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Name :   Diane Golden
Organization :   Association of Assistive Technology Act Programs
Post Date :   9/9/2005

Section Comments
Section :  6.8.3.5
Page no. :  41
Line no.:  4
Comment :  Current Standard 6.8.3.5  -- If the normal procedure includes VVPAT, the Acc-VS should provide features that enable voters who are blind to perform this verification.  (Page 41, line 4)

The first two standards taken together deny equal access to systems using paper ballots, including VVPAT, for visually impaired voters who require large print text output.  If a paper ballot is or can be the vote of record, accessibility standards must ensure alternative large print output of that paper ballot is available.  It is discriminatory based on disability type to require audio output (thus providing access for individuals who are blind) yet not require large print text output for individuals with other vision disabilities.  

Standard 2.2.7.1.2.2.6 may require appropriate accessibility (both large print and audio output), however the wording is unclear.  The second sentence limits its application to situations in which a state requires a VVPAT to be an official ballot.  Election officials at more than just the state level could require or allow the paper ballot to be the official vote record.  The standard must make it clear that if the paper ballot is or can be the official vote of record it MUST be accessible to voters who are blind and those with low vision.  It is unclear why this second sentence was added to a standard that is limited to blind voters when the language applies it to “visually impaired voters” which includes all types of vision disabilities.