January 6, 2020

Ms. Huma Ahmed, City Clerk
City of Beverly Hills
455 N. Rexford Drive, Room 290
Beverly Hills, California 90210
Dear Ms. Ahmed:
This responds to your letter of December 31, 2019 in which you expressed concerns and
offered recommendations for modification to the County’s Voting Solutions for All People
(VSAP) voting system that will be used in the March 3, 2020 Presidential Primary Election to
which the City has consolidated its General Municipal Election.
Specifically, you addressed your comments to the contest layout format, functionality of the
“MORE” button used to view all candidates in a contest and navigation features on the new
VSAP Ballot Marking Devices (BMD). Further, you expressed concern that the layout would
disadvantage candidates based on ballot order and cited past election margins in City contests
as a basis for that concern.
We take concerns regarding the fairness and integrity of the County’s voting system seriously.
The very nature of the VSAP initiative has been about inclusion, usability, accessibility and
security in modernizing the voting systems and options in Los Angeles County.
To that end, we engaged with recognized experts in human-centered design, usability and
accessibility during the design and development phases of the project and throughout the
project. The ballot layout features have been subjected to significant review by both a
stakeholder advisory committee and a technical advisory committee and unprecedented public
engagement through user testing, a mock election and a pilot election.
Moreover, in response to concerns and recommendations, the following features were added to
enhance the "MORE" button: (i) addition of a pulsating yellow ring to the "MORE" button which
already includes an arrow; (ii) addition of a gradient effect to provide visible indication that the
contest continues; and (iii) orienting voters to the "MORE" button navigation through Election
Worker training and informational displays at Vote Centers. These enhanced features also
work together with other usability features such as prompts to notify the voter of the choices

 Ms. Huma Ahmed
January 6, 2020
Page 2 of 4
marked and any remaining voting options that may have been missed, and multiple prompts for
voters to review selections prior to printing and again after printing, but before casting the ballot.
Prior pilot election results and findings further indicate that users were able to recognize and
use the "MORE" button to navigate pass the initial screen to view the names of all candidates
on the BMD, and that the candidates receiving the fewest votes were consistent across all three
ballot types (BMD, vote by mail, and Inkavote).
Taken altogether, we believe there is strong evidence to show that voters can recognize and
use the "MORE" button as currently designed to scroll to the remaining candidates before
making his or her desired election in a contest. There are also other factors and timing issues
limiting our ability to modify the VSAP system, as further addressed below.
Background
Ballot layout specifications for voting equipment are subject to California Voting System
Standards (CVSS) adopted by the Secretary of State. There are specific requirements related
to accessibility, navigation, font size and usability. These requirements are part of the
independent testing and certification required of all voting systems used in California.
Examples include:
• presenting the ballot in compliance with minimum font sizes identified in the Elections Code,
but also so it allows the voter to adjust the font size throughout the voting session;
• disabling scrolling functionality that could cause accidental activation or voting; and
• providing unambiguous feedback regarding the voter’s selection, such as displaying a
checkmark beside the selected option and/or conspicuously changing appearance on the
screen.
VSAP Design
In the original design of the BMD layout, contests with over four candidates/selections were
listed with the first four candidates on a screen with a circular “MORE” button with an up/down
arrow to navigate to the remaining candidates/selections. The design and navigation
configuration are similar and consistent to State certified BMD ballot layouts offered by other
vendors and used in other California counties.
While the format complied with CVSS specifications, validated through stakeholder and
technical advisory reviews and functioned well in user testing, concerns were raised about the
visibility of the “MORE” button and potential impact for candidates/selections not listed on the
initial/first appearance of the contest.
No changes were made before the BMD ballot was used for the Mock Election; although the
issue was logged, and refinements were proposed for consideration and testing. The issue was
raised again by voters and observers in the Mock Election; although data in the multiple
selection contests that appeared on the Mock Election ballot, of which there were several,
consistently demonstrated that voters navigated the ballot using the “MORE” button to review
all selections.

HOA.102757820.2

 Ms. Huma Ahmed
January 6, 2020
Page 3 of 4
Recommendations
Suggestions offered in feedback before and from the Mock Election included adding color to the
“MORE” button, reducing the font size on contests with over four candidates/selections to fit on
a single screen/view, and/or adding “pop-up” screens to alert voters to the continuation of the
contest.
Refinement and Modification
Responsive to the concerns and recommendations, we again consulted with design and
usability experts and with our development/manufacturing team to make refinements and
modifications. These include:
•
•
•

adding a pulsating yellow ring to the “MORE” button;
adding a gradient effect to visibly indicate that the contest continues vs hard page stops that
appear that all options are visible in a single view; and
orienting voters to the “MORE” button navigation through Election Worker training and
informational displays at Vote Centers

Reducing the font size to list all candidates in a single view would not be compliant with the
CVSS specifications and would cause variation of layout from one contest to another. Adding
“pop-up” screens was discouraged by design and usability consultants/experts based on
concerns for consistent design and navigation associated with the full user experience.
Pilot Election Results and Findings
The above referenced refinements and modifications were made before the November Pilot
election in which voters were given the option to vote on the BMD or to use the traditional
InkaVote ballot. While the Pilot Election was limited, the contest for Long Beach City Council,
First District included eight candidates and thus provided a good test and comparison of ballots
cast on the old system all listed on a single page to ballots cast using the BMD where the
“MORE” button navigation was required to view all selections.
From the pilot election, we analyzed three ballot types – vote by mail, BMD and InkaVote. The
results revealed minimal differences between the ballot types. Similarly, the candidates
receiving the fewest votes were consistent across all three ballot types and appeared on both
the initial and continuation screens on BMD ballots.
Related Feature Enhancements
Related usability features embedded in the BMD design include prompts to review screens that
notify the voter of the choices marked and any remaining voting options that may have been
missed (i.e. remaining selections for a vote for multiple contests where the voter only initially
selected one choice) and multiple prompts for voters to review selections before printing and
again after printing, but before casting the ballot.
Of note, these features were non-existent on the County’s legacy InkaVote Voting System.
Instead, in contests with a large numbers of candidates (examples include Governor and US
Senate in 2018), because candidate names extended to additional ballot pages the data
showed many voters made selections on each page resulting in an overvote that canceled their
selection. This is improved on the BMD where overvoting cannot occur.
HOA.102757820.2

 Ms. Huma Ahmed
January 6, 2020
Page 4 of 4

Similarly, the InkaVote Voting System had limited capacity to accommodate consolidation
of
m unicipal and district elections with the County's even-year, state election cycles. The VSAP
system extends the capacity for compliance with new laws requiring municipalities and districts
to consolidate their elections and allows for significant improvements in language service
s and
accessibility.
Summary
We recognize this is an important issue for CUSS compliance and for public acceptance
of the
new voting devices. The refinements and modifications made enhance the visibility of
the
"MORE" button from the initial design. The user testing, consulting advice from usability
and
design experts and stakeholders, and the data from the Mock and Pilot Elections are
compelling evidence that voters recognize and respond to the "MORE" button utility.
Additionally, we believe voter orientation and onsite signage at Vote Centers around the
"MORE" button is prudent and will further enhance voters' understanding and effectiv use
e
of
the BMD ballot format. As a result, those elements will be incorporated into our Vote Center
training program and display resources.
Additional modifications, like the second suggestion made in your letter, to the layout
would
require coding changes that would require resubmission of the system for testing and
certification. Those actions cannot occur before the March 2020 election. Even if that was
feasible, the BMD layout would remain subject to compliance with the CUSS requirements
previously cited.
Again, we appreciate you contacting us regarding the City's concerns and recommendation
s.
We have a long established, collaborative working relationship with cities in the County
and we
have appreciated the spirit of partnership city participants have offered throughout the VSAP
initiative. We are confident that, continuing to work together, we can ensure compliance
with
State voting system requirements and provide voters with an improved voting experie
nce.
Sincerely,

DEAN C. LOGA
Registrar-Recorder/County Clerk
c: All Members, Los Angeles County Board of Supervisors
Nicole Davis Tinkham, Assistant County Counsel, Los Angeles County
Alex Padilla, Secretary of State
Ben Allen, State Senator
Richard Bloom, State Assemblymember
Beverly Hills City Council

HOA.102757820.2

LAuote.net

12400 Imperial Highway, Nortivalk,California 90650