EAC - Voluntary Voting System Guidelines

Name : | David B. Aragon
Organization : | N/A
Post Date : | 9/30/2005
Section Comments
Section : | 6.7.2.2
Page no. : |
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Comment : | The Air Is Not "Entirely Controlled by the Voting Official" §6.7 .2.2 requires: There shall be no undocumented use of the wireless capability, nor shall there be any use of the wireless capability that is not entirely controlled by the voting official. This requirement appears to be for documentation, but it actually calls out a technical capability at (or possibly beyond) the outer fringes of current wireless technology, namely, that the wireless capability be "entirely controlled by the voting official". The voting official cannot "entirely control" the wireless capability unless provided with hardware that reliably detects when wireless transmissions are taking place and what type of data is being transferred. (The voting official has more control, arguably still not "entire" control, if the wireless interface is physically removed from the voting equipment except during specific data transfer operations when the voting official can insert the wireless interface.) "Controlling the air" is a tenn used in business to describe management's ability to configure authorized transmissions and detect unauthorized ones within a business enterprise. This is a new area, in which only three vendors (two of them start-ups) provide any capability, and the need for improvement is recognized. The equipment is expensive and requires training to properly operate, especially if other, uncontrolled wireless equipment is within range (e.g. in an adjacent room or building). When wireless equipment is installed in a commercial site, even the trained IT staff require additional training by the wireless system vendor before they can effectively "control the air". It is not a function that election officials can reasonably be expected to perform, and they ought not to be led to believe they are performing it when they are not. The technical and economic obstacles to meeting §6.7.2.2 are therefore considerable. The wording of §6.7.2.2 invites creative non-compliance by implying that documentation could be a means of meeting it.