In general, I find the proposed regulations incomplete even with respect to vital basic issues like tabulation procedures and criteria for deciding winners.  As an example, I doubt that anyone would understand what is meant by the "inclusive Gregory Method of Reallocation" after reading the definition in the proposed regulation.  Furthermore, I cannot imagine how this method could possibly be implemented in a hand-counted multi-seat RCV election by local election officials nor am I aware of any certified tabulation software available to be employed as an alternative to hand counting. 

The fact that the issue of write-in votes is never mentioned I find to be a serious omission.  With the 10% threshold for resolving write ins in place this would seldom be an issue but there should be some acknowledgement of the possibility of write-in votes in RCV general elections and instructions provided on how they would be addressed especially when sufficiently numerous to trigger the 10% rule.

I am not an enthusiast for RCV but accept that it is worth a try in local elections, at least in primaries where no write-ins are permitted.  However, more work needs to be done before we are ready for RCV, particularly for multi-seat elections.  And voter education concerning ballot marking instructions as well as explanations of how the ballots are counted will be a major challenge.  I cannot imagine trying to explain to voters complicated issues like the Gregory reallocation method and the Droop threshold for determining winners.

I agree with the comments and editing suggestions by David O'Brien of RepresentUs and Chris Hughes from the Ranked Choice Voting Resource Center as well as those of G. Michael Parsons of FairVote.  And I share Mr. Bell’s concerns about allowing General Registrars to duplicate ballots that are unreadable by ballot scanners.

I am the Secretary of the Charlottesville Electoral Board.