IEEE Representative Comments on EAC Plans for Voting Systems Guidelines
By Cem Kaner, J.D., Ph.D. Professor of Software Engineering, Florida Institute of Technology
February 22, 2009
The following open letter was sent along with detailed comments (click here to download) to the Election Assistance Commission on February 20, 2009. The EAC Standards Board will meet February 26-27 in Orlando.
I am concerned by recent developments in the updating of the Voluntary
Voting System Guidelines (VVSG).
Unless I misunderstand your intentions, your current approach will not
implement most of the 2007 draft of the VVSG but will instead make
revisions to VVSG-2005 that:
(a) fail to implement most of the security-improvement provisions of
the 2007 amendments to VVSG
In addition, Board of Advisors Resolution 2007-D12 recommends that EAC
remove all requirements that mandate election procedures instead of
equipment standards. I am unsure of the scope of your authority in this
regard but the variation in local election procedures is enormous and
there are credible research reports that even minimal standards of
control (such as reconciling the count of voters against the count of
votes cast in a precinct) are sometimes not present.
(b) change the testing effort in ways that, on balance, will probably
make testing less expensive for the vendor but less likely to expose
defects in the software
(c) potentially fail to improve the ease, cost, accuracy and public
visibility of the task of auditing election results
(d) do somewhat improve usability and accessibility characteristics of
Just as hanging chads were probably the result of poor local practices
(not emptying the trays containing waste from punched ballots) rather
than equipment defect or voter error, improper or inadequate practices
with any type of voting equipment can wipe out those benefits
(reliability, security, usability, accessibility, auditability) that
might otherwise have been available. Controlling the equipment without
setting baselines for election procedures will not do much to help
Americans vote in ways that get their votes accurately received and
I believe these developments reflect a grave error and I urge you to
Cem Kaner, J.D., Ph.D.
Professor of Software Engineering, Florida Institute of Technology
www.kaner.com www.testingeducation.org http://www.satisfice.com/kaner/
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