> While the allowable election error rate established by the Federal Election Commission (FEC.gov) guidelines is 1 in 250,000 ballots (.0008 percent), ASOG’s forensic analysis observed an error rate of 68.05 percent, which is a significant and fatal error in security and election integrity.

This bit is more than a little disingenuous, and I would honestly expect better.

The first problem is that there is no cite for said FEC guidelines, and I'm unable to find any documentation corroborating that number (though that could easily be a failing on my end). There is a reference later on to [0], but it quotes a different number:

> According to the NCSL, Michigan requires testing by a federally accredited laboratory for voting systems. In section 4.1.1 of the Voluntary Voting Systems Guidelines (VVSG) Accuracy Requirements 1. *All systems shall achieve a report total error rate of no more than one in 125,000.*

The second problem is that there are two different and incompatible definitions of "error rate" in play here, and Ramsland conflates the two. This makes the comparison he attempts to draw nonsensical.

The VVSG have a very specific definition of "report total error rate" ([0], starting PDF page 87) (paraphrased to try to save space):

> a. All systems shall achieve a report total error rate of no more than one in 125,000 (8×10–6).

> b. Given a set of vote data reports, the observed cumulative report total error rate shall be calculated as follows.

> i. Define a “report item” as any one of the numeric values (totals or counts) that must appear in any of the vote data reports.

> ii. For each report item, compute the “report item error” as the absolute value of the difference between the correct value and the reported value.

> iii. Compute the “report total error” as the sum of all of the report item errors from all of the reports.

> iv. Compute the “report total volume” as the sum of all of the correct values for all of the report items that are supposed to appear in the reports.

> v. Compute the observed cumulative report total error rate as the ratio of the report total error to the report total volume.

For comparison, this is how Ramsland calculated the 68.05% error rate:

> 1. We reviewed the Tabulation logs in their entirety for 11/6/2020.

> * The election logs for Antrim County consist of 15,676 total lines or events. Of the 15,676 there were a total of 10,667 critical errors/warnings or a 68.05% error rate.

This is an entirely different number that can't be used to determine whether a voting machine satisfies the error requirements.

The third problem is that the VVSG error numbers here are being misused. From the first paragraph of Section 4.1.1 ([0], PDF page 87) (emphasis added):

> The following requirements are intended to allow tolerance for unpreventable hardware-related errors that occur rarely and randomly as a result of physical phenomena. They are not intended to allow tolerance of software faults that result in systematic miscounting of votes.

According to Ramsland (emphasis added):

> Most of the errors were related to configuration errors that could result in overall tabulation errors or adjudication

Certainly doesn't sound like "unpreventable hardware-related errors" to me...

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> The ASOG audit also discovered software changes on Oct. 23, 2020, and then again on Nov. 5, 2020, just after the election. In accordance with the Help America Vote Act, this violates the 90-day Safe Harbor period which prohibits changes to election systems, without these systems undergoing recertification.

A cite here would have been very helpful. I looked through what appears to be the text of the Help America Vote Act [1], and I found no reference to a 90-day Safe Harbor period. I haven't found any other reference to such a thing, though I wouldn't be surprised if I were looking in the wrong place.

In any case, the reason I want such a site is that I suspect there might be differing definitions of "changes to election systems" that Ramsland might be taking advantage of, similar to the first point you quoted.

[0]: https://www.eac.gov/sites/default/files/eac_assets/1/28/VVSG...