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National Issues

IEEE Representative Comments on EAC Plans for Voting Systems Guidelines PDF  | Print |  Email
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.

Dear Commissioners:

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

(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 voting systems.
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.

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 counted.

I believe these developments reflect a grave error and I urge you to reconsider.

Cem Kaner, J.D., Ph.D. Professor of Software Engineering, Florida Institute of Technology
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