Our presumptive President-Elect chose to take time out from his Sunday (November 27) to inform us via Twitter (with no evidence) that millions of people voted illegally, and that but for those illegal votes, he would have won the popular vote nationally. (As of this writing Hillary Clinton is more than 2,200,000 ballots ahead of Trump in the popular vote).
Not to mention that he has in the space of a couple of inflammatory Tweets managed to insult the professionalism and intelligence of every county and state voter registrar, election worker, poll watcher, precinct judge, county elections board member, and state election officer in the country, not to mention every—or at least 3 million—of us voters.
If this is what we have to look forward to for the next four years, the ratings for Trump’s reality TV version of the federal government should be through the roof, right? So at least we have that going for us. It’s obscene—if understandable; this is the PEOTUS, after all— that this story got any traction at all.
But first, given that in my last post I opined that the Clinton campaign would be unlikely to seek recounts in Wisconsin, Pennsylvania, and Michigan, and given that events have proven my opinion to be wrong, let’s address the decision by the Clinton campaign to piggyback on the Jill Stein campaign’s recount requests.
General counsel to Hillary for America Marc Elias (via a statement posted on Medium, and as quoted extensively in Rick Hasen’s blog) makes it clear that Hillary Clinton is wholly realistic about the likelihood that the recounts will not change the outcome of the election, but that such recounts should prove useful as audits of the accuracy and integrity of the election process and to settle fears regarding the risks of result-changing “hacks.”
Briefly, the Clinton campaign would not have pursued recounts but for the fact that
(1) The Stein campaign raised the money and filed the paperwork to get the ball rolling, and
(2) Voters were collectively so disturbed and agitated by evidence of foreign meddling and interference in the election that it made sense for the Clinton campaign to join in the recount effort in order to bring closure to the election.
So why did Stein’s campaign ask for recounts in the first place?
I don’t know—I guess it’s possible that the Stein campaign coordinated with the Clinton campaign, but that seems unlikely, given that neither campaign will benefit in any direct political way from behind-the-scenes cooperation.
I suspect that the Stein recount was motivated by no more than what it seems to be on its face—a grassroots-driven gift propelled by very real and understandable anxiety on the part of committed Stein supporters who could not have been happy with the idea of a Trump victory, especially if it was the result of some sort of direct interference or manipulation of the vote totals in key precincts.
Finally, Paul Musgrave, an assistant professor of political science at the University of Massachusetts Amherst, has written a nice summary explanation as to why Russia benefits—at least in the short term—from all this anxiety.
I. PRAISE WHERE PRAISE IS DUE
Great in-depth political reportage is not easy — and it is a hard thing for any journalist to write compellingly about the quotidian mechanisms of democracy, as opposed to the comparatively simpler narrative about candidates winning and losing.
And when election experts assert that (Donald Trump’s tweets notwithstanding), there is no way for the presidential election to be rigged with fake votes, voter impersonation, people voting as dead voters, illegal voters, etc., the technical reasons for those assertions are sometimes glossed (or glazed, as in glazed eyes) over.
Discussions of ballot security protocols, chain-of-custody documents, seal registers, and other voting safeguards are usually not what one would think of as making for compelling television journalism topics, which is a shame.
To the extent that the media fails to educate voters about how and why elections are secure, voter ignorance about election security can make voters vulnerable to fear-mongering.
Inasmuch as television news reporting is often negatively (and sometimes unfairly!) perceived as “shallow” and insubstantial, I think it’s important to call television news stations out for praise when they do a great job.
On October 20, 2016 (well before the beginning of the early voting period), KTRE TV (the ABC affiliate in Nacogdoches, Texas) ran a story by Thomas Hoce that effectively rebutted the “rigged election” falsehood with specific technical information supplied by interviews with Connie Brown, the Angelina County Elections Administrator, and Todd Stallings of the Nacogdoches County Elections office. My only editorial suggestion would be that titling the story as “East Texas election officials talk possibility of election rigging” was a little misleading and unfair.
I would have gone with something more like, “East Texas election officials debunk possibility of election rigging.”
Among other things, Mr. Stallings mentioned that in his county [and, I, the Texas Election Law Blogger, will add, and as is standard practice across Texas and the nation],
- the voting systems are not networked or connected to the internet, that
- the ballot tabulators are audited for accuracy before and after the ballot tabulations are run,
- that the State demands a “test” partial manual recount of ballots to test against the possibility of error,
- that the voting systems and tabulating equipment are secured with tamper-resistant seals, and
- that audit logs are maintained for each instance in which the election records are accessed.
On the one hand, nothing that Mr. Stallings said was particularly stunning or noteworthy —elections always produce a prodigious amount of redundant public security records and proof of veracity as part of the statutorily required audit trail.
But (outside of election workers and a few interested officials and academics) journalists rarely include a description of this audit trail as part of a routine dinnertime local television news story about the election. So kudos to KTRE and Thomas Hoce for having aired some of the procedural reasons why the election won’t be—in fact, can’t be—”rigged.”
II. PLAYING ON VOTER FEARS
And now for some criticism. Whereas one TV station in a comparatively small East Texas market did an admirable brief story quelling election fears, TV stations in the much larger Austin market (FOX7 News Austin , KEYE, and KVUE) ran stories on October 19th that might have exacerbated voter anxieties unnecessarily.
Two years ago, a woman named Laura Pressley lost a hard-fought bid to be elected to a seat on the Austin city council; she subsequently filed an election contest asserting that the way in which electronic votes were preserved and tabulated after the election materially affected the outcome of the election.
Her argument was that because early votes cast on electronic machines were not reproduced in hard copy prior to Election Day, they could not be manually recounted and compared against a pre-Election Day partial tally. (The candidate made this assertion because she had done relatively well in early voting, but lost based on Election Day turnout, and believed that the divergent trends suggested irregularity.)
Given that Pressley’s contesting of the 2014 election results had been dismissed by the trial court for lack of evidence, one might wonder what change of circumstance made her story newsworthy on October 19 of this year, when her allegations were run under the headline, “Texas election integrity questioned.”
The implication from the story is that the State of Texas is doing something suspicious by granting waivers to some counties that release those counties from the obligation to do mandatory partial manual counts of optical scan ballots.
It’s an odd irrelevancy, given that
- (1) Laura Pressley’s 2014 election didn’t have any optical-scan ballots, and so the State waiver she describes is unconnected to her election contest; and
- (2) the State’s waiver is a specific response to the way in which certain brands of optical scanners of marked paper ballots (mechanically similar to the scanners used to tabulate multiple-choice tests) accumulate and preserve precinct-by-precinct early voting and Election Day vote totals.
A better headline for this story could have been, “Two years later, losing candidate still thinks she shouldn’t have lost.”
Of the three versions of Ms. Pressley’s “Election Integrity Story” that ran in the Austin market, the KVUE version contained the most explanatory context, including a rebuttal and criticism of alarmist talk about election fraud, and a reminder that widespread fears of election “rigging” are unfounded. The FOX7 version of the story was the shortest and least critical of its source, and omitted key information that would have placed Ms. Pressley’s complaints in context.
III. ARE ELECTION PROCEDURES TOO BORING TO MAKE GOOD NEWS?
Eh … I’m biased against saying that election procedures are “boring.” TV news producers face tremendous time limitations when trying to explain a complicated story, and election law is complicated; there’s no getting around that.
But elections are exciting, and election security should (or could) be described in a compelling way. And I think there’s a public benefit to be gained from airing news stories that give election administration a wider audience.
Ari Berman & Others on Texas Voter Registration and Jim Crow: tl;dr: Racism, Recalcitrance, Restrictions
Although Mr. Berman’s recent election stories have been been national in scope (he’s examining violations of voting rights in North Carolina, Wisconsin, and Ohio, among other places) his cover story for this week’s issue specifically focuses on the State of Texas’s discriminatory voter I.D. law and our restrictive voter registration laws.
Berman’s coverage in The Nation‘s cover story, “Texas’s Voter-Registration Laws Are Straight Out of the Jim Crow Playbook” spotlights the restrictions on volunteer deputy voter registrars (or “VDRs”).
The story also looks at threats by some Texas officials to investigate voters who lack the narrow range of acceptable forms of photo I.D. required under the State’s 2011 voter I.D. law that was struck down in July of this year as racially discriminatory.
From the cover story in the October 31, 2016, issue of The Nation:
“VDRs [Volunteer Deputy Registrars] were established in 1985, but the restrictions on voter registration were significantly toughened by the Texas legislature in 2011 to require county trainings, ban non-Texans, and prohibit VDRs from being compensated based on the number of people they register. As a result, ‘Texas is the most restrictive state in the union when it comes to voter registration,’according to the Texas Civil Rights Project.”
A bit more on selected links included in this post:
Ari Berman’s Twitter feed is a good source of links not only to Mr. Berman’s own journalism, but also to other materials relating to civil rights and voting rights issues generally: https://twitter.com/AriBerman
My source for the text of provisions from Chapters 63 and 13 of the Texas Election Code (relating to voter I.D. and volunteer deputy voter registrar laws respectively) is the Texas Legislature Online: http://www.capitol.state.tx.us funded by us, the people of the great state of Texas.
Texas Voter ID Troubles Continue; District Court Orders Judicial Oversight of Texas Voter Education – And the State Doubles Down By Disparaging the Motives Of Voters Who Claim Not To Have Photo I.D.
I. APPARENTLY, THE STATE CAN SCRUTINIZE VOTERS WHO SUBMIT DECLARATIONS OF REASONABLE IMPEDIMENT IN LIEU OF PHOTO ID
On September 22, 2016, the Texas House of Representatives Elections Committee conducted a routine interim hearing on various technical matters relating to election administration. For three and a half hours the committee members and witnesses discussed proposed legislative tweaks to the petition signature process, to municipal elections, to obligation bonds and taxes, and so on. You can watch the whole hearing if that’s your thing, but for my money the really interesting stuff doesn’t come up until the very end of the hearing.
As the hearing wrapped up, State Representative Celia Israel asked an official from the Texas Secretary of State’s office about a court order that had been issued two days prior to the committee hearing. In particular, Representative Israel was curious to find out what the State was doing to educate voters about I.D. requirements for the November 8, 2016, election.
In response to the questions, Director of Elections Keith Ingram explained that the State had incorporated the text of the court’s most recent directive into the website and upcoming print and media advertising; he specified that voters who “do not possess [the statutorily mandated forms of photo I.D.] and cannot reasonably obtain it,” could cast a regular ballot by completing a “Declaration of Reasonable Impediment,” if they also supplied alternate forms of documentary evidence of their identity.
Representative Mike Schofield then took the discussion in a new direction (starting at the 3 hour, 36 minute mark), after asking if the State could track information about whether the Declarations were submitted by people who actually have I.D.:
What I don’t want to see is a gross number, and everybody acts as if those people don’t have I.D…. If you pretend you don’t have it, and use one of these declarations, that’s illegal, isn’t it?
In response to the question, Mr. Ingram clarified that voters entitled to use the Declaration would be those who had either never been issued one of the six forms of photo I.D. listed under the law, or those whose previously issued I.D.s had been lost or destroyed, and who had a reasonable impediment to replacing the missing I.D.
Representative Israel raised a hypothetical situation (described starting at 3 hours 45 minutes) in which a voter’s “reasonable impediment” is that the voter is voting at a polling place on one end of town, but left her photo I.D. at home, at the other end of town.
In that circumstance, Mr. Ingram explained that assuming that the voter filled out the “Declaration” and wrote down that the reasonable impediment was “left my I.D. at home,” the election worker would have to take the declaration at face value and allow the voter to cast a ballot.
Representative Schofield seemed incredulous, asking, “Is that … is that correct? … You’re going to let them vote with a ‘Reasonable Impediment?'”
The Director of Elections responded:
The poll worker cannot challenge the ‘Reasonable Impediment’ asserted by the voter. …. But if that’s the reasonable impediment, I think the voter is at risk, because they’re not following the law. But that’s not for the poll worker to decide. [Emphasis added by me.]
Committee vice-chair Craig Goldman then asked, “But, how does that get challenged, and then how is their vote null and void?”
The Director of Elections explained:
The vote will never be null and void. It’ll get challenged in an election contest, if it’s a close election. And obviously these things [the Declarations of Reasonable Impediment] will be available for folks to give to their district attorneys to follow up on. [Emphasis added by me.]
Representative Schofield pressed the issue as the hearing entered its final minutes (at the 3 hour 46 minute mark):
I realize we’re going to have a lot of illegal votes and a lot of fraudulent votes. That’s why we have voter I.D. My concern is that there are going to be a lot of people trying to thwart the [voter I.D.] law who have valid drivers’ licenses; who have passports; and are going to assert these declarations. Their votes may count in this election, but I want to make sure that when we go back to court, we’re not saying ‘oh, there’s this huge number of people that filed these declarations.’ I want to drill down and find out which one of ’em [declarations] were bogus. [Emphasis added by me.]
The Director of Elections responded, “And I’ll think you’ll be able to tell easily.” He then went on describe how one of the Declarations of Reasonable Impediment that had already been used in an off-season tax ratification election indicated that one voter had written that the “reasonable impediment” was “fascist law.”
The committee chair said: “Fascist law? They wrote that?”
What’s troubling about the exchange (aside from Representative Schofield’s counterfactual and inflammatory assertion that there’s going to be a lot of “fraudulent votes” in this election), and what should be especially troubling to the plaintiffs in the voter I.D. lawsuit, is the implication—encouraged both by Representative Schofield’s assertion that “we’re going to have a lot of illegal votes,” and by the response from the Director of Elections that voters who use the Declaration can be tracked, and possibly referred to local district attorneys for prosecution for illegal voting—that voting without an approved photo I.D. is automatically suspect.
So … why is this suggestion of potential criminal prosecution troubling?
Because it is not a stretch to imagine that statements like this could have a chilling effect — dissuading eligible, qualified voters without approved photo I.D. from voting. In other words, threatening to investigate voters who file a ￼Reasonable Impediment Declaration could end up hurting the very group of voters that the August 10, 2016, court order was intended to help.
Think I’m exaggerating about “threatening to investigate”?
On September 9, 2016, Rick Hasen, Chancellor’s Professor of Law and Political Science at the University of California, Irvine, posted a story on his Election Law Blog about the motion for enforcement of the August 10 court order filed by the private (non-Department of Justice) plaintiffs in Veasey v. Perry. These plaintiffs were reacting to this August 26, 2016, news story (as quoted in the private plaintiff’s motion):
[Harris County Clerk Stan] Stanart says he will investigate everyone who signs that form to assure they are not lying. Whether anything happens, that’s up to the [Harris County District Attorney’s Office]. But after the votes are counted and the election ends, Stanart said his office will be checking to see whether a person who signed the sworn statement has a Texas Department of Public Safety-issued ID through the DPS database.” Meagan Flynn, Harris County Clerk Will Vet Voters Who Claim to Lack Photo ID, HOUSTON PRESS, Aug. 26, 2016.
So to recap: As of late August in a presidential election year, the chief election official in Harris County, the most heavily populated county in Texas, was quoted as intending to investigate voters who claim they lack photo I.D.s.
That threat of punitive or retributive investigation prompted the federal district court in Corpus Christi to issue on September 20 a legal order, in which the court told the State to clarify and make explicit that voters who reasonably lacked photo I.D. were legally entitled to an alternate method of qualifying for a regular ballot.
But then in the hearing on September 22, just two days after the court order, the State was still discussing the option of criminal investigations and prosecutions of voters without photo I.D.s, in order to satisfy a Republican state legislator’s concerns about the effective enforcement of the State’s photo I.D. law.
And the statements of the Director of Elections reassuring Representative Schofield that voters who vote without photo I.D. can be tracked and investigated echoed the statements made in August by Harris County Clerk Stan Stanart.
II. BACKGROUND — WHAT’S ALL THIS ABOUT “REASONABLE IMPEDIMENT”?
After the conservative Fifth Circuit appellate bench ruled that the State of Texas had enacted a discriminatory voter I.D. law, the federal district court in Corpus Christi that has been handling the photo I.D. suit (Veasey v. Perry) issued a judicial order on August 10, 2016, to remedy the immediate effects of the discriminatory law.
The plaintiffs in the ongoing lawsuit relating to voter I.D. then filed a motion informing the district court judge that the state’s officials were misrepresenting the court’s directive. (see, e.g., the Texas Tribune‘s September 7, 2016, story).
The August 10 judicial order had provided that voters who could not “reasonably” obtain an acceptable form of photo I.D. could substitute the use of some other forms of identification if they completed a “declaration of reasonable impediment.” The Elections Division at the Texas Secretary of State’s Office did not include the word “reasonably” in training materials, the agency’s website, and voter information posters, leaving the impression that the only voters who could access alternative forms of identification were those who were absolutely unable to get the photo I.D.
Omitting the word “reasonably,” which had been specifically included in the district court’s August 10 judicial directive, may seem like a minor editorial alteration. But in making that omission, the State gave the plaintiffs the impression that State officials were dragging their feet in response to the August 10 court order.
The Department of Justice summarized the problem in its September 6, 2016, motion to enforce the August 10, 2016, remedial order as follows:
If you want to vote in the November 8, 2016, general election, you must register to vote by no later than Tuesday, October 11, 2016.
(If you are already registered to vote, then going to one of these sites will help you verify that you are registered.
For instance. My highly politically opinionated wife (hint: not a Trump supporter) just realized she doesn’t know where her 2016 voter registration card is. Cobbler’s family. No shoes.)
Of Human Error and Voting By Mail, or, to Get All Modern on You, Customer Experience Issues with Ballot by Mail
I got a call the other day from a family member in Texas who had a question about her mail-in ballot.
Briefly, she had filled in her choices and put the ballot in the “big” (“carrier”) envelope to mail it back to the county election administrator, but then realized that she had an extra envelope left over — the smaller white “security” envelope that is intended to preserve the anonymity of the vote.
Worried, she opened up the big (“carrier”) envelope in order to retrieve the ballot so that she could put it in the security envelope, but in opening the big envelope, she tore the seal that bore her signature across the flap of the envelope. Now she was afraid that she had irretrievably invalidated her vote.
I. WHEN WE MAKE MISTAKES, IT ISN’T ALWAYS OUR FAULT
When something breaks or goes awry, do you blame yourself? In that instant when I realized our washing machine wasn’t spin-drying clothes, or when our car was stalling out at stop lights, I did momentarily interrogate myself. “What did I do wrong?” I’ve felt that stab of self-doubt and recrimination when my phone died, or when I lost my ATM card.
But sometimes there are systems and processes that invite and encourage the accumulation of errors, independent of any basic competence or mindfulness that we might apply to the tasks we attempt. Some processes are particularly and almost comically byzantine. We encounter convoluted Kafkaesque nightmares of contradictory and misleading expectations and commands that seem almost intentionally designed to lead us astray, and then leave us feeling dumb and guilty when we err, as if our mistake is some reflection on us and our value as a human being, and not merely a consequence of the fiendish trap that has been laid for us.
II. AN EMBARRASSMENT OF INSTRUCTION, ADVICE, AND EXHORTATION CRASHES INTO OUR BRAINS
For those of you who have never requested a ballot by mail or voted absentee, here’s what the process looks like:
First, not everyone is qualified to vote by mail. In Texas, to qualify for a ballot by mail, a person has to be (1) absent from the county on Election Day and during early voting; (2) over age 65 or disabled; or (3) confined in jail, but eligible to vote. (My relative falls in (1) or (2) but not (3).)
After receiving a valid application for a ballot by mail (and assuming such an application is received not later than the eleventh day before the election (i.e., by no later than October 28, 2016 for the November 8, 2016 election), the early voting clerk for your county will send out a “kit” of materials for the voter to read through and assemble to return.
The kit (which is mailed out in its own special envelope) consists of a blank ballot, something called a carrier envelope, something called a ballot envelope, instructions, one or more advisories and notices (including, potentially, one or more of the following: a statement of residence, a notice (for voters over 65 or disabled) regarding the status and condition of the voter’s annual application for a ballot by mail, and a notice regarding identification for first-time voters), as well as a list of designated write-in candidates.
The thing called a “carrier envelope” is the “big” envelope that the voter will use to mail in the completed ballot, along with whatever else it is that the voter may be expected to mail back to the early voting clerk, such as a statement of residence, a statement confirming the correct mailing address for purposes of administering an annual application for a ballot by mail, and photocopied identification (for such voters as have to submit that material). The carrier envelope has suitably terrifying blocks of dense text to accommodate the regulation of mailed-in votes, and is printed in such a way as to ensure that the voter’s signature extends across the adhesive flap sealing the envelope.
The thing called a “ballot envelope” may either be an ordinary blank envelope, or may be a more elaborately printed envelope that announces itself boldly as a “ballot envelope” with its own collection of dense text. In either case, the ballot envelope is the envelope that is designed to hold the completed ballot.
So the voter is expected to fill out the ballot, put the ballot in the “ballot envelope,” seal the ballot envelope, put the ballot envelope in the “carrier envelope,” possibly sign an affidavit of residence, possibly copy a valid form of identification (if a first-time voter), put the affidavit and I.D. (if required) in the carrier envelope, seal the carrier envelope, sign the carrier envelope, and (if necessary) have the person who assisted the voter or served as a witness on behalf of the voter to sign the carrier envelope.
The thing is … the instruction sheets in the “kit” multiply and proliferate in potentially confusing ways. Some information is duplicated or separated into separate forms used for specific purposes. Not every voter will see the same forms (only voters who have moved or who have not voted recently will likely see a “Statement of Residence,” and only new voters are likely to get a notice regarding I.D.). And the blocks of text start to blend together. NOTICE. WARNING. DO NOT. REMEMBER. INSTRUCTIONS. INSERT. MUST. PER SECTION. AS REQUIRED. WARNING. WARNING. WARNING.
So … things fall apart. It is extremely common for things to fall apart. In fact, some forms of falling apart are intrinsic to the process of voting by mail.
- More than one ballot per envelope: It isn’t unusual that two or more voters living under the same roof will vote by mail in the same election, and often these voters will understandably short-circuit a few steps in the process by putting their ballots into the same envelope.
- Forgetting the statement of residence affidavit: When such an affidavit is called for, it sometimes gets misplaced.
- Putting the ballot directly into the carrier envelope, instead of the ballot envelope: This happens so often; so, so often. This error doesn’t in any way affect the validity of the vote, but means that the voter has given up the anonymity usually ensured when the early voting ballot board opens up the carrier envelopes and dumps out the envelope contents.
- Anxious reopening: This is common too. You voted. You put everything in the envelope. Right? Or did you? Oh god! You voted for the wrong person! Or you forgot to include something. Maybe you can just c-a-r-e-f-u-l-l-y peel open the envelopes to fix your mistake.
RRRrrripp! Dang! Now what?
Some errors are recoverable, and some are not, depending on where they occur in the process. Generally one hopes that common sense on the part of the election officials will prevail to give effect to the voter’s intent, but sometimes that isn’t possible.
If an early voting ballot board receives a carrier envelope that’s been ripped open and resealed, the concern is that the board may interpret the carrier envelope to have been tampered with by someone other than the voter, and may decide not to count the vote on the grounds that the ballot was compromised.
What if the voter includes a long, handwritten and heartfelt explanation? “I was rushed! I tore the envelope open to doublecheck that I hadn’t done anything wrong — It’s really my vote, I swear!”
Eh … who knows? At least such a note provides context — and it will get read by a human being who can exercise independent judgment to forgive the mistake and count the ballot. Or not.
III. MY SUGGESTION TO MY CALLER: VOTE IN PERSON
In the face of error in assembling the ballot for return to the early voting clerk, one option for the mail-in ballot voter is to cancel the application for the ballot by mail and vote in person.
Which … okay. Let’s agree that this is not an ideal solution. It isn’t even possible in some circumstances — what about the person whose only realistic option was to vote by mail? Maybe it’s someone who is far away from home, or who is physically incapable of voting in person. What comfort is it to the person who cannot vote in person to suggest that an error in the mail-in ballot process can be fixed at the polling place or in the early voting clerk’s office?
Given how impractical my suggestion was for fixing the problem of a torn-open carrier envelope, why did I bother making the suggestion in the first place? Because one option (mailing a visibly tampered-with carrier envelope to the early voting clerk) would create a measurable and real risk that the early voting ballot board might (out of an abundance of caution and nervousness about “fishiness”) resolve not to count that ballot, whereas if the voter canceled the application and voted in person, the ambiguity raised by the torn envelope would be eliminated.
So again, my advice was fraught with all sorts of imperfections and weighing of options and appearances. Practically speaking, it might be easier for the voter to just write a big long note to the ballot board, (“Please, please, please count my ballot!”), drop the note in the envelope, tape everything shut, mail the whole mess in, and be done with it.
From my perspective, though, I thought, “why risk it?” I mean, why risk that the vote might not be counted? My aversion is with respect to the unknowable judgment of the early ballot board judge, who must weigh the integrity of the ballot against the common-sense understanding that people will often tear open their own carrier envelopes.