EAC - Voluntary Voting System Guidelines

Name : | Dan McCrea et al.
Organization : | Miami-Dade Election Reform Coalition
Post Date : | 9/30/2005
Section Comments
Section : | 1.1
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Comment : | These comments address the objectives, and scope of the VVSG as set forth in Sections 1.1 and 2.2. In light of these comments, we also call upon EAC to reexamine the definitions in 1.5, 1.5.1, 1.5.3 and the glossary definition of voting system in Appendix A. Our poll closing observation work has influenced our comments on many provisions of the guidelines. Of premier importance is our belief that the objectives and scope of the draft VVSG are too narrowly conceived from a functional perspective. This is especially true for elections run using DREs. As we explain in Section 3 proper ballot accounting procedures are an essential component of an election run on DREs, without which, such an election is baseless. Ballot accounting must be addressed in The Guidelines, as part of an expanded scope. In assessing the VVSG we submit that the EAC has construed its objectives too narrowly by drawing a tight circumference around the hardware and software issues for voting systems and by failing to analyze how the hardware and software actually operate when used in elections. The VVSG wrongly establish a bright line between voting technology and election administration; this improperly isolates the latter from specific consideration to the detriment of the former. This can be a fatal error, as our report, Get it Right the First Time, makes clear. Election administrators using complex DRE technology cannot view administration and system technology as separate categories; rather they need to know that the two are inextricably intertwined. Both sound considerations of law and policy argue that EAC include in the scope of The Guidelines how DREs are used in the real world. This will require a detailed examination of the interrelationship between DREs and the environment in which they are operated. The Guidelines must address how election officials use these machines to run an election and what types of problems are routinely encountered. In particular, The Guidelines must incorporate sound ballot accounting procedures that ensure ballots are properly accounted for before tabulation commences.