EAC - Voluntary Voting System Guidelines

Name : | Christopher J. Dodd
Organization : | U.S. Senate
Post Date : | 9/30/2005
Section Comments
Section : | 6.8
Page no. : | 6-36
Line no.: |
Comment : | Although this section deals specifically with VVPAT, HAVA is clear that the definition of voting system, to which the requirements attach, includes "the total combination of mechanical, electromechanical, or electronic equipment . . ... that is used to maintain and produce any audit trail information." (42 USC 1548 1) Consequently, the Commission should consider expanding the VVSG security provisions which apply to VVPAT to apply to any form of voter verification that is used to maintain and produce any audit trail information, consistent with the VVSG definition found in Appendix A (A-3 5). Under HAVA, any such system must meet the requirements of section 301 (a), specifically, the disability accessibility and alternative language accessibility requirements. Over the next 24 months, prior to these guidelines becoming effective, jurisdictions and vendors are likely to develop alternative means of accomplishing HAVA requirements for voter verification and audit trails and the guidelines should be clear that all disability and alternative language access requirements must be met regardless of whether a jurisdiction implements VVPAT or an alternative verification technology.