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

Section Comments
Section :  3.2.4.2.3
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Comment :  Although the VVSG defines In the Glossary an "Electronically-Assisted Ballot Marker", or EBM, it makes no reference to such ballot marking devices anywhere in the body of the standard (not even within Section 3.2.4.2.3, Marking Devices), and only makes a single reference to them in Appendix 0 (Independent Dual Verification), which is merely informative and not part of the standard.

Given that optical scan ballot systems are still the dominant voting technology in the U.S. (both In terms of the number of counties using such systems and the percentage of ballots cast in the last federal election), a significant fraction of such optical scan jurisdictions are deploying EBMs in order to meet the disability access requirements mandated by HAVA §301(a)(3).  

Accordingly, the lack of any standards In this VVSG that pertain to EBMs or to the use of privacy sleeves/envelopes to convey optical scan ballots between EBMs and precinct-count optical scanners represents a serious omission. Standards for EBMs, privacy sleeves, and for the interoperability of such devices each other and with precinct-count optical scanners are clearly needed and should be addressed by the VVSG.