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

General Comments
Comment :  On July 20, 2005, the EAC Issued ”EAC Advisory 2005-004: How to determine if a voting systems is compliant with Section 301(a) - a gap analysis between 2002 Voting Systems Standards and the requirements of Section 301(a)", In that advisory, EAC identifies various gaps between the existing 2002 VSS and the requirements of HAVA. As currently written, the VVSG suffers many similar gaps with respect to HAVA requirements, and these urgently need to be addressed before the VVSG becomes operative.

Definitions of critical terms are not handled in a clear and consistent fashion In the VVSG. Some terms are defined In Section 1.5, "Definitions", while other terms are defined In Appendix A, "Glossary". The various entries in the glossary appear to have been drawn from a variety of sources, with no apparent effort to reconcile these into a consistent nomenclature or taxonomy. As a result, various terms are used inconsistently across the various definitions in the glossary, and within the body of the VVSG (see separate comments submitted for the Glossary section); in addition, the hierarchical relationships between various terms is often obscured. As a result, the precise meaning of various standards is often unclear because the specific terms used to define those standards are themselves iII-defined.

Accordingly, a serious effort is needed to reconcile the definition of terms both In Section 1.5 and in the Glossary.