US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Al Kolwicz
Organization :   CAMBER
Post Date :   9/30/2005

General Comments
Comment :  

Writing a superficial overview will not suddenly make the VVSG useable.  Editing the VVSG will not make it useable.  The problem with the guide is fundamental -- it is aiming at the wrong target, and it is using the wrong ammunition.  
a. The guide is incomplete (wrong target).  The election system involves many components – the VVSP addresses very few of them.  For example, the guide does not address public oversight, yet public oversight is a fundamental component of a trustworthy election process.  The guide does not address procedures, such as authentication that a voter is the person who they claim to be.  All of the components of the election system must be identified, and must be documented in a high-level systems diagram supplemented with a high level systems description.  The diagram and description must be void of specific implementation details, and must not require change for different implementations.  The current guide violates these precepts.
 
b. The guide addresses implementation-level details (wrong ammo).  The VVSG should specify only:  required results, measurement specifications for each result, acceptable performance for each result, and consequences when the required result is not achieved. HOW the result is achieved must be invisible in the VVSG.  Instead, this guide is burdened with detailed descriptions of how things are to be done for specific implementations.  For example, there is no general requirement that people and procedures be tested and measured.  One of the problems with the approach taken in the VVSG is that it will require revision every time a new technology is introduced.  Remember, it will take years before any VVSG change will be reflected in a majority of the nation’s voting systems.  Unless changed to reflect principles rather than implementations, the VVSG will fail in its goal of returning public trust to the election system.