Open Comments to SOS Proposed Rules

This post continues a series on the current Minnesota Secretary of State, posts which can be reviewed here.

Once logged in to Gravicus, feel free to put your own comments here.

What are proposed rules?

Basically, proposed rules provide the Office of the Secretary of State to carve out subtle changes to the state statutes, in some areas conflicting with federal and state standards. Consider as a metaphor the 80,000 federal tax code which allows carve-outs to those who understand how to use them.

So far, there are 12 comments, including Governor candidate Phillip Parrish, with mine being the most recent, at the bottom:

Jerry Ewing at October 10, 2025 at 3:37pm CDT

I object to one major change– the elimination of a witness address on the absentee ballot. The change in the law did NOT permit the elimination of this requirement, but the rule can be easily corrected. See the attached.

John Billo at October 10, 2025 at 10:45pm CDT

Regarding proposed amendments to Minnesota rules 8210.2400, Safeguarding Procedures and 8200.9115, Form of Polling Place Rosters:

On November 5th, 2024 when I voted at Precinct ST CLOUD W4 P5 0350, I was not provided a voter privacy folder, which made me uncomfortable as I normally rely on this protection to ensure my ballot choices remain private.

I believe these proposed rules are insufficient to prevent voter privacy violations and will be difficult to enforce based on documented failures in current practice. Minnesota has experienced documented instances of election-related violations including; Two Nevada residents charged in 2025 with conspiracy to commit voter registration fraud, submitting fraudulent applications in 2021-2022. A 2024 case where a woman was charged with felony voter fraud for voting using her deceased mother's absentee ballot. A 2022 case involving an individual who voted twice in the 2020 election. There were a few cases documented by KARE 11 showing 123 election-related charges statewide over four years, with the most common being “ineligible voter knowingly votes”.

The proposed rules lack sufficient enforcement mechanisms, lack specific procedures for local election officials to investigate and correct violations without fear or retaliation from county administrators or otherwise.

They contain inadequate training requirements, without clear escalation procedures. Our election officials may continue to receive discouragement when attempting to enforce election law requirements.

These expand ballot vulnerability periods. Any new rules should not provide longer period during which ballots remain unprotected, this creates additional opportunities for tampering or procedural violations.

Any new rules introduced must include robust enforcement mechanisms to maintain public confidence in election integrity and protect our fundamental voting rights for American, Minnesotan citizens.

Please reference case number 70-CV-24-17210, Aaron Paul v. Brad Tabke, 21 missing absentee ballots affecting election outcome.

Federal case against Ronnie Williams and Lorraine Combs (U.S. District Court, Minnesota, June-July 2025 guilty pleas)

State case against Danielle Miller (Itasca County District Court, charged October 2024, trial scheduled October 2025)

KARE 11 analysis documenting 123 election-related charges statewide (2020-2024)

Daniel Passer at October 11, 2025 at 3:14pm CDT

I also object to the elimination of a witness address on the absentee ballot. i also object to the deletion of the identification and listing of the specific categories of residential facilities (see lined-out lines 2.3 thru 2.16) By deleting this information, it is much more challenging for election administrators to properly administer the election due to the imposition of the lack of knowledge under the "Proposed Permanent Rules Relating to Election Administration" of what constitutes a "Residential facility". If Minnesota Statute 201.061 has been affected by law enacted during the 2025 Regular Session which affect the accuracy of any portion of lined-out lines 2.3 thru 2.16, then the solution is NOT to simply line-out lines 2.3 thru 2.16; Rather, update the practical and helpful information contained in lines 2.3 thru 2.16, which serves as a tool to more effectively manage the administration of elections, so that lines 2.3 thru 2.16 are fully aligned with law enacted during the 2025 Regular Session.

Sal Jane at October 12, 2025 at 6:07pm CDT

I write this not only as a concerned citizen, but also from personal observation: while serving as a voting judge in Minnesota, I have witnessed election irregularities that reinforce my view that the proposed rules are inadequate.

I believe the proposed rules are insufficient to prevent voter privacy violations and will be difficult to enforce, especially given documented failures under current practice in Minnesota. Examples include:

• The case Aaron Paul v. Brad Tabke, Case No. 70‑CV‑24‑17210, in which 21 absentee ballots were discovered missing in the House District 54A election. Twenty of those were from a single Shakopee precinct, and they appear to have been discarded while still sealed in their secrecy envelopes. The margin of victory was only 14 votes, meaning these missing ballots could have changed the outcome. (Democracy Docket)
• In 2025, two Nevada residents, Ronnie Williams and Lorraine Lee Combs, were charged with conspiracy to commit voter registration fraud for submitting fraudulent voter registration forms in 2021‑2022. (AP News)
• A 2024 case in Itasca County in which a woman was charged with felony voter fraud for attempting to vote using her deceased mother’s absentee ballot. (AP News)
• A 2024 case in Hubbard County, where a head election judge is charged with allowing 11 unregistered individuals to vote, neglect of duty, and related offenses. (CBS News)

Additionally, a KARE‑11 analysis documented 123 election‑related charges statewide from 2020 to 2024, with “ineligible voter knowingly votes” being among the most common offenses. (You may wish to reference this statistic in your published materials.)

Concerns with the Proposed Rules

• Lack of robust enforcement mechanisms. The proposals do not clearly define how violations will be detected, investigated, or penalized. Without these, even serious infractions may go unchallenged.
• Insufficient protection for local officials. There are no explicit safeguards to protect election administrators or judges from retaliation (political, professional, or administrative) when they seek to enforce rules or report irregularities.
• Training and escalation gaps. The current proposal lacks detailed, mandatory training and escalation procedures for when election workers observe or suspect violations. Without clear protocols, inconsistencies will persist, and officials may be discouraged from acting.
• Extended ballot vulnerability periods. Any rule that prolongs the time during which absentee or other ballots are unprotected (e.g. before they are secured, counted, or sealed) increases risk of tampering, loss, or procedural error.

My Personal Observation

While serving as a voting judge, I witnessed irregularities—such as unclear handling of absentee ballots, ambiguous instructions in polling stations, and situations where chain of custody seemed weak. These experiences underscore that despite good intentions, policies without strong enforcement, transparency, and accountability are easily circumvented or rendered ineffective.

Recommendations

Any new rules introduced should include:

1. Clear, enforceable mechanisms with meaningful penalties for violations.
2. Specific protocols for investigation, correction, and documentation when irregularities are raised.
3. Protection for election officials who act to enforce the law, including whistleblower‑type safeguards.
4. Mandatory, ongoing training, with escalation steps when issues arise.
5. Minimization of periods during which ballots are vulnerable to loss or misuse.

These safeguards are essential not only to maintain public confidence in our democratic process but to protect the voting rights of every Minnesota citizen.

Thank you for considering these points.

Phillip Parrish at October 13, 2025 at 10:34am CDT

Testimony Statement for Phillip C. Parrish Office of Administrative Hearings Public Hearing on Proposed Permanent Rules Relating to Elections Administration Docket No. 8-9019-39440 (Revisor’s ID R-4824)

Administrative Law Judge Lipman, members of the Office of the Secretary of State, and fellow Minnesotans. My name is Phillip C. Parrish. I am a retired Lieutenant Commander in the U.S. Navy with 21 years of service in counterterrorism and foreign policy, a farmer, and an educator. Today, I testify in strong opposition to the proposed rules under Revisor’s ID R-4824, which amend Minnesota Rules Chapters 8200-8250. These rules, framed as mere “technical clarifications,” are a dangerous evasion of our sacred duty to secure elections. They not only fail to comply with state and federal law—they actively violate it, perpetuating fraud risks that threaten our democracy.

Let me be clear: Minnesota’s voter rolls are a ticking bomb—3.6 million registered voters against a 4.2 million voting-age population, riddled with deceased entries, duplicates, post-election ghost additions (over 1,130 in 2024), and non-citizen vulnerabilities. The U.S. Department of Justice’s lawsuit against Secretary of State Steve Simon, filed September 25, 2025, demands full access to these rolls precisely because of NVRA and HAVA violations. Yet these rules do nothing to fix it. Instead, they lock in the status quo, defying the law and inviting exploitation.

First, on voter roll maintenance: The National Voter Registration Act (NVRA, 52 U.S.C. § 20507) mandates “reasonable efforts” to remove ineligible voters through regular cross-checks against sources like SSA death records and Census data. The Help America Vote Act (HAVA, 52 U.S.C. § 21083) requires “current and accurate” statewide lists with proactive audits. Minnesota Statutes § 201.071 echoes this, demanding prompt removals upon reliable evidence. But R-4824’s tweaks to § 201.071—merely clarifying forwarding of misrouted applications—omit any automatic, monthly purges. This breaks NVRA § 8(a)(4) by failing to maintain clean lists, as ruled in U.S. v. Virginia (DOJ NVRA suit, 2020), where courts ordered automated removals to prevent inflation. Without compliance, we’re complicit in the 100.88% “turnout” farce of 2024.

Second, citizenship verification: HAVA § 303(a) requires documentary proof of U.S. citizenship for registrants, reinforced by President Trump’s Executive Order 14,248 and the SAVE Act. Minnesota Statutes § 201.061, subd. 3, governs same-day registration, yet the rules expand unlimited vouching in facilities without verification—opening doors to non-citizen voting amid our 20% foreign-born surge. This violates NVRA § 4’s safeguards against ineligible registration, contravening Supreme Court precedent in Crawford v. Marion County Election Board (553 U.S. 181, 2008), which upheld strict ID to deter fraud. Lax vouching isn’t access—it’s abuse, as seen in July 2025’s guilty pleas for fake forms.

Third, data security and testing: HAVA § 202 demands “adequate safeguards” for computerized lists, including encryption and independent audits. NVRA § 7(d) prohibits foreign interference. But R-4824’s changes to § 206.82 extend public testing notices to five days without banning overseas software like Konnech—exposed in Nevada indictments for CCP ties. This breaches federal law, ignoring GAO reports (2019) on six states’ failures in basic security, and risks hacks like the July 2025 St. Paul ransomware attack that leaked 43 GB of data.

Fourth, training and transparency: Minnesota Statutes § 206.57 expands judge training but skips fraud detection (e.g., multi-state duplicates, ActBlue schemes), violating HAVA’s integrity mandates. § 201.091 “clarifies” notices but blocks public/DOJ access, defying NVRA § 8(c)(2)’s disclosure requirements—as in U.S. v. Louisiana (2020), where courts compelled transparency.

These violations aren’t oversights—they erode trust, disenfranchise citizens, and siphon billions in federal funds via padded headcounts. For 2026, they could rig races, mocking the 14th Amendment and Article IV’s republican form guarantee.

To comply and secure our elections, the rules must be amended as follows: 1. Real-Time Audits: Require monthly cross-checks against SSA, Census, and USCIS databases, with 30-day purges (amend § 201.071)—NVRA/HAVA compliant. 2. Citizenship Proof: Mandate birth certificates, passports, or REAL ID for all registrations; limit vouching to verified citizens (amend § 201.061, subd. 3)—align with SAVE Act and HAVA § 303(a). 3. Secure Systems: Ban foreign software; require U.S.-based encryption and public blockchain logging for changes (update § 206.82)—fulfill HAVA § 202 safeguards. 4. Post-Election Controls: Freeze rolls 30 days pre-election; publish daily change logs (amend § 203B.125)—prevent ghost additions. 5. Enhanced Training: Add modules on fraud detection, whistleblower protections, and penalties for non-reporting (revise § 206.57)—meet HAVA integrity standards. 6. Funding Accountability: Deduct grants for >1% roll inflation; redirect to audits (new under § 201.221)—end grift. 7. Transparency Mandates: Grant anonymized DOJ/public access; issue quarterly accuracy reports (amend § 201.091)—NVRA § 8(c)(2) compliant.

Judge Lipman, reject these rules as proposed. Demand amendments or withdrawal. As a concerned citizen, I urge enforcement of these fixes to protect Minnesota’s elections. I encourage the legislators to complete the respective documents to pull this back into their arena and full bring the rules into State and Federal compliance. Respectfully Phillip C. Parrish 507-838-6514

Phillip Parrish at October 13, 2025 at 10:39am CDT

Docket No. 8-9019-39440 (Revisor’s ID R-4824)

Regarding comment and link from SOS council. The link they provided during the hearing exposed further violations or procedural errors:

Procedural Errors in Minnesota Elections Rulemaking 2025-2026 (R-4824, OAH Docket 8-9019-39440) The Minnesota Secretary of State’s (SOS) proposed amendments to election rules (Minn. Rules Chapters 8200-8250) violate the Minnesota Administrative Procedure Act (Minn. Stat. §§ 14.001–14.70). Below are key procedural errors and compliance failures, based on the provided document, the SOS webpage, and related sources.

1. No Quarterly Docket Updates (Violation of Minn. Stat. § 14.366) • Issue: The public rulemaking docket, required to be updated quarterly, was dormant from October 2023 (initial comment period) to August 2025 (Dual Notice), a 21-month gap. • Impact: Violates transparency mandates, limiting public tracking of rule progress.
2. Outdated Webpage Information (Non-Compliance with § 14.366) • Issue: The SOS webpage inaccurately states the Dual Notice “will be” published on August 25, 2025, despite its actual publication (State Register Vol. 50, No. 08). Links reference outdated “2023-24” rulemaking. • Impact: Misleads public, undermining notice requirements (§§ 14.14, 14.22).
3. Faulty Hearing Access (Violation of §§ 14.14–14.15) • Issue: The October 10, 2025, WebEx hearing link (https://tinyurl.com/Oct10Hearing) was non-functional, with reported connectivity issues and exclusion of speakers. No in-person option was offered despite cybersecurity concerns. • Impact: Denies public participation, violating due process.
4. Inadequate Documentation of Comments/Requests (§§ 14.22, 14.366) • Issue: No clear list of hearing requests or comment summaries is provided on the docket. Access to 2023 and 2025 comments is cumbersome, requiring agency contact or OAH navigation. • Impact: Obscures accountability and public input tracking.

Substantive Concerns (Brief): Critics note potential conflicts with federal laws (e.g., NVRA, HAVA) on voter roll maintenance and audits, risking invalidation (see Crawford v. Marion County, 2008). A 2023 SOS rulemaking was struck down for similar issues. Respectfully Phillip C. Parrish 507-838-6514

I submit this letter I sent to Rep Quam for the record.

Dear Rep Quam, As the Republican chair of the House Elections Finance and Government Operations Committee, you have the authority to address critical flaws in the Secretary of State’s proposed elections rules (OAH Docket 8-9019-39440; Revisor’s ID R-4824, amending Minnesota Rules Chapters 8200-8250). As you witnessed, I testified against these rules at the October 10, 2025, public hearing, citing their failure to comply with state and federal law.

The rules violate the National Voter Registration Act (52 U.S.C. § 20507) and Help America Vote Act (52 U.S.C. § 21083) by lacking automated voter roll purges, robust citizenship verification, secure data systems, and transparent access. Minnesota Statutes (§§ 201.071, 201.061, 206.82) are similarly undermined, risking fraud and eroding public trust, as highlighted by the DOJ’s September 25, 2025, lawsuit against Secretary Simon.

Under House Rule 10.01 and Minn. Stat. § 3.193, you can take the following actions to bring the rules into compliance: 1. Convene a Special Hearing: Schedule an informational hearing to question SOS officials on procedural failures (e.g., outdated docket, violating § 14.366) and substantive gaps, such as no monthly SSA/Census cross-checks for voter rolls. 2. Demand Agency Reports: Use oversight authority (§ 14.116) to require SOS audits on roll accuracy and compliance with NVRA/HAVA mandates, building on your July 29, 2025, letter to Simon. 3. Submit Formal Comments: File committee comments (§ 14.26) on the Statement of Need and Reasonableness, rejecting non-compliant rules and proposing amendments for real-time audits, citizenship proofs (per SAVE Act), U.S.-based encryption, and public data access. 4. Propose Legislation: Lead the committee in drafting bills to amend statutes (e.g., § 201.071 for 30-day purges, § 203B.125 for pre-election roll freezes) to enforce federal and state requirements. 5. Issue a Resolution: Work with Co-Chair Rep. Mike Freiberg to pass a resolution urging the SOS to revise or withdraw the rules, ensuring alignment with legal standards.

These steps leverage the committee’s recent work on secure elections funding ($3.86M in the September 30, 2025, omnibus bill). As a friend and fellow Republican, I urge you to act swiftly to protect Minnesota’s elections.

Respectfully, Phillip C. Parrish 507-838-6514

Phillip Parrish at October 13, 2025 at 11:39am CDT

Post-Hearing Comments on Testimony by Hana Abdelhamid (OAH Docket No. 8-9019-39440)

Submitted by: Phillip C. Parrish

Date: October 13, 2025

Re: Proposed Amendments to Minnesota Rules Chapters 8200-8250 (Revisor’s ID R-4824)

Administrative Law Judge Lipman:

I submit these post-hearing comments pursuant to Minn. Stat. § 14.15, subd. 1, which allows for additional written material within five business days following the October 10, 2025, public hearing. These comments address the testimony provided by Hana Abdelhamid, a registered lobbyist and Legislative and Policy Associate at O’Connell Consulting LLC, during the hearing. Her statements in support of the proposed rules are problematic because they advocate for adoption of changes that fail to comply with state and federal law, potentially misleading the record. Furthermore, as a lobbyist, her participation may violate disclosure and ethical requirements under Minnesota Statutes Chapter 10A.

Background on Ms. Abdelhamid’s Testimony

During the hearing, Ms. Abdelhamid spoke in favor of the Secretary of State’s (SOS) proposed rule changes, emphasizing the need to “keep the progress” on voter access. She argued for maintaining or expanding provisions related to voter registration, absentee balloting, and ballot instructions without addressing documented compliance issues. This included no acknowledgment of the rules’ failure to incorporate mandatory voter roll maintenance (e.g., monthly purges for deceased or ineligible voters) or citizenship verification safeguards. Her testimony ignored ongoing concerns raised in the U.S. Department of Justice’s September 25, 2025, lawsuit against SOS Steve Simon for NVRA violations (52 U.S.C. § 20507) and aligned with advocacy for broader access at the expense of integrity measures required by HAVA (52 U.S.C. § 21083) and Minnesota Statutes §§ 201.071 and 201.061.

Why the Testimony is Problematic

1. Promotion of Non-Compliant Rules: Ms. Abdelhamid’s endorsement of the rules as “technical clarifications” that advance access overlooks their substantive deficiencies. For instance, the proposed amendments to voter registration (§ 8200) and absentee ballot procedures (§ 8230) do not mandate real-time audits or automated cross-checks against SSA death records and USCIS data, violating NVRA § 8(a)(4)’s requirement for “reasonable efforts” to maintain accurate lists. Courts have invalidated similar lax rules (e.g., U.S. v. Virginia, 2020). By urging adoption without amendments, her testimony supports provisions that perpetuate inflated rolls (e.g., Minnesota’s 3.6 million registered voters vs. 4.2 million voting-age population) and risks fraud, as evidenced by 2024 post-election additions and non-citizen vulnerabilities. This creates an unbalanced record, downplaying legal risks and potentially influencing the ALJ’s findings under § 14.15.
2. Bias and Omission of Legal Obligations: As an advocate for clients focused on health care, human services, and democracy issues (e.g., via O’Connell Consulting’s work with nonprofits like TakeAction Minnesota), her testimony appears to prioritize policy goals over legal compliance. She omitted discussion of federal mandates like HAVA’s audit requirements or Supreme Court precedents (e.g., Crawford v. Marion County Election Board, 2008) upholding strict verification to deter fraud. Such selective advocacy misrepresents the rules’ alignment with law, undermining the rulemaking’s purpose to conform to statutes (§ 14.131 Statement of Need and Reasonableness).

Potential Violations of Lobbyist Rules

Ms. Abdelhamid is a registered lobbyist in Minnesota, as confirmed by public records from the Campaign Finance and Public Disclosure Board (CFB). Under Minn. Stat. § 10A.01, subd. 21, lobbying includes efforts to influence administrative action, such as rulemaking under Chapter 14. Her testimony constitutes lobbying activity, as it sought to influence the SOS’s adoption of rules. While registration satisfies § 10A.03, the following aspects may violate Chapter 10A:

1. Failure to Disclose Representation (§ 10A.08, subd. 1): If Ms. Abdelhamid testified on behalf of a client or principal (e.g., an association spending >$3,000/year on lobbying per § 10A.01, subd. 33), she must disclose this to the CFB within 14 days of her appearance. The hearing record does not indicate such disclosure during her remarks. Non-disclosure incurs late fees ($25/day up to $1,000) and potential civil penalties ($1,000). If undisclosed, this violates transparency requirements for hearings with rulemaking authority.
2. Potential Misleading or False Statements (§ 10A.025, subd. 2): Lobbyist reports must be certified as true, and knowingly providing false information is punishable by up to $3,000 civil penalty (gross misdemeanor). While testimony itself is not a “report,” advocating for rules known to conflict with law (e.g., ignoring NVRA/HAVA) could be seen as misleading the ALJ. If her subsequent reports (due January 15 per § 10A.04, subd. 2) omit or misrepresent the subjects lobbied (e.g., administrative actions without detailing rule numbers), it compounds the issue.
3. Ethical Prohibitions on Advocating Illegal Actions: Chapter 10A prohibits contingent fees tied to outcomes (§ 10A.06, gross misdemeanor) and requires accurate reporting of specific subjects of interest (§ 10A.04, subd. 4). More broadly, lobbyists must avoid actions that undermine public trust. Advocating for non-compliant rules may breach implied ethics, as the CFB can investigate staff-reported violations (§ 10A.022) and impose penalties for non-cooperation (§ 10A.025, subd. 5). If her testimony encourages adoption of rules that violate federal law, it risks board scrutiny, especially amid the DOJ lawsuit.

Recommendations

• Exclude or Discount Testimony: Under § 14.15, subd. 2, the ALJ should weigh evidence for relevance and reliability. Ms. Abdelhamid’s statements should be discounted due to bias and omissions.

• Require Disclosure and Investigation: Direct the SOS or CFB to verify her compliance with § 10A.08 disclosure. If violations are found, refer to the board for enforcement.

• Amend Rules for Compliance: As detailed in my hearing testimony, incorporate NVRA/HAVA fixes (e.g., monthly purges, citizenship proofs) to address these gaps.

These issues highlight the need for a balanced record. I request rebuttal opportunity per § 14.15, subd. 1, once other comments are available.

Sincerely, Phillip C. Parrish 507-838-6514

Jerry Ewing at October 15, 2025 at 9:59am CDT

I see that my attachment did not get included in my comment above. Again, complete removal of the witness ID is in error and unnecessary. I will try again.

Attachments: written_comments_on_rule_changes.docx

miriam arnold at October 18, 2025 at 4:11pm CDT

I object to the entire set of proposed voting rules changes. Mr Simon and his office had in the past make subtle language changes which deviated from the MN State Statue to influence in how the election process will carry out. In 7-2024 Logic and Public Accuracy Test, Stillwater Township failed to perform on the test deck with no under votes sencerio in the US senate race of both GOP & DFL parties. I pointed it out to Amy Stenftenagel, the Washington County Auditor, and discovered she was using the MN Rules 8220.1050. I then informed her the MN State Statue 206.83 supersedes the Rules and the Public Accuracy Test would need to be redone. Amy doubled down on it and we filed an affidavit. Sebsequently the 2024 Primary election was conducted on a failed test desk. How can the public trust our election when there is no transparency and fairness? A trusted transparent election is the constitutional right of every American citizen. Thanks! Respectfully submitted, Miriam Arnold 14535 118th St N, Stillwater, MN 55082 mimarnold53@hotmail.com 6512954886

Attachments: 7-2024_PAT_test_deck_pg_1.pdf 7-2024_PAT_test_deck_pg_2.pdf 7-2024_PAT_test_deck_pg_3.pdf

miriam arnold at October 21, 2025 at 4:12pm CDT

In this video: https://www.youtube.com/live/d4YiUA2Uib0?si=naescZtnmfNG53yl Go to timeline 1:44:00 Steve Simon said under oath if an affidavit is filed then an investigation must take place according to MN law. I submitted an affidavit to Amy Stenftenagel and there was no investigation on this and she didn't redo the test deck for the 2024 Primary election. Respectfully submitted, Miriam Arnold 14535 118th St N, Stillwater, MN 55082 mimarnold53@hotmail.com 6512954886

Attachments: Rick_s_Affidavit_2024_PAT__1_.pdf

Erik van Mechelen at October 22, 2025 at 4:44pm CDT

The Secretary of State has been quoted in the Star Tribune and in Minnpost (attached) as saying anyone who questions elections is coating themselves in shame that will never wash off, ever. By proposing rule changes that stray from state statutes, is the Secretary himself questioning elections and therefore worthy of the same shame he has wished upon so many others?

Having made this factual statement and asked a pertinent question, I now too object to the premise of the proposed rules conceptually. It is interesting that Steve Simon, as the current Minnesota Secretary of State (although in his last year now), gets to appoint a legislative liaison as a director-type role. Is Simon, by proposing these rules, indicating that this person was unsuccessful in lobbying the legislature appropriately to his publicly stated agenda of finding an intersection between security and accessibility? Why do the proposed rules contain little in regard to the most pressing issues currently in the news?

For example, the Office of the Secretary of State failed to identify 500-600 fake registrations while simultaneously refuses to give basic data to the DOJ from the statewide voter registration system; meanwhile, the Office also may be failing to identify non-citizen registrations, as evidenced by comments in the Fraud hearing on Oct 14 where the Elections Director, Paul Linnell, stated that reports could potentially be run to discover these—but made little indication they had actually been run—and the Secretary also dodged the question, referring to his immigrant mother. I too have an immigrant parent, and the personal story only served to eloquently evade the question.

Maybe it would be too burdensome to address these concerns with the proposed rules. However, for an office with an annual budget of more than $20 million, the public, I think, is eager to know whether the proposed rules are fully compliant with federal laws and state election codes, as well as not subtly undermining basic integrity through carve-outs similar to the 80,000-line tax code. The more rules, the more ways to subvert a simple, clear, process.

All of these changes should have been addressed through a press-conference-type event, multiple hours if needed, to in detail explain the reasoning. Again, the Office has plentiful resources to do this, all public dollars—the public should not have to log in to discussions on Granicus Ideas to first become fully informed and then decipher where the proposed rules are out of sync with federal and state standards or laws.

Thank you for considering this comment from a 2022 candidate for SOS who received 37% (110,000 votes) in a primary election which was not adequately audited but for which one cast vote record file was received from one county, a cast vote record file which the current Secretary of State used to say did not exist in Minnesota, but is a national and state standard through the NIST and the EAC's VVSG guidelines (which are adopted and therefore law in Minnesota) since 2005.

And what about proposed rules that are missing? What about making it clear that using electronic poll pads is optional (paper rosters can be used)? What about making a rule that allows for optional use of electronic tabulation equipment and reporting software, since hand counting is clearly a good method as it is the prescribed method for the post-election reviews statewide? What about making ballot images available to public viewing again? That way citizens could cross reference the work the county and state have done (as well as the tabulation and reporting software) in tally votes? The list goes on of welcome additions to find the intersection between security and accessibility that the Secretary purports to want.

I will be monitoring carefully to note whether this comment is removed. It is far less inflammatory than the Secretary's own statement that anyone questioning elections will be coating themselves in a shame that will never wash off, ever (attached). The Secretary is an advocate of free speech, and I really don't mind him expressing himself that way publicly, even though I think he may regret doing so.

Attachments: coating_in_shame.png

Erik van Mechelen is a writer detailing the departments within our own government with whom the public is in contention with but should not be... the Office of the Secretary of State is using its office to bend or even change rules that are clearly out of line with election laws (state statutes) making subversion of official election results even easier than it already is. See [S]elections in Minnesota or Auditing Minnesota: The 2022 SOS Campaign for details on how computers run simulations (not elections) and parties attempt to control candidates, respectively. Erik is a writer in Minneapolis. His most recent book is Ten Days in Minneapolis.