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Name :   Pamela Smith
Organization :   The Verified Voting Foundation
Post Date :   9/30/2005

General Comments
Comment :  General Comments on the
Technical Guidelines Development Committee (TGDC) Draft Voluntary Voting Systems Guidelines (VVSG)
Following are some general comments on various portions of the Draft Voluntary Voting Systems Guidelines. The Verified Voting Foundation’s founder David Dill testified1 to
the Election Assistance Commission (EAC) on July 28, 2005 on various points, including voter-verified paper records (VVPR), terminology on such records in the guidelines,
wireless networking, etc. Some key issues are discussed below.

VOTER VERIFIED PAPER RECORDS:
The EAC to date has declined to require or even recommend a voter-verified paper record. The excuse: explicit language for VVPR was not part of the Help America Vote
Act (although a strong argument can be made that it is implied). However, the EAC is not bound by the advisory recommendations of the TGDC, and has the power to express such
a requirement in the guidelines. We believe it is within the EAC’s interpretive powers to
define the document used in the manual audit.

Inclusion of the requirement would help define more appropriately the mandatory paper audit trail in Section 301(a)2 of the Help America Vote Act (HAVA). No legitimate audit
can be carried out unless that audit uses a contemporaneous independent indelible record of the voter’s intent. No electronic record -- unseen by the voter and subject to
programming error, equipment malfunction or even malicious tampering -- can reasonably meet that standard, nor any reprint (unverified by the voter) of that same
electronic record. Thus it would vastly improve the legitimacy of the nation’s elections if the EAC were to clarify that the manual paper audit trail indeed shall be voter-verified.
On January 18, 2005 Professor Ron Rivest introduced a resolution (#13-05) to require voter-verified paper trails at the TGDC meeting. Professor Rivest is the member of the
TGDC with (by far) the greatest expertise in computer security. That resolution was voted down, by members of the committee who know less about computer security than the person who introduced the measure.
We urge the EAC to reinstate the recommendation in resolution #13-05 and require the essential safeguard of voter-verified paper records.