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Doug Jones: "Comments on the EAC TGDC Testimony"

elections

Doug comes through with another set of great notes from a voting event... this time it was the EAC Technical Guidelines Development Committee hearing on Sept 20, 2004. Some excerpts:

I believe that the time has come to ban the use of infrared optical mark-sense ballot scanners. In the late 1960s and early 1970s, when this technology was developed, infrared emitter-photosensor pairs may have been a reasonable choice, but today, we have nearly white LEDs and broad spectrum photosensors on the market that can easily sense any mark that would be visible to the human eye, and we ought to demand their use.

If you're interested in this, check out Doug's guide on optical sensing voting equipment.

If just 1 percent of the voters inspect their voter-verifiable ballots and would be willing to complain vocally if they saw problems, then the voter-verifiable model will test the machines more thoroughly than the parallel testing model. In fact, as Jim Adler has shown, in Confidence -- What it is and how to achieve it, presented at the NIST Symposium on Building Trust and Confidence in Voting Systems last December (see http://www.votehere.net/papers/NIST_121003.pdf), random voters testing 1 percent of the ballots offers a far stronger test than random testing of 1 percent of the machines.

This is an important observation... that is, only having 10-20% of voters checking the VVPAT's printed out by a system such as Sequoia's VVPAT VeriVote printer, is vastly superior to, for example, California's 1% manual recount requirement.

We should eliminate the term audit trail from the voting system standards in the form it is currently used. This term, as currently used, is misleading, and should be replaced by the term event log, because the audit trail of a process is the totality of all information an auditor might want to inspect, including event logs, actual ballot images, and all of the paper records surrounding the process. This observation was first made to me by Donald Llopis of the Miami-Dade Elections office.

Alright, but we just got used to the acronym VVPAT! Just kidding. This makes good sense.

If the law gives primacy to any one of these records, then a crook attacking the vote collected at that polling place need only corrupt that one record. This is the primary weakness of HR2239, the Voter Confidence and Increased Accessibility Act of 2003, where subparagraph 4.a.'2.'B.'iii says "The ... paper record ... shall be the official record used for any recount conducted with respect to any election in which the system is used."

Doug has compelled me on this issue. Note that this is also a problem with the California SoS's AVVPAT regulations.

Finally, why we should not standardize the state certification process...

I believe that the second reason is more important! Up to the point where the voting system is submitted to the states for testing, all of the tests to which it is subjected are predictable. Certainly, this is true of the testing at the ITA under the FEC/NASED Voting System Standards, where the vendor knows that each objectively testable criterion in the standards is likely to lead directly to some test.

At the state level, however, the vendors cannot currently guess what tests they will be subjected to. Some states have minimal tests, some rely entirely on the ITA's, but others offer significant and surprising tests. The ITA is asking, does the voting system satisfy each objectively measurable criterion in the voluntary Federal standards. The states first ask if the machine meets the requirements of state law, but having asked this, the examiners in may states are asked to give an opinion about whether the machine will accurately and fairly capture and record the intent of the voters. This is an open ended requirement that allows them to exercise some creativity in their tests, and between the 50 states, this creativity has led those of us involved in state testing to find significant problems.