EAC - Voluntary Voting System Guidelines

Name : | Christopher J. Dodd
Organization : | U.S. Senate
Post Date : | 9/30/2005
Section Comments
Section : | 2.2.7.1.1
Page no. : |
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Comment : | The VVSG's approach to accessibility issues for persons with disabilities raises a number of concerns, particularly with regard to the inconsistent use of "shall" and "should' in terms of guidelines to implement the disability access requirements under section 3 0 Z (a) of HAVA. 2,2.7.1.1. (p. 2-13). The WSG defines specific performance and technology requirements for Direct Recording Electronics ("DRE") voting systems in order to meet the needs of persons with several types of disabilities, but not all diverse disabilities. These standards do not provide for accessibility to a11 voters who reflect the wide range of disabilities. Such a standard is neither inclusive nor nondiscriminatory. The standard of "several types of disability" violates the broad principle of nondiscrimination in the VVSG Human Factors section. The standard is also inconsistent with HAVA as enacted. The disability provisions in section 30 1 (a)(3) of HAVA requires that voting systems shall be accessible for individuals with disabilities, including nonvisual accessibility for the blind and visually impaired, in a manner that provides the same opportunity for access and participation (including privacy and independence) as for other voters. As drafted, the VVSG does not effectuate the inclusiveness of HAVA which leaves behind no individual with disabilities. The Commission should revisit 2.2.7.1, consult with the diverse disabilities communities, and include specific recommendations to provide accessibility for a11 known disabilities, not only the several types of disabilities envisioned by the current VVSG.