United States General Accounting Office

GAO Report to the Honorable

John Edward Porter

House of Representatives

May 1997 BILINGUAL VOTING

ASSISTANCE

Assistance Provided

and Costs

GAO/GGD-97-81

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-275220 

May 9, 1997

The Honorable John Edward Porter

House of Representatives

Dear Mr. Porter:

The Voting Rights Act of 1965, as amended (42 U.S.C. 1973 et seq.), was

enacted to, among other things, protect the voting rights of U.S. citizens of

certain ethnic groups whose command of the English language may be

limited (minority language groups). The act’s “bilingual voting assistance

requirements” apply to ethnic groups in 422 “covered jurisdictions”—most

of which are counties—in 28 states.1

 Critics of the bilingual provisions

have charged that the implementation of these requirements has been

costly and has been of questionable benefit in increasing voter turnout of

the targeted ethnic groups.

This report responds to your request that we review two aspects of the

implementation of bilingual language provisions of the act. You asked that

we determine (1) the types of assistance jurisdictions provided for the

1996 general election; and (2) the actual cost that covered jurisdictions

incurred to provide bilingual voting assistance in 1996,2

 and in prior years,

if available.

To determine the types of assistance jurisdictions provided and the related

costs, we surveyed election officials representing each covered

jurisdiction and each state that had covered jurisdictions. In all, we

solicited responses from election officials in 28 states and 391 covered

jurisdictions.3

 See appendix I for a detailed discussion of our objectives,

scope, and methodology. In total, 26 states and 292 covered jurisdictions

responded to our questionnaires, a response rate of 93 percent and

75 percent, respectively.4

 (See app. II).

1

Alaska, Arizona, and Texas are the only states in which the act’s provisions apply to all jurisdictions in

the state.

2

We requested that covered jurisdictions provide information on the actual costs of providing bilingual

voting assistance during 1996, including primary election and early voting period costs.

3

For the 25 covered jurisdictions in Alaska (as determined by the 1990 Census) and the 3 covered

jurisdictions in Hawaii, state election officials requested that they be permitted to respond for the

jurisdictions; in both Alaska and Hawaii, the state and not the local jurisdictions is responsible for

election administration. Their responses are contained in discussions of state assistance. In addition,

New York City Board of Election officials agreed to provide a response for four covered

jurisdictions—Bronx, Kings, Queens, and New York Counties. Their response is included in the

discussions on jurisdiction assistance. Thus, 422 covered jurisdictions, in total, were represented by

the jurisdictions and states to which we mailed surveys.

4

All percentages in this report have been rounded to the nearest percentage point.

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B-275220 

The information contained in this report is limited to the data provided by

the states and jurisdictions that responded to our survey. To the extent

practical, we attempted to verify the completeness and accuracy of the

responses. Where a response to a question was inconsistent with other

answers elsewhere in the survey or where a respondent failed to answer a

question, we contacted them to clarify or determine the response. On cost

questions, we requested that respondents only provide actual costs for

which they had supporting documentation, not cost estimates. In a

number of cases jurisdictions provided us documentation supporting their

costs; additional details are provided in appendix I (see page 34). Because

the jurisdictions that reported costs were geographically dispersed, it was

not practical to further verify the costs reported.

For both objectives, the survey was affected by variables which limit the

responses’ generalizability. For example, the covered jurisdictions varied

in (1) the number of polling locations where bilingual voting assistance

was provided, (2) the size of the populations in need of assistance, and

(3) the number of minority groups for whom assistance was required.

Accordingly, comparisons across jurisdictions are not meaningful and the

responses of states and covered jurisdictions cannot be projected or

generalized to nonresponding jurisdictions.

On April 9, 1997, we requested comments from the Attorney General or her

designee on a draft of this report. On April 18, 1997, the Chief of the Voting

Section, Civil Rights Division, on behalf of the Attorney General, provided

technical information, which we incorporated where appropriate. We did

our work in Washington, D.C., from July 1996 through April 1997 in

accordance with generally accepted government auditing standards.

Results in Brief Of the 292 jurisdictions that responded to our survey, 272 reported

providing bilingual voting assistance for the 1996 general election. Of the

292 respondents, 213 said that they provided both written and oral

bilingual voting assistance to their minority language voters; 45 said that

they provided written assistance only; 14 said that they provided oral

assistance only; and 20 said they did not provide any assistance. With

respect to the jurisdictions not providing any assistance, 5 said that they

tried but were unable to identify individuals needing assistance; 13 said

that no one needed assistance or that no one had ever sought assistance;

and 2 believed that they had been exempted from providing assistance. In

addition, five jurisdictions and two states reported furnishing bilingual

voting assistance to groups that the act did not require them to assist.

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Of the 258 jurisdictions that reported providing written assistance:

• 94 percent said that they provided bilingual or separate translated ballots;

• 87 percent said that they provided bilingual or translated voting

instructions;

• 71 percent said that they provided bilingual or translated signs at polling

places; and,

• 70 percent said that they placed bilingual notices in newspapers.

Of the 227 jurisdictions that reported providing oral assistance:

• 82 percent reported that bilingual employees worked in their offices or at

the polls to provide assistance;

• 15 percent reported that they used volunteer assistants; and,

• 13 percent reported that they hired special interpreters.

In addition to assistance provided by jurisdictions, states may also provide

assistance, such as translations of state election propositions or translated

sample ballots. Twelve of the 26 states that responded said that they

furnished some bilingual voting assistance. The 14 remaining states

reported that they provided no bilingual voting assistance. In addition,

some states, such as California and New Jersey, have adopted their own

laws requiring bilingual voting assistance.

As the act does not require covered jurisdictions and states to maintain

data on the costs of providing bilingual voting assistance, information

provided by the surveyed jurisdictions and states on their costs was scant.

Of the 272 jurisdictions that reported providing assistance in 1996, 208

were unable to provide information on their costs. Of the 64 jurisdictions

that reported cost information, only 34 provided information on total costs

and the remainder provided partial costs. The 34 jurisdictions’ reported

costs varied greatly. For example, several counties which reported

providing oral language assistance reported no additional costs, as they

used bilingual workers to provide assistance. Conversely, Los Angeles

County, CA, which reported providing written and oral bilingual assistance

in Spanish, Chinese, Vietnamese, Japanese, and Tagalog (a Philippine

language) at over 5,600 polling places, reported additional costs exceeding

$1.1 million.

Of the 12 states that provided assistance, only Hawaii and Florida reported

their total costs for providing bilingual voting assistance in 1996. Arizona,

Massachusetts, Michigan, New Mexico, and Rhode Island reported partial

Page 3 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

cost data. Hawaii and Florida reported costs for bilingual voting assistance

in 1996 of $23,328 and $7,900, respectively.

Only 29 jurisdictions and 6 states provided some data on election year

costs for 1992 to 1995. For example, 28 jurisdictions reported 1994 election

year costs and 12 jurisdictions reported 1995 costs. Moreover, the amounts

jurisdictions reported spending on bilingual voting assistance in prior

years varied widely—ranging from no costs for a 1995 election in Central

Falls, RI, to $764,900 for the 1994 elections in Los Angeles County, CA. The

amounts states reported also varied by year.

Background In 1975, Congress amended the Voting Rights Act and extended its

coverage to protect the voting rights of citizens of certain ethnic groups

whose language is other than English. The act’s language minority

provisions require states and covered jurisdictions—political

subdivisions—that meet the act’s coverage criteria to conduct elections in

the language of certain “minority language groups” in addition to English.

The act defined these language minorities as persons of Spanish heritage,

American Indians, Asian Americans, and Alaskan Natives.

Where the applicable minority groups have a commonly used written

language, the act requires covered jurisdictions to provide written election

materials in the languages of the groups. For American Indians and

Alaskan Natives whose languages are unwritten, only oral assistance and

publicity, e.g., public information spots on the radio, are required. All

covered jurisdictions must provide oral assistance when needed in the

minority language. Both written and oral assistance must be available

throughout the election process from registration to election day activities

and are required for all federal, state, and local elections.

According to the Civil Rights Division’s Voting Section, the objective of the

act’s bilingual assistance provisions, in the Attorney General’s view, is to

enable members of applicable language minority groups to participate

effectively in the electoral process. Further, according to the Section,

jurisdictions should take all reasonable steps to achieve the goal, but they

are not required to provide bilingual assistance that would not further that

goal. A jurisdiction need not, for example, provide bilingual assistance to

all of its eligible voters if it effectively targets its bilingual program to

those in actual need of bilingual assistance.

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B-275220 

The implementation of the act by states and jurisdictions could vary

depending on the extent that the states provide assistance. For example,

where states provide ballot translations for national and state issues and

offices, the covered jurisdictions only have to translate the portions of

ballot issues and offices that pertain to them. Where states provide no

assistance, the responsibility for assistance falls entirely to the

jurisdictions.

The act, as amended, contains two sections—4(f)(4) and 203(c)—which

provide specific criteria for determining which states and jurisdictions are

to be covered by the bilingual voting provisions. The act designates the

Attorney General or the Director of the Census to make these

determinations (see app. III). In total, 422 jurisdictions in 28 states were

covered during 1996. These included three states—Alaska (Alaskan

Natives), Arizona (Spanish heritage), and Texas (Spanish

heritage)—which were covered statewide (i.e., the act’s provisions apply

to all political subdivisions within the state). Figure 1 illustrates the

number of covered jurisdictions in each state.

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B-275220 

Figure 1: Locations of Covered Jurisdictions by State

FL


(9)

CA


(21) CO


(9)

OR


(1)

AK

25

AZ


ID


(4)

ND


(3)

CO


(11)

SD


(8)

MS


(6)

OK


(1) 15

HI


(3)

IA


(1)

WI


(1)

IL


(1)

MI


(4)

NY


(7)

NJ


(5)

CT


(4)

RI


(1)

MA


(5)

NC


(1)

PA


(1)

ID


(4)

CO


(11)

SD


(8)

IA


(1)

MS


(6)

OK


(1)

NC


(1)

NY


(1)

UT


(1)

NV


(2)

NM


(26)

ND


(3)

TX


254

LA


(1)

WI


(1)

IL


(1)

NY


(7)

PA


(1)

MI


(4)

Statewide - all jurisdictions covered

( ) Limited coverage - number of covered jurisdictions indicated in ( )

Coverge does not apply

1

Source: Department of Justice and Bureau of Census data.

Some covered jurisdictions have more than one ethnic group for which

they are required to provide minority language voting assistance. Figure 2

shows the number of minority language groups by ethnicity within the 422

covered jurisdictions.

Page 6 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Figure 2: Number of Minority

Language Groups by Ethnicity in

Covered Jurisdictions

Jurisdictions

0

50

100

150

200

250

300

350

Spanish Heritage

American Indians

Alaskan Natives

Asian Americans

Ethnic groups

352

66

25

10

Note: Jurisdictions with multiple language minorities within the same ethnic group are counted

only once. Thus, if a jurisdiction contained Chinese, Japanese, and Vietnamese American

minorities, it is only counted once as an Asian American jurisdiction. However, if it contained

Hispanics and Chinese Americans, it is counted as both a Spanish heritage and an Asian

American jurisdiction.

Source: GAO analysis of the Code of Federal Regulations (28 CFR Ch.1).

The Department of Justice’s Civil Rights Division is to oversee the covered

states and jurisdictions’ implementation of the act. Where states and

jurisdictions fail to comply with the provisions, the Department of Justice

may bring civil action to attain compliance with the bilingual language

provisions.5

5

Individuals also have a right to bring civil actions to obtain relief.

Page 7 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Assistance

Jurisdictions and

States Reported

Providing in 1996

Most jurisdictions that reported providing bilingual voting assistance in

the 1996 general election said that they provided both written and oral

assistance. As shown in figure 3, about 73 percent of the 292 jurisdictions

responding reported that they provided both written and oral assistance.

Seven percent reported that they did not provide bilingual voting

assistance for the 1996 general election (see page 13). Moreover, five

jurisdictions that reported providing assistance also reported providing

assistance to other language minority groups that the act did not require

them to assist.

Figure 3: Percent of Jurisdictions

Reporting Various Types of Bilingual

Voting Assistance for the 1996 General

Election

73% • Written and oral

•15%

Written only

•

5%

Oral only

•

7%

Did not provide assistance

Source: GAO survey.

For 14 jurisdictions that reported providing oral assistance only, the act

required 12 to provide assistance to American Indian groups. In addition,

some jurisdictions that reported providing written and oral assistance

Page 8 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

actually provided assistance to more than one covered ethnic group, and

depending on the group assisted, the type of assistance they provided may

have varied. For example, Gila, AZ, reported providing written and oral

assistance to Hispanics but only oral assistance to Apache Indians whose

language is not written to the extent needed for election translation.

Twenty-six of the 28 states surveyed responded. Of the responding states,

12 reported providing bilingual voting assistance. In addition, some states

had passed their own legislation requiring some form of bilingual voting

assistance (see page 15). Arizona, California, Connecticut, Hawaii,

Massachusetts, New Mexico, and Texas reported providing both written

and oral assistance. Florida, Michigan, New Jersey, and Rhode Island

reported providing written assistance only. And, Alaska reported providing

oral assistance only. Moreover, two states, California and Hawaii, reported

providing assistance to groups that the act did not require them to assist.

Written Assistance

Reported by Jurisdictions

and States

As shown in figures 4 and 5, bilingual ballots were the most frequent type

of written assistance reported by jurisdictions and bilingual voting

instructions were the single most frequent written assistance reported by

states. Of the 258 jurisdictions that reported providing written assistance,

231 reported providing bilingual ballots. Of the 11 states that reported

providing written assistance, 7 reported providing bilingual voting

instructions. However, among jurisdictions, the types of bilingual voting

assistance they reported providing ranged from ballot assistance alone to

all voting materials provided to voters.

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B-275220 

Figure 4: Types of Written Bilingual Voting Assistance Jurisdictions Reported for the 1996 General Election

Number of jurisdictions

0

25

50

75

100

125

150

175

200

225

250

Bilingual

Separate translated

Instructions

Signs

Sample bilingual/translated ballot posted

Published in

newspapers

Mailed to voters

Other

231

12

224

183

151

181

54

45

Ballots Voting information Notices Othera

Note: More than one type of assistance may have been provided.

aOther assistance includes translated materials such as state propositions and analyses and

candidate statements.

Source: GAO survey.

Page 10 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Figure 5: Types of Written Bilingual Voting Assistance States Reported for the 1996 General Election

Number of states providing type of assistance

0

1

2

3

4

5

6

7

8

Bilingual

Separate translated

Instructions

Signs

Sample bilingual/translated ballot posted

Published in

newspapers

Mailed to voters

Other

6

1

7

5

6 6

4

8

Ballots Voting information Notices Othera

Note: More than one type of assistance may have been provided.

aOther assistance includes, for example, translations of propositions, constitutional amendments,

and forms.

Source: GAO survey.

Appendix IV provides examples of translated voting instructions that were

provided to some minority language voters and a portion of a bilingual

ballot.

Oral Assistance

Jurisdictions and States

Reported

Almost all jurisdictions and states that provided minority language oral

assistance did so by hiring bilingual poll and office workers or using the

assistance of volunteers. Of the 227 jurisdictions that reported providing

minority language oral assistance, 187 reported that they had hired

Page 11 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

bilingual workers and 35 reported that they used the assistance of

volunteers. In addition, 13 jurisdictions reported providing minority

language tapes describing the ballot and/or voting instructions. Of the

eight states providing bilingual oral assistance, four employed bilingual

workers and two hired interpreters to provide assistance. Figures 6 and 7

show the types of oral assistance provided by 227 jurisdictions and 8

states, respectively.

Figure 6: Types of Bilingual Oral

Assistance Jurisdictions Reported for

the 1996 General Election

Number of jurisdictions

0

25

50

75

100

125

150

175

200

Bilingual poll/office workers

Volunteers

Hired interpreters

Language recordings

Othera

187

35 30

13

34

Note: More than one type of assistance may have been provided.

aOther includes radio announcements; a telephone hotline; and bilingual officials in other offices

who could assist, if needed.

Source: GAO survey.

Page 12 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Figure 7: Types of Bilingual Oral

Assistance States Reported for the

1996 General Election

Number of states providing type of assistance

0

1

2

3

4

5

6

Bilingual poll/

office workers

Volunteers

Hired interpreters

Language recordings

Othera

4

0

2

4 4

Note: More than one type of assistance may have been provided.

aOther includes public service announcements, telephone assistance, and additional special

bilingual assistants.

Source: GAO survey.

Twenty-eight of the 227 responding jurisdictions reporting oral assistance

provided this assistance to American Indian groups. In addition, the state

of Alaska reported providing oral assistance to American Indian groups in

six jurisdictions. Of these 34 jurisdictions, only 4 reported providing

bilingual written materials as well as oral assistance to the American

Indian groups.

Some Covered

Jurisdictions Reported

Providing No Bilingual

Assistance

Although the jurisdictions that we surveyed were designated to provide

bilingual voting assistance, 20 jurisdictions reported that they did not do

so for the 1996 general election. They reported not providing assistance

because they said that they (1) were unable to locate or identify

Page 13 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

individuals in their areas needing assistance (5 jurisdictions), (2) were not

contacted by individuals in need of assistance or did not know of

individuals needing assistance (13 jurisdictions), or (3) believed they had

been exempted from providing assistance (2 jurisdictions).

Of the 20 jurisdictions that reported not providing assistance, 17 were

designated to provide it to American Indian groups and 3 were designated

to provide it to Spanish heritage groups. Three of the jurisdictions

designated to provide assistance to American Indian groups responded

that they had contacted tribal officials to identify those in need of

assistance but were told that no need existed. Another jurisdiction said

that it had conducted a telephone survey of registered voters but was

unable to find anyone in need of assistance. Further, 11 of the 20

jurisdictions indicated that should someone seek assistance, they had

interpreters who were on call or could otherwise provide assistance.

According to the Civil Rights Division’s Voting Section, one should

interpret with care a jurisdiction’s response to the survey that it did not

provide bilingual voting assistance. Most of the jurisdictions that indicated

they had not provided bilingual voting assistance had relatively few

members of the applicable language group, and the Attorney General’s

minority language guidelines explain that the objective of the bilingual

provisions is “to enable members of applicable language minority groups

to participate effectively in the electoral process.” Accordingly, the Section

said further inquiry would be needed to determine whether such a

jurisdiction has violated the bilingual requirements of the act.

Some Jurisdictions and

States Reported Providing

Assistance to Groups That

Were Not Required to Be

Covered

Five jurisdictions and two states reported that in addition to providing

assistance to minority language groups, as required under the act, they

also furnished assistance to other groups. Table 1 identifies the

jurisdictions and states that reported providing assistance to other groups

and the groups that they assisted.

Page 14 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Table 1: Jurisdictions and States That

Reported Assisting Other Groups in

1996 Jurisdiction or state

Groups required to be

assisted Other groups assisted

Jurisdictions:

New York City, NYa Spanish heritage, Chinese Korean

San Francisco City and

Co., CA

Chinese Spanish heritage

Santa Clara Co., CA Spanish heritage Vietnamese, Chinese

Sandoval Co., NM American Indian Spanish heritage

Santa Fe Co., NM Spanish heritage American Indian

States:

California none Korean

Hawaii none Chinese, Korean

aThe New York City response provided consolidated data for Bronx, Kings, Queens, and New

York counties.

Source: GAO survey.

Some States Have Adopted

Their Own Bilingual Voting

Assistance Requirements

Several states have enacted laws requiring some form of minority language

voting assistance during the election process. California, for example,

requires that minority language sample ballots be posted in polling places

in which the Secretary of State determines such assistance is needed. Also,

when a need exists, county clerks are required to make reasonable efforts

to recruit election officials fluent in minority languages. The state

considers assistance to be needed when 3 percent or more of voting age

citizens lack sufficient English skills to vote without assistance, or when

citizens or organizations provide information supporting a need for

assistance.

New Jersey requires that bilingual sample ballots be provided for election

districts where Spanish is the primary language for 10 percent or more of

the registered voters. Also, two additional election district board members

who are Hispanic in origin and fluent in Spanish must be appointed in

these districts.

In Texas, the election code specifies that bilingual election materials be

provided in precincts where persons of Spanish origin or descent

comprise 5 percent or more of the population of both the precinct and the

county in which the precinct is located. In these covered precincts, the

following materials must be presented bilingually: instruction cards,

ballots, affidavits, other forms that voters are required to sign, and

Page 15 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

absentee voting materials. In addition, the judge presiding over an election

in covered precincts must make reasonable efforts to appoint election

clerks who are fluent in both English and Spanish.

Also some states, such as North Dakota and Colorado, have laws that

entitle non-English speaking electors to have assistance, e.g., for preparing

ballots or operating voting machines, when they request it.

Costs Jurisdictions

and States Reported

Incurring to Provide

Bilingual Voting

Assistance in 1996

In response to our survey questions on the cost of providing bilingual

voting assistance,6

 34 jurisdictions said they reported all costs and 30

jurisdictions said they reported partial costs for 1996 elections. Likewise,

two states reported all and five states reported partial bilingual voting

assistance costs for 1996 elections.7

For prior year elections, 29 jurisdictions and 6 states reported data for

costs they incurred to provide bilingual voting assistance. Generally,

jurisdictions and states said they did not keep track of the costs they

incurred to provide the minority language portion of their voting

assistance. Further, they are not required to identify such costs.

Few Jurisdictions and

States Said They Identified

Costs for Providing

Bilingual Voting Assistance

Covered jurisdictions and states are not required to maintain data on their

costs of providing bilingual voting assistance. However, a small number of

jurisdictions and states reported cost information for providing bilingual

voting assistance. About 76 percent of the jurisdictions (see fig. 8) and

42 percent of the states that provided bilingual voting assistance were

unable to determine the cost of doing so. Some jurisdiction officials said

that their jurisdictions have provided bilingual assistance for so many

years that it is just a part of their total election process and they did not

bother to keep track of the bilingual assistance costs.

6

Our survey requested that respondents provide only the actual costs to implement the federal

bilingual voting assistance provisions for which they had supporting documentation. We asked that

they not provide cost estimates. We did not verify the cost data they provided.

7

Bilingual voting assistance costs the states reported are over and above the costs the jurisdictions

reported.

Page 16 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
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Figure 8: Percent of Jurisdictions

Providing Bilingual Cost Data for

Elections in 1996

12% • Provided all costs

11% • Provided partial costs

76%•

Unable to provide cost information

Note: Does not add to 100 percent due to rounding.

Source: GAO survey.

Most of the jurisdictions that were unable to provide cost data, cited, as

causes, the lack of specificity in (1) printers’ billing statements for election

materials and (2) their accounting systems. In analyzing the jurisdictions’

responses, we noted that 135 of the 272 jurisdictions reported they were

unable to provide cost data for providing written assistance but reported

using only bilingual workers or volunteer assistants to provide oral

assistance. Figure 9 shows the specific reasons 231 jurisdictions reported

being unable to do so.

Page 17 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
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Figure 9: Reasons Jurisdictions Could

Not Provide Bilingual Assistance

Costs

Number of jurisdictions

0

25

50

75

100

125

150

175

200

Printers did not

provide itemized statements

Accounting system

did not itemize costs

Can’t separate

federal from state requirement

Othera

177

107

66

28

Note: Some jurisdictions gave more than one reason.

aOther includes reasons such as being generally unable to separate the bilingual costs from the

other costs incurred.

Source: GAO survey.

In addition, we contacted three printers of election materials and ballots in

Texas8

 to determine whether they could provide information on the cost of

publishing the minority language portion of the ballot. None of the printers

contacted could provide the costs of the minority portion of the ballot.

One printer estimated that for 1996, the minority language portion of the

ballot comprised about 25 percent of the total cost of ballots.

8

These printers printed election materials and ballots for about 80 percent of Texas’ 254 counties.

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Jurisdictions’ Reported

Costs for Elections in 1996

Of the 272 responding jurisdictions that reported providing bilingual voting

assistance, 34 jurisdictions reported the total cost of providing such

assistance,9

 of which 6 jurisdictions said they provided oral assistance

only but at no additional cost. In addition, 30 jurisdictions reported partial

cost data. Table 2 shows the total costs jurisdictions reported they

incurred to provide bilingual voting assistance under the act.10

9

In reporting cost information, we requested that respondents include primary elections and, where

applicable, the early voting period of the general election as part of the total costs for carrying out the

elections. Because the data were not reported separately, costs of assistance for jurisdictions with

primary elections or early voting cannot be distinguished from costs for jurisdictions that did not have

such elections.

10The six jurisdictions that reported providing oral bilingual assistance at no additional cost were

Jones County, MS; Newton County, MS; Humbolt County, NV; Harding County, NM; Benson County,

ND; and Shannon County, SD.

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Table 2: Jurisdictions’ Reported Total

Costs for Providing Bilingual Voting

Assistance in 1996

Name of jurisdiction

Types of

groups

assisted

Number of

polling places

Number of

bilingual

polling places

Alameda Co., CA S, C 1,034 1,034

Colusa Co., CA S 17 17

Inyo Co., CA S 22 1

Kings Co., CA S 28 28

Los Angeles Co., CA S, C, V, J, F 5,632 5,632

Orange Co., CA S, V 1,628 1,628

San Benito Co., CA S 22 17

San Diego Co., CA S 1,510 1,510

San Francisco City and Co., CA C 652 250

Santa Clara Co., CA S 1,146 1,146

New Britain, CT S 19 8

Bingham Co., ID S, I 22 2

Power Co.,ID I 7 2

Springfield, MA S 64 64

Chelsea, MA S 10 10

Clyde Township, MI S 1 1

Zilwaukee Township, MI S 1 1

Middlesex Co., NJ S 247 225

Luna Co., NM S 13 13

New York City, NYf S, C 1,280 788

Suffolk Co., NY S 350 350

Jackson Co., NC I 18 1

Adair Co., OK I 18 18

Central Falls, RI S 9 9

Dewey Co., SD I 14 9

Todd Co., SD I 11 6

Andrew Co., TX S 5 5

San Juan Co., UT I 15 7

Page 20 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

f

l

s

Types of help

provided Total election costs

Bilingual written

costs

Bilingual

oral costs

Other bilingual

costs

Total bilingual

costs

4 Written/oral $2,842,300 $213,200 b $23,778c $236,978

7 Written/oral 83,500 300 b d 300

Oral 79,372 a $100 d 100

8 Written/oral 220,200 66,500 2,000 d 68,500

2 Written/oral 30,981,718 828,800 276,300 d 1,105,100

8 Written/oral 5,730,100 340,400 66,800 d 407,200

7 Written/oral 111,400 15,300 b d 15,300

0 Written/oral 3,450,000 29,400 2,160 d 31,560

0 Written/oral 3,200,000 78,000 b d 78,000

6 Written/oral 5,405,000 581,123 62,125 d 643,248

8 Written/oral 50,100 700 b d 700

2 Oral 109,000 a 1,200 d 1,200

2 Oral 19,361 a 200 d 200

4 Written/oral 47,000 500 b d 500

0 Written/oral 48,700 1,000 b d 1,000

Written/oral 4,500 900 162 d 1,062

Written 1,000 0e a d 0

5 Written/oral 281,058 105,200 b d 105,200

3 Written/oral 26,000 15,000 b d 15,000

8 Written/oral 16,000,000 369,500 216,900 d 586,400

0 Written/oral 1,800 1,000 b d 1,000

Written/oral 18,000 100 200 d 300

8 Oral 1,000 a 100 d 100

9 Written/oral 12,749 100 b d 100

9 Oral 16,450 a 138 d 138

6 Oral 17,100 a 700 d 700

5 Written/oral 6,300 1,900 700 d 2,600

7 Oral 68,500 a 44,500 d 44,500

Page 21 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Legend: S = Spanish heritage; C = Chinese; V = Vietnamese; J = Japanese; F = Filipino; and I =

American Indian.

aFor jurisdictions providing oral voting assistance only, bilingual written assistance costs are not

applicable. Likewise, for jurisdictions providing written assistance only, bilingual oral assistance

costs are not applicable.

bFor jurisdictions providing both written and oral assistance, but which reported no costs for oral

assistance, the oral assistance was reportedly provided by bilingual poll/office workers at no

additional cost.

cOther included computer upgrades, word processing package purchases, and additional costs

for office personnel.

dJurisdiction did not indicate costs in this category.

eZilwaukee reported incurring no additional costs as bilingual sample ballots and other bilingual

voting materials that it posted were paid for by the state and the county.

f

The New York City response provided consolidated cost data for Bronx, Kings, Queens, and New

York counties.

Source: GAO survey.

In addition to the above jurisdictions, table 3 provides information on the

30 jurisdictions that were able to provide partial cost information.

Page 22 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Page 23 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Table 3: Jurisdictions’ Reported Partial

Costs for Providing Bilingual Voting

Assistance in 1996

Name of jurisdiction

Types of

groups

assisted

Total polling

places

Bilingual

polling places

Coconino Co., AZ S, I 75 75

Maricopa Co., AZ S, I 843 92

Pima Co., AZ S, I 402 402

Imperial Co., CA S 65 65

Kern Co., CAa S 318 237

Monterey Co., CA S 169 52

Riverside Co., CA S 961 961

San Bernardino Co., CAa S 876 291

Tulare Co., CAa S 168 168

Ventura Co., CA S 427 427

Yuba Co., CA S 43 43

Saguache Co., CO S 10 10

Hartford Town, CT S 27 27

Collier Co., FL S, I 94 94

Dade Co., FL S 576 576

Hillsborough Co., FL S 314 314

Monroe, Co., FL S 33 33

Orange Co., FL S 218 218

Passaic Co., NJ S 279 81

Union Co., NJ S 219 46

Cibola Co., NM S, I 30 30

Lea Co., NM S 46 46

San Juan Co., NM S, I 83 83

Taos Co., NM S, I 40 40

Valencia Co., NM S 36 36

Philadelphia Co., PA S 1,681 1,681

Lamb Co., TX S 12 11

Parmer Co., TX S 10 9

Collin Co., TX S 119 119

Jones Co., TX S 15 5

Page 24 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

l

s

Types of help

provided Total election costs

Bilingual written

costs

Bilingual

oral costs

Other bilingual

costs

Partial bilingual

costs totals

5 Written/oral $242,600 unknown $1,500 $275e $1,775

2 Written/oral 3,500,000 $3,400 294 d 3,694

2 Written/oral 1,640,363 unknown 600 d 600

5 Written/oral 277,665 70,200 c d 70,200

7 Written/oral 800,000 23,000 c d 23,000

2 Written/oral d 38,500 c d 38,500

Written/oral 2,700,000 22,800 unknown d 22,800

Written/oral 1,550,315 72,400 2,340 d 74,740

8 Written/oral 329,900 18,591 c d 18,591

7 Written/oral unknown 3,400 c 200e 3,600

3 Written/oral 188,896 16,651 c d 16,651

0 Written/oral 28,000 200 c d 200

7 Written/oral 24,370 1,432 c d 1,432

4 Written/oral 540,000 2,000 unknown d 2,000

6 Written/oral 2,700,000 53,900 c d 53,900

4 Written/oral 1,080,000 700 c d 700

3 Written/oral 65,000 2,662 c d 2,662

8 Written/oral 1,348,400 12,200 c d 12,200

Written/oral 727,100 8,349 25,000 d 33,349

6 Written/oral 634,800 14,400 4,300 d 18,700

0 Written/oral 44,844 unknown 4,960 d 4,960

6 Written/oral 84,779 9,699 c d 9,699

3 Written/oral 450,100 unknown 64,600 1,976e 66,576

0 Written/oral f unknown 120 d 120

6 Written/oral 120,500 2,000 500 6,500e 9,000

Written/oral f unknown 3,100 d 3,100

Written/oral 5,900b unknown 700 d 700

9 Written/oral 5,500b unknown 600 d 600

9 Written/oral 230,000b 4,000 c d 4,000

5 Written/oral 10,983b unknown 300 d 300

Page 25 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Legend: S = Spanish heritage and I = American Indian.

aTotal election costs for Kern County, San Bernardino County, and Tulare County, CA, were only

for the primary election. Bilingual assistance costs for San Bernardino County were only for the

primary election. Bilingual assistance costs for Kern County and Tulare County were for both the

primary and general elections.

bIn Texas, the political parties paid the costs of the primary elections, while the jurisdictions paid

the costs for the general election.

cFor jurisdictions providing both written and oral assistance, but which reported no costs for oral

assistance, the oral assistance was reportedly provided by bilingual poll/office workers or

volunteers at no additional cost. For jurisdictions providing written assistance only, no oral

assistance was provided.

dJurisdiction did not indicate costs in this category.

eOther bilingual costs included: Coconino County, AZ, incurred mileage costs; Ventura County,

CA, replaced signs, instructions, and forms; San Juan County, NM, produced video and audio

tapes and purchased bulletin boards; and Valencia County, NM, purchased audio/visual

equipment for pollworker training.

f

Jurisdiction did not complete this question.

Source: GAO survey.

States’ Reported Costs for

Elections in 1996

Of the 12 state respondents that reported providing bilingual voting

assistance, Florida and Hawaii reported total bilingual voting assistance

costs for the 1996 elections. Arizona, Massachusetts, Michigan, New

Mexico, and Rhode Island provided partial cost data. Table 4 presents the

cost data reported by the seven states for the 1996 elections.

Page 26 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Table 4: States’ Reported Costs for Providing Bilingual Voting Assistance in 1996

State

Type of help

provided

Bilingual written

costs

Bilingual oral

costs

Other bilingual

costs

Total bilingual

costs

Total costs:

Hawaii Written/oral $22,648 $680 a $23,328

Florida Written 7,900 b a 7,900

Partial costs:

Arizona Written/oral 3,970 a a 3,970

Massachusetts Written/oral 3,437 0c a 3,437

Michigan Written 3,930 b a 3,930

New Mexico Written/oral unknown 9,400 $60,900d 70,300

Rhode Island Written 8,000 b a 8,000

aStates did not report costs in these categories.

bStates provided written assistance only; bilingual oral assistance costs were not applicable.

cMassachusetts reported providing oral assistance at no additional cost by having state

employees available that spoke the minority language.

dNew Mexico provided grants to jurisdictions to provide bilingual voting assistance.

Source: GAO survey.

States’ and Jurisdictions’

Reported Costs for Prior

Elections

For prior election years 1992 to 1995, 29 jurisdictions and 6 states provided

cost data. However, the cost data provided may not represent all bilingual

costs.

The bilingual assistance costs jurisdictions reported for prior years’

elections varied widely. For example, Central Falls City, RI, reported costs

of $83 for 1992, $164 for 1993, $175 for 1994, but $0 for 1995. Los Angeles

County, CA, reported costs of $451,800 for 1993, $764,900 for 1994, and

$292,400 for 1995. Table 5 shows the prior year election costs reported by

the jurisdictions.

Page 27 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Table 5: Reported Costs to Provide

Bilingual Voting Assistance by

Jurisdiction, Election Years 1992-1995 Name of jurisdiction

Bilingual

costs 1992

Bilingual

costs 1993

Bilingual

costs 1994

Bilingual

costs 1995

Alameda Co., CA $67,300 $48,200 $191,800 $33,563

Colusa Co., CA 300 a 300 a

Imperial Co., CA a a 47,800 16,700

Inyo Co., CA a 45 90 a

Kern Co., CA 51,000 a 30,000 a

Los Angeles Co., CA a 451,800 764,900 292,400

Orange Co., CA 160,084 a 381,138 a

Riverside Co., CA 11,452 7,659 22,008 22,972

San Benito Co., CA 12,562 a 10,175 418

San Diego Co., CA 19,299 25,557 45,000 28,800

San Francisco City and

Co., CA

34,552 45,865 43,571 35,632

Santa Clara Co., CA a a 352,447 a

Tulare Co., CA 38,100 9,900 19,400 11,000

Ventura Co., CA 600 100 14,200 a

Yuba Co., CA a a 28,793 a

Saguache Co., CO a a 110 a

Windham Co., CT a a a 1,700

Orange Co., FL 7,344 a 5,400 a

Bingham Co., ID 500 a 500 a

Power Co., ID a a 200 a

Clyde Township, MI 422 106 500 a

Union Co., NJ a 36,900 32,000 24,500

New York City, NYb 127,060 309,620 450,624 264,226

Jackson Co., NC 325 a 332 a

Lea Co., NM 13,872 a 12,195 a

Adair Co., OK 117 a 117 a

Central Falls City, RI 83 164 175 0

Dewey Co., SD 452 a 406 a

San Juan Co., UT a a 49,700 a

aJurisdictions did not report costs in these years because, for example, they were unable to

determine those costs or no elections were held.

bThe New York City response provided consolidated cost data for Bronx, Kings, Queens, and

New York counties.

Source: GAO survey.

Page 28 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
B-275220 

Similarly, the costs reported by the six states for prior election years

varied. For example, for 1994, Hawaii reported costs of $610, while New

Mexico reported costs of more than $70,000. Four of the states reported

they did not incur any election costs in odd-numbered years, but other

states did not provide cost information for a year. Table 6 shows the prior

year election costs reported by the states.

Table 6: States’ Reported Prior Year

Election Costs, 1992-1995

State

Bilingual

costs 1992

Bilingual

costs 1993

Bilingual

costs 1994

Bilingual

costs 1995

Arizona a a $10,000 a

Hawaii $1,872 a 610 a

Massachusetts 3,000 a 6,000 a

Michigan 1,590 $806 8,901 a

New Mexico a a 70,300 a

Texas 146,524 247,295 1,520 $248,281

aStates did not incur or did not provide costs for these years.

Source: GAO survey.

We are providing copies of this report to the Chairmen of the House and

Senate Committees on the Judiciary and their respective Ranking Minority

Members. We will also make copies available to others on request.

Major contributors to this report are listed in appendix V. If you have any

questions about this report, please call me on (202) 512-8777.

Sincerely yours,

Norman J. Rabkin

Director, Administration of

 Justice Issues

Page 29 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

32

Appendix II 

Listing of States and

Covered Jurisdictions

That Responded to

GAO’s Survey

41

Appendix III 

Coverage Criteria for

Implementation of the

Voting Rights Act

Provisions Regarding

Language Minority

Groups

49

Appendix IV 

Examples of Bilingual

Voting Written

Assistance Materials

52

Appendix V 

Major Contributors to

This Report

56

Tables Table 1: Jurisdictions and States that Reported Assisting Other

Groups in 1996

15

Table 2: Jurisdictions’ Reported Total Costs for Providing

Bilingual Voting Assistance in 1996

20

Page 30 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Contents

Table 3: Jurisdictions’ Reported Partial Costs for Providing

Bilingual Voting Assistance in 1996

24

Table 4: States’ Reported Costs for Providing Bilingual Voting

Assistance in 1996

27

Table 5: Reported Costs to Provide Bilingual Voting Assistance by

Jurisdiction, Election Years 1992-1995

28

Table 6: States’ Reported Prior Year Election Costs, 1992-1995 29

Table II.1: States and Covered Jurisdictions that Responded to

GAO’s Survey and the Applicable Ethnic and Minority Language

Groups

41

Figures Figure 1: Locations of Covered Jurisdictions by State 6

Figure 2: Number of Minority Language Groups by Ethnicity in

Covered Jurisdictions

7

Figure 3: Percent of Jurisdictions Reporting Various Types of

Bilingual Voting Assistance for the 1996 General Election

8

Figure 4: Types of Written Bilingual Voting Assistance

Jurisdictions Reported for the 1996 General Election

10

Figure 5: Types of Written Bilingual Voting Assistance States

Reported for the 1996 General Election

11

Figure 6: Types of Bilingual Oral Assistance Jurisdictions

Reported for the 1996 General Election

12

Figure 7: Types of Bilingual Oral Assistance States Reported for

the 1996 General Election

13

Figure 8: Percent of Jurisdictions Providing Bilingual Cost Data

for Elections in 1996

17

Figure 9: Reasons Jurisdictions Could Not Provide Bilingual

Assistance Costs

18

Figure I.1: Location and Number of Spanish Heritage Covered

Jurisdictions

36

Figure I.2: Location and Number of Asian American Covered

Jurisdictions

37

Figure I.3: Location and Number of American Indian and Alaskan

Native Covered Jurisdictions

38

Figure IV.1: Bilingual Ballot - Comal County, TX 53

Figure IV.2: Bilingual Instructions - Los Angeles County, CA 54

Page 31 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Our objectives were to determine (1) what types of bilingual voting

assistance states and covered jurisdictions provided during the 1996

general election to implement the bilingual voting assistance provisions of

the Voting Rights Act of 1965, as amended; and (2) the actual costs states

and covered jurisdictions incurred in 1996 to provide bilingual voting

assistance and materials, as well as the actual costs they incurred in prior

elections. Regarding cost information, we agreed to collect election costs,

not voter registration costs, and only obtain the actual bilingual costs of

the states and covered jurisdictions (not estimates).

We began our review by carrying out a search of the legal and social

science literature on bilingual voting assistance. We reviewed the studies

identified through the search, as well as relevant newspaper articles and

reports by the Congressional Research Service. We also reviewed our 1986

report on the costs and use of bilingual voting assistance during the 1984

general election.1

 We contacted Department of Justice and Bureau of

Census officials to identify jurisdictions covered by the act.

To address both our objectives, we sought descriptive data and other

information about all 422 covered jurisdictions and the 28 states in which

the jurisdictions were located, through mail-out questionnaires. We

developed one questionnaire to request information from the covered

jurisdictions and a second questionnaire to solicit information from the

states in which the covered jurisdictions were located. We sent a

questionnaire to election officials representing 3912

 covered jurisdictions

and the 28 states.

With respect to the first objective, we requested, from each covered

jurisdiction and state, information on the types of written and oral

bilingual voting assistance provided. In addition, we asked the states and

jurisdictions to provide samples of the written materials and information

provided to minority language voters.

1

Bilingual Voting Assistance: Costs of and Use During the November 1984 General Election

(GAO/GGD-86-134BR, Sept. 1986).

2

For the 25 covered jurisdictions in Alaska (as determined by the 1990 Census) and the 3 covered

jurisdictions in Hawaii, state election officials requested that they be permitted to respond for the

jurisdictions; in both Alaska and Hawaii, the state and not the local jurisdictions is responsible for

election administration. Their responses are contained in discussions of state assistance. In addition,

New York City Board of Election officials agreed to provide responses for four covered

jurisdictions—Bronx, Kings, Queens, and New York Counties. Their response is included in the

discussions on jurisdiction assistance. Thus, in total, 422 covered jurisdictions were represented by the

jurisdictions to which we mailed surveys.

Page 32 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Regarding the second objective, we asked the covered jurisdictions and

states to provide actual cost information for the 1996 general election,

including early voting and absentee voting costs, and for the primary

elections. We also asked the jurisdictions and states to provide actual data

for other costs that were the result of providing bilingual voting assistance,

e.g., for special equipment such as enhanced voting machines. We solicited

information on the actual costs incurred by the jurisdictions and states to

provide written and oral assistance costs as well as other related costs for

elections between 1992 and 1995. If, however, a state or jurisdiction could

not provide actual cost data, we asked that it not provide estimated costs.

Further, we used the questionnaires to collect information on bilingual

voting assistance laws in the 28 states. Specifically, we asked the states

and jurisdictions to provide information on any state or local bilingual

voting assistance requirements.

To develop the questionnaires, we spoke with officials in the Voting Rights

Section of the Civil Rights Division of the Department of Justice. In

addition, we contacted state elections officials in the 28 states where the

422 jurisdictions were located to (1) obtain the names and addresses of the

appropriate election officials in the covered jurisdictions and (2) ascertain

what information might be available on the bilingual voting assistance

materials provided and the costs of providing such materials. We pretested

the questionnaires, by telephone, with election officials from judgmentally

selected states and covered jurisdictions. Through these pretests, we

received input from states and jurisdictions in different geographic

regions. We revised the questionnaires on the basis of this input.

On November 15, 1996, we mailed the questionnaires. We followed up with

a second mailing to those jurisdictions that had not responded by

December 23, 1996. In mid-January 1997, we followed up with phone calls

to election officials in those jurisdictions and states that had not

responded.

In all, we received information about 323 of the 422 covered jurisdictions

and 26 of the 28 states. Specifically, we received fully or partially

completed responses from 292 (75 percent) of the 391 covered

jurisdictions sent questionnaires. Alaska and Hawaii provided information

for the 28 jurisdictions in their states. The New York City Board of

Election provided responses for four covered jurisdictions—Bronx, Kings,

Queens, and New York Counties.

Page 33 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

To the extent practical, we attempted to verify the completeness and

accuracy of the responses. We conducted edit checks of key responses for

completeness. When necessary, we contacted respondents to obtain

responses to incomplete answers and to resolve any apparent

inconsistencies between answers to different questions. For Los Angeles

County, we contacted an election official to determine the source of Los

Angeles’ reported bilingual assistance cost information. As a consistency

check, where possible, we compared questionnaire responses on the

assistance provided with the samples of written election materials the

respondents provided us. Of the 258 respondents reporting that they

provided written bilingual voting assistance, 155 or 60 percent sent us

samples of the bilingual materials they provided.

In addition, a number of jurisdictions provided us documentation

supporting their costs. Ten jurisdictions provided copies of invoices they

received to support, in total or in part, the bilingual costs they reported

and seven jurisdictions provided, in their questionnaire responses,

itemized cost breakdowns to support the costs they reported. For

example, Pima County, AZ, provided copies of invoices supporting the

$600 in costs it reported; Monterey County, CA, provided invoices totaling

$17,511.68 it received for, among other things, translations of candidate

statements and ballot measures; and San Bernardino County, CA, showed

on its response, among other things, calculations to support $2,340 it paid

in pay adjustments to its bilingual staff. A Los Angeles County official told

us that their reported costs were prepared by their budget and accounting

section, which tracks the cost information, and were based on hard copy

evidence. Moreover, she said that the county has to follow accounting

rules and regulations specified by the county auditor. Furthermore, we

extended our reporting deadline, because we had asked for actual costs

and some jurisdictions, such as New York City and San Francisco, had not

received all of their invoices in time to meet our originally requested date.

The supporting documentation the jurisdictions provided was not

inconsistent with the bilingual costs they reported. Because the

jurisdictions that reported costs were geographically dispersed, it was not

practical to fully verify the costs reported.

For both objectives, however, the questionnaire findings were affected by

a variety of limitations in the information and data available. The covered

jurisdictions varied in the number of polling places where bilingual

assistance was provided, the size of the populations in need of bilingual

assistance, and the number of minority groups provided bilingual

assistance within the jurisdiction. Accordingly, comparisons across

Page 34 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

jurisdictions are not meaningful and findings should not be projected to

nonrespondents.

Further, the response rate varied across minority language groups. We

received information about 262 (74 percent) of the 352 jurisdictions

required to provide assistance to Spanish heritage groups. Figure I.1

illustrates the location and number of these jurisdictions.

Page 35 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Figure I.1: Location and Number of Spanish Heritage Covered Jurisdictions

Statewide - all jurisdictions covered

( ) Limited coverage - number of covered jurisdictions indicated in ( )

Coverge does not apply

1

FL


(6)

NJ


(5)

CT


(4)

RI


(1)

MA


(5) WI


(1)

IL


(1)

NM


(23)

TX

254

CO


(9)

CA


(17)

AZ

15

NY


(6)

PA


(1)

MI


(4)

Source: GAO analysis of Department of Justice and Bureau of Census data.

We received information about all 10 jurisdictions required to provide

assistance to Asian Americans. Figure I.2 illustrates the location and

number of these jurisdictions.

Page 36 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Figure I.2: Location and Number of Asian American Covered Jurisdictions

Statewide - all jurisdictions covered

( ) Limited coverage - number of covered jurisdictions indicated in ( )

Coverge does not apply

1

HI


(3)

CA


(4)

NY


(3)

Source: GAO analysis of Department of Justice and Bureau of Census data.

We received information representing 513 (77 percent) of the 66

jurisdictions required to provide assistance to American Indians. The state

of Alaska provided statewide information on assistance provided to

3

We received statewide information from Alaska where there are six jurisdictions with American

Indian populations.

Page 37 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Alaskan Natives (25 jurisdictions). Figure I.3 illustrates the location and

number of the American Indian and Alaskan Native covered jurisdictions.

Figure I.3: Location and Number of American Indian and Alaskan Native Covered Jurisdictions

Statewide - all jurisdictions covered

( ) Limited coverage - number of covered jurisdictions indicated in ( )

Coverge does not apply

1

FL


(5)

CA


(3) CO


(9)

OR


(1)

AK

25

AZ


(9)

UT


(1)

NV


(2)

ID


(4)

ND


(3)

CO


(2)

NM


(9)

SD


(8)

IA


(1)

MS


(6)

NY


(1)

TX


(2)

OK


(1)

LA


(1)

NC


(1)

NY


(1)

Note: Of the 25 Alaskan jurisdictions, 6 provided assistance to both Alaskan Natives and

American Indians.

Source: GAO analysis of Department of Justice and Bureau of Census data.

Page 38 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Thus, we can report responses representing all Alaskan Native and all

Asian American jurisdictions. We can report responses representing

77 percent of the American Indian jurisdictions. Of the 90 Spanish heritage

jurisdictions (26 percent) not reporting, most were in Texas. Since even

within a language group, the jurisdictions are very different, comparisons

across jurisdictions or projections of findings to the nonrespondents

within a particular language group should not be made.

We received information from jurisdictions in all 28 states. The

respondents included urban and rural jurisdictions. We did not, however,

receive information from the major metropolitan areas of Suffolk County,

MA—Boston—and Harris County, TX—Houston. We did not receive

information from the states of Colorado and Nevada.

In addition, 20 of the jurisdictions responding reported providing no

bilingual voting assistance. Seventeen of these jurisdictions were to

provide assistance to American Indians; they comprised one fourth of the

66 jurisdictions required to provide assistance to American Indians. Three

of the 20 jurisdictions were to provide assistance to Spanish heritage

groups. Since the 20 jurisdictions were not randomly distributed among

the respondents but were primarily American Indian jurisdictions, there

may be something unique about these jurisdictions, e.g., the size of the

minority language population or the oral language tradition, that could

explain the responses. Further, since the responses were self-reported,

reflecting the interpretation of the respondent, conclusions regarding

compliance cannot be drawn without further inquiry.

In addition, differences in the calculation and reporting of election costs

precluded comparisons among the jurisdictions and states that could

provide election cost and/or bilingual cost data. For example, for Texas

jurisdictions’ total election costs did not include the costs of primary

elections because the political parties paid the primary costs, while across

California the jurisdictions incurred both primary and election costs.

Because of the differences in election and bilingual assistance costs across

the states and jurisdictions, we did not attempt to compare the percentage

of bilingual costs to total costs across jurisdictions, calculate any summary

costs, or use these data to project the costs of nonrespondents. We only

reported the cost figures as provided by the jurisdictions and states that

could provide us with actual cost data. We did not verify independently the

cost data provided.

Page 39 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix I 

Objectives, Scope, and Methodology

Further, in an effort to obtain cost information in addition to that provided

by the questionnaire respondents, we contacted three printers in Texas.

We focused on Texas because it had the largest number of covered

jurisdictions (254) of any state and these jurisdictions comprised over half

of the total of covered jurisdictions nationwide. Since few Texas

jurisdictions could provide any cost data and most Texas jurisdictions

used these printers, we contacted them to ask whether they could provide

cost information.

On April 9, 1997, we requested comments from the Attorney General or her

designee on a draft of this report. On April 18, 1997, the Chief of the Voting

Section, Civil Rights Division, on behalf of the Attorney General, provided

technical information, which we incorporated where appropriate. We did

our work between July 1996 and April 1997 in accordance with generally

accepted government auditing standards.

Page 40 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

The following table shows the states and covered jurisdictions that

responded to GAO’s survey and the related ethnic and minority language

groups to whom bilingual voting assistance applied.

Table II.1: States and Covered Jurisdictions That Responded to GAO’s Survey and the Applicable Ethnic and Minority

Language Groups

State Covered jurisdiction Ethnic groups (minority language group)

Alaskaa Alaskan Natives (Eskimo, Aleut); American Indian

(Athapascan, Tanaina, Tlinglit, Kuchin)

Arizona Coconino County American Indian (Havasupai, Hopi, Navajo);

Spanish heritage

Gila County American Indian (Apache); Spanish heritage

Graham County American Indian (Apache); Spanish heritage

Greenlee County Spanish heritage

La Paz County Spanish heritage

Maricopa County American Indian (Pima, Yavapai); Spanish heritage

Mohave County Spanish heritage

Pima County American Indian (Pima); Spanish heritage

Pinal County American Indian (Apache, Pima); Spanish heritage

California Alameda County Asian American (Chinese); Spanish heritage

Colusa County American Indian (Wintun)

Fresno County Spanish heritage

Imperial County Spanish heritage

Inyo County American Indian (Spanish)

Kern County Spanish heritage

Kings County Spanish heritage

Lake County American Indian (Spanish)

Los Angeles County Asian American (Chinese, Filipino, Japanese,

Vietnamese); Spanish heritage

Merced County Spanish heritage

Monterey County Spanish heritage

Orange County Asian American (Vietnamese); Spanish heritage

Riverside County Spanish heritage

San Benito County Spanish heritage

San Bernardino County Spanish heritage

San Diego County Spanish heritage

San Francisco County Asian American (Chinese)

Santa Clara County Spanish heritage

Tulare County Spanish heritage

Ventura County Spanish heritage

(continued)

Page 41 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Yuba County Spanish heritage

Coloradob Alamosa County Spanish heritage

Archuleta County Spanish heritage

Bent County Spanish heritage

Conejos County Spanish heritage

La Plata County American Indian (Ute)

Las Animas County Spanish heritage

Montezuma County American Indian (Ute)

Otero County Spanish heritage

Rio Grande County Spanish heritage

Saguache County Spanish heritage

Connecticut Bridgeport Town (Fairfield County) Spanish heritage

Hartford Town (Hartford County) Spanish heritage

New Britain Town (Hartford County) Spanish heritage

Windham Town (Windham County) Spanish heritage

Florida Broward County American Indian (Mikasuki, Muskogee); Spanish

heritage

Collier County American Indian (Mikasuki)

Dade County American Indian (Mikasuki); Spanish heritage

Hardee County Spanish heritage

Hendry County American Indian (Mikasuki, Muskogee)

Hillsborough County Spanish heritage

Monroe County Spanish heritage

Orange County Spanish heritage

Hawaiia Asian American (Filipino, Japanese)

Idaho Bingham County American Indian (Shoshoni)

Owyhee County American Indian (Shoshoni)

Power County American Indian (Shoshoni)

Illinois Cook County Spanish heritage

Iowa Tama County American Indian (Fox)

Louisiana Avoyelles Parish American Indian (French)

Massachusetts Chelsea City (Suffolk County) Spanish heritage

Holyoke City (Hampden County) Spanish heritage

Springfield City (Hampden County) Spanish heritage

Michigan Clyde Township (Allegan County) Spanish heritage

Zilwaukee Township (Saginaw County) Spanish heritage

Mississippi Jones County American Indian (Choctaw)

Kemper County American Indian (Choctaw)

Leake County American Indian (Choctaw)

(continued)

Page 42 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Neshoba County American Indian (Choctaw)

Newton County American Indian (Choctaw)

Nevadab Elko County American Indian (Shoshoni)

Humboldt County American Indian (Paiute)

New Jersey Essex County Spanish heritage

Middlesex County Spanish heritage

Passaic County Spanish heritage

Union County Spanish heritage

New Mexico Chaves County Spanish heritage

Cibola County American Indian (Keres, Navajo, Zuni); Spanish

heritage

Colfax County Spanish heritage

Dona Ana County Spanish heritage

Eddy County Spanish heritage

Grant County Spanish heritage

Guadalupe County Spanish heritage

Harding County Spanish heritage

Hidalgo County Spanish heritage

Lea County Spanish heritage

Luna County Spanish heritage

McKinley County American Indian (Navajo, Zuni)

Mora County Spanish heritage

Quay County Spanish heritage

Roosevelt County Spanish heritage

San Juan County American Indian (Navajo)

Sandoval County American Indian (Jicarilla, Keres, Navajo, Towa)

Santa Fe County Spanish heritage

Socorro County American Indian (Navajo); Spanish heritage

Taos County American Indian (Tiwa); Spanish heritage

Torrance County Spanish heritage

Union County Spanish heritage

Valencia County American Indian (Keres, Tiwa); Spanish heritage

New York Franklin County American Indian (Mohawk)

New York Cityc Asian American (Chinese), Spanish heritage

Suffolk County Spanish heritage

North Carolina Jackson County American Indian

North Dakota Benson County American Indian (Dakota)

Eddy County American Indian (Dakota)

Ramsey County American Indian (Dakota)

(continued)

Page 43 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Oklahoma Adair County American Indian (Cherokee)

Oregon Malheur County American Indian (Paiute)

Pennsylvania Philadelphia County Spanish heritage

Rhode Island Central Falls City (Providence County) Spanish heritage

South Dakota Dewey County American Indian (Dakota)

Gregory County American Indian (Dakota)

Lyman County American Indian (Dakota)

Mellette County American Indian (Dakota)

Shannon County American Indian

Todd County American Indian (Dakota)

Tripp County American Indian (Dakota)

Ziebach County American Indian (Dakota)

Texas Andrews County Spanish heritage

Aransas County Spanish heritage

Archer County Spanish heritage

Atascosa County Spanish heritage

Bailey County Spanish heritage

Bastrop County Spanish heritage

Baylor County Spanish heritage

Bee County Spanish heritage

Bowie County Spanish heritage

Brazoria County Spanish heritage

Burnet County Spanish heritage

Caldwell County Spanish heritage

Calhoun County Spanish heritage

Callahan County Spanish heritage

Cameron County Spanish heritage

Camp County Spanish heritage

Carson County Spanish heritage

Castro County Spanish heritage

Childress County Spanish heritage

Cochran County Spanish heritage

Coke County Spanish heritage

Collin County Spanish heritage

Concho County Spanish heritage

Cooke County Spanish heritage

Comal County Spanish heritage

Coryell County Spanish heritage

Crane County Spanish heritage

(continued)

Page 44 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Crockett County Spanish heritage

Crosby County Spanish heritage

Culberson County Spanish heritage

Dallam County Spanish heritage

Dallas County Spanish heritage

Dawson County Spanish heritage

Deaf Smith County Spanish heritage

Denton County Spanish heritage

Dewitt County Spanish heritage

Dickens County Spanish heritage

Dimmit County Spanish heritage

Donley County Spanish heritage

Duval County Spanish heritage

Eastland County Spanish heritage

Ector County Spanish heritage

Edwards County Spanish heritage

El Paso County American Indian (Spanish); Spanish heritage

Ellis County Spanish heritage

Erath County Spanish heritage

Falls County Spanish heritage

Fannin County Spanish heritage

Fayette County Spanish heritage

Fisher County Spanish heritage

Floyd County Spanish heritage

Foard County Spanish heritage

Fort Bend County Spanish heritage

Franklin County Spanish heritage

Freestone County Spanish heritage

Frio County Spanish heritage

Gaines County Spanish heritage

Garza County Spanish heritage

Gillespie County Spanish heritage

Glasscock County Spanish heritage

Goliad County Spanish heritage

Gonzales County Spanish heritage

Gray County Spanish heritage

Grayson County Spanish heritage

Gregg County Spanish heritage

Grimes County Spanish heritage

(continued)

Page 45 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Guadalupe County Spanish heritage

Hall County Spanish heritage

Hardeman County Spanish heritage

Hardin County Spanish heritage

Hartley County Spanish heritage

Hays County Spanish heritage

Hemphill County Spanish heritage

Henderson County Spanish heritage

Hidalgo County Spanish heritage

Hockley County Spanish heritage

Hood County Spanish heritage

Hopkins County Spanish heritage

Howard County Spanish heritage

Hudspeth County Spanish heritage

Hunt County Spanish heritage

Irion County Spanish heritage

Jack County Spanish heritage

Jackson County Spanish heritage

Jeff Davis County Spanish heritage

Jefferson County Spanish heritage

Jim Hogg County Spanish heritage

Jim Wells County Spanish heritage

Jones County Spanish heritage

Karnes County Spanish heritage

Kaufman County Spanish heritage

Kenedy County Spanish heritage

Kent County Spanish heritage

Kerr County Spanish heritage

Kimble County Spanish heritage

Kinney County Spanish heritage

Kleberg County Spanish heritage

La Salle County Spanish heritage

Lamb County Spanish heritage

Lavaca County Spanish heritage

Lee County Spanish heritage

Leon County Spanish heritage

Limestone County Spanish heritage

Lipscomb County Spanish heritage

Live Oak County Spanish heritage

(continued)

Page 46 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Llano County Spanish heritage

Lubbock County Spanish heritage

Lynn County Spanish heritage

Madison County Spanish heritage

Martin County Spanish heritage

Mason County Spanish heritage

McLennan County Spanish heritage

McMullen County Spanish heritage

Medina County Spanish heritage

Menard County Spanish heritage

Midland County Spanish heritage

Milam County Spanish heritage

Mitchell County Spanish heritage

Montague County Spanish heritage

Moore County Spanish heritage

Newton County Spanish heritage

Nolan County Spanish heritage

Oldham County Spanish heritage

Orange County Spanish heritage

Palo Pinto County Spanish heritage

Panola County Spanish heritage

Parmer County Spanish heritage

Pecos County Spanish heritage

Polk County American Indian (Alabama)

Potter County Spanish heritage

Presidio County Spanish heritage

Reagan County Spanish heritage

Real County Spanish heritage

Red River County Spanish heritage

Refugio County Spanish heritage

Roberts County Spanish heritage

Robertson County Spanish heritage

Runnels County Spanish heritage

Rusk County Spanish heritage

San Augustine County Spanish heritage

San Saba County Spanish heritage

Schleicher County Spanish heritage

Scurry County Spanish heritage

Shelby County Spanish heritage

(continued)

Page 47 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix II 

Listing of States and Covered Jurisdictions

That Responded to GAO’s Survey

State Covered jurisdiction Ethnic groups (minority language group)

Smith County Spanish heritage

Starr County Spanish heritage

Sutton County Spanish heritage

Swisher County Spanish heritage

Tarrant County Spanish heritage

Taylor County Spanish heritage

Terrell County Spanish heritage

Terry County Spanish heritage

Throckmorton County Spanish heritage

Titus County Spanish heritage

Tom Green County Spanish heritage

Travis County Spanish heritage

Upton County Spanish heritage

Uvalde County Spanish heritage

Val Verde County Spanish heritage

Van Zandt County Spanish heritage

Victoria County Spanish heritage

Ward County Spanish heritage

Washington County Spanish heritage

Webb County Spanish heritage

Wharton County Spanish heritage

Wichita County Spanish heritage

Wilbarger County Spanish heritage

Willacy County Spanish heritage

Wilson County Spanish heritage

Winkler County Spanish heritage

Wood County Spanish heritage

Yoakum County Spanish heritage

Zapata County Spanish heritage

Zavala County Spanish heritage

Utah San Juan County American Indian (Navajo, Ute)

Wisconsin Curtiss Village (Clark County) Spanish heritage

aAlaska and Hawaii provided consolidated responses for all state jurisdictions.

bState did not respond to GAO’s survey.

cThe New York City response provided consolidated responses for Bronx, Kings, Queens, and

New York counties.

Source: GAO survey and Appendix to Part 55, Code of Federal Regulations (28 CFR Ch.1).

Page 48 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix III 

Coverage Criteria for Implementation of the

Voting Rights Act Provisions Regarding

Language Minority Groups

The Voting Rights Act of 1965, as amended, contains two sections—4

(f)(4) and 203(c)—which provide criteria for determining which states and

jurisdictions are to be covered by its minority language provisions. The

following material was excerpted from the Code of Federal Regulations

(28 CFR Ch.1), which describes the coverage criteria.

§55.5 Coverage Under

Section 4(f)(4).

(a) Coverage formula. Section 4(f)(4) applies to any State or political

subdivision in which

 (1) Over five percent of the voting age citizens were, on November 1,

 1972, members of a single language minority group,

 (2) Registration and election materials were provided only in English

 on November 1, 1972, and

 (3) Fewer than 50 percent of the voting-age citizens were registered to

 vote or voted in the 1972 Presidential election.

All three conditions must be satisfied before coverage exists under section

4(f)(4).1

(b) Coverage may be determined with regard to section 4(f)(4) on a

statewide or political subdivision basis.

 (1) Whenever the determination is made that the bilingual requirements

 of section 4(f)(4) are applicable to an entire State, these requirements

 apply to each of the State’s political subdivisions as well as to the

 State. In other words, each political subdivision within a covered

 State is subject to the same requirements as the State.

 (2) Where an entire State is not covered under section 4(f)(4),

 individual political subdivisions may be covered.

§55.6 Coverage Under

Section 203(c).

(a) Coverage formula. There are four ways in which a political subdivision

can become subject to section 203(c).2

 (1) Political subdivision approach. A political subdivision is covered if1

Coverage is based on sections 4(b) (third sentence), 4(c), and 4(f)(3).

2

The criteria for coverage are contained in section 203(b).

Page 49 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix III 

Coverage Criteria for Implementation of the

Voting Rights Act Provisions Regarding

Language Minority Groups

 (i) More than 5 percent of its voting age citizens are members of a

 single language minority group and are limited-English proficient; and

 (ii) The illiteracy rate of such language minority citizens in

 the political subdivision is higher than the national illiteracy rate.

 (2) State approach. A political subdivision is covered if-

 (i) It is located in a state in which more than 5 percent of the voting

 age citizens are members of a single language minority and are

 limited-English proficient;

 (ii) The illiteracy rate of such language minority citizens in the state is

 higher than the national illiteracy rate; and

 (iii) Five percent or more of the voting age citizens of the political

 subdivision are members of such language minority group and are

 limited-English proficient.

 (3) Numerical approach. A political subdivision is covered if-

 (i) More than 10,000 of its voting age citizens are members of a single

 language minority group and are limited-English proficient; and

 (ii) The illiteracy rate of such language minority citizens in the

 political subdivision is higher than the national illiteracy rate.

 (4) Indian reservation approach. A political subdivision is covered if

 there is located within its borders all or any part of an Indian

 reservation-

 (i) In which more than 5 percent of the voting age American Indian or

 Alaska Native citizens are members of a single language minority

 group and are limited-English proficient; and

 (ii) The illiteracy rate of such language minority citizens is higher than

 the national illiteracy rate.

(b) Definitions. For the purpose of determinations of coverage under

section 203(c), “limited-English proficient” means unable to speak or

understand English adequately enough to participate in the electoral

process; “Indian reservation” means any area that is an American Indian or

Page 50 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix III 

Coverage Criteria for Implementation of the

Voting Rights Act Provisions Regarding

Language Minority Groups

Alaska Native area, as defined by the Census Bureau for the purposes of

the 1990 decennial census; and “illiteracy” means the failure to complete

the fifth primary grade.

(c) Determinations. Determinations of coverage under section 203(c) are

made with regard to specific language groups of the language minorities

listed in section 203(e).

Page 51 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix IV 

Examples of Bilingual Voting Written

Assistance Materials

The following are excerpted examples of bilingual voting materials

provided by covered jurisdictions.

Page 52 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix IV 

Examples of Bilingual Voting Written

Assistance Materials

Figure IV.1: Bilingual Ballot - Comal County, TX

Page 53 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix IV 

Examples of Bilingual Voting Written

Assistance Materials

Figure IV.2: Bilingual Instructions - Los Angeles County, CA

English

Vietnamese

Chinese

Page 54 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix IV 

Examples of Bilingual Voting Written

Assistance Materials

Spanish

Japanese

Tagalog

Page 55 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
Appendix V 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Laurie E. Ekstrand, Associate Director

James M. Blume, Project Director

Robert P. Glick, Project Manager

Barbara A. Stolz, Senior Evaluator

Amy E. Lyon, Senior Evaluator

David P. Alexander, Senior Social Science Analyst

Stuart M. Kaufman, Senior Social Science Analyst

Jim Fields, Senior Social Science Analyst

Katherine M. Wheeler, Publishing Advisor

Michelle D. Wiggins, Issue Area Assistant

Office of the General

Counsel

Ann H. Finley, Senior Attorney

(182028) Page 56 GAO/GGD-97-81 Bilingual Voting Assistance Provided and Costs
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