EAC - Voluntary Voting System Guidelines

Name : | Christina Galindo-Walsh
Organization : | National Disability Rights Network
Post Date : | 9/30/2005
Section Comments
Section : | 2.2.7
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Comment : | NDRN_b Some Guidelines Decrease Accessibilitv The current FEC 2002 standards were developed to apply to Direct Recording Electronic (ORE) voting systems without a WPAT. When ORE machines are used alone and the electronic vote is the official vote of record, these standards provide a satisfactory level of accessibility for individuals who are blind and require an audio/tactile ballot, for those who have partial vision and require large print visual display, and for those with dexterity limitations who cannot manipulate a paper ballot. However, when these same standards are applied to a ORE-WPAT system, as the WSG anticIpates, they fall short because they do not require that voters with dexterity and low vision be able to review and cast their WPAT privately and ind ependently. The VVSG are intended to fulfill the mandates of HAVA by bringing the 2002 Voluntary Voting System Standards developed by the Federal Election Commission (FEC) up-to-date with the requirements of HAVA. For the disability rights community, progress on this front is especially important since HAVA's passage marked the first time federal law affirmatively guaranteed individuals with disabilities access to a private and independent vote. It is because of this great achievement that NDRN is so troubled by guidelines that, if implemented, will actually decrease the accessibility embedded in the standards set forth by the FEC in 2002. By carrying forward standards devised to apply to traditional DRE systems and not adding guidance to assure that newer voting mechanisms, such as the WPA T, are accessible, the VVSG fails to maintain the level of accessibility provided in the FEC's 2002 standards. Good public policy demands that if a level of accessibility has been achieved, policies to be implemented should at a minimum maintain, not decrease, accessibility. Somewhat analogous to this situation, the current ADA Standards prohibits alterations that decrease accessibility when making modifications to buildings. To maintain the level of accessibility provided by the FEC 2002 standards, the WSG should require an accessible VVPA T (audio and large print display) so that Individuals with all types of vision disabilities have a private and independent opportunity to review the WPAT when it constitutes the vote of record. Also, as mentioned above. the WSG should require that voters with motor disabilities, as well as those with impaired vision, be able to submit privately and independentJy a paper ballot when the normal voting process includes such a procedure. None of these requirements are unreasonable or technologically infeasible, and they are all consistent with the intent of the statute.