you read the inspector general’s report? I am assuming that you have read it. 

Ms. HILLMAN. I have seen the same redacted version that I believe you have. 

Mr. DAVIS of Alabama. I am looking at page 16. And I don’t want 

to waste time with a lot of questions about it, but I was struck by 

one e-mail exchange between Mr. von Spakovsky and Mr. 

DeGregorio. And at some point, Mr. von Spakovsky says the fact 

that you, Ms. Hillman, does not want to do this because she does 

not want to anger her friends at the League of Women Voters is 

no need for you, Mr. DeGregorio, to be railroaded into this. What 

is your professional response to Mr. von Spakovsky’s characterizations here? 

Ms. HILLMAN. Well, first let me tell you, I did not know until this 

report came out that that e-mail exchange happened to my colleague’s credit. But Mr. von Spakovsky is entitled to his opinion, 

but the facts are not correct. 

Mr. DAVIS of Alabama. And tell me what is incorrect about Mr. 

von Spakovsky’s version of the facts? 

Ms. HILLMAN. There was no conversation that I had with the 

League of Women Voters about the release, or not release of the 

report or what the report would say. And as Mr. DeGregorio said 

in his e-mail there was nothing I did to—in fact, if anything, I was 

trying to shove that report out the door when I found out it had 

been delayed. 

Mr. DAVIS OF ALABAMA. And I certainly don’t want to read Mr. 

von Spakovsky’s mind, but I frankly didn’t even read him to literally insinuate that you had a communication with the League of 

Women Voters. I am reading this as a little bit of a dig, frankly, 

that he is saying that—I guess he could have said liberal dogooders instead of League of Women Voters. Am I out of line in my 

interpretation? 

Ms. HILLMAN. Well, I am sure he said that because I was formerly employed with the League and there are people who would 

suggest that the League’s position on issues is different than 

theirs. 

Mr. DAVIS of Alabama. We were talking, and Mr. McCarthy, I 

suppose was talking from the other side of the aisle about this 

question. Obviously, it is not illegitimate for Mr. von Spakovsky to 

have given some input or for DOJ to have given some input to the 

EAC. I don’t think that itself is problematic. But on the other hand 

there appears to be a line. And my sense is that Mr. von 

Spakovsky may have attempted to cross that line with Mr. 


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DeGregorio. Let me just ask all the Commissioners to give a quick 

response. Are any of you troubled by Mr. von Spakovsky’s efforts 

to influence Mr. DeGregorio? Ms. Davidson, are you troubled by 

what you read in this report by Mr. von Spakovsky? 

Ms. DAVIDSON. You know, I believe that everybody has a right 

to an opinion. We get many things, e-mails from individuals that 

feel that we should be doing something different than what we are 

and we are trying to follow the law. Everybody has a right to an 

opinion, but it is our responsibility to stand up and make sure that 

we take the proper action. 

Mr. DAVIS of Alabama. Let me get at it this way because our 

time is limited, and I know the cell phone is going to go off again 

in a minute. I think we can all stipulate to what I said. We all 

agree with the generality that everybody has a right to have an 

opinion, everybody has a right to insert their opinion. It is up to 

the Commission to be independent. I am asking a very specific 

question about Mr. von Spakovsky’s role. And I am asking if the 

Commissioners are troubled by Mr. von Spakovsky’s reference, for 

example, to a political compromise agreement between EAC and 

DOJ. Do any of the Commissioners present think that it would be 

appropriate for the EAC to enter a ‘‘political compromise agreement’’ with DOJ? Ms. Rodriguez, do you think that would be appropriate? 

Ms. RODRIGUEZ. I don’t even know what it is, so I—I don’t know 

what it is. I’m sorry, this is an extraordinary term. 

Ms. LOFGREN. Ms. Hunter, does that concept strike you as an appropriate one, the idea of a political compromise, because this is 

Mr. von Spakovsky’s phrase, not mine? 

Ms. HUNTER. Certainly a political compromise wouldn’t be the 

proper words to use. I would not have used those words, and I suppose he may wish he had not either. But my read of the report is 

that this exchange is not about the voter fraud intimidation report, 

rather it is about conflicting interpretations of a provisional ballot 

law vis-a`-vis an Arizona law and EAC guidance that was put out 

several years ago that in many people’s view was incorrect. And so 

Mr. von Spakovsky was saying he was willing to change his opinion 

from the Department of Justice’s perspective which was, in some 

people’s view, overly restrictive on when Federal law requires you 

to give a provisional ballot. 

So he is saying I am going to change my position on that, if EAC 

would please consider changing your position on this. So it was 

more a legal situation where my interpretation is he didn’t want 

the Federal agencies to have differing views. It was not about the 

voter fraud intimidation report. 

Mr. DAVIS of Alabama. Since I am hearing the cell phone I will 

close out, but I will just end my last 10 seconds by saying that I 

think I understand better now why Senator Bayh and why some 

other people have issues with Mr. von Spakovsky. Because as I understand the role of the Commission, your work and the diligent 

work that you Commissioners are doing is not enhanced by an 

overt politicization, it is not enhanced by an attempt at an overt 

politicization. And I think I agree with Ms. Rodriguez that this notion of a political compromise agreement just doesn’t strike me as 


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being remotely relevant to what you do and what DOJ does. Thank 

you, Madam Chairwoman. 

Ms. LOFGREN. Thank you. The gentleman yields back. I would 

recognize the gentleman from Texas, Mr. Gonzalez, for 5 minutes. 

Mr. GONZALEZ. Thank you very much, Madam Chairwoman. 

Chairwoman Rodriguez I am going to follow up on what the Ranking Member of the Subcommittee, Mr. McCarthy, was talking 

about, the Arizona situation. I am trying to get it straight in my 

mind. There has not been a final legal determination on the merits 

of the case challenging the citizenship requirement as outlined in 

Arizona law pursuant to, I guess, Proposition 200. I know the injunctive relief has been dissolved and that issue has probably resolved. But the underlying case itself, is it still pending? 

Ms. RODRIGUEZ. Yes, it is still pending. 

Mr. GONZALEZ. So it is possible that when this case is finally determined——

Ms. RODRIGUEZ. Commissioner Hunter would like to say something. 

Mr. GONZALEZ. Oh, I am sorry. 

Ms. HUNTER. I just wanted to make a comment that it is true 

that there are some claims remaining in the case. However, the 

District Court recently dismissed on summary judgment many of 

the claims, including the one that this Arizona law violates the 

NVRA. That claim was dismissed, so that issue is no longer in the 

courts. 

Mr. GONZALEZ. But there are other—I mean, the summary judgment only addressed certain grounds? 

Ms. HUNTER. That’s correct. 

Mr. GONZALEZ. So they still have a legal challenge, which I am 

not sure what the basis may be. I am sure those of constitutional 

dimension. The bottom line is we have pending litigation that could 

be determined and a judgment rendered in favor of those challenging legitimacy of the law. I think we can agree on that. So 

what would happen if that comes to pass in the next few months 

after November? 

Arizona is insisting on the citizenship provision, rejects thousands and thousands of individuals that are going to be 

disenfranchised for all elections up until the time that the court 

does make its decision. So the court makes a decision in December 

or whatever; election’s over, presidential election and so on. How 

do you undo that? 

Ms. HUNTER. The court could have granted an injunctive relief 

if they were concerned of such a scenario that you point out. And 

the court would resolve the injunctive relief. As Secretary of State 

Brewer has said on numerous occasions in public hearings the 

minute the injunction was issued she immediately stopped enforcing that law, and the minute the injunction was lifted she resumed 

enforcing it. Of course, a law is good unless and until it is overturned. 

Mr. GONZALEZ. Well let me ask you this, then. You took a time 

out while there was injunctive relief, and during that period of 

time, didn’t reject any applications or registration forms that didn’t 

comply with the citizenship requirement, would that be correct? 


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Ms. HUNTER. That is what I have heard the Secretary of State 

say yes, sir. 

Mr. GONZALEZ. So those individuals came in without that requirement. Then when the injunctive relief was dissolved or whatever, we have this other population that is subjected. Wouldn’t the 

prudent thing to do is simply make sure everybody then—it doesn’t 

make sense to me that you are going to have two basic standards; 

one that came during the injunctive relief and those that will come 

afterwards. I am just wondering. Now, you could simply say, ‘‘We 

start the process over and everybody that may have registered 

without the requirement has to reregister or whatever.’’ But it just seems to me that the prudent thing while you still 

have a challenge to this law would simply [be] to proceed. Now, I 

am just—this is going to be resolved I take it. And I am not sure 

if it is going to be resolved. You all are going to reconsider it. 

What’s the consequence to no action by the Commission? What is 

the consequence again to an action that would not support what 

Arizona is attempting to do and Arizona would proceed? 

Ms. HUNTER. The consequence, I don’t know if anybody else——

Mr. GONZALEZ. No action, first of all. 

Ms. HUNTER. What is the consequence on if we don’t change the 

form? 

Mr. GONZALEZ. If you don’t approve the form as submitted. 

Ms. HUNTER. Well, the law is good law unless and until it is 

overturned. So that is just a clear principle. And I think we have 

the responsibility to accurately reflect State laws on the Federal 

form. The United States Constitution protects the right of States 

to set eligibility requirements. 

And the Federal form has a perfect place for that in the State 

instructions portion of the form. If the EAC were to determine or 

to delay action on this issue, in my view, we are impermissibly 

eroding the right of the State to set the eligibility requirements. 

Mr. GONZALEZ. Let me ask you, what constitutes a State; people, 

right? 

Ms. HUNTER. Yes. 

Mr. GONZALEZ. But you are disenfranchising voters, would you 

not? While something is still pending and a law is being challenged; What would be the basis and reason for that? Now I understand you can have frivolous lawsuits out there, but once this is 

taken care of, then you have stare decisis, you have precedent, the 

issue is dead, it is long gone, it has been decided. But it has not 

been decided. So why wouldn’t you, if you are going to err, why 

wouldn’t you do that on the side of making sure you don’t disenfranchise voters? 

Because after the fact, when you do disenfranchise you cannot 

undo it. Those people will not be allowed to vote. And it is still a 

very, very real possibility that the law would be set aside. I am just 

saying you all ought to always think in terms of not 

disenfranchising individuals, especially while you have pending litigation, and I would yield back. 

Ms. LOFGREN. Thank you. The gentleman’s time has expired. I 

am going to ask just a few questions, if I could. And just on the 

subject that has been discussed both by Mr. McCarthy and Judge 

Gonzalez. As I understand the question really posed by yourself, 


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Chairman Rodriguez, is that the issue is whether the Federal law 

really preempts the State’s opportunity to do what they are asserting to do by their proposition, which is the very same issue that 

is before the U.S. Supreme Court in the Indiana case, I think. 

As a matter of fact, I have offered an amicus brief with Senator 

Feinstein suggesting that, in fact, the Federal law does preclude 

the ability of States to do what Indiana attempted to do, and by 

extension, also the State of Arizona. And if I am hearing you correctly, correct me if I am wrong, you know reasonable people can 

differ, and apparently do on the Commission and in the country. 

The question is is that what has really caused the inability for the 

Commission to reach a conclusion on this, is the disagreement on 

how to view that legal question? Is that accurate? 

Ms. RODRIGUEZ. That is Madam Chair. And I always thought 

that the Federal form and the whole NVRA process was to equalize 

procedures across the country so that any voter who wanted to participate in a Federal election knew what form to use and what to 

do. And in my opinion the Arizona requirement puts an additional 

burden on the voter in Arizona. 

Ms. LOFGREN. If I could, I share your opinion, but the point I am 

trying to make is that the Supreme Court itself was trying come 

to grips with this. It is not a surprise. It is a difficult question that 

the Commission itself is trying to come to grips with this, and it 

is not easy to reach agreement in every case. So I think that is 

what has happened here. 

Ms. HILLMAN. Madam Chair, if I might just say, on that point, 

yes, it is true we have disagreement. And we were proceeding on 

the premise that we would be reviewing the regulations once transferred to EAC from the FEC. And then came the inability of FEC 

to take action because it doesn’t have a quorum, so we are sort of 

stuck there. We continue to work this through. But there are two 

points I would make. It is my understanding that Federal agencies 

don’t, unless there is some absolute emergency, promulgate regulations while a case is going on in court. That, generally speaking, 

it is prudent to wait until the case is over and the final judgment 

has been rendered. 

Secondly, under Federal law a form cannot be initially rejected 

if a voter turns it in incomplete. That form must be returned to the 

voter noting the incompleteness. So if under Arizona they receive 

a mailing form and they believe that it is within their right to ask 

for proof of citizenship they must go back to that voter before they 

can reject the voter’s application. 

Ms. LOFGREN. Commissioner Davidson, did you want to weigh in 

on this point? 

Ms. DAVIDSON. Could I please. I completely agree with a lot of 

what has been said. But I think there is one thing that I think that 

has been brought up to date, is the State rights. And Commissioner 

Hillman is completely right, they do have to go back to the voter. 

But as time gets closer to that election is my concern. And then the 

voters, they don’t know what the requirements are. Then there is 

possibly not time to get back to that voter, and that is the voters 

that I am very concerned about. 

Ms. LOFGREN. Let me turn to another subject, because it really 

is the gist of the IG report, and really the attention that we gave 


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to the Commission last year. We had administrative law experts 

testify before this Subcommittee and the EAC to discuss Federal 

administrative procedure requirements applicable to the Commission. And they were experts. And they had recommendations for 

EAC on implementation of various procedural regulations. Has 

that been helpful, have you been able to adopt some of the recommendations that those experts had made, have we had the 

training opportunities that were suggested on the Administrative 

Procedures Act implemented? 

Ms. HILLMAN. The answer to your question is yes, and yes. Yes, 

the suggestions were helpful. We have, in fact, retained consultants. You asked about the use of consultants. We need the expertise to help us cut through the bureaucracy of Federal Government. 

And we are in the process of having many of those written up for 

us and staff have been undergoing training, particularly in the 

issue of managing contracts. 

Ms. HILLMAN. Could I add one thing? Because of your meeting 

also and bringing those individuals in, we also had a hearing, a 

public hearing and brought in some of those same people to really 

discuss deeper of about what we needed, and that was very helpful 

also. 

Ms. LOFGREN. That is great feedback to have. Just a last question. I believe that the EAC has created a new chief operating officer position. And I am interested in what are going to be the respective roles of the executive director, the chief operating officer 

and the general counsel after this person has been hired? And the, 

I don’t know if this is accurate or not, but I received the impression 

that the general counsel had been undertaking functions that were 

unusual for a general counsel, broader than a traditional general 

counsel position. 

Will the filling of this new position change the alignment of the 

general counsel’s position and will it be a more standard administrative structure after that. 

Ms. RODRIGUEZ. I will take that, Madam Chair. The chief operating officer will report to the executive director. I think the general counsel is very relieved that we are going in this direction so 

that she doesn’t have to double up and help with the budget as she 

had in the past. She is a statutory officer of the organization. So 

she will not report to the chief operating officer, she will continue 

to report to, he or she, whoever it is, shall continue to report to the 

executive director. But the chief operating officer will then have 

line reporting or other staff will have line reporting to the chief operating officer. 

Ms. LOFGREN. All right. I am going to, before my cell phone goes 

off again, and hoping that we will get our regular lighting system 

replaced before our next hearing, we won’t have votes for another 

few minutes, so we do have time. I know Mr. McCarthy had additional questions. I would like to recognize him for another 5 minutes. And we will go until we get called away to vote. 

Mr. MCCARTHY. I thank you, Madam Chair, for the kindness of 

letting us go. Let me touch base a little more on this Arizona issue, 

because I heard our colleague talk about disenfranchised. But I 

guess to Commissioner Hunter, it is my understanding, okay, this 


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law has passed in Arizona, more than two years, so they have 

changed their voter registration in Arizona already, have they not? 

Ms. HUNTER. Yes, sir, they have. 

Mr. MCCARTHY. So if I go to your Web site and I pull off that 

form and I fill it out, I am disenfranchised because I am going to 

get rejected by the Secretary of State, rightfully so, because of the 

law they passed. So by doing nothing you are disenfranchising. Am 

I seeing this wrong? 

Ms. HUNTER. Well, you are not seeing it wrong. I think the Secretary of State, I am not sure about this, but I think she takes that 

form and then tries to ascertain the information from the voter. 

And so it is not rejected out of hand, but she has to go through an 

additional step. So it is obviously cumbersome, I would imagine, 

and it is not useful to provide information that is not accurate. 

I think there are other examples of States that are before the 

Commission now where it might even be more obvious that voters 

are disenfranchising. One example is that the address for the State 

of Colorado is inaccurate. And we know that the voter registration 

deadline in New Jersey is inaccurate. They have changed it from, 

I believe, it is 30 days to 21 days. And in Rhode Island, persons 

who are no longer incarcerated, even if they are still serving parole 

may now register to vote in Rhode Island. 

However, if they looked at our form they would not know that 

and they would think that the old law was still in effect, which 

would mean that they are not able to register unless they are either not incarcerated or not serving parole. So those examples, in 

a lot of ways, are clear examples of voters who will not be able to 

register by virtue of the fact that the EAC has not properly updated the State instructions portion of the form. 

Mr. MCCARTHY. That is disturbing to me. 

Ms. HUNTER. Yes. 

Mr. MCCARTHY. I don’t understand what those five that we 

talked about earlier that you just laid out, the same five, why that 

takes so long to get forward, and by doing nothing, we are 

disenfranchising people. When is your next meeting and why 

couldn’t this be moved forward? 

Ms. HUNTER. Our next meeting is next Wednesday in Denver, 

Colorado. And one of my colleagues alluded to the fact, and maybe 

she wants to address it, that Commissioner Hillman has proposed, 

I believe it is an up or down vote on each and every State request 

that is before the Commission. So these issues will be addressed 

next Wednesday. 

Mr. MCCARTHY. So we might be able to move forward even 

though someone waits 2 years? 

Ms. HUNTER. Hopefully. 

Mr. MCCARTHY. But I am concerned because—maybe you can 

give a little better explanation to me about where we are in the 

court system. If the court system decides this does not have anything to do with the National Voter Registration Act which gives 

you the power to change, then why can’t you move forward with 

Arizona? 

Ms. HUNTER. Well, I don’t think there is any reason that we 

shouldn’t. Each from the day the lawsuit was filed—of course, there 

are many lawsuits that challenge many laws, both Federal and 


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State all throughout the country. And if one were not to enforce a 

law just because it has been challenged in a court, that would obviously drastically change the dynamic of our system. So in my view 

even on the day that the lawsuit was filed that is not relevant with 

regard to our responsibility. Now, of course, if a court ruled the law 

unconstitutional, of course, we would immediately remove that 

from the form. 

Mr. MCCARTHY. There is a lot of laws I don’t agree with. Most 

of them speeding laws, but I still abide by them until they are 

overturned. 

Ms. HILLMAN. If I might. For me it is not just about Arizona. The 

EAC has been criticized for taking actions without having in place 

proper procedures and policies. And what I have been pushing is 

that the EAC adopt from some very simple and clear procedures as 

to how we will consider requests from States for changes to the 

State instructions portion of the form. We have not been able to 

come to agreement on it. It is true that probably of the six or seven 

States that have requests before us Arizona is the, the Arizona request is the one that is the stickler. I requested that we separate 

those two and say let us continue discussing what the Federal law 

provides for, what NVRA provides for, what HAVA provides for, 

where this request fits under current regulations and move the others and we could not. 

I am reluctant to do case-by-case regulation, that is as a State 

request comes in, we vote it up or down. But I am also sensitive 

to the fact that unfortunately we have lost 3 good months since 

January trying to work this out, and it is time for us to move forward. 

Mr. MCCARTHY. But you have got—well, my concern is you have 

got Arizona there for 2 years, and what procedures would you 

have? Because you had four individuals, if two individuals want to 

say no we don’t personally agree with that State, you can hold 

somebody up this whole time and disenfranchise a lot of voters. I 

think the procedure would have to be if you can’t act then someone 

has to. If you can’t come together and someone has been there 2 

years going forward, you are disenfranchising a State, and I don’t 

believe that is fair in the process. I yield back and I appreciate the 

Chair. 

Ms. LOFGREN. The gentleman’s time has expired. The gentleman 

from Texas, Mr. Gonzalez, is recognized. 

Mr. GONZALEZ. I guess if you take any decision-making process 

and knowing that there is someone else making a decision that is 

subsequent to yours that could truly alter the consequence of your 

decision, I would think you would be very, very, very, very careful 

and choose that course of action that wouldn’t do—in other words, 

it is just—yes, there is going to be harm either way. Let’s say the 

court comes and sets it aside; there is going to be harm. Where is 

there less harm? 

And the question then comes: What are you trying to protect? 

And that is people that are not citizens from voting, and all of us 

would join you in that endeavor. It’s how you go about doing it. 

What is the proof that you are requiring and so on? You can check 

off a box, you sign it. And if you are lying about your address, your 

residency, you are lying about citizenship or so, that could subject 


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you to some sort of penalty. And then the reality of the situation. 

What do you have empirically out there that really would indicate 

that you have that kind of problem on such large scale that you 

would be willing to implement that right now before it’s fully tried 

in the judicial system? What is this evil. What is this danger and 

who are you disenfranchising? 

I mean, those are really serious questions and where you do 

greater harm to the body politic and to the electoral system. I 

would hope that you would look at that. Now, is it fair to Arizona 

that it has been delayed and that it is being challenged? I mean, 

we could go on and on. But I think the reality of the situation is, 

you are going to do a lot greater harm by moving forward before 

you have some sort of judicial determination. 

I want to go on to another topic and something I wanted to cover. 

My staff indicated here, it says that mandated studies and reports 

have not been submitted by due dates, reports on registrations by 

mail, electronic voting, free absentee ballot postage and so on. And 

I am just assuming what we are talking about is some sort of reports being received by election authorities that had deadlines: Are 

they tardy, are they late, how late and when do you catch up? 

Ms. HILLMAN. Well, Congressman Gonzalez, some of the report 

due dates were required before the Commission was established. 

And in a couple of cases the scope of the project was such that we 

did finally get started on the free or reduced postage for absentee 

ballots voted. It took us a long time to find the consultants who 

could work with us on that. On the Social Security issue, the use 

of the Social Security number, we are having conversations with 

Social Security about how we wrap our arms around that study, 

and even Social Security is having some challenges coming to grips 

with it. 

So there are a couple of studies that because of the unique nature of the issue we have been a bit challenged to find the resources we need so that we could move forward. With respect to 

some of the other studies it is what the inspector general identified 

earlier. We had staff multi-tasking all over the place. And we realized that we were asking the staff to perform outside their areas 

of expertise, but we had no choice. We had to hit the ground running. And to a question that was asked earlier, HAVA envisioned 

that GSA would provide certain administrative support services to 

EAC, they could not do that. They just structurally did not have 

the human resource capacity to assist us. 

There was no one place we could go. I personally harassed the 

Office of Personnel Management for over a year to help us to put 

together our human resources manual. They said that is not their 

job. And we said we have nowhere else to go. They finally 

capitulated and worked with us on it, and once we got started we 

were able to complete the project. I have been astounded how difficult it is to get the information you need. It would be nice to be 

able to go to an agency, get their document and say let us use this 

as our document. But then we have to apply it to our unique situation and go through that process. 

One thing I have learned my two tours of duty with Federal Government, if you don’t know the right question to ask, you will never 

get the information and you don’t know what you don’t know until 


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you hit that brick wall and you say darn, what is this now? So it 

has been a very interesting experience getting a brand new agency 

started, particularly since we had such immediate deadlines like 

the 2004 presidential, the 2006 general and now the 2008 with 

many, many things to do. So it is true that a couple of the studies 

are behind date, but we are pushing ahead. 

Mr. GONZALEZ. Thank you very much. I yield back. 

Ms. LOFGREN. The gentleman yields back. I am just wondering, 

I don’t know if you know the answer to this today, but about the 

funds provided for covered jurisdictions to meet their requirements 

under Section 203 of the Voting Rights Act, are funds sufficient to 

meet those needs of limited English proficient voters in that section? Do we need to address that in terms of our budget here? Anybody who knows the answer or you can get back to me. 

Ms. HILLMAN. We will get back to you. We don’t have jurisdiction 

over that. And to my knowledge since I have been on the Commission jurisdictions have not spoken to us directly about the need for 

more funds. We are assisting in many ways by providing as many 

materials as we can in different languages so the election officials 

can just use them right away and not have to do their own work. 

Ms. LOFGREN. Has there been consideration of an EAC study on 

language accessibility throughout the country in addition to those 

jurisdictions that are subject to the Voting Rights Act? 

Ms. HILLMAN. We are working on that. And what we are doing 

is as we are working on it, we are producing whatever documents 

we can. And so we haven’t yet determined what the final report to 

Congress should be on that issue, but we are looking at the issue 

and producing what materials we can and identifying what the 

challenges are that the officials have. 

Ms. LOFGREN. Okay. Yes, Commissioner Davidson. 

Ms. DAVIDSON. We have even had one of our staff individuals 

that has actually attended a conference for the nonspeaking languages that was held in New Mexico, I believe. 

Ms. LOFGREN. You mean unwritten language? 

Ms. DAVIDSON. You are absolutely correct, the unwritten languages. And so we are interested even in that area of the arena 

of it, so that we can at least do some best practices or the quick 

starts and at least get that out as quickly as possible. 

Ms. LOFGREN. Well, all those bells and whistles mean that we 

have votes on the floor of the House. And I would like to thank all 

the Commissioners for being here today and for your testimony and 

answering our questions. We may have additional questions which 

we will send to you if we do and ask that you answer them as 

promptly as you can. I just will say I was talking about language 

accessibility. 

I can still say this for only one more year, that I was on the 

Board of Supervisors in Santa Clara County longer than I have 

been in the House of Representatives, and one of our obligations 

was to oversee the registrar of voters. And it is chaos, but it is a 

wonderful responsibility. And one of the things we did when I was 

in local government was to go beyond what was required of us on 

language accessibility, because especially in California you have 

these initiatives. They are so complicated. 


smartinez on PROD1PC64 with HEARING
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And I will never forget a very elderly gentleman came and he 

spoke to us in English, but with a pretty heavy accent, and he 

thanked us for making available to him information. He said for 

the first time I get to vote the way I want instead of the way my 

son tells me to. So it is very important, and I hope that we can get 

the results of that study. At this point our hearing is—yes, Ms. 

Rodriguez. 

Ms. RODRIGUEZ. Thank you, Madam Chair. I just wonder if we 

might supplement the record with a little bit more information 

about some of the gaps that we left in our responses? 

Ms. LOFGREN. That would be absolutely fine. Just get it to the 

staff. And again, thank you so much for being here. We look forward to additional progress, and this hearing is adjourned. 

[Whereupon, at 4:57 p.m., the subcommittee was adjourned.] 

[Information follows:] 


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smartinez on PROD1PC64 with HEARINGInsert graphic folio 294 here 42740A.209
247 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 295 here 42740A.210
248 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 296 here 42740A.211
249 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 297 here 42740A.212
250 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 298 here 42740A.213
251 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 299 here 42740A.214
252 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 300 here 42740A.215
253 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 301 here 42740A.216
254 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 302 here 42740A.217
255 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 303 here 42740A.218
256 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 304 here 42740A.219
257 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 305 here 42740A.220
258 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 306 here 42740A.221
259 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 307 here 42740A.222
260 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 308 here 42740A.223
261 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 309 here 42740A.224
262 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 310 here 42740A.225
263 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 311 here 42740A.226
264 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 312 here 42740A.227
265 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 313 here 42740A.228
266 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 314 here 42740A.229
267 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 315 here 42740A.230
268 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 316 here 42740A.231
269 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 317 here 42740A.232
270 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 318 here 42740A.233
271 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 319 here 42740A.234
272 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 320 here 42740A.235
273 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 321 here 42740A.236
274 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 322 here 42740A.237
275 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 323 here 42740A.238
276 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 324 here 42740A.239
277 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 325 here 42740A.240
278 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 326 here 42740A.241
279 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 327 here 42740A.242
280 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 328 here 42740A.243
281 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 329 here 42740A.244
282 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 330 here 42740A.245
283 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 331 here 42740A.246
284 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 332 here 42740A.247
285 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 333 here 42740A.248
286 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 334 here 42740A.249
287 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 335 here 42740A.250
288 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 336 here 42740A.251
289 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 337 here 42740A.252
290 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 338 here 42740A.253
291 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 339 here 42740A.254
292 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 340 here 42740A.255
293 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 341 here 42740A.256
294 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 342 here 42740A.257
295 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 343 here 42740A.258
296 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 344 here 42740A.259
297 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 345 here 42740A.260
298 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 346 here 42740A.261
299 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 347 here 42740A.262
300 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 348 here 42740A.263
301 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 349 here 42740A.264
302 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 350 here 42740A.265
303 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 351 here 42740A.266
304 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 352 here 42740A.267
305 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 353 here 42740A.268
306 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 354 here 42740A.269
307 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 355 here 42740A.270
308 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 356 here 42740A.271
309 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 357 here 42740A.272
310 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 358 here 42740A.273
311 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 359 here 42740A.274
312 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 360 here 42740A.275
313 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 361 here 42740A.276
314 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 362 here 42740A.277
315 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 363 here 42740A.278
316 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 364 here 42740A.279
317 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 365 here 42740A.280
318 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 366 here 42740A.281
319 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 367 here 42740A.282
320 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 368 here 42740A.283
321 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 369 here 42740A.284
322 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 370 here 42740A.285
323 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 371 here 42740A.286
324 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 372 here 42740A.287
325 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 373 here 42740A.288
326 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 374 here 42740A.289
327 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 375 here 42740A.290
328 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 376 here 42740A.291
329 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 377 here 42740A.292
330 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 378 here 42740A.293
331 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 379 here 42740A.294
332 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 380 here 42740A.295
333 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 381 here 42740A.296
334 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 382 here 42740A.297
335 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 383 here 42740A.298
336 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 384 here 42740A.299
337 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 385 here 42740A.300
338 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 386 here 42740A.301
339 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 387 here 42740A.302
340 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 388 here 42740A.303
341 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 389 here 42740A.304
342 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 390 here 42740A.305
343 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 391 here 42740A.306
344 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 392 here 42740A.307
345 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 393 here 42740A.308
346 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 394 here 42740A.309
347 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 395 here 42740A.310
348 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 396 here 42740A.311
349 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 397 here 42740A.312
350 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 398 here 42740A.313
351 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 399 here 42740A.314
352 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 400 here 42740A.315
353 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 401 here 42740A.316
354 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 402 here 42740A.317
355 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 403 here 42740A.318
356 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 404 here 42740A.319
357 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 405 here 42740A.320
358 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 406 here 42740A.321
359 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 407 here 42740A.322
360 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 408 here 42740A.323
361 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 409 here 42740A.324
362 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 410 here 42740A.325
363 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 411 here 42740A.326
364 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 412 here 42740A.327
365 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 413 here 42740A.328
366 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 414 here 42740A.329
367 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 415 here 42740A.330
368 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 416 here 42740A.331
369 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 417 here 42740A.332
370 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 418 here 42740A.333
371 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 419 here 42740A.334
372 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 420 here 42740A.335
373 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 421 here 42740A.336
374 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 422 here 42740A.337
375 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 423 here 42740A.338
376 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 424 here 42740A.339
377 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 425 here 42740A.340
378 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 426 here 42740A.341
379 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 427 here 42740A.342
380 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 428 here 42740A.343
381 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 429 here 42740A.344
382 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 430 here 42740A.345
383 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 431 here 42740A.346
384 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 432 here 42740A.347
385 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 433 here 42740A.348
386 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 434 here 42740A.349
387 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 435 here 42740A.350
388 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 436 here 42740A.351
389 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 437 here 42740A.352
390 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 438 here 42740A.353
391 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 439 here 42740A.354
392 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 440 here 42740A.355
393 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 441 here 42740A.356
394 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 442 here 42740A.357
395 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 443 here 42740A.358
396 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 444 here 42740A.359
397 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 445 here 42740A.360
398 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 446 here 42740A.361
399 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 447 here 42740A.362
400 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 448 here 42740A.363
401 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 449 here 42740A.364
402 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 450 here 42740A.365
403 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 451 here 42740A.366
404 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 452 here 42740A.367
405 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 453 here 42740A.368
406 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 454 here 42740A.369
407 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 455 here 42740A.370
408 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 456 here 42740A.371
409 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 457 here 42740A.372
410 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 458 here 42740A.373
411 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 459 here 42740A.374
412 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 460 here 42740A.375
413 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 461 here 42740A.376
414 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 462 here 42740A.377
415 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 463 here 42740A.378
416 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 464 here 42740A.379
417 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 465 here 42740A.380
418 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 466 here 42740A.381
419 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 467 here 42740A.382
420 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 468 here 42740A.383
421 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 469 here 42740A.384
422 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 470 here 42740A.385
423 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 471 here 42740A.386
424 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 472 here 42740A.387
425 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 473 here 42740A.388
426 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 474 here 42740A.389
427 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 475 here 42740A.390
428 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 476 here 42740A.391
429 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 477 here 42740A.392
430 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 478 here 42740A.393
431 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 479 here 42740A.394
432 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 480 here 42740A.395
433 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 481 here 42740A.396
434 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 482 here 42740A.397
435 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 483 here 42740A.398
436 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 484 here 42740A.399
437 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 485 here 42740A.400
438 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 486 here 42740A.401
439 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 487 here 42740A.402
440 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 488 here 42740A.403
441 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 489 here 42740A.404
442 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 490 here 42740A.405
443 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 491 here 42740A.406
444 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 492 here 42740A.407
445 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 493 here 42740A.408
446 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 494 here 42740A.409
447 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 495 here 42740A.410
448 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 496 here 42740A.411
449 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 497 here 42740A.412
450 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 498 here 42740A.413
451 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 499 here 42740A.414
452 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 500 here 42740A.415
453 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 501 here 42740A.416
454 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 502 here 42740A.417
455 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 503 here 42740A.418
456 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 504 here 42740A.419
457 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 505 here 42740A.420
458 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 506 here 42740A.421
459 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 507 here 42740A.422
460 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 508 here 42740A.423
461 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 509 here 42740A.424
462 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 510 here 42740A.425
463 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 511 here 42740A.426
464 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 512 here 42740A.427
465 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 513 here 42740A.428
466 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 514 here 42740A.429
467 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 515 here 42740A.430
468 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 516 here 42740A.431
469 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 517 here 42740A.432
470 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 518 here 42740A.433
471 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 519 here 42740A.434
472 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 520 here 42740A.435
473 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 521 here 42740A.436
474 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 522 here 42740A.437
475 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 523 here 42740A.438
476 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 524 here 42740A.439
477 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 525 here 42740A.440
478 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 526 here 42740A.441
479 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 527 here 42740A.442
480 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 528 here 42740A.443
481 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 529 here 42740A.444
482 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 530 here 42740A.445
483 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 531 here 42740A.446
484 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 532 here 42740A.447
485 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 533 here 42740A.448
486 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 534 here 42740A.449
487 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 535 here 42740A.450
488 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 536 here 42740A.451
489 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 537 here 42740A.452
490 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 538 here 42740A.453
491 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 539 here 42740A.454
492 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 540 here 42740A.455
493 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 541 here 42740A.456
494 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 542 here 42740A.457
495 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 543 here 42740A.458
496 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 544 here 42740A.459
497 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 545 here 42740A.460
498 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 546 here 42740A.461
499 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 547 here 42740A.462
500 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 548 here 42740A.463
501 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 549 here 42740A.464
502 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 550 here 42740A.465
503 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 551 here 42740A.466
504 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 552 here 42740A.467
505 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 553 here 42740A.468
506 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 554 here 42740A.469
507 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 555 here 42740A.470
508 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 556 here 42740A.471
509 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 557 here 42740A.472
510 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 558 here 42740A.473
511 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 559 here 42740A.474
512 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 560 here 42740A.475
513 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 561 here 42740A.476
514 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 562 here 42740A.477
515 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 563 here 42740A.478
516 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 564 here 42740A.479
517 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 565 here 42740A.480
518 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 566 here 42740A.481
519 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 567 here 42740A.482
520 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 568 here 42740A.483
521 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 569 here 42740A.484
522 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 570 here 42740A.485
523 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 571 here 42740A.486
524 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 572 here 42740A.487
525 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 573 here 42740A.488
526 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 574 here 42740A.489
527 


smartinez on PROD1PC64 with HEARINGInsert graphic folio 575 here 42740A.490
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 576 here 42740A.491
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 577 here 42740A.492
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 580 here 42740A.495
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 584 here 42740A.499
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 585 here 42740A.500
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 586 here 42740A.501
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 587 here 42740A.502
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 590 here 42740A.505
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 591 here 42740A.506
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 594 here 42740A.509
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 595 here 42740A.510
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 596 here 42740A.511
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 605 here 42740A.520
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 606 here 42740A.521
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 608 here 42740A.523
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smartinez on PROD1PC64 with HEARINGInsert graphic folio 618 here 42740A.533
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