US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Robert Kibrick
Organization :   The Verified Voting Foundation
Post Date :   9/30/2005

General Comments
Comment :  HAVA permits a relatively wide range of voting systems to be used, so long as those systems comply with the voting standards specified in HAVA §301. This range of systems Includes older voting technologies, such as hand-counted paper ballots and punch cards, along with newer technologies, such as optical scan and DRE voting systems.

Unfortunately, there is a general disconnect between the range of voting systems permitted under HAVA and the range of voting systems that appear to be covered by various portions VVSG. Accordingly, there Is considerable ambiguity as to applicability of various provisions of the VVSG In polling places where a mix of these systems are deployed so as to comply with the disability access requirements of HAVA, e.g., a polling place that uses an precinct count optical scan system augmented by an Electronic Ballot Marker (EBM) to comply with HAVA's §301(a)(3) requirement.

The VVSG should clarify the applicability or non-applicability of its various provisions to each of the different types of voting technologies permitted under HAVA. For example, requirements pertaining to sealed paper paths for the VVPAT printer component attached to DRE voting systems should be clarified as pertaining specifically to such systems and not to paper-based voting systems such as precinct count optical scan systems augmented with EBMs.