My Comments on California's Draft Criteria for Top-To-Bottom Review of Voting Systems

California Secretary of State Deborah Bowen has begun a Top-To-Bottom (TTB) review of voting systems used in California. On Thursday of last week, the Secretary released a set of draft criteria to be used in the TTB review process ("Top-To-Bottom Review of Electronic Voting Systems Certified for Use in California Elections").

The Secretary sought public comment and we were given 6 days to submit documents. We're already seeing news stories about the comments submitted by CACEO (the California Association of Clerks and Election Officials); they are very concerned about how the TTB review will impact preparations for the new February 2008 primary ("E-voting machines face tough new standards").

I submitted comments today and I've made my comment submission available here in PDF: "Comments on California Secretary of State’s Draft Criteria for TTB Review".

Let me know if you have comments on my comments. I'd be especially interested in thoughts on the "learning bias" problem I discuss in the red teaming section; the idea is that it is hard to run a series of consistent red team exercises as the evaluators learn after each exercise.

If we would have had more time, I could have passed it around and brokered some institutional sign-offs. Alas, 6 days is a very short comment period!