EAC - Voluntary Voting System Guidelines

Name : | Sanford Morganstein
Organization : | Populex Corporation
Post Date : | 8/26/2005
Section Comments
Section : | 6.8
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Comment : | The introduction to VVSG § 6.8 states that the requirements for VVPAT are intended to help states that have VVPAT laws. The risk in the way the VVSG is currently drafted is that states may have passed legislation prior to the EAC’s adoption of the VVSG. Consequently, they may have adopted laws that are unaware of important distinctions between Voter Verified Paper Audit Trails, Voter Verified Paper Ballots and other flavors of tangible audit trails. We point out that others have used the following terms and we suggest including such terms in formal definition and in the glossary: * Voter Verified Paper Ballot (VVPB) * Voter Verified Paper Record (VVPR) Consequently, we think it is very important that VVSG be made clear that the guidelines that follow § 6.8 are for machines that produce both an electronic version of the ballot and a tangible, voter-verified version of the ballot. That clarity should also extend to making it clear that requirements for secure paper paths of § 6.8 do not apply to systems that produce a paper ballot that is tabulated by optical scanning or other paper ballot counting methods. There is much in § 6.8 et seq. that provides excellent guidance for vendors and for election jurisdictions. We do not recommend that all of the guidelines of § 6.8 be abandoned for Voter Verified Paper Ballot systems, but that appropriate distinctions be made for systems that are not DRE systems. Consequently, in our comments, we will only point out sections of the VVPAT guidelines that we feel are inappropriate. We think the rest of the guidelines can provide important guidance to vendor and election jurisdiction alike for systems that produce a Voter Verified Ballot, whether or not those systems are VVPAT, VVBP or something similar.