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from Bo Lipari, 2/17/06
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Revised
Voting Machine Standards Introduced
On
Tuesday, 2/14/06 the State Board of Elections met in public and executive
session. At the meeting, the Second Draft of the Voting Machine Regulations was
formally introduced. This revision is the State Board’s response to the public
commentary on the Draft Voting System Standards.
The
proposed final standards are now available for public comment. The final 10 day
public comment period will end on Friday, 2/24/06. Details about how the public
can submit comments on the proposed final standards can be found below, as well
as a link to the document.
NYVV
Comments on the Revised
Regulations
Unfortunately,
the proposed final standards do little to improve the many weaknesses present
in the original version of the Draft Standards. It is disappointing, and a
cause for concern, to see how much of the detailed technical commentary the
State Board received was simply ignored in the latest revision.
One
welcome addition is a lengthy section describing requirements for voter
verified paper ballots (VVPAT), which was notably absent from the Draft
Standards. But overall, nothing substantive has changed. Among many crucial
issues not addressed in the Final Standards are:
* The certification and testing
process is vendor driven and managed. Far too much discretion is given vendors
to define and influence the certification process.
* Allows the State Board to waive
any requirements without cause.
* Does not require vendors to submit
both DRE and scanner systems.
* Does not require that all written
procedures used to conduct testing, the tests themselves, and the results of
such testing be fully and readily available and open to the public.
* Poor acceptance test requirements.
* No requirement for comprehensive
security testing of voting systems such as “Red Team” tests.
* No requirement for the usability
and accuracy of the system to be demonstrated to the public. Each system must
be required to pass a multi-machine Public Mock Election Test.
* No requirement for a challenge
system under which independent experts can petition the Board to perform a test
in order to prove system shortcomings.
NYVV and
several noted security experts will be submitting detailed commentary on the Second
Draft of the Regulations. As currently written, the revised regulations
do little to protect our right to vote. The State Board of Elections must
recognize that the voters are the primary stakeholders in elections, and we
require adequate security safeguards, comprehensive and extensive testing of
voting systems, and a fully visible and transparent process.
Submitting
Comment on the Final Standards
The
public can submit comments on the proposed final standards by Friday, 2/24/06
by sending them to:
NYS Board
of Elections
Or via
email:
Download
the Second Draft of the Voting Machine Regulations: http://www.elections.state.ny.us/hava/2ndDraftVotingMachineRegs.pdf