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| | Name : | Sanford Morganstein | Organization : | Populex Corporation | Post Date : | 8/26/2005 |
| Section : | 6.8 | Page no. : | | Line no.: | | Comment : | The introduction to VVSG § 6.8 states that the requirements for VVPAT are
intended to help states that have VVPAT laws. The risk in the way the VVSG is
currently drafted is that states may have passed legislation prior to the EAC’s
adoption of the VVSG. Consequently, they may have adopted laws that are unaware
of important distinctions between Voter Verified Paper Audit Trails, Voter Verified
Paper Ballots and other flavors of tangible audit trails.
We point out that others have used the following terms and we suggest including
such terms in formal definition and in the glossary:
* Voter Verified Paper Ballot (VVPB)
* Voter Verified Paper Record (VVPR)
Consequently, we think it is very important that VVSG be made clear that the
guidelines that follow § 6.8 are for machines that produce both an electronic version
of the ballot and a tangible, voter-verified version of the ballot. That clarity should
also extend to making it clear that requirements for secure paper paths of § 6.8 do not
apply to systems that produce a paper ballot that is tabulated by optical scanning or
other paper ballot counting methods. There is much in § 6.8 et seq. that provides
excellent guidance for vendors and for election jurisdictions. We do not recommend
that all of the guidelines of § 6.8 be abandoned for Voter Verified Paper Ballot
systems, but that appropriate distinctions be made for systems that are not DRE
systems. Consequently, in our comments, we will only point out sections of the
VVPAT guidelines that we feel are inappropriate. We think the rest of the guidelines
can provide important guidance to vendor and election jurisdiction alike for systems
that produce a Voter Verified Ballot, whether or not those systems are VVPAT,
VVBP or something similar. | |
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