Public comments being requested by the EAC

[BeFree]

The Voluntary Voting System Guidelines were developed under the Help America Vote Act of 2002 (HAVA) Section 202 mandate that the U.S. Election Assistance Commission (EAC) update the 2002 Voting System Standards to address increasingly complex voting system technology. They were designed for state and local election officials to help ensure that new voting systems function accurately and reliably.

The Guidelines are provided for a 90 day public comment period which officially began June 29, 2005 upon notice in the Federal Register. All comments must be received by EAC on or before 5:00 p.m. EDT on September 30, 2005. All comments will be posted on the EAC website. Comments may also be sent to [e-mail] or by fax to Voting System Guidelines Comments at [phone]. Comments may also be mailed to Voting System Guidelines Comments, U.S. Election Assistance Commission, 1225 New York Ave., NW, Suite 1100, Washington, D.C. 20005.

The Guidelines are also available in hard copy format or on CD-ROM. Call EAC at [phone] or [phone] to request a copy or for more information.

At the conclusion of the public comment period and after the consideration of comments received, EAC commissioners will vote to approve the Voluntary Voting System Guidelines. The final version will be made available to the public at that time.


http://www.glynn.com/eac_vvsg/intro.asp

[BeFree]

1. VVPAT- OPTIONAL? Why is it optional?

6.8 Requirements for Voter Verified Paper Audit Trail (Optional )

This section contains requirements for Voter Verified Paper Audit Trail (VVPAT) voting systems. VVPAT is not mandatory. These requirements are provided for system certification testing for those states that have decided to include VVPAT as a requirement for their voting systems.

http://www.glynn.com/eac_vvsg/vg1/v1s6.htm#_v1s6t01157968

[Kip Humphrey]

2. My Submitted Public Comments and recommendations for Section 6.8

Submitted public comment, see below. Deletions shown as <itallic>, discussion and recommended changes in Bold:

6.8 Requirements for Voter Verified Paper Audit Trail <(Optional )>

This section contains requirements for Voter Verified Paper Audit Trail (VVPAT) voting systems. VVPAT is <not> mandatory and constitutes the "ballot of record" for all digital voting systems. These requirements are provided for system certification testing for <those states that have decided to include VVPAT as a requirement for their> all digital voting systems.

6.8.1 Display and Print a Paper Record

6.8.1.1 The voting system shall print and display a paper record of the voter’s ballot choices prior to the voter making the ballot choices final.
V Voting System Vendor
Pre-Voting Voting Post-Voting

Discussion: This is the basic requirement for VVPAT capability. It requires that the paper record be created as a distinct representation of the voter's ballot choices. It requires that the paper record contain the same information as contained in the electronic record and be suitable for use in verifications and recounts of the election and of the voting station’s electronic records. <Thus, either> Only the paper <or electronic> record <could> can be used as the ballot of record for the election.

6.8.1.2 The paper record shall constitute a complete record of ballot choices that <can> is required to be used to assess the accuracy of the voting station’s electronic record, to verify the election results by conducting mandatory random real-time manaul paper audits of the digital vote processing system, and in <full> all recounts.
V Voting System Vendor
Pre-Voting Voting Post-Voting

Discussion: This requirement exists to make clear that it is possible to use the paper record for checks of the voting station’s accuracy in recording voter’s ballot choices, as well as usable for election audits (such as mandatory <1>5% recounts). The paper record shall also be suitable for use in <full>all manual recounts of the election.

6.8.1.3 The paper record shall contain all information stored in the electronic record.
V Voting System Vendor
Pre-Voting Voting Post-Voting

Discussion: The electronic record cannot hide any information related to ballot choices; all information relating to ballot choices must be equally present in both records. The electronic record may contain other items that don't necessarily need to be on the paper record, such as digital signature information.

*NEW* 6.8.1.4 The paper record shall be used to conduct mandatory, random, manual, real-time, paper audits of the digital voting system.

V Voting System Vendor
Pre-Voting Voting Post-Voting

Discussion: The electronic record, digital vote processing system, and electronic vote tabulation must be audited in real time without notifying the system of the auditing process ongoing. A minimum of 5% of paper ballots of record, selected entirely at random, will be directly and manually compared to the digital record at each node within the digital vote processing system. All digital vote processing systems are requred to maintain an unbroken, fully auditable chain of custody of electronic vote records from the vote input device through to and including the electronic vote tabulator that produces the vote count of record. All digital vote processing systems that fail to provide an unbroken audit trail able to be audited by random, manual, real-time, audits using the paper ballot of record are unacceptable for use in elections.


Sincerely,
Kip Humphrey
51 Capital March
Election Assessment.org
[e-mail]
[e-mail]


The new section (6.8.1.4) should probably be broken down into 2 or 3 separate sections (see Discussion), but I am late for work.

Kip