Aaron Burstein (UC Berkeley Law) and I just finished a large regulatory filing that will be of interest to any of you election technology geeks out there. Enjoy and be sure to let us know if you have feedback (there's another round of comments sometime in the future on a revised draft).
ACCURATE Submits Comments on the Voluntary Voting System Guidelines
5 May 2008
A Center for Correct, Usable, Reliable, Auditable and Transparent
Elections (ACCURATE) submitted public comment today to the
U.S. Election Assistance Commission on their draft Voluntary Voting
System Guidelines (VVSG), urging the Commission to adopt certain key
features fo the draft. The VVSG provides a national certification
framework for U.S. voting systems against which 40 states require
their voting systems to be certified.
ACCURATE's comments laud the new draft as a groundbreaking and badly
needed overhaul of our national voting system standards while making
constructive suggestions for further development.
The most significant element of the draft VVSG is the requirement for
software independence, which would require voting systems to be
designed so that undetected flaws in the voting system software cannot
cause changes in the vote count. ACCURATE fully supports requiring
software independence as the backbone of a robust and comprehensive
next-generation voting system certification regime.
The commentary goes on to emphasize the importance of welcome features
of the draft: adversarial vulnerability testing, volume testing, the
new framework for usability and accessibility testing and
comprehensive voting system documentation requirements. The comment
closes by pointing out areas of the VVSG that will require increased
institutional support outside of the VVSG process, including the
crucial innovation class and a closed loop for incident reporting and
feedback.
ACCURATE plans to participate further as the draft VVSG is modified
and extended.