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Professor Dan Tokaji
Election reform, the Voting Rights Act, the Help America Vote Act, and related topics -- with special attention to the voting rights of people of color, non-English proficient citizens, and people with disabilities

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Equal Vote
Tuesday, October 4
ACCURATE Comments on EAC Voting System Guidelines
A Center for Correct, Usable, Reliable, Auditable and Transparent Elections (ACCURATE) has submitted these comments in response to the Election Assistance Commission's Voluntary Voting System Guidelines. This group consists of several prominent computer scientists, including David Dill and Avi Rubin, and recently was awarded a major grant from the National Science Foundation. Here's a summary from the introduction to ACCURATE's comments:
Voting systems must ensure security, privacy, transparency, usability, accessibility and equality. Through the 2005 Voluntary Voting System Guidelines (the Guidelines) the Election Assistance Commission is responsible for translating these diverse values into specifications and requirements that reliably instill these values in voting systems. As past elections and past standards amply illustrate, the distillation of these broad core democratic values into workable voting system requirements that can be effectively evaluated is a complicated, continuous process. To accomplish this task there must be (1) consensus on the meaning of the values listed above, (2) a concerted effort to determine how the Guidelines will drive system design to align with these values, and (3) a sophisticated understanding of how to assess compliance with these requirements and, in a broader sense, of whether the requirements ultimately further the values that inspired them....

ACCURATE's comments provide several levels of advice and direction to the EAC. In section II, we identify fundamental problems with the process that the EAC has set forth for certifying and evaluating voting systems, and suggest solutions to those problems. First, we call for increased transparency throughout the EAC's processes and the certification and testing process. Second, we call for a reorientation of the VVSG away from its current overwhelming focus on functional testing to discipline-specific approaches to certification and evaluation. Third, we call for a systems approach to voting system certification and evaluation which importantly includes capturing, learning from, and responding to experiences with voting systems at the polling place. Fourth, we recommend that the EAC develop a more nimble and timely approach to updating the VVSG and requiring voting system compliance with new guidelines.
I've sometimes disagreed with members of this group in the past, most notably on the subject of whether to require that electronic machines generate a contemporaneous paper record, or "voter-verifiable paper audit trail" (VVPAT). But for those interested in electronic voting, the comments are worth reading for the constructive approach to the challenges and opportunities offered by electronic voting. I especially appreciate the fact that, rather than focusing only on security and transparency, they incorporate other values -- equality, accessibility, and usability -- into their analysis. Particularly deserving of attention are their recommendations regarding transparency in certification, source code transparency, consideration of field data, continual updating of standards, interoperability, and attention to usability issues. Whether or not these recommendations are adopted as part of the voluntary voting system guidelines, they're important things to consider for the future.

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