EAC - Voluntary Voting System Guidelines

Name : | Al Kolwicz
Organization : | CAMBER
Post Date : | 9/30/2005
Section Comments
Section : | A2A
Page no. : |
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Comment : | 2. The proposal for accreditation of Testing Laboratories and the testing process itself is headed in the wrong direction. a. Missing, for example, is a way to pay for the testing. The vendors should not pay, because that would compromise the integrity of the Testing Labs. The people should not pay for overly expensive or frivolous tests, and should be compensated through penalty fees, for poor vendor performance. b. There is nothing proposed that will motivate vendors to withhold certification requests until they have a very high degree of confidence that the certification process will not discover a deviation between requirements and the implementation. c. The role of the public, and in particular the interested professional computer scientists, is missing. d. There is no penalty when a Testing Lab fails to detect problems that make it into production. How is a lab de-certified? e. Who is accountable for the quality of the election process? f. Also, because of the fundamental problems with the VVSG, described above, the Testing Labs are going to be testing the wrong stuff. There is a difference between systems testing that is aimed at requirements and architecture (what), and implementation testing that is aimed at implementation specifications (how). Few people have the skills needed to draw the elegant line between requirements/architecture and the implementation specifications. The VVSG desperately needs these skills. Unless the VVSG is revamped, I anticipate that it will become a burden on the public. It will generate enormous costs, fail to deliver quality, and be rejected by the public as a solution to their concerns.