US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Section CommentsGeneral CommentsGlossary Comments
 
Name :   Stanley A. Klein
Organization :   N/A
Post Date :   9/30/2005

General Comments
Comment :  Without a requirement for proper ESD protection, absent from the 1990 FEC specification,
voting machine manufacturers have no incentive to provide it and every incentive to avoid the
cost of providing it. Claims that redundant memories provide protection against loss of recorded
votes depend on independent failure of the memories. If both memories fail because of the same
problem, the claims of protection by redundancy are invalid. For example, if two memories are
connected to the same bus (computer internal wiring) and an ESD event puts thousands of volts
onto that bus, there could easily be a commonmode
failure of both memories losing all votes
recorded on the machine.
Based on the above considerations, it is likely that any touchscreen DRE designed and tested to
the VVSG or the predecessor FEC specifications would be vulnerable to electrostatic disruption,
possibly including complete loss of recorded votes. This is especially critical for touchscreens
designed and tested to the FEC 1990 specification. A proper specification at 35KV or higher
may well be difficult to meet. However, the goal of the VVSG should be election integrity, not
an effort to ensure that touchscreen technology can continue to be used in voting machines.