EAC - Voluntary Voting System Guidelines

Name : | Lee Page
Organization : | Paralyzed Veterans of America
Post Date : | 9/30/2005
Section Comments
Section : | 2
Page no. : |
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Comment : | However, the Voluntary Voting System Guidelines (VVSG) are inconsistent in the use of “shall” and “should” throughout the recommendations. Specifically, Subsection 3 of the proposed VVSG (p.2-22), which pertains to voters with “lack of fine motor control or use of their hands” is littered with “shoulds” rather than “shalls.” Section 3.4 (p.2-23, line 21) states “[t]he Acc-VS should provide a mechanism to enable non-manual input that is functional equivalent to tactile input” (emphasis added). Section 3.5 states “If the normal procedure is for voters to submit their own ballots, then Acc-VS should provide features that enable voters who lack fine motor control or the use of their hands to perform this submission” (emphasis added). Finally, Subsection 3 provides no specific guidance on the accessibility of VVPAT to voters who lack fine motor control or use of their hands. This inconsistency of language makes it appear that one disability is entitled to more access to the vote that another. Section 301 of HAVA clearly states that voting be accessible to “individuals with disabilities, including non-visual accessibility for the blind and visually impaired”. By definition the term “individuals with disabilities” includes voters with dexterity disabilities. Accordingly, this Commission’s rationale set forth in its July 5, 2005 letter to the TGDC and NIST regarding the need to change the VVSG pertaining to voters who are blind and visually impaired must also be applied to the VVSG guidelines pertaining to voters with lack of fine motor control or use of their hands. Use of the term “should” leaves room for interpretation as to whether a feature is required. The term “shall” clearly indicates that the requirement exists. [Statements submitted at EAC public hearing, August 23, 2005, Denver]