A report released today by Common Cause makes a powerful case that President Trump’s “election integrity” commission is a sham, rigged to exploit public fears about a voter fraud epidemic that exists only in the minds of the president and his hardcore supporters.

“Flawed From the Start” compares the Presidential Advisory Commission on Election Integrity with three high profile national election studies conducted since 2001. In each case, the Trump commission is found wanting.

“Rather than undertaking a serious and much needed study of reforms that would protect and strengthen the integrity of our elections, the commission is geared to provide a platform for policies that will roll back voting rights,” the report asserts. In its first three months alone, the 12-member panel “has made errors that threaten voters’ privacy, undermine transparency in government, and could kick eligible voters off the rolls,” it adds

Authored by Allegra Chapman, Common Cause’s senior counsel and director of voting and elections, and Stephen Spaulding, chief of strategy and external affairs, the report examines the commission’s controversial request that state election officials supply it with an extensive assortment of personal information about voters, including party registrations and the last four digits of their Social Security numbers.

The request ignored limits many states place on the use of such data, the authors note, and the commission has sent conflicting signals about whether the data will be made public. Concerns about the loss of their privacy apparently have motivated thousands of voters to cancel their registrations; in Colorado alone, officials report more than 5,000 de-registrations.

The commission has indicated that it hopes to use the data to build a national voter database to support claims that tens of thousands of people are registered in more than one state and that registration records are out of date. The report notes that many states refused to provide all or part of the data the commission is seeking however, and that the records involved are notoriously unreliable as indicators of duplicate registrations.

The commission’s request to the states also appears to violate a federal law that bars federal authorities from seeking information on Americans’ exercise of their free speech rights, the authors write. Common Cause has filed suit asking for a federal court order stopping the data collection.

Other highlights of the report:

• The commission is partisan, with seven Republicans including Vice President Mike Pence, the commission chair, and only five Democrats. Commissions appointed during the administrations of former Presidents George W. Bush and Barack Obama were more evenly split by party, with  respected leaders like former Presidents Jimmy Carter and Gerald Ford given equal authority as co-chairs.

• The Trump commission’s vice chair, Kansas Secretary of State Kris Kobach, is using it to boost his campaign for governor of Kansas. Kobach “has a long history of attempting to lengthen and complicate voter registration processes and identifying cases of ‘vote fraud’ that prove unfounded,” the authors write. Commissioner Hans von Spakovsky “also has been a key figure in drumming up unsubstantiated fears about voter fraud.”

• The commission has not met legal requirements that it provide the public with notice of and access to its meetings. Its next meeting, scheduled for Tuesday, Sept. 12 is billed as a public hearing but attendees will not be permitted to speak. Instead, they must submit written comments by this Friday, Sept. 8.

• As secretary of state and a candidate for governor of Ohio, Commission member Ken Blackwell mistakenly posted the full Social Security numbers of 1.2 million Ohioans; a month later, his office inadvertently distributed voter registration lists including information on 5.7 million voters in the state. Blackwell also instructed clerks to refuse voter registration applications submitted on forms of less than 80-pound stock paper, the thickness of a postcard; clerks later convinced him to undo the decree as unnecessary.

• Commissioner J. Christian Adams has made unsubstantiated claims that huge numbers of “aliens” are voting in U.S. elections. Recently, as president of the Public Interest Legal Foundation, a conservative nonprofit, he published a report claiming that 5,500 noncitizens are registered in Virginia, and thousands cast ballots. The data behind those claims is “Not just incredibly inflated; designed – and specifically designed – to get inaccurate information,” according to Justin Levitt, an election law expert at the Loyola Law School and a former deputy assistant attorney general in the Obama administration.

Near its conclusion, the report observes that “To date, the Pence-Kobach commission has identified little that requires fixing in the elections system. Its focus is a hyped-up fear of illegal voting, despite an abundance of studies demonstrating the lack of a widespread problem.” While several commissioners are on record in support of addressing issues of engagement and confidence in the system, “there has been no movement to obtain information from the states that would help the commission assess current problems and propose sensible solutions.”

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