February 24, 2006


To the Commissioners and staff of the NYSBOE:


As an elected official, I know the importance of being responsive to the public one serves. Considering the thousands of hours which members of the public devoted to providing detailed comments and testimony regarding your first draft voting system standards, your failure to consider most of them is profoundly discouraging to those of us interested in protecting the security of our vote.


Even so, many individuals and civic groups have patiently given further analysis of your second draft, and I hope you will pay close attention.  So as not to be redundant, my comments will be much briefer.


My message to you is this: Your office clearly lacks the understanding of the issues and the technical expertise to craft these standards in an effective way. PLEASE get the professional help you need, especially from computer professionals or groups such as ACCURATE (Mr. Kellner knows them), to create standards that will truly safeguard our right to vote.


Key points:

The certification process, including testing procedures and events, must be much more open to the public than you currently permit.

Get computer security experts to help you design the source code requirements, testing, and certification measures necessary to GUARANTEE security of the vote.

Allow independent security professionals to petition to perform independent tests.

Require a professional "Red Team" test to attempt to overcome the safeguards.

Don't allow the vendors so much power in the testing and certification process. They are to serve the people, not vice versa.


Conclusion: You are operating on the heart of democracy, performing a "heart transplant" with these new voting systems we will be using. If you were real doctors performing a real heart transplant, you would be using specialists, wouldn't you? Well, now is the time to call in the specialists you need for this all-important procedure. If you fail in this operation, we will lose democracy in New York State, and it will be your fault.



Nicola Coddington

Member, Citizens for Voting Integrity


Trustee, Village of Irvington