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Chapter 2: Conformance Clause

This chapter provides information and requirements relating to how manufacturers and test labs can use the features of this document to assess whether a voting system conforms to the VVSG. It is written with these audiences in mind; the overview information in Chapter 4 of the Introduction is written for readers with less-technical backgrounds.

2.1 Structure of Requirements

Each part of the VVSG is organized into hierarchically organized sections that address topics of interest. Sections typically begin with prose explaining the general purpose, etc. This is informative background to help understand the requirements. Sections also contain requirements, which are the hard and fast rules to be followed for conformance. The VVSG carefully distinguish normative requirements from informative context using conventions that are explained below.

Each voting system requirement is identified according to a hierarchical scheme in which higher-level, "parent" requirements (such as "provide accessibility for visually impaired voters") are supported by lower-level subrequirements (e.g., "provide an audio-tactile interface"). "Parent" requirements have identifiers consisting of a section number suffixed by a letter (e.g., 1.2.3-A) and are indicated by straight arrows in the left margin. Subrequirements have identifiers consisting of their parent requirements' identifiers suffixed by a digit (e.g., 1.2.3-A.1) and are indicated by bent arrows in the left margin.

Each requirement is composed of a descriptive title, normative text, optional informative discussion, and two fields labeled Applies to: and Test reference:.

The applicability of a requirement is specified with the Applies to: field, which indicates the class(es) of voting systems or devices to which the requirement applies. Classes are defined in Part 1: 2.6 "Extensions".

A requirement having N different classes separated by commas in its Applies to: field is equivalent to N separate requirements that repeat the same text, each repetition applying to one of the listed classes.

The scope of a parent requirement is inherited by its subrequirements unless they explicitly specify a narrower scope. The scope may be narrowed through a generic relation (e.g., DRE is a subclass of Vote-capture device) or a partitive relation (e.g., a DRE is part of a Voting system). If no narrowing is needed then the Applies to: field may be omitted.

The Test reference: field indicates the general testing approach or approaches that would be used to assess conformity with the requirement.

57 Comments

Comment by Kathy Finger (Voter)

Hi, As a database and web developer, I have no faith whatsoever in electronic voting systems that don't provide for a thorough vote verification system based on paper (preferably derived from hemp or other renewal resource but that's another issue). Anything short, is a sham of true democracy. Please help restore democracy in this country; the extra steps and resources are worth it. If we don't have such transparency, we don't have democracy.

Comment by Michael E. Ryder (General Public)

Seven years have passed since the disastrous election foul-up of the last presidential election. Have you not yet learned that the oldest way is the best way to verify how and for whom a voter voted? A written ballot or a written confirmaion is essential for, 1. Voter confirmation, and 2. verification of vote as shown on electronic ballot. Please take action immediately to ensure that this happens, and that all of America can be represented by valid votes.

Comment by Diana Rae Bevis (Voter)

To ensure democracy, we need to be able to account for all votes. Electronic counting is too fallible. Millions of voted were lost last election. We need votes audited independently of their software.

Comment by Barry K. Miller (Local Election Official)

As a local election official, I have not seen any reason to remove the voting machines which are currently in use. There is a record of everyone's vote, there is minimal amount of time involved at the end of the voting period to tally the votes. Why spend our hard-earned tax dollars on the folly of any voting machine changes?

Comment by Casey Reed (Voter)

Software Independence (SI) is essential in a world where errors to manipulations of software rendered totals of votes happens. There needs to be two independent systems. One has to be hand counted paper ballots, at least the top three races for president, congress, and governor. This hand count can be done with a separate ballot that is counted in the polls on election day. This count would become an instant audit of the election board and poll. The electronic count could be recounted at a later date, but having the hand count with a smaller separate ballot from the one scanned, as is done here in New Mexico, would facilitate two independent canvasses of the election. I do not think many realistic voters and computer literate people trust electronic election systems or the software. We need hand counted paper ballots on election day in the polls. Get it right on election day!

Comment by Barbara Schultz (General Public)

In regard to paper records and/or paper ballots: Probably even before then, but certainly over the past four years, I have read countless articles about the ease with which computer systems can be hacked; we all know how easily computers malfunction. We have heard stories about votes for one candidate being switched to that person's opponent, or votes being "lost." We have read about districts where more people voted than were registered -- and vice versa. We have heard about situations where people's ballots contained a vote for every candidate EXCEPT the president. And no way to hold the system accountable! It is terribly important that ALL VOTES BE COUNTED, AND COUNTED ACCURATELY. If we cannot have faith in our voting system, how can we have faith in the officials elected? And why should we continue to elect the people responsible for it?

Comment by Marion Wipf (Voter)

Any system that does not have a verifiable process should not be used......EVER! We all have had problems with electronic technology. Our computers, ATM's, cash cards, etc. OUR BASIC RIGHT TO VOTE CANNOT BE TAMPERED WITH! It's happened in the last two elections and look what we got as a result. If there is a paper trail, and the Supreme Court doesn't overturn the whole process, then all the votes can be counted. IT IS OUR RIGHT TO HAVE A SYSTEM WHERE ALL VOTES CAN BE COUNTED!

Comment by Julian Kernes (Voter)

I am concerned with the increased privatization of many functions that were regulated by government that we are changing into the old Feudal Lords state. With the control of the vote in the hands of software manufacturers many people whether right or wrong feel elections are fixed or voting totals flipped. Without an independent paper trail to verify the vote we will never know if We the People as our Constitution begins are being represented and our concerns are being address rather than just the exclusive interests of a minority of unelected executives. That balance can be checked with properly designed clear, easy to use paper ballots independent of manufactured software.

Comment by Mike McKibben (Voter)

It is imperative that we make our election process as reliable and accountable as possible. The system software must be made as tamper proof as it can be, and there must be a way to create a verifiable paper trail in the event a recount of votes is needed. The 2000 election in Florida should never be repeated in our great country, and can be prevented if the right action is taken now. Computer voting systems may not be subject to "hanging chads", but without the proper security, they can leave an election in question due to tampering or untimely power outages.

Comment by Chris Kelly (General Public)

I think that BlackBoxVoting.org showed each & every reason why electronic voting is NOT what it is cracked up to be! Thankfully, in our small town, we still use paper ballots. I still don't believe that GWB won either election, without the help of his *friends*!

Comment by Barbara Hibino (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Sheldon A Maskin (Voter)

As a voter, the following quote expresses my feeling about software voting. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Thank you. Sheldon A Maskin Anna Maria, FL

Comment by June Oliver (Academic)

We need a paper trail.

Comment by David Earl Johnson (General Public)

Software Independence (SI) is an important advance toward verifiable voting: it means that voting systems should not rely only on software, because software can contain errors or problems that are impossible to detect without an independent record of voter intent. Of present technologies, only systems that utilize voter-verifiable paper records or voter-marked paper ballots would be software-independent. It is critical that we have a system of voting that is above board and beyond tampering that is implicit in paperless voting.

Comment by Christopher Garvey (Voter)

DRE's have no place in a verifiable voting system. They cannot reliably create a trustworthy paper trail.

Comment by Julia Craig (Voter)

I am very worried about computer systems used for voting. Computers do make errors. Also they can have changes made by people who want to illegally change the vote, if they have any contact with the voting computers. Therefore, for me to believe that a voting system is safe and honest, I believe that there should be a way of finding out what the voter meant to vote for without depending on the reliability of the computer.

Comment by claire e. benson (Voter)

2004 problems with touch screen machines: No electricity, touch screen machines didn't work. Too few touch screen machines, the lines were over 8 hours long. Touch screen machines were broken, took corporate tech's to reprogram, fix, the touch screen machines counted backwards for thousands of votes before it was noticed. Machines locked in the principal's office. Polls couldn't open until 8:30 am, because machines locked in principal's office, or machines didn't work. A paper receipt on a touch screen machine will not fix these problems, nothing will fix these problems. Only a marked card stock ballot,using scanners, and with a random mandatory audit of a percentage of precincts, will fix these problems with touch screen machines. In 2006, Minnesota met these requirements for the first time, and is the first state to do so in the US. We cannot have different standards for each state in federal elections, as the results affect all of us, not just the one state in which the standards meet a minimum requirement for fair elections. Touch screen machines have been replaced with scanned card stock ballots with only seven weeks to election date in several states in previous elections, where these problems had surfaced in primaries. Now Republicans are saying that seven months is not enough time to achieve this easily met standard. This is ridiculous.

Comment by Alice Lovely (Voter)

Hi, I am very concerned about my vote being properly recorded and available for recount in the event that is necessary. A paper ballot is essential to ensure computer-recorded votes are accurate and reflect the intentions of each voter as well as to ensure the ability to have an accurate recount in the event there is any reason to question the accuracy of the votes made. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Marvin Blair (General Public)

All electronic voting should have paper verification systems.

Comment by Linda Finlay (General Public)

If people can't trust the integrity of elections, as is now the case, democracy is meaningless. We must have voting systems that record and recover voter decisions that don't depend on software, which is always susceptible to error and hacking. We need voter-verified paper ballots in some form.

Comment by Franklin Eventoff (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Software Independence (SI) is an important advance toward verifiable voting: it means that voting systems should not rely only on software, because software can contain errors or problems that are impossible to detect without an independent record of voter intent. Of present technologies, only systems that utilize voter-verifiable paper records or voter-marked paper ballots would be software-independent. However, software independence may not make it into the final guidelines; those who still support paperless electronic voting are opposing SI.

Comment by Janet Goldner (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Evelyn Heinze (General Public)

Computer systems are subject to errors. They can malfunction or be intentionally corrupted. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. E. Heinze

Comment by Allison Midgley (General Public)

Computer systems and software need to be verifiable in a way that doesn't rely on the computer system. There are too many ways that computers can malfunction or be tampered with at any point in the process from build to vote, and finding and verifying these issues may take too long after an election. There must be some sort of "paper trail" or record independent of the software!

Comment by Seth Edelman (Voter)

Sometimes changes in computer data cannot be detected. Computers and files can be hacked and modified, a problem seen weekly somewhere in the world. Supposedly secure systems containing military information, financial information, etc., etc. are constantly being reported to have been compromised. Hackers, like virus creators, are always one step ahead of those seeking to thwart them. In short, computer files cannot be shown to be a secure way of collecting and retaining some of the most important data we have: the votes of American citizens. Lower tech but much better for the purpose are voter-verified paper ballots.

Comment by Michael Farrier (Voter)

simple. paper trail, paper trail, paper trail. checks and balances. people who administer are not the ones to double check. people who install are not involve in the repair, debugging, replacing or administering. do not depend on exit polling. people lie. companies lie to protect their interest. assume nothing. again. paper trail.

Comment by Astrida Onat (Voter)

In my experience, I've found that computer systems often have built in errors. Although the errors may have been created inadvertently, they can be deliberate or subject to deliberate malfunctions (viruses). In my work and for personal use, I have always kept a hard copy of important electronic documents so that, if there is a malfunction, I have backup on what was in the computer. No less should be expected of any computer system that is put into place to record and recover votes and voter intent. Anything less than backup hard copies of the votes and voting process lacks integrity and subvets our democratic process.

Comment by Marilyn Sebek (Voter)

The ONLY system that is acceptable must have paper ballots that can be physically counted. Oklahoma has a great system that other states should adopt.

Comment by Mary Ann Maikish (Voter)

Any electronic device for voting should have in addition to optical scanners--verified voter paper trails or our democracy is compromised. Please refer to the HBO documentary done by the grandmother from Ohio.

Comment by mim (Voter)

It's really hard to imagine that we are run by machines and the corrupt that run them. Scared to vote, you bet!

Comment by Otto J Hunt (General Public)

I am an electrical engineer who has worked on designing rugged computers. I say from experience that computers systems have all kinds of errors. That is the reason for parity bits. Such systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. For these reasons it is essential to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Darrell Phare (Voter)

What, I haven't learned by now? Of course we need paper-verifiable ballots. Leaving it up to trusting ANYONE including technology. These computerized systems are all open for tampering and if there is a question? we've seen what we had and because of that, we know what we NEED! No vote without hard-copy verification and the time necessary to verify, thereby saving our Democracy.

Comment by Jerry Redwine (Voter)

Every single vote must have a paper trail that can be recounted, by hand if necessary, nothing else is acceptable.

Comment by Professor David S. Tartakoff (emeritus) (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by William McGuffey (Voter)

People who tamper with the voting process should be shot as traitors. This can be retoactive since these traitors have cost us so much.

Comment by Ben Guthrie (General Public)

A verifiable record not dependent on software is critical to the integrity of any voting system.

Comment by Christine Hanson (Voter)

In general, I want PAPER BALLOTS. NO MORE SOFTWARE VOTING MACHINES.So what if it takes longer to count the votes? Too many problems with computer voting. NO MORE COMPUTER VOTING MACHINES!!!!

Comment by Martin Albaum (General Public)

Software Independence should be a key requirement. This means the ability to track and identify the errors--intentional and unintentional--that can infiltrate software.

Comment by Linda McDonald (Academic)

In order to maintain our democracy in these days of electronic voting, it is essential that there is a verifiable paper backup. There is already a widespread belief that some elections have been "stolen" by rigged computer systems. Please give us and the world back the credibility of our remarkable system of self-government. Thank you, Linda McDonald

Comment by Penelope Needham (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Janet M. Powers (Academic)

Since software and computer systems in general are subject both to error and tampering, it is essential that voters who use computerized voting machines have some kind of a record of their vote so that they know that their choices have been recorded correctly. It is a travesty of the democratic system for one party or the other to have access to voting machine software that can distort an individual citizen's vote. We desperately need safeguards against this sort of activity.

Comment by Ken Finton (General Public)

Software independent voting with paper audit trails are the only way to protect our democracy. Reliance upon software that can be corrupted or rigged at any point without detection is something that would only appeal to those who want to fix votes and elections. We MUST have ballots that can be printed and recounted and verified. Perhaps voting machines cannot do this at all. Paper ballots might be bad for trees, but they are food fr democracy.

Comment by CHAYA FINTON (Academic)

My vote is to retain paper ballots as backup even if machines are used. I have voted by absentee ballot for the last two elections to make certain my vote counts. I work every election as an election judge and I can assure you that something was wrong with the 2004 election on Colorado, as my precinct where I as a judge was not properly counted and the tally we posted did not agree with the final results. Protect out democracy first. Computer systems are subject to errors. Computer systems can malfunction or be corrupted at any stage of their design, manufacture, and use. No one will even know the election was rigger. Ut is critical to the s that our voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Elisha Ignatoff (General Public)

Look to Kenya. If we lose our faith that our electoral machinery is both accurate and impartial. . . that is our future.

Comment by Kathleen Ragan (General Public)

I'm having a hard time understanding all this, but I feel strongly that computer software is not reliable enough and is too susceptible to be used without having a paper ballot that can be counted to verify the vote. Please make a paper ballot backup a requirement. thank you, Kathleen Ragan

Comment by Aleithia Artemis (Advocacy Group)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture, and use. Because elections are a competitive event, there is a high degree of temptation to do this. The methods used to do this can be extremely difficult to foresee and detect. There have already been past elections which were stolen directly as a result of computer systems being used in the voting process. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The only way to achieve this is voter-verified paper ballots.

Comment by Karen Giles (Voter)

Extensive investigation has proven beyond any doubt that computer voting systems are subject to errors and to fraud. Hundreds of thousands of votes have been lost and election outcomes changed due to malfunctions and corruption. According to Clint Curtis designed a program to determine election results, this can be done so it is not detectable. See: Rigged USA Elections Exposed http://www.youtube.com/watch?v=JEzY2tnwExs&feature=related If there is to be any hope of having legitimate elections where the people's votes determine the winners of elections, there must be a paper record of every vote where the voter marked their choices themselves and sees that they are accurate. There must be a way to recover votes if machines that count them malfunction. There must be a paper record to count the vote as cast by the voter, not as programmed by the system designer. In order for there be a recount or an audit as required by law in may areas, there must be a record of the votes that does not depend on software which is not reliable.

Comment by Carrie Odgers (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Ray Wolfe (Academic)

I feel that integrity and verifiability of the voting record is of the utmost importance. Please work to obtainthe requirement that documentation of voting records are available to allow verification.

Comment by Jeannie Marsh (Local Election Official)

I am a precinct chair and experience shows me that it is absolutely essential to have a marked paper ballot to count when things for wrong as they do in all elections. We must have the right for a qualifed voter to vote and that the vote be counted accurately. Our democaracy is at stake. Cut out the games and get real. We have just gone through two presidential elections that we really are not sure that the man who became president was actually elected fairly, honestly, and accurately.

Comment by Judith Norell (None)

All computer systems are subject to subtle errors. Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. I urge you to do this: to provide a means of recording and recovering voter intent that does not depend on the reliability of software, i.e. paper trails and records.

Comment by William F Jenkins, Jr. (Voter)

From our three branches of state to the method we use to hand count ballots, the foundation of this experiment in proxy violence we call democracy depends on opposing forces acting transparently. An election process which forbids "We the People" from evaluating the collected evidence of our will is antithetical to this foundation. An institutional audit of the evidence by partisan governmental agencies will never be sufficient to engender trust in the process. Therefore, the first and most important verification of any election must always come in the form of our ability to manually count the ballots to the maximum extent We wish to perform the task. Any mechanized process must be based on the same transparent adversarial methodology. To that end We need technical specifications crafted by governmental standards bodies and relevant manufacturing interests for: I. A standardized ballot layout equally discernable by humans as well as machines from all manufacturers. II. Classes of counting devices of suitable duty, security and functionality for various ballot counting tasks including - A. Ballot box device to verify legibility, accept & store ballots, compile the initial count and backup the evidence; B. Small scale counting device for precinct-level verification; and, C. Large scale counting device for institutional verification. III. A process supporting verification by certified and tested equipment owned by candidates, the political parties and voters - A. On election night in the precinct limited to devices from the parties and a randomly selected voter or two; B. For a period prior to the manual count or formal completion of the canvas by the candidates, parties and a limited number of randomly selected voters' devices; and, C. After the election to the maximum extent the evidence can tolerate. In short, the governmental and manufacturer monopoly on counting equipment must cease in order to provide a counting methodology matches our values as a nation. We the People will never consider evidence beyond our comprehension and/or our review sufficient for the causes of our union. We desperately need a reliable eWitness to augment and mirror our manual processes. Thank you for this opportunity to comment on the draft VVSG.

Comment by Cynthia Chase (Voter)

Dear Sir or Madam, I am extremely concerned about a threat to fair voting. We absolutely need Software Independence--SI--to remain part of the federal guidelines for voting systems. I work with computers and am highly aware that software can contain problems that are impossible to detect--that can't be detected unless you have paper trail. It's CRUCIAL thatSoftware Independence be among the final criteria in the final version of the federal guidelines. It's crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that DOES NOT DEPEND on the reliability of software. Please ensure that SI is part of the federal guidelines. Sincerely, Cynthia Chase

Comment by Robert O'Connor (General Public)

We MUST have a means of recording and recovering votes that do NOT depend on complicated software alone. Most systems I have heard of/read about that are ONLY computerized without printing outputs per ballot do NOT provide adequate recovery mechanisms and they often malfunction. Please continue to require a ballot recording mechanism that does provide separate - paper-type - information that can be used for both original counts and recounts. Thank you.

Comment by Linda Brenner (Academic)

I strongly support keeping a paper trail within our voting. The machines used could simply have their cutting blades SHARPENED. WE SHOULD STAY SOFTWARE INDEPENDENT. Please note the film "MAN OF THE YEAR" We MUST be able to recount votes. Otherwise, one more questionable election outcome and the American people will loose ALL faith in our system of government.

Comment by Ian Aeby (Voter)

Dear EAC, As an electronics engineer who has worked on both private and public projects of varying complexity (from mathematics teaching machines to space exploration and nuclear weapons test) I have suffered a lifetime of frustration from software bugs. It seems that regardless of how robust the system hardware is designed, some programmer will always find a way to turn it on its head and produce errors all the way form the very nearly undetectable to the truly absurd. Most of the time these errors result from human fallibility, but the software arena also seems to be particularly attractive to persons with malicious intent (viruses, spam, denial of services attacks, etc., etc.). In short, the results of voting are too important to leave exclusively to software. And while I am much in favor of the environmental benefits of a paperless system, at this time voter marked paper ballots are our best hope for meeting the requirements of software independence and durable voter verifiable records. That said, there is still very tangible value in employing electronics methods to voting. However, this value will be seriously compromised if we cannot agree on a common data format and communication protocols. In this regard it might be prudent to engage the expertise of industry standards experts such as the IEEE or ANSI. Operating in the fast paced electronics market has compelled these groups to develop fast-track standards methods that could be beneficial to EACs efforts to adopt a universal data format for voting systems. Thank you for taking the time to solicit and read my comments. Sincerely, Ian Aeby

Comment by Barbara Peterson (None)

I am extremely concerned about the reliability and integrity of computerized voting systems. I sincerely feel we can do better without computers, but if we must use them, it's crucial that the systems provide a means of recording and recovering voter intent. The computer system must not depend on the reliability of software, which can malfunction or intentionally manipulated and or corrupted. Sincerely Barbara Peterson

Comment by E Smith/P Terwilliger (Manufacturer)

2.3. "Product standard" is not defined. 2.4-A. Section (b) says "(see below)". It is not clear which "below" is indicated. A vague reference of this sort has no place in a requirement statement. Table 2-1, 5th row uses "product" instead of "system". 2.7-A. "undetectable" is an absolute and hence untestable. 2.7.2, first bullet, first line "be" is missing (after "must").

2.2 Normative Language

The following keywords are used to convey conformance requirements:

  • SHALL indicates a mandatory requirement to do something. Synonymous with "is required to."
  • IS PROHIBITED indicates a mandatory requirement not to do something. Synonymous with "shall not."
  • SHOULD, IS ENCOURAGED indicate an optional recommended action, one that is particularly suitable, without mentioning or excluding others. Synonymous with "is permitted and recommended."
  • MAY indicates an optional, permissible action. Synonymous with "is permitted."

Requirements are further indicated by the presence of green text and arrows in the left margin. Requirements are directly applicable to achieving conformance to the VVSG.

Informative parts of this document include discussion, examples, extended explanations, and other matter that is necessary for proper understanding of the VVSG and conformance to them. Informative text may serve to clarify requirements, but it is not otherwise applicable to achieving conformance to the VVSG.

5 Comments

Comment by Barry K. Miller (Local Election Official)

As a local election official, I have not seen any reason to remove the voting machines which are currently in use. There is a record of everyone's vote, there is minimal amount of time involved at the end of the voting period to tally the votes. Why spend our hard-earned tax dollars on the folly of any voting machine changes?

Comment by Mara Alper (Voter)

It is essential for our democracy that voting systems be Software Independent with verifiable paper trails. Without these, we no longer have a true democracy. I value my country for its democracy. Let us up hold that with Software Independent voting systems

Comment by Marion Wipf (Voter)

This is ridiculous......Nevermind the wording.....just make sure our voting system is verifiable..... with hard copies. That's it. End of story. Stop making everything so complicated.

Comment by Eric Zuesse (Voter)

All certified voting equipment and supplies shall provide to the voter a physical ballot which that voter may then mark, and which marked ballot that voter may then place into a receptacle from which all ballots shall be counted and tabulated so as to produce the vote totals. After vote totals have been tabulated, all ballots shall be placed in a secured facility for storage and for possible re-counting. All ballots shall be stored there for one year if no request for a recount is filed within that period, and shall be stored for however long is necessary to resolve all issues in the event that within a year of the voting-date a request for a recount is filed. Only by these means can a rational voter trust that he or she is a citizen in a democracy, and not a citizen in a dictatorship. Electronic means of recording votes shall not be permitted to be used in the United States of America, because this nation is a democracy, not a dictatorship.

Comment by Rex A Dwyer (Voter)

Software independence is crucial to the integrity of the election system. Even software that has been thoroughly reviewed by experts can harbor undetected flaws; space and missile development have provided some spectacular examples. In addition, the potential for deliberate perversion of the software is always present. Legislatures show increasing concern for the authentication of the identity of voters who present themselves at the polls. New enforcement efforts against a small number of fraudulent voters each casting a single illegitimate vote will be wasted if an even smaller number of conspiring programmers can falsify precinct results on a large scale. The Guidelines suggest that Software Independence may be achievable without independent voter-veriable records, i.e., some form of marked ballot, and I, too, admit this as a theoretical possiblity for the future. Nonetheless, I believe the citizenry as a whole is entitled to transparent records verifiable after the fact by a committee of average citizens without special training.

2.3 Conformance Designations

A voting system conforms to the product standard if all stated requirements that apply to the voting system and its constituent devices are fulfilled. The implementation statement (see Part 1: 2.4 "Implementation Statement") declares the capabilities, features and optional functions that have been implemented and are subject to conformity assessment.

There is no concept of partial conformance—neither that a voting system is x % conforming, nor that a device that is not a complete voting system by itself is conforming. Individual devices of voting systems are not tested except as parts of complete systems. [3]

5 Comments

Comment by Richard Carback (Academic)

This draft has given an architecture and taxonomy of voting systems and the devices they use. It also goes into device specific requirements. I find it absurd and protectionist that there is not, at least, limited device-level certification. In other words: If I am a printer company, and I make great printers, there is no facility for me to get my VVPAT printer certified under the VVSG as meeting all the requirements. Instead, I have to contract with a company making a voting system to have my device included. The problem with this situation is that it is in the best interest of the voting company to find the cheapest printer that passes certification. Election officials may never get the choice to buy my superior product, because I cannot get it certified under the VVSG without a voting company. Likewise, it discourages a voting company from offering multiple kinds of compliant printers, because for each printer they offer, they must bundle it with their larger voting system(s) for it to be considered certified. Lack of device level certification severely limits the usefulness of federal certification of voting equipment for states. I find the footnote explaining this away unconvincing. Lets take a look at it in pieces: "[3] A prerequisite for device-level certification would be prescribing a system architecture so that the responsibilities of each device and the interfaces between those devices could be well-specified." An architecture is not necessary when specific devices are already identified (e.g. printer). Even if this statement were true, the VVSG already gives various system architectures and a taxonomy for voting systems. The interfaces between devices, however, is something that is necessary to specify, but in many cases, standard interfaces exist, and it would be worthwhile to define them if they did not exist (The document already requires common industry data format support). "Such prescription is undesirable." Why? "More importantly, even with a prescribed architecture, a device-level certification would provide no assurance that any particular system that included that component would function as specified." Again, why is this true? Note that, using my preexisting example, if I know my printer conforms to the VVSG (assuming a specified interface), and that my larger system conforms to the VVSG, why shouldn't they work? "That assurance can only be obtained by evaluating the complete system in the configuration in which it is to be deployed." In other words, I can only be assured my new CDROM drive will work if I can find a computer exactly like mine with that CDROM drive in it, and not because I know my computer supports IDE drives, and the CDROM drive is an IDE drive? Perhaps, in some special case, these statements are true, but not as they are presently written in this draft.

Comment by Mary Ann Maikish (Voter)

All electrronic voting devices must have optical scanners in addition to verified voter paper trails or our democracy is in trouble. Please refer to HBO documnetary regarding the ability to compromise the electronic voting machines done by an Ohio grandmother.

Comment by Barry K. Miller (Local Election Official)

As a local election official, I have not seen any reason to remove the voting machines which are currently in use. There is a record of everyone's vote, there is minimal amount of time involved at the end of the voting period to tally the votes. Why spend our hard-earned tax dollars on the folly of any voting machine changes?

Comment by Marion Wipf (Voter)

IT HAS TO BE VERIFIABLE. HARD PAPER COPY....NO MATTER WHAT SYSTEM YOU DECIDE TO USE. KEEP IT SIMPLE, STUPID!

Comment by Mara Alper (Voter)

It is essential for our democracy that voting systems be Software Independent with verifiable paper trails. Without these, we no longer have a true democracy. I value my country for its democracy. Let us up hold that with Software Independent voting systems

2.4 Implementation Statement

An implementation statement documents the requirements that have been implemented by the voting system, the optional features and capabilities supported by the voting system, and any extensions (i.e., additional functionality beyond what is defined in the VVSG) that it implements.

An implementation statement may take the form of a checklist to be completed for each voting system submitted for conformity assessment. It is used by test labs to identify the conformity assessment activities that are applicable.

4 Comments

Comment by Diane Gray (Voting System Test Laboratory)

The information in this Chapter does not convey just how much information is required in the Implementation Statement. Suggest Chapter should either be expanded or at least include a list of the other Parts and Chapters of the document which discuss Implementation Statement requirements.

Comment by Valerie Nixon (Voter)

Voter-verified paper records are most effective. They cannot be unscrupulously tampered with, and honest mistakes are, less likely. OUR VOTES SHOULD MATTER!!

Comment by Minda Rae Amiran (General Public)

It is essential that the requirements include a device that produces a voter-verifiable, recountable paper-trail documenting the voter's choices, or that the voting machine record voter choices on a paper ballot that can be kept for verification of the machine's totals.

Comment by Barry Schaeffer (Voter)

All computer systems are subject to errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is ABSOLUTELY necessary to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.
2.4-A Implementation statement

An implementation statement SHALL include:

  1. Full product identification of the voting system, including version number or timestamp;
  2. Separate identification of each device (see below) that is part of the voting system;
  3. Version of VVSG to which conformity assessment is desired;
  4. Classes implemented (see Part 1: 2.5.3 "Classes identified in implementation statement");
  5. Device capacities and limits (especially those appearing in Part 1: 8.3.1 "Domain of discourse");
  6. List of languages supported; and
  7. Signed attestation that the foregoing accurately characterizes the system submitted for testing.

Test Reference: Part 3: 4.1 "Initial Review of Documentation"

DISCUSSION

This requirement addresses many issues about the scope of conformity assessment and uncertainty whether particular features have been implemented in voting systems.

A keyboard, mouse or printer connected to a programmed voting device, as well as any optical drive, hard drive or similar component installed within it, are considered components of the voting device, not separate devices. The voting device is "responsible" for these components—e.g., a DRE must prevent unauthorized flashing of the firmware in its optical drive or other components that could be subverted to manipulate vote outcomes.

Specified capacities and limits should include the limit (if any) on the length of a candidate name that the system can process and display without truncation and similar limits for any other text fields whose usable or practically usable sizes are bounded. If the system provides a way to access the entirety of a long name even when it does not fit the width of the display and does not use any data structures that would force truncation, such a limit might not apply.

Manufacturers may wish to contact their intended testing labs in advance to determine if those labs can supply them with an implementation statement pro forma to facilitate meeting this requirement.

Source: New requirement.

11 Comments

Comment by Diane Gray (Voting System Test Laboratory)

Includes "should" and "might not apply". Specified capacities and limits are testable items which will require stated limits. States the manufacturers may wish to contact intended test labs for a possible pro forma implementation statement. To ensure consistency by users, suggest a standard pro forma implementation statement be developed.

Comment by Premier Election Solutions (Manufacturer)

Version numbers more commonly apply to the individual devices rather than the complete system. Also version numbers are commonly not known until the completion of the testing. The requirement to provide specfic limits for a system is broad and subject to interpretation. All systems have limitations and determining which limits to include is highly subjective.

Comment by Terry Zenner (General Public)

This really is simple folks. For accuracy assured voting there must be a paper trail to compare to the software result in an election period

Comment by Edd Blackler (Voter)

I am extremely concerned about the reliability of any voting system software that does not provide a means of recording and recovering voter intent that does not depend on the reliability of the software." Our democratic process depends on complete transparency when it comes to voting and legislative actions. Please do everything possible to make this election one we can all be proud of.

Comment by Sally Blakemore (General Public)

What has happened in this country is treasonous. Tampering and manipulating voting machines that the public believes to "carry" their vote for them and having it lost, switched and dumped is not democracy. This has been going on for 8 years if not more. I want paper and I want a voting system that is "designed" to do what is supposed to do under law and not designed to do what it is not supposed to do. Karl Rove and George Bush should be impeached, imprisoned for life for what they have done to this country and world.

Comment by Mara Alper (Voter)

It is essential for our democracy that voting systems be Software Independent with verifiable paper trails. Without these, we no longer have a true democracy. I value my country for its democracy. Let us up hold that with Software Independent voting systems

Comment by Barry K. Miller (Local Election Official)

As a local election official, I have not seen any reason to remove the voting machines which are currently in use. There is a record of everyone's vote, there is minimal amount of time involved at the end of the voting period to tally the votes. Why spend our hard-earned tax dollars on the folly of any voting machine changes? To put our trust into a computer to record our vote is a serious undermining of our representative form of government.

Comment by Annbritt duChateau (Voter)

Software is prone to bugs and errors that escape detection and correction during the development process. In addition, software can be corrupted either inadvertently or maliciously once it is in use. In this regard, it is extremely important that electronic voting systems in use in the United States have a secondary or backup capability to verify a voter's selection that is independent of the software."

Comment by Chris Garvey (Voter)

DRE's inherently don't create a verifiable paper trail, and should not be used in a voting system.

Comment by Marion Wipf (Voter)

KISS......KEEP IT SIMPLE STUPID! VERIFIABLE.....HARD PAPER COPY......OH, YES.....AND BY THE WAY.... ANYONE FOUND TAMPERING WITH OUR VOTING SYSTEM SHOULD BE PROSECUTED.....

Comment by Michele Smith (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. We need a paper trail. Thank you!

2.5 Classes

2.5.1 Voting device terminology

The following terms are defined in Appendix A: voting device, activation device, Vote-capture device, IVVR vote-capture device, paper-based device, electronic device, programmed device, tabulator, precinct tabulator, central tabulator, audit device, VEBD, Acc-VS, MMPB, EBM, VEBD-A, VEBD-V, DRE, VVPAT, optical scanner, ECOS, MCOS, PCOS, CCOS, and EMS.

2.5.2 Classes overview

A class simultaneously identifies a set of requirements and a set of voting systems or devices to which those requirements apply. The purpose of classes is to categorize requirements into related groups of functionality that apply to different types of voting systems and devices.

Classes may subsume other classes. For example, paper-based device subsumes MMPB EBM, and optical scanner. The subsuming class is called the superclass while the subsumed classes are called subclasses.

A group of related classes forms a classification lattice with a largest class at the top and a smallest class at the bottom. The largest class subsumes all other classes. For voting systems the largest class is called Voting system; for voting devices the largest class is called Voting device. The smallest class is subsumed by all other classes. In this discussion the smallest classes are unnamed and are only present to complete the formalism.

Subclasses "inherit" the requirements of their superclasses. Additionally, a subclass may further constrain a class by adding new requirements. However, a subclass is not allowed to relax or remove requirements inherited from a superclass.

There is no assumption of disjointness for classes. Unless otherwise specified, a voting system or device may belong to several classes simultaneously, such as Acc-VS and DRE to signify an accessible DRE device.

A voting system conforms to a class if all stated requirements identified by that class are fulfilled. Since subclasses are not allowed to relax or remove requirements inherited from a superclass, it is true in all cases that a voting system or device conforming to a subclass also conforms to all of its superclasses. For example, a voting system conforming to any subclass of Voting system fulfills the general requirements that apply to all voting systems.

The classification mechanism is useful in many different contexts when there is a need to identify specific portions of the VVSG. Part 1: Table 2-1 provides several examples.

Table 2-1 Use of classes in different contexts

Context

Use

VVSG

Requirements applicable to a given class

Implementation statement

This system conforms to a specified class

Conformity assessment

Tests and reviews applicable to the specified class

Certification

Scope of certification is the specified class

Declaration of conformity

This product is certified to that class

Request for proposals

Seeking to procure a system conforming to a specified class

Part 1: Figure 2-1 and Part 1: Figure 2-2 repeat in pictorial form the classification hierarchies that are defined in the next section to illustrate their high-level structure. A class is represented by an oval containing the name of the class. When two classes are connected by a line, this indicates that the higher class subsumes the lower one. The "subsumptions" are also described in the next section.

Figure 2-1 Voting device classes

image020

Figure 2-2 Voting system classes

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16 Comments

Comment by Carolyn Coggins (Voting System Test Laboratory)

One of the goals of the new standard is transparency. It does not foster transparency if less accessible terminology is used. Nor does it facilitate the work of the labs or manufacturers in communicating information if a term used through out the document has to be translated over and over again for new users. "Subsumes" is not a universally understood term and should be replace everywhere it is used in the document. "Includes" or "incorporates" are good alternatives.

Comment by Brian V. Jarvis (Local Election Official)

(Section 2.5.1 did not have it's own "comment" link.) In section 2.5.1: - "voting device" does not have a hyperlinked definition. - "activation device" has a broken hyperlink. - "Acc-VS" has a broken hyperlink.

Comment by ted selker (Academic)

With the end-to-end definition here, it seems that a voting system includes: 1. the registration system, 2. the ballot generation, 3. the voting device, 4. the ballot collecting, and 5. the reporting system.

Comment by Carolyn Coggins (Voting System Test Laboratory)

Figure 2-1 Why isn't a DRE a Precinct Tabulator?

Comment by Carolyn Coggins (Voting System Test Laboratory)

Figure 2-2 The approach of classifying voting variations is convoluted and unworkable. This is about supported and unsupported functionality that can be turned off and on. Hence saying a system function is a type of device doesn't work because whether it is turned on or off, its the same device. The failure of this approach is demonstrated in Section 7. It is full of repetitive requirements which say nothing and provide no clarification in order to bend around this concept. Example: 7.7.2-A Says tabulators shall support all voting variations indicated in the implementation statement. Rather than expanding this single requirement to define "support" 17 requirements have been added, half of which say a tabulator of "X" class shall be capable of tabulating votes, overvotes and undervotes. (A DRE can be a tabulator and of the write-in voting device class, but it can't record overvotes.) The approach must be one where the voting variation functionality is defined with detailed testable . Testable requirments for voting variations have been side stepped in this document.

Comment by Frank Padilla (Voting System Test Laboratory)

Requirements versus functions are not really clear.

Comment by James C. Johnson III (Local Election Official)

Software Independence (SI) is an extremely important concept in ensuring that the voters’ intent is accurately reflected in the vote that is counted. Because in any case SI requires a paper ballot to be marked, in the best case by the voter, or alternatively by a ballot marking device, the data capture process will require [precinct based – my preference] (optical) scanner to capture the data and convert it into an electronic form where it can be transmitted, tallied and reported. Optical scanners, which are also computer controlled and programmable (microcode and firmware) may also become points of attack on the voting system. This is mitigated somewhat by audit provision requiring a random audit of some percent of the ballots from randomly chosen precincts. Below I suggest some measures that will allow auditing of 100% of the ballots, once at the precinct and once at the central site using scanners from different manufacturers; or because standardization and competition will drive down prices, two counts could be performed at the precinct by independently manufactured scanners. This reduces the need for manual audits and hand counts unless discrepancies are found. I would like to recommend that the EAC develop and enforce interoperability requirements for all voting system components. This would require the development of standards that all voting subsystems must meet, similar to those developed by OASIS (Election Markup Language [EML]) and by the IEEE p1583 (Voting Equipment Standards), and p1622 (Voting System EDI) subcommittees. As a minimum, such standards would mandate that: 1) Ballots should be readable by any certified scanner regardless of the manufacturer. 2) When ballot data is transferred between devices it should use standard syntax and semantics allowing different manufacturer’s equipment to be used at any point in the processing chain. 3) All database formats should be published and standardized so that any required software (e.g., reporting software) can be obtained from a variety of suppliers. 4) Consider using Open Source software for any function where such software is available. In order to promote transparency, source code for any software used should not be proprietary and should be available for viewing by responsible research or academic organization. These measures should reduce price by promoting competition and allowing Boards of Election to select equipment from multiple vendors, who presumably have developed their systems independently. This is a safeguard against malicious code being introduced at any step in the process by a single vendor. Because Boards of Elections can buy compatible component from any manufacturer, any subsystem, from the voter registration database to the final reporting system could be purchased from any vendor or obtained as Open Source code where available.

Comment by Mara Alper (Voter)

It is essential for our democracy that voting systems be Software Independent with verifiable paper trails. Without these, we no longer have a true democracy. I value my country for its democracy. Let us up hold that with Software Independent voting systems

Comment by J Goldner (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Larry Martin (General Public)

I am a software engineer, and this (2.5.2 Classes overview) is the section where I stopped reading. Voting is simple. A piece of paper and a pen. In Iraq they do it with fingerpaints. The people responsible for this effort really need to take a step back and consider what problem they are trying to solve. Any technological system can be subverted given opportunity and motivation. Elections provide lots of both. Let's please apply the KISS principle and return to paper ballots. Thank you, Larry Martin Orange County, NC Home of the Tarheels AND paper ballots

Comment by Barry K. Miller (Local Election Official)

As a local election official, I have not seen any reason to remove the voting machines which are currently in use. There is a record of everyone's vote, there is minimal amount of time involved at the end of the voting period to tally the votes. Why spend our hard-earned tax dollars on the folly of any voting machine changes? I do not see any improvement over the class of system now in place. If there is extra hours required for the compilation of absentee voters it is well worth the efforts to hire the personnel to accomplish this task.

Comment by Marion Wipf (Voter)

You can't be serious? Just make the system verifiable.....you know....hard paper copy....so we can count every vote!

Comment by Ben Mencher (Academic)

As we claim to live in a democracy and at the root of our rights in a democracy is our individual vote. Surely as citizens of one of the wealthiest countries in the world, we can afford to have a receipt for each vote cast. It is unamerican and totalatarian in nature to tell the people that they should just trust "The State". If we can insist that citizens must show ID to vote than we can also have a receipt with the voters name and candidate that they voted for. This should not be up for discussion with our elected officials as they should concur that, we the people of The United States have the right to have our vote accurately counted. I also believe in the future, elections should be changed to June as this would give us more time for a recount if major problems were found. The elections could last for one full week as this would be more inclusive and increase voter participation. There have been many reports of polls closing before the people could cast their votes due to problems with the machines, inclement weather, misunderstandings, and generally long lines. The country is more populated than it was when our current voting time was chosen, thus it is grossly outdated. Most states for state elections give their residents a full week to get their ballots cast. The national election is no less important and should seriously consider adapting this week long strategy. Changing the elections to June would also allow for a smooth transition of power if there were a national crisis. If we asked the people their opinion on this matter, I believe it would be clear that they would want the best chance for their vote to be counted and would greatly support a week long process. Today as many votes go uncounted we only give the illusion of a free election. China uses the spilled blood of dissidents to shine their floors so The Olympics glisten brightly. Thank You 503-236-0927

Comment by Laurie Smyla (General Public)

Democracy is defined by the right and ability of a citizen to cast his or her vote and know that vote is counted. I make this statement to clear through some of the rhetoric I have read on this site. 1) The United States needs a national voting standard to be applied to all polling stations in all national elections. 2) Within these standards should be the mandate that the mechanism used to collect the votes be accurate, consistent, verifiable and free from any possible tampering or contamination of data. 3) As an incentive, it should be impressed upon the States that if they adopt the national voting standard in all their elections, a portion of their election costs will be reimbursed by the Federal Government. I have a deep love for my country and I have been saddened by the callous indifference our government has shown toward our most precious foundation of democracy, the right to vote!

Comment by Mary Lou Diehl (Voter)

Confidence that elections are honest means that the intention of the voter must NOT depend on electronic records: there MUST be a paper record that can be audited and/or recounted. Counting the vote must be based on visible paper records,preferably marked by the voter him or herself.

Comment by Jean Nichols (General Public)

It is very important that our votes are all counted accurately. We need a system with a verifiable paper trail that does not depend on software alone. All computer systems are subject to errors at any point during their design, manufacture, or use. Software can be easily defective, corrupted, or manipulated. We need to have a system where votes, if questioned, can be recorded and recovered to make sure they match the intent of the voter. This system should not be dependent on the reliability of software.

2.5.3 Classes identified in implementation statement

2.5.3-A Implementation statement, system classes

An implementation statement for a voting system SHALL identify:

  1. All applicable classes from Part 1: 2.5.3.1 "Supported voting variations (system-level); and
  2. Either the IVVR class, or an innovation class submission class that also suffices to achieve software independence.

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

DISCUSSION

By definition, the class Voting system applies to every voting system. All voting systems are required to achieve software independence. The IVVR design is one way to accomplish this. Alternatives may be approved through the innovation class submission process.

Source: New requirement.

7 Comments

Comment by Gary Martin (Voter)

Of course it's clear that we need verifiable voting results. Get those damn paper trail machines now!

Comment by Robert L Youngblood SFE (Voting System Test Laboratory)

October 7, 2004 To whom it may concern: I’ve been sitting back listening to all the rhetoric on touch screen voting. Very little of it is with true knowledge and common sense! Back during the voting scam in Florida there was much said with no substance, which is what usually happens when a new policy is being implemented. Millions of votes have been cast on those documentation card readers and very few people, if any, could not understand how the system works. Hanging chad and dimpled chad can only happen under certain conditions. None of which could explain the so-called difficulty people were having casing their vote. You can also do a recount with the same results each time. The bottom line is, people want to be sure that their vote is cast as they intended it to be. Get rid of the tried and true and stay on the BLEEDING edge of technology. That is the mindset of most in policy-making decisions within our governments. Business understands, "If it ain’t broke, don’t fix it". Try this scenario. Firmware written within the machine is date coded to change every third vote from one party or candidate to another. This is only on the day of the election, between the hours that the election takes place. After the program runs its course, it can destroy itself or be written off as a software glitch. This means that a TROJAN horse is in the place of election even though those who would protect our votes are carefully watching it. This may sound ridiculous, but we have software today that writes its own code and viruses or worms can do the same thing. The only way to do a true recount under these conditions would be to have everyone who voted to come back and revote. Even with a printer giving you a copy of what you voted, the vote would still be skewed. Your vote would be recorded on paper but what was sent to the system would be changed. You may ask why that is not true of the older computer related machines. These machines had what is called hardware executive and cannot be changed. One I am familiar with is a company who did their back-ups religiously. The hard drive goes down and they found that the back-ups for an entire year were garbage. Even though they had magnetic tape and a burner CD for back-up a date code was put on the system that showed the data as a mirror image when the verify was done. After so many days, you would not be able to read it. This system had no Internet access or modems. It was the so-called sealed system. Much like what is being sold to our boards of elections. Yes, in time the information was gotten off the CD, but not until after that company went into bankruptcy, i.e., the election was over!!!!! I’ve been a Senior Engineer in computer systems for 38 years and in business for myself for 20 of those years. Viruses are not something new. They were used in the beginning to be sure the bill to the computer support group was paid. If you did not pay your bill, the system could be halted by NOT calling in on a modem and resetting a date counter. When time ran out the system shut down. That means inaction (a "0" or "0’s and I’s") can set forces into action as well as an action (1 of a 0 or 1). The customer had to call the support group and not only pay the past due bill but also pay for a service call to get the system running again. All I am trying to convey here is, we are heading down a slope that will put a very few people in total control of a most important piece of our sovereignty as a state and a nation. Yes the old way is slow but the assurance is by far more preferable! Sincerely yours, Robert L. Youngblood SFE

Comment by Matthew McCright (Voter)

All computer systems can be deliberateley corrupted at any stage of their design, manufacture, and their use. The U.S. voting/election processes involve strong emotions that often cloud judgement and deform the societal goals to enhance gain by one party or another. There are also enormous financial incentives for business, political parties & other organizations, and key individual participants. In that context, I believe that it is critical to create systems that emit manipulation-resistant documentation of each and every voter's behaviors -- their votes -- as a backup and audit trail to the tabulation and summary output from those systems. Because all computer systems are subject to subtle errors and malfunction, it can be extremely difficult to foresee and detect deliberate computer system mis-use or manipulation. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software, electronic storage media, or data cummunications infrastructure.

Comment by Mathew Goldstein (General Public)

I am an Information Technology Specialist with experience coding on all platforms from mainframes to desktops and web applications in many languages, including a voted preferential ballot ranking program I wrote in PERL. While the use of complicated software in electronic voting systems has substantial benefits, including promises of future benefits that have not yet been fully realized or fully implemented, it also introduces additional risks of malfunction and of accidental or deliberate corruption of the results that can be difficult to detect or diagnose and impossible to correct after the fact. Accordingly, software independence is an essential requirement to protect the integrity of the election process when counting votes in electronic voting systems.

Comment by Elizabeth Chesser (Voter)

I am a Florida resident and have so little faith in the integrity of the Florida voting system and those who control it that I always vote by absentee ballot. Tests of Diebold and Sequoia touch screen voting machines, performed on 12/13/05 in Leon County FL, demonstrated that the software could be hacked and votes changed without detection!! Can you imagine ATM machines without paper backup? In the unlikely -we're talking banks here - event that the bank's software fails and doesn't deduct your withdrawal from your account, you know you better not count on that windfall. Any programmable device has the potential to malfunction or be tampered with. Our votes must have the protection of an Independent Voter Verified paper Record!!

Comment by David Kirschner (Voter)

I have been involved in software design since the mid-1980s, and am well-aware of how easily software can possess programming flaws or accidental or deliberate corruption. The more complex a software system, the greater the likelihood of programming errors, and also the greater possibility of hiding "back doors" or triggerable alternate code paths which can alter the tally. The larger the code footprint on mass storage, the greater the likelihood of random corruption. Our voting system is too critical to be entrusted to totally electronic systems. We MUST provide some means of paper audit, and the best means is to use a paper ballot with unequivocal marking. Furthermore: Vendors' contentions that their software posseses "trade secrets" and therefore not open to code audit is WHOLLY UNACCEPTIBLE in a transparent voting process, and their insistence on this stipulation should disqualify their systems from use. If software is used in any stage of the voting process, there MUST be the means of an independent code audit, and ironclad assurance that the running code is identical to that which passed audit.

Comment by Katherine O'Sullivan (Voter)

Please ensure that whatever system is adopted is software independent. Any system that is not software independent cannot be relied upon to deliver untampered-with election results
2.5.3-B Implementation statement, device classes

For each distinct device included in the system, an implementation statement for a voting system SHALL identify:

  1. All applicable classes from Part 1 Section 2.5.3.2; and
  2. All applicable classes from Part 1 Section 2.5.3.3.

Test Reference: Part 3 Section 4.1, Requirement Part 3: 4.2-C

DISCUSSION

By definition, the class Voting device is applicable to every voting device.

Source: New requirement.

No Comments

No Comments
2.5.3-C Implementation statement, voting variations documentation references

For each of the voting variations identified per Requirement Part 1: 2.5.3-A and Requirement Part 1 :2.5.3-B, the implementation statement SHALL cite the specific section or sections of the Voting Equipment User Documentation where the use of that voting variations is documented.

Test Reference: Part 3 Section 4.1

DISCUSSION

Voting variations are enumerated in Part 1 Section 2.5.3.1"Supported voting variations (system-level)" and Part 1: 2.5.3.2 "Supported voting variations (device-level)".

Source: New requirement.

1 Comments

Comment by rodney schroeter (Academic)

Computer systems can malfuntion or be manipulated. Use paper ballots

2.5.3.1 Supported voting variations (system-level)

The classes enumerated in this section identify voting variations supported by the voting system. Although the intent of most is apparent from the applicable requirements, the following may require additional explanation.

Conformance to the Write-ins class indicates that the voting system is capable of end-to-end processing of write-in votes, including reconciliation of Write-ins (see Part I: Section 7.7.2.4 "Logic for reconciling write-in double votes") and generation of a final, consolidated report that includes individual tallies for all write-in candidates. If the voting system requires the allocation of write-in votes to specific candidates to be performed manually, then it does not satisfy Requirement Part 1: 6.2-A and therefore does not conform to the Write-ins class. However, it may conform to the Review-required ballots class (see below).

The same principle applies to the Absentee voting class and the Provisional-challenged ballots class. If the counting of these ballots is external to the voting system, then the system does not satisfy Requirement Part 1: 6.2-A therefore does not conform to the Absentee voting or Provisional-challenged ballots class, respectively.

Conformance to the Review-required ballots class indicates that the voting system is capable of flagging or separating ballots for later processing and including the results of that processing in the reported totals. If the consolidation of counts from Review-required ballots with counts from other ballots is external to the voting system, then the system does not satisfy Requirement Part 1: 7.8.3.3-I and therefore does not conform to the Review-required ballots class.

In some systems, write-in votes are counted as anonymous ballot positions, and these votes are assigned to candidates through manual post-processing only if the election is close enough to warrant the effort. Although this approach does not conform to the Write-ins class, the system's handling of write-in positions is identical to its handling of other ballot positions, so the behavior is testable.

Choose all that apply.

  • In-person voting
  • Absentee voting
  • Provisional-challenged ballots
  • Review-required ballots
  • Primary elections (subsumes Closed primaries and Open primaries)
  • Closed primaries
  • Open primaries
  • Write-ins
  • Ballot rotation
  • Straight party voting (subsumes Cross-party endorsement)
  • Cross-party endorsement
  • Split precincts
  • N-of-M voting
  • Cumulative voting
  • Ranked order voting

The class Voting system subsumes all of the above.

5 Comments

Comment by Brian V. Jarvis (Local Election Official)

In the 1st paragraph: - "variations" has an extra "s". - in the 2nd sentence, it is not clear what "the intent of most" is referring to?

Comment by ted selker (Academic)

With respect to the goals of the recommendations, no-excuse absentee voting is out of conformance with all security and integrity precautions.

Comment by Premier Election Solutions (Manufacturer)

The "Write-in Class" should be renamed to identify it for what it is, an Automated Write-in Class. It is inaccurate to imply that a paper based optical scan voting system cannot handle write-in votes just because the write-ins have to be manually reviewed. This class should be renamed for what it represents, which is an "Automated Write-in Class". Proposed Change: Change the name of the "Write-in Class" to "Automated Write-in Class".

Keith M. Corbett (General Public)

typo: "voting variationss"

Comment by J.Montana (None)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

2.5.3.2 Supported voting variations (device-level)

It is necessary to specify voting variationss at the device level as well as the system level because a system may support a given voting variations without having that support in every device. For example, a system may support Absentee voting by having absentee ballot support in one special tabulator and in the central EMS. However, for the most part, these should agree with the variations claimed at the system level.

Choose all that apply.

  • In-person voting device
  • Absentee voting device
  • Provisional-challenged ballots device
  • Review-required ballots device
  • Primary elections device (subsumes Closed primaries device and Open primaries device)
  • Closed primaries device
  • Open primaries device
  • Write-ins device
  • Ballot rotation device
  • Straight party voting device (subsumes Cross-party endorsement device)
  • Cross-party endorsement device
  • Split precincts device
  • N-of-M voting device
  • Cumulative voting device
  • Ranked order voting device

The class Voting device subsumes all of the above.

No Comments

No Comments

2.5.3.3 Voting device classes

The classes enumerated in this section identify different types of voting devices.

Choose all that apply.

  • audit device
  • electronic device (subsumes programmed device)
  • Vote-capture device (subsumes IVVR vote-capture device and VEBD)
  • paper-based device (subsumes MMPB, EBM and optical scanner)
  • programmed device (subsumes VEBD, tabulator, and activation device)
  • IVVR vote-capture device (subsumes MMPB, EBM, and VVPAT)
  • VEBD (Voter-Editable Ballot Device) (subsumes EBM, VEBD-A, VEBD-V and DRE)
  • tabulator (subsumes DRE, EMS, optical scanner, precinct tabulator and central tabulator)
  • activation device
  • MMPB (Manually-Marked Paper Ballot)
  • EBM (Electronically-assisted Ballot Marker) (subsumes EBP)
  • VEBD-A (Audio VEBD) (subsumes Acc-VS)
  • VEBD-V (Video VEBD) (subsumes Acc-VS)
  • DRE (Direct Record Electronic) (subsumes VVPAT)
  • EMS (Election Management System)
  • optical scanner (subsumes MCOS, ECOS, PCOS and CCOS)
  • precinct tabulator (subsumes PCOS)
  • central tabulator (subsumes CCOS)
  • EBP (Electronic Ballot Printer)
  • Acc-VS (accessible voting station)
  • VVPAT (Voter-Verifiable Paper Audit Trail)
  • MCOS (MMPB-Capable Optical Scanner)
  • ECOS (EMPB-Capable Optical Scanner)
  • PCOS (Precinct-count optical scanner)
  • CCOS (Central-count optical scanner)

The class Voting device subsumes all of the above. Only direct subsumptions are described above, but subsumption is transitive, so if X subsumes Y and Y subsumes Z, then X subsumes Z.

PCOS is implied if precinct tabulator and optical scanner are identified. CCOS is implied if central tabulator and optical scanner are identified.

6 Comments

Comment by Carolyn Coggins (Voting System Test Laboratory)

Why is there an MCOS and an ECOS? Optical scanners must read manually or electronically marked paper ballots. There are functions with regarding to reading manual and electronic marks but this is NOT a different piece of equipment. This approach is convoluted.

Comment by Frank Padilla (Voting System Test Laboratory)

Is there a difference in Optical Scanners that is testable and appreciable? MCOS v/s ECOS

Comment by J Goldner (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Dr. David B. Dunning (Voter)

Here in Oregon we vote by mail using paper ballots which are counted on ES&S optical scanners. All in all a pretty good system, but one which we are now improving by requiring random hand count auditing of the machine count. If there were time, a full hand count would be the most trustworthy system, but in place of that, a machine count of paper ballots with a fool proof system of onging (during the count!) random handcounts is acceptable! Anything less invites fraud!

Comment by Judy Gibbs (None)

Computers are all subject to hacking, and can be tampered with by anyone who is computer savy. Glitches and the like can do irrevocable damage making computers unsafe for voting purposes. We have already experience elections with major controversy over the system that was used. Let's not let that happen again. It makes us look so stupid as a country! None of us ever know who the real winner really is.

Comment by Skip Parrish (Federal Agency)

PCOS or Precinct level tabulators is more of a sales designation.. in the marke today there are No scanners that do 100% tabulation in the pricinct, but augment a collection process stage that is finalized by election night tabulation software such as GEMS, or UNITY. Recient research has disclosed "arithmetric functions" still present in summary and consludation functions of tabulation software used to form the "evidence" of elecitons for canvass boards. Total tabulation is NOT done at the pricinct level but a stage of it to be finalized by the "counting room or tabulation room" election night software. Mixed or "blended" systems such as DRE and Scanners must combine arithmetric functions at a common software source in this case GEMS or UNITY as example. Further base data used in the evidence of election report requires consoldation and further arithmetic functions to arrove at primary source data for evicence of the election. Many State laws reqiring observers are based on "the counting of the vote" or " tabulation " thus a correct difinition here will facilitate more open and transparent elections and thus voter confidence in the process.

2.5.4 Semantics of classes

A class simultaneously identifies a set of requirements and a set of voting systems or devices to which those requirements apply.

For a class C, let S(C) represent the set of voting systems or devices identified by C and let R(C) represent the set of requirements applicable to those voting systems or devices.

A subclass identifies a superset of the requirements and a subset of the voting systems or devices identified by its superclass. A voting system that conforms to a subclass necessarily conforms to its superclass. The superclass is said to subsume the subclass.

If class C1 subsumes C2, then

C sub 2 is a superset of C sub 1

(Meaning: The set of requirements applying to C2 is a superset of the set of requirements applying to C1.)

C sub 2 is a subset of C sub 1

(Meaning: The set of voting systems identified by C2 is a subset of the set of voting systems identified by C1.)

A class may have multiple superclasses. Let P(C) represent the set of superclasses of C. Then

C is superset of union of C’s superclasses

(Meaning: The set of requirements applying to C is a superset of the union of the sets of requirements applying to each of C's superclasses.)

C is subset of intersection of C’s superclasses

(Meaning:  The set of voting systems identified by C is a subset of the intersection of the sets of voting systems identified by each of C's superclasses.)

Given classes C3 and C4, one may derive a new subclass by combining C3 and C4. The combining operation on classes is represented with a wedge (Λ).

Class inheritance

(Meaning: The set of requirements applying to C3 Λ C4 is a superset of the union of the set of requirements applying to C3 and the set of requirements applying to C4.)

Class intersection

(Meaning: The set of voting systems identified by C3 Λ C4 is the intersection of the set of voting systems identified by C3 and the set of voting systems identified by C4.)

By default, this new subclass, C3 Λ C4, identifies the union of the requirements and the intersection of the voting systems or devices identified by C3 and C4. However, additional requirements that applied to neither superclass may apply specifically to the new subclass.

Part 1: Figure 2-3 shows an example in which a new subclass is derived from Acc-VS and VVPAT.

Figure 2-3 Device class formed by wedge (Λ)

image041

A class that is derived by combining classes that are disjoint is said to be incoherent and identifies no voting systems or devices. The set of requirements identified by an incoherent class is likely to be self-contradictory.

1 Comment

Comment by Diane Gray (Voting System Test Laboratory)

Suggest simplifying this chapter.

2.6 Extensions

Extensions are additional functions, features, and/or capabilities included in a voting system that are not defined in the VVSG. To accommodate the needs of states that may impose additional requirements and to accommodate changes in technology, these VVSG allow extensions. However, as extensions are essentially subclasses of one or more classes defined in these VVSG, they are subject to the integrity constraint that applies to all subclasses: an extension is not allowed to contradict or relax requirements that would otherwise apply to the system and its constituent devices.

1 Comment

Comment by Electronic Privacy Information Center (Advocacy Group)

2.6-B Extensions shall be reported to the EAC. Reports of extensions to voting systems shall include the following information: • Purpose of the extension(s) • What benefit is intended by the addition of the extension • Risks to the election environment that the extension might pose if any • Tests performed and their results • Reports on use of extension in election environments • Feedback from election administrators on their willingness to deploy extension in their election jurisdictions • Disclosure of all information regarding the applicability of the extension to 2007 VVSG standards Discussion: The topic of software and firmware upgrades may be efficiently dealt with in under this topic, but care should be taken to assure that it is not used when the change in question affects key voting system functions such as vote recording, tabulation, retention, and reporting. Application for extensions should be managed in such a way that limits the number and type that a single approved voting system can acquire without the system being subjected to a full standards review process.
2.6-A Extensions shall not break conformance

Extensions SHALL NOT contradict or relax requirements of these VVSG.

2 Comments

Comment by Linda Vitale (Voter)

In order to sustain the viability and integrity of every vote, by every voter, it is imperative to our Democracy that there be a way to verify each and every vote cast. ALL voting system software in America MUST be "software independent" in order to achieve that goal. We cannot have a truly Democratic voting process without being able to assure that all votes are accounted for. Human as well as software error has been a common malady is every election since we have changed from paper to electronic voting. Software Independence would circumvent any malicious or unintentional voter fraud.

Comment by Jill Godmilow (Academic)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. They are also subject to subtle errors. Voting systems must provide a means of recording and recovering voter intent that does not depend on the reliability of software.

2.7 Software Independence

This section contains requirements related to software independence. software independence means that an undetected error or fault in the voting system’s software is not capable of causing an undetectable change in election results. All voting systems must be software independent in order to conform to the VVSG. There are currently two methods specified in the VVSG for achieving software independence: 1) through the use of independent voter-verifiable records (IVVR) and 2) through the innovation class.

160 Comments

Comment by Stuart Venters (None)

The concept of software independence, that is making the election system immune to S/W bugs changing the results is fundamental to having trusted elections. (It also presumes hardware independence.) I have 2 areas of comment: First, the effort required by the election officials to detect a S/W induced change must be small enough so that a few random checks can be done routinely on each election. (Also, KISS is important in the audit process.) Second, it seems that there might be 3 ways to achieve software independence. 1) Provide an audit path independent of software (IVVR) 2) Come up with an architecture that's immune to bugs (innovation class) 3) Prove that there are no bugs in the software 2 and 3 are both long shots, but 3 seems likely to have better odds than 2. (The odds are long because it's really hard to know you have covered failure modes you haven't thought of.) A possible way to approach 3 would be to publish the software and put up a reward for bugs found. (Alas, this is in conflict with current voting machine vendor business practices.) With the current state of the art, I suspect 1 is the only way to have a trusted election. PS, You might add 'just and interested voter' to your list of affiliations.

Comment by Brian V. Jarvis (Local Election Official)

Regarding the definition of "software independence." Does this definition imply that a "known" error or fault in the voting system's software could be capable of causing an undetectable change in election results? Recommend modifying the definition to indicate that no error or fault in the voting system's software is capable of causing an undetectable change in election results.

Comment by ted selker (Academic)

"SHALL be software independent, that is, an undetected error or fault in the voting system's software SHALL NOT be capable of causing an undetectable change in election results." should be changed to: "SHALL be single agent independent, that is, an undetected error or fault in any one voting system's record SHALL NOT be capable of causing an undetectable change in election results."

Comment by Harry VanSickle (State Election Official)

This section defines software independence, but the guidelines need to further explain how software independence is possible. In that software independence is a core requirement of the guidelines, we are assuming that it is realistic. Please provide a more detailed explanation within the materials explaining how a voting system can take a vote from the user through software that is actually independent of the voting system.

Comment by Sean Freese (Voter)

As an IT professional, I am fully aware of how easily computer systems can malfunction or be tampered with by unscrupulous individuals. Furthermore, keeping ahead of glitches and security threats is often a goal rather than a reality. Therefore, with something as vitally important as an election, it's crucial that voting systems have some system of verification that is not reliant on software alone. Votes recorded must be recoverable no matter what may happen to the system for recording them after they have been cast.

Comment by Charlotte Joy Martin, Ph.D. (Academic)

Computer systems can manifest subtle errors, malfunction, or undergo deliberate corruption. Such eventualities can occur in so many possible ways as to be terribly hard to anticipate preventatively in all or even most cases. Electoral integrity depends upon a means of recording and recovering voter intent external to software.

Comment by Mallory Sanders (Voter)

There is only one reason and one reason alone why anyone would NOT want voter verifiable records and that is so that they can cheat the votes and the voters. We are done with stolen elections and if the so-called president tries to veto proper and rightful legislation you need to find out what he says his reasons are and then see to it that they are widely publicized. Because there is no good reason. Any accurate voting system must provide a means of recording and recovering voter intent that does not depend on the reliability of software. Do not align yourself with the criminal elements in the White House. History. Will. Out.

Comment by Barbara Trypaluk (Advocacy Group)

I am in favor of software independence. Since computer systems can malfunction or be deliberately tampered with, the methods used to detect problems cannot be left up to corporation-owned software. In order for the elections to be conducted fairly, the means of recording each vote cannot then depend solely on the reliability of the software.

Comment by Sally Harvey (Voter)

Votes should be verifiable without depending on the reliability of software.

Comment by Nancy Rudolph (Voter)

I believe that every device must be implemented so that we get truly verifiable voting results and therefore all voting systems must be software independent. The way we vote today with so many unpredictable variations definitely needs an independent system where irregularities are athought to exist. Every vote should count.. Please keep this software independence in place. Thank you. Nancy Rudolph voter in every election for the past 62 years.

Comment by Steve Dickman (Academic)

For election integrity, it is crucial that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The tried-and-true most reliable and honest solution is paper ballots / paper records!

Comment by Richard M. Gutierrez (General Public)

Reliance on software solely to acurately calculate votes is dangerous and foolish. The confidentiality and integrity of the voting system will be at risk unless a backup system is utilized to offset hackers and potential viruses that imperil software programs.

Comment by Bruce Hawkins (Academic)

As a physicist and computer professional for over 40 years, I am all too aware of how easily software systems may be corrupted and yield unintended results. We must be wary of coding errors as well as intentional fraud.

Comment by Dean E. Sizemore (Voter)

Although a completely paperless voting system sounds good in theory, it is not without its flaws. Voting is too important an issue to relegate to a system that has already proven to alter election outcomes in the past. Until we find a way to ensure that a paperless voting system will deliver an accurate outcome, we need to maintain a paper trail system that can verify election results in the event of a questionable ballot issue.

Comment by Eric Ramstad (Voter)

Software can be corrupted or malfuntion in ways that are scarcly detectable, endangering our election results. We must have software independent means to verify election outcomes, such as paper copies.

Comment by jeff hannigan (General Public)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Alisa Beaton (Academic)

Independence from electronic software is absolutely necessesary for the establishment of an auditable voting system. This can only be accomplished through the utilization of voter-marked paper ballots. The federal guidelines being proposed do not require, explicitly, the use of paper ballots. I believe the federal guidelines need to be changed to include such a requirement, and that all states be required to follow the guidelines.

Comment by George Harvey (Academic)

Software independence is essential for: 1. Accuracy of voting records. 2. Preventing manipulation by politicians and corporations. 3. Prevention of interference from foreign agents. 4. Eliminating prolonged disagreements between dissatisfied voters and record-keepers.

Comment by Christopher Patry (Voter)

Computer software is NOT reliable on a consistent basis. It is also easily manipulated. I have been using computer software for 30 years and I am well aware of its vagaries. If people are to have confidence in the voting systems in this country, it is absolutely imperative that we not rely on software independence. I oppose any attempt at corrupting the political process with voting software that is not independently verifiable with a paper trail of voter intent. I intend on making this same comment to my Congressional Representatives.

Comment by John Q. Murray (General Public)

My B.S. is in Computer Science, I have 20 years experience as a software engineer, I own a rural weekly community newspaper, and I am currently in graduate school seeking a Master of Public Administration degree. I am very familiar with software systems, with our election processes, and I am very concerned about the future of our republic. That is why I am writing to urge support for software independence through use of independent voter-verifiable records (IVVR). As an American, I believe that competition breeds innovation. Adoption of IVVR will enable measurement and comparison of different software systems. I strongly urge support for software independence as a way of supporting competition and enabling innovation that will improve speed, improve accuracy, and reduce cost.

Comment by Barbara Schultz (General Public)

We have seen so much evidence over the last few election cycles that electronic voting systems that do not involve a paper copy or voter-marked paper ballots can, first of all, easily be hacked and tampered with. They are also, like all computer systems, prone to error. We have seen the votes for one candidate transferred to his/her opponent. We have seen votes simply disappear. We have seen more votes cast than there are voters, and vice-versa. We have seen whole communities cast ballots, somehow managing to vote for every position but president. We are approaching another national election. We must have confidence that our votes will be counted accurately. We must believe in the outcome of our elections, or why have them?

Comment by Ella Lasky (Voter)

It is important to have a paper backup of electronic voting because all software can make mistakes. thank you

Comment by Dona R. Wildove (Voter)

The voting machines should have a paper ballot for voter verification.

Comment by Cynthia Hilts (Voter)

Since software programs are imperfect, and also subject to hacking or built-in corruptions, each vote should be recorded also on paper, so that audits and recounts are feasible and independent of any software problems that may arise.

Comment by Lois Mason (Voter)

My comments posted with 2.7-A should actually be posted here. Software independence MUST be a requirement for any election reform. Voter trust is essential for the strength of our democracy.

Comment by Ellen Parker (Academic)

I am concerned about software independence due to the possibility of malfunction of software. Therefore it is necessary that there be a paper record and trail of voting.

Comment by Sue Avedon (Voter)

I am writing to encourage the use of software independent voting systems. We must ensure that computer errors do not influence election results.

Comment by Teresa Moler (Local Election Official)

Voters have made comments that they are not confident that their vote is being counted by the machine. Software is not reliable and humans make mistakes when it comes to software and outside influences may also be a factor. It is important to have visible evidence of a person's vote. Having it on the machine, is not enough. Election officials and voters are not software engineers generally.

Comment by dori ahern (Voter)

the same companies that make computerized voting machines have designed banking machines. How could it be that we can get a receipt of our banking transactions and not for one of the most important guarantees of our democracy? NO MACHINE SHOULD BE AUTHORIZED TO RECORD OUR PRECIOUS VOTE UNLESS IT IS A COUNTING MACHINE THAT WE INPUT OUR PAPER BALLOTS INTO, OR A COMPUTERIZED SYSTEM THAT VERIFIES AND RECORDS OUR INTENT ON PAPER - INDEPENDENT OF THE SOFTWARE! THIS IS A NO BRAINER.

Comment by Paul E Slowick (Voter)

While technology is wonderful in this day and age and makes many tasks extremely efficient and less expensive, voting is a function that should not be totally given over to technology and automation. Paper verifiable ballots are still neccessary to ensure a safe, proper and verifiable voting process. There are too many ways that a totally electronic voting system can be made unreliable and subject to fraud and tampering. A paper back-up is needed also for ballot verification. When modern, electronic computers first appeared on the world scene, they were unreliable and subject to "crashing" and un-authorized use. After 40 or 50 years computers are STILL subject to the same ills. We have not come that far yet where computer systems are safe and reliable. Someone must recognize this where our voting systems are concerned also and protect them. Back-up, back-up, back-up is a common phrase in the computer world. Let's use that phrase with voting systems and back-up the process with paper, too!

Comment by Aimee Schmidt (Voter)

As an experienced software quality assurance engineer I know how easy it would be to program a routine that would alter the vote as cast yet print, either on screen or on paper, the selection as cast. I have not seen a protocol within this document that addresses this fundamental vulnerability. Software errors and system malfunctions certainly shouldn't alter the vote as cast, which is addressed here, but as I read the language there is no "chain of custody" to prevent either a hacker or the code's developer from altering the code AFTER it's audit/inspection and BEFORE its use in voting machines. The voting tally machine must also be off the network so that viruses cannot be introduced that can alter the votes between the time the verification printout is received by the voter and total votes are tallied on a central computer. Encryption may be able to prevent this if the data must be transmitted across the wire.

Comment by Sarah Staats (General Public)

A democracy unable to count its citezens' votes correctly is not a democracy. All software is vulnerable. Thus there must be reliable backups, so that verifiable recounts can be performed. "Trust me" is not accdeptable!

Comment by Pete Weaver (General Public)

IVVR's are the only acceptable alternative. Every vote must have a paper trail backup for verification. Software is unreliable and subject to manipulation and fraud. The only way our elections can be protected from this threat is accurate paper records.

Comment by Bena Silber (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Dorene Carrel (Voter)

I favor software independence for any new voter legislation. Voter intent should not be tied into the reliability of software. Software is subject to breakdowns and corruption. Allow voter intent to be evaluated separately.

Comment by Sabra Hoffman (Voter)

At the Ashland, Oregon, Independent Film Festival, I watched UNCOUNTED, a documentary citing numerous failures of local US voting systems in the past eight years. Among the most shocking and flagrant was vote flipping due to deliberate tampering with computers. Such violations of our democracy wouldn't be possible with a paper print-out to validate the computer tally. I am 65 years old and I've never been more cynical about the proper functioning of our democracy. Can you imagine the deterioration of patriotism if large segments of our society come to believe they are being disenfranchised?

Comment by Jennifer Hale (Voter)

ALL computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Keep a paper record! We have all at one time or another learned the importance of backing up data - and when it comes to recording data, nothing beats a hard copy. The voters of America deserve it. Keep a paper record! Thank you!

Comment by Jesse Crane-Seeber (Voter)

I applaud the effort to ensure an IVVR voting requirement. The security of our elections in the age of cyber terrorism and blatant corporate corruption is imperative. I remain concerned that 'innovative' systems may try to work around some type of physical paper trail. No software system is 100% secure or free of errors and flaws, so ensuring that every single American voter can verify that their vote was correctly registered is essential. Please ensure that every vote leaves behind the type of physical evidence necessary to detect and correct software error, vote fraud, or cyber attack.

Comment by Dr. Andy Johnson (Academic)

All electronic devices can be compromised, corrupted, and/or repurposed. We can't always tell whether someone has manipulated software. Worse, there are many opportunities for this to happen. Therefore it is critically important that software independence must include a voter-verifiable paper record that survives the voting process and is available for auditing.

Comment by Dessa Kaye (Voter)

I have been voting on a paper ballot all of my adult life. There is nothing so difficult about our elections that we need to use electronic voting machines. They are so notoriously unreliable that they require a voter-verified paper trail so why not just use a tried-and-true paper ballot to begin with? This will also create an IVVR free from power/software/technology falures and incompatible formats and which can easily support hand audits.

Comment by Mary Alice Scully (Voter)

Voting is important to all of us..the fiasco of '02 and the skepticism of '04 elections suggests that anything which will give voters confidence that the system is safe will go a long way toward deepening voters belief in the process.....Having a paper trail for the votes that is cheat-proof is one way to reassure all of us that if necessary, the votes can be counted "the old-fashioned way"... There are many goals here....making voting computer-easy and swift is only one of them....convincing the public that the elections are not stolen is another...and even more important.... Please give us a voting process we can trust...

Comment by Software Independance (Voter)

The fact that this isn't a no-brainer shows ignorance an the part of legislators toward the follies that computer programmers like myself know all too well. Without verifyable paper voter records to verify the intent of the voter, which the voters can even see themselves, then we do not have a democratic election system. What we have without paper records is a Wizard of Oz scam on the American people with our elections opened wide for the kind of election theft that creates volumns of documented examples in every election since these election stealing contraptions were introduced. The fact that our democracy is a for-show scam and not a legitamate democracy is the real reason for voter apathy in America.

Comment by Misha Cohen (Academic)

It seems obvious (as this description of proposed legislation says) that the elections system must be as simple as possible and kept as un-corruptible by human purposeful tampering as well as by inadvertent computer error. To this end, I do think that independence from software to tally election results is a crucial part of this process. If we do have software-dependent methods we must also have non-software methods of tallying results that work in parallel (i.e. simply have two methods that back each other up in case of error on the software side). It is ridiculous that the public should need to comment on this process at all. Tallying election results is basic democratic-necessity stuff. It seems, again, obvious that we should have the simplest, most fool-proof system we can develop. This seems to me to be an optical scanner system.

Comment by Mary Agee (Voter)

Because computer systems are subject to subtle errors, malfunctions, and deliberate corruption, I urge you to provide a means of recording and recovering voter intent that does NOT depend on the reliability of software. There are currently 2 methods specified that will achieve software indenpendence: 1) through the use of independent voter-verifiable records (IVVR) and 2) through the innovation class. Thank you for taking comments on this issue that it critical to the viability of our democracy. Sincerely, Mary Agee

Comment by Steve Sears (General Public)

Computers are subject to errors. They can malfunction or be corrupted at anytime during their design, manufacture, and use. These methods can be extremely difficult to discover. So, it is crucial to the integrity of elections that voting systems provide for recording and recovering voter intent that does not depend on the reliability of these machines and their software.

Comment by Jonas Woolverton (Voter)

Electronic voting has been demonstrated can be corrupted too easily and should be phased out by 2012. The only instance where I can see electronic voting used is in instances where the voter has a physical disability that would be assisted by a touch screen. But even in those instances, every single computer should print out a paper receipt or punch card that can then be dropped off into a ballot box. The Federal goverment needs to regulate voting in this country so that the voting machines are uniform from city to city, state to state.

Comment by steve marvin (Local Election Official)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Lou A. Roberts (Voter)

It is absolutely essential for the continued health of our democracy that the voting system be secure. This means that software errors or glitches, wherever or whenever they occur, must not affect the integrity of my vote or that af any other. There is perhaps nothing in our system that is more important than an independent and secure vote. The vote must be clear independent of the software system. I think a voter verified paper ballot accomplishes this in the best possible way.

Comment by Guy Hathaway (Voter)

I do not trust any computer-driven machine to count my vote, regardless of what "Class" you put it in. I worked for IBM in the US, Europe and Canada for thirty three years. I know exactly how easy it is for any computer to err, and for any computer program to yield a desired result regardless of input. There is no technical reason that the counting of voter-marked paper ballots cannot be handled by voters at the precinct in a matter of hours. There is every legal reason for this to be the only method used to verify election results: the votes do not belong to the government. Votes belong to the citizens who are provided by the Constitution the right to select (employ) government representatives (employees). The hope that we will accept being told (not asked) to trust that our votes will be counted as we cast them, and attributed to the candidates of our choice, is no longer a rational expectation for anyone who has had any part in the HAVA debacle. The vote is the last fragile leverage with which US citizens can affect who actually controls the many levels of government. The EAC is a hugely successful attempt to break that linkage by eliminating voter confidence in the very system foisted on us by people who know everything about writing obfuscatory law and nothing about the technologies they have attempted to force us to purchase for use against our own interests. Its members should apologize, come clean about the motives of those who installed them, and do all they can to educate the voting public as to the reason why every registered voter's franchise is exactly as valuable as that of every other registered voter. The next skewed election will light fuses no amount of official blather or deceit can extinguish. It is not too late to turn away from the disaster of a "unitary executive" dictatorship. Clean up elections, and we will do the rest.

Comment by Robert D. Klauber, PhD (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Dr Louis G Puls (Advocacy Group)

There is NO reliable software independence possible if the software is proprietary and closed. Any software used in a public voting system must be OPEN software, unrestricted by ANY trade secrets, available to all, and subject to independent expert analysis and testing, followed by fully responsive modification under fully open procedures. Anything else is smoke and mirrors, vulnerable to a wide array of error, lack of upgrades and patches, and outright hacking and fraud.

Comment by Leigh A. Young (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Of course the companies that own the software and voting machines will not want to abide by this new rule; they will probably say and do everything possible in order to protect the status quo, but most American voters know that this software has been tampered with in the past and will continue to be in the future if there are no safeguards put in place to prevent this from occuring again in future elections. We DESERVE better checks and balances to insure that our votes are counted correctly. Thank you very much for the opportunity to comment on this crucial subject.

Comment by Jon Slenk (General Public)

I'm a computer software professional (B.S. Math/Computer Science 1992, been working ever since) who has worked on a range of systems, both software and hardware. I know not only through theory but also extensive personal experience that all computer systems are subject to errors, from the obvious to the most subtle and hard to find. It is therefore of the utmost importance that election and voting systems provide a record/paper-trail of voter intent that explicitly does not depend on the reliability of computer systems.

Comment by j e (Academic)

All computer systems are subject to errors; some may be obvious but the majority are likely to be subtle. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, voting systems absolutely *must* provide a means of recording and recovering voter intent that does not depend on the reliability of software. This is a zero-order issues that is crucial to the integrity of elections.

Comment by Alice Lovely (Voter)

I am very concerned about my vote ( and others') being counted and awailable for a recount if needed. For that reason I feel strongly that there must be a verifiable paper ballot for everyone's vote. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Thank you.

Comment by Thomas Hicks (General Public)

Masters Degree in Computer Science. Having developed software for over 30 years, I know that it is impossible to remove all defects from any piece of software. In addition, software is especially subject to corruption, either accidentally or deliberately. For these reasons 1) independent, open software review is a standard best practice in the software industry and 2) it is crucial that voting systems provide an independent means of recording and verifying voter intent that does rely on software.

Comment by Jean Braun (General Public)

"The electronic voting machine shall produce a paper record with a manual audit capacity." - HAVA (Help America Vote Act) - Section 301(a)(2)(B)(i) Because the essential "paper trail" has already been provided in HAVA, an essential task of the Elections Assistance Commission must be to recover tax monies from Boards of Elections which are out of compliance with HAVA by the purchase of DREs which do not have the paper record with a manual audity capacity or are otherwise defective.

Comment by Christine Rossi (Academic)

I spend a good deal of my work time on computers and know how unreliable and easily manipulated they can be.It is vital to voting integrity that we have a means of tallying votes that is independent of computer software.

Comment by Elizabeth V. Millard (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Elizabeth V. Millard 2012 Valle Rio Santa Fe, NM 87505

Comment by Dr. Paul A. Curto (General Public)

No alteration of the software used to compile or reconcile election results should be allowed to be active unless it is traceable to the actual data, lines of code, time and place of alteration or correction, name of person approving the alteration, and name of the person or persons carrying out the changes or corrections. Rationale: If the changes are not traceable, neither will be the results.

Comment by Daphne Webb (Advocacy Group)

Independent Software shall not have hidden codes that can alter the results of an election. Seriously? Do we even have to have that comment made? How is it that we've been voting on machines that allow such an atrocity. If the HAVA act was about helping people vote, it's not working. It has been proven beyond a shadow of a doubt that a voter verified paper trail is critically important to the accuracy of our elections. The Software used to register voters should also be simplified and be made to be more accurate. Election commissions are bogged down and burdened with all of the voter requirement changes that are happening weekly. FIX THE ELECTIONS~!

Comment by Elizabeth Constable (Local Election Official)

Software Independence is an integral part of making sure that ballots are counted fairly. Without a paper trail (such a voter verification slip or voter-marked ballot) there would be no way to physically go back to the ballots in the event of a problem. It is not too hard to imagine a situation in which a voting machine would freeze (as all computers are known to do), and lose at least some of the votes it had tabulated. Rather than get into the mess of requiring a re-vote, which would be difficult in any case, it is much better to safeguard votes by maintaining a paper component in the voting process. Software independence must be included in these standards.

Comment by Joan Brunwasser (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. In point of fact, because of the tremendous amount of evidence that the machines are inaccurate, insecure, extremely expensive, and the process can't be observed by citizen/voters, I would advise junking the whole system and going back to paper ballots, hand counted at the precinct level on election day, in front of citizen observers, with results posted at the precinct and verified totals in the aggregate (counting provisional ballots and absentees) before the media is allowed to announce a winner. Without a strict chain of custody and transparency in the process, there is no reason to trust that our votes are being counted as cast, or counted at all, for that matter. That is the real reason - the fact that the voter is asked to 'trust' election officials, voting machine vendors, poll workers, vendors' technicians - to confirm the validity of the elections. That is not what was intended by our nation's founders. Vote in private, count the votes in public. That is the only way to keep all the parties honest and to give well-deserved confidence to the voters as to the integrity of our elections. Thank you for your time. Joan Brunwasser, Voting Integrity Editor, OpEdNews.com

Comment by Lois Peterson (Voter)

Please ensure that there is software independance for voting machines. I am a software tester and I KNOW that ALL software goes out with defects. Try as we might, we cannot anticipate all the problems that may occur with software use. There MUST be a PAPER trail in case of malfunction of the software and/or the machines. This is crucial to verify the accurate results of a vote count!!

Comment by Janet Goldner (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Russell Stein (Voter)

While it may be possible in the future for electronic voting machine makers to convince the Commission and/or local election officials that they have achieved software independence by the deveopment and implementation of one or more new technologies, it is extremely unlikely that they will be able to convince me and other voters of that milestone. Voters want to mark a real ballot (rather than a computer screen); they want to hold a card or piece of paper in their hand after they vote confirming that their vote has been recorded correctly (even if they have to leave it behind when they exit the polling place; and they want all recounts that are held to be based at least in part on the tallying of such voter-verified paper or cards. None of this can be achieved by software programming, no matter how complex or sophisticated. Therefore, I urge the Commission to amend this Chapter to require IVVR in all cases -- at least for the forseeable future. Thank you, Russell Stein Cocoa, Florida

Comment by Dona Morford (Voter)

If any voting is to be done with any kind of computerized method, there must be a form of trackable back-up. A number of things could happen that could effect the turnout of votes if not using another hard copy format to back it up. This includes computer crashing, computer hackers, electricity failures, user error (accidentally pressing the wrong button or clicking on someone they didn't want to).

Comment by Laurel Lambert Schmidt (General Public)

We desperately need a paper trail. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Matthew Rammelkamp (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Nancy Dobson (Voter)

Without a fair vote count America does not have a democracy. If legislators do not support software independence it is because they do not want America to have a democracy. It would certainly increase citizen confidence in their government if software independence is supported.

Comment by Colleen McLean (General Public)

Good Evening. I believe that in order for people to have any faith in any voting system, it is imperative that there be some standard measure enacted that provides a way of recording, and being able to confirm voter intent. Software and voting systems, as has been well documented, are subject to 'glitches' that lose votes, miscalculate votes, and produce 'phantom votes'. Obviously, there has been no method provided to detect malignant software. I have to say, the insecurity, and lack of accountability for the erosion of our ability to cast a ballot in this country is appalling, and inexcusable. Sincerely, Colleen McLean

Comment by Oliver Yourke (General Public)

As a user of computers in my daily work, I can tell you that they are subject to errors. They are also subject to accidental corruption as well as deliberate misdeed (as with a virus). Sometimes, it can be near impossible to detect and correct such problems. The outcome of elections is too important to our democratic government process to risk on the vagaries of software.

Comment by Kenneth Walton (Academic)

Computer systems are inherently prone to errors and can malfunction or can be deliberately corrupted at any stage of their design, their manufacture, and their use. The deliberate methods used to alter results can be almost impossible to detect. Therefore, it is absolutely critical to election integrity that all voting systems provide a way to record and recover voter intent that does not depend on the reliability of software. This may be the single most important aspect of maintaining voter integrity!

Comment by Ethan Gold (Voter)

Software independence is ESSENTIAL for the voting guidelines. If voting systems are software-only-based, in the event of problems there is no way to verify voter intent. This is the essence of accuracy in vote-counting, and thus the essence of democracy itself.

Comment by William T Kilgore (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. A a software systems professional, I know the problems that can affect software systems, and I have no confidence in a voting system where results cannot be verified independent of the system.

Comment by Sandra Carr (General Public)

I feel that software shouldn't be used as a means for voting. The process may be faster but there may be an error in the software.

Comment by Zack Smith (Voter)

Come on guys, you and I know proprietary software can have code written to falsely attribute a vote towards the non intended candidate. Only a voter verified paper trail, auditable by the voter before the vote is tallied and able to be successfully used in a recount is the answer. Anything less is a SCAM on your part. We know it and you know it. After the fiascos of 2000 and 2004 we will not let you cheat us of our vote anymore. We still have the capacity to overthrow the government if it fails to heed the consent and wishes of the governed. This is our right and our duty. Read the Declaration Of Independence.

Comment by Katherine Forrest, MD (Advocacy Group)

The Commonweal Institute, the organization of which I am president, has been involved with election security issues for over five years at the local, state, and Federal levels. Based on our knowledge and practical experience, I believe it is critically important to have every vote represented in an independent, durable, voter-verifiable form independent of electronic devices. I urge you to include software independence in the EAC guidelines for voting technology.

Comment by Alexandra Self (General Public)

I am completely in favor of voter marked paper ballots and it must be soft-ware independent. We have had enough voting machine chicanery and stolen elections. Now we MUST have an independent verifyer attest to the soft-ware being independent of any political party or people up to no good.

Comment by Dr. Janis S. Taylor (General Public)

All software is subject to bugs and unforseen problems. Only independently verifiable voter results through a paper trail can insure that we the voters get our inalienable right of a voice in this democracy. Ensure veribiable votes for all.

Comment by Gerald R. Harp, Ph.D. (Academic)

There is a mathematical THEOREM (due to Turing) which states that no piece of complex software can ever be fully tested and shown to be without flaw (because it is impossible to test every possible response to input data in a finite amount of time). Hence we should never trust software without independent verification.

Comment by Gale Tichenor (Voter)

Computer software is notoriously unreliable and prone to hacking and virus attacks. Voting systems should have a means to verify votes such as paper records or voter-marked paper ballots This is crucial to the integrity of our election system.

Comment by Tony Livaudais (Voter)

"All computer systems can be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Anne Hilts (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software Anne

Comment by George W. O'Connor (Voter)

While I understand that the electronic world has created many jobs to lobby their products and to manufacture and support their gadgets, I believe that a simple paper and pencil/pen ballot is more than adequate for every election I know of (from President to local dog catcher). The time between the casting of ballots and the related oath-taking ceremonies is long enough that the process of counting ballots does not have to be concluded in a matter of moments. The idea that we must know who has won each election before we go to bed is senseless. I recognize that the mass media creates the excitement and the suspense of our electoral process but the speed of vote counting serves only their needs to generate advertising revenue. In this current time period, we are taking well over a year to decide who will represent the major parties for the highest national office. Let us carefully mark our ballots, fold them and drop them in the box and then conduct the task of counting. It will save every community vast amounts of money. Pencils and paper are not expense and have served us well since voting in this country began.

Comment by Daniel Ilie (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Bill and Jan Tache (Voter)

We want to return to paper voting systems, like what California has done. All computer systems are corruptible. Several of the machine systems currently in use have been hacked quite easily. THIS SITUATION IS TOTALLY UNACCEPTABLE! Further, the software systems codes etc. are property of the corporations and not known to the state officials. There is no place for this kind of secrecy in the area of voting. AND REALLY THERE IS NO NEED! There must ALWAYS be a detailed paper trail. Even the supermarkets or ATM machines give paper trails. The public would scream if there were no print-out of what we buy in stores. THERE IS NO GOOD REASON TO SETTLE FOR LESS IN VOTING. OUR DEMOCRACY DEPENDS ON COMPLETELY TRANSPARENT ELECTIONS. OUR CONSTITUTION DEMANDS IT. PLEASE PROTECT OUR DEMOCRACY! THANK YOU. Bill and Jan Tache

Comment by Lori A. Clarke (Academic)

As an expert in software verification, I can assure you that there is no way to guarantee that a software system will always behave correctly. When testing such systems it is impossible to consider all the cases that could lead to an inaccurate count. Using formal analysis techniques, we can sometimes verify important properties about a system, but there is no way to know if we have considered all the important properties. It is not surprising that commercial systems usually have defects and that security breaches often occur. Thus, for something as important an an election, it is necessary to have an independent means of evaluating the results. We expect an itemized printout when we checkout from the supermarket. Certainly the validity of an election is more important than the cost of our groceries. Lori A. Clarke Department of Computer Science University of Massachusetts, Amherst

Comment by Andrew Leone (Voter)

Voting systems must provide a means of recording and recovering voter intent that does not depend on the reliability of software because all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect.

Comment by Dave Nelson (Voter)

Any computer system can be hacked. And if a particular can't be hacked today, it will be tomorrow. And being hacked, the election would be rigged. We all know this. If you don't believe it's possible you are living in a fantasy world. Since it appears that we MUST HAVE THOSE ELECTION RESULTS PRONTO, we're going to be using computers. But we must have a paper trail to back it up in order to protect the voting process. Period. People who are incapable of understanding this perhaps shouldn't be allowed to vote. Hmm... What we should really do is have all elections use ONLY paper, and the voter would have to make marks on paper, and those pieces of paper would be counted by hand by multiple people and it would take one or two weeks to get it done. So what? At least we'd all know for sure the results. There's always a lame duck period anyway. And Hallmark could make a holiday out of it and we'd all send cards to each other wishing our rival candidates the best of luck during Counting Week. Or something...

Comment by Rosalie Fontana (Voter)

I will only have confidence in an electronic voting system if there is a voter verifiable paper trail. I get a receipt when I pump gas at a gas station, why can't I get one when I vote. Rosalie Fontana Bloomingdale, NY 12913

Comment by Andrew Russell (Voter)

Please keep electronic voting independent. It is important that software be able to independently checked to make sure there were no errors.

Comment by Dean A Keesey (Voter)

As a software engineer I KNOW how easy it can be for engineers to create 'back doors' in order to rig a system. Our democracy relies on systems which INCLUDE, but are NOT LIMITED TO SOFTWARE. The system must be engineered to withstand assaults to election integrity by those that would promise to deliver an particular outcome to a candidate, as the PRESIDENT OF DIEBOLD PROMISED A VICTORY TO CANDIDATE BUSH. I have seen documentary footage of a software engineer who worked for Diebold's president where that engineer stated publicly that he was asked to design a system where the outcome could be rigged from the inside. The System for counting votes should have integrity even when the software fails, either by malicious OR non-malicious intent. That means the System for counting votes should have an auditable paper trail.

Comment by m. tischler (Voter)

you must have paper back-up. not to do so invites fraudulent tampering, which will steal the popular voice.

Comment by robert k gilland (General Public)

With the importance of the up coming election all measures should be taken to certify insure the correct counting of the votes. Verification is the most important step in achieving this

Comment by Jubal Molitor (Academic)

Software Independence is essential, because without it the programmer or programmers are given power above and beyond all three branches of government and the national electorate to effect election results. Guarding against the abuse of civil rights through emerging technologies is, and will remain one of the great challenges of the twenty first century, of which this measure is a cornerstone.

Comment by Jon Bailey (Voter)

EAC, I appreciate what you've done in spelling out the requirements for voting machine hardware and software. I hope you agree we are still far from real accountability, and the manufacturers have been incredibly belligerent in their responses to even the most basic concerns. Many of the machines still have gaping security holes and no clear method for verifying THEIR vote count. This is really outrageous. The consequences of errant or intentionally manipulated results can change the course of history, and their is ample evidence it has occurred already. We have to require a checking method that doesn't rely on the integrity of THEIR software, which is easily corrupted at every stage of the voting process. Please require a printed record of every vote cast (not totals!). Thank you for offering this platform to express our concerns, EAC.

Comment by Judy Schwartz (Voter)

It is VITAL that the our new voting machines be software independent. The use of computer machines are not foolproof, do not always have a paper trail and will cause unbelievable problems that will discourage voters from one of their most important rights. Again, I cannot stress strongly enough that our machines MUST BE software independent.

Comment by charles edwards (Academic)

"We all know that computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be corrupted deliberately at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Jennifer Hamilton (Voter)

Given how imperfect computer softwear can be and how easy errors and manipulation can happen, as a voter I feel it is crucial to the protection and improvement of our voting system that an independant way of recording and recovering voter intent, independant of softwear, is essential.

Comment by Lorraine Kitman-Trimmer (Voter)

It is no secret that ALL computer systems are subject to errors. Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is CRUCIAL to the INTEGRITY of ELECTIONS that voting systems provide a means of recording and recovering VOTER INTENT that DOES NOT DEPEND on the RELIABILITY of SOFTWARE.

Comment by joyce Herman (General Public)

We have seen that it is too easy for software problems, either spontaneously or human initiated, to compromise the integrity of the vote. We need to have verifiable non-software methods, in order to be certain of reliability.

Comment by M. Johanna Rickl (Voter)

As a voter I want my vote counted as I voted. Computers are so subject to error (and hacking) that it is crucial to have another system of verification. Please keep in place a system independent of the computer in order to do justice as well as increase voter confidence. The worst thing for a democracy is for citizens to feel that their vote doesn't get counted or is subject to manipulation.

Comment by Carol Cox (Voter)

Voting systems must provide a means of recording votes. It has been established that computer systems can malfunction and also be manipulated to perform a certain way. Software has been designed that cannot foresee or detect such errors. Therefore, I am very opposed to using computers for voting in the USA. A reliable paper trail is essential to uphold the integrity of every vote, which is what democracy is all about!

Comment by Pamela Hall (Voter)

Software is subject to bugs and corruption. We need verifiable voting that is independent of corporate software, such as paper ballots

Comment by Andi Weiss Bartczak (Voter)

From experience I know that software systems are so complicated that there are always errors in how they run. I am very suspicious of any voting machine that contains software programs. As a voter I demand that 1)the program be simple and easy to spot errors in 2)that voting machines don't and can't connect to central systems, which would make them vulnerable in other ways to being hacked 3) have permanent records for recounting 4) are user-friendly for the many people who never use a computer

Comment by Nancy Rutenber (Voter)

Computer software can have slight errors, computer systems can malfunction or be courupted by someone's design. These can be difficult to find. Therefore, voting systems need to always have an independent check which does not rely solely on the realiability of softwared.

Comment by Robert W Burks (Voter)

Due to the ability to manipulate voting results in electronic voting machines today it is imperative that some form of 'paper trail' be implemented independently of the voting device itself to ensure that all votes have been recorded correctly. Failure to do this will corrupt the voting process and will not acurately show voter preference for a particular candidate as was done in both the 2000 and 2004 elections.

Comment by Padawer, Miriam E. (Voter)

DREs are not acceptable until thoroughly tested by independent experts. Entire software program Shall be made public before acceptance ofthe machines, long enough in advance to let independent computer experts test the system for resilience against hacking and other shenanigans. We've had too much trouble with elections already! Voting is central to our free democratic philosophy. It can not be compromised again. EVER! I thank the commission for protecting our essential voting rights. Your efforts are super important.

Comment by Dr. Wayne Sygman (Voter)

What is the PURPOSE of voting in a true democracy? This answer is an obvious one. This purpose, and literally the whole reason d'etre of a democracy, is completely undermined if the voting procedure is suspect. There MUST be Software Independence. Otherwise, one is in support of a Fascist Plutocracy. There is no middle road path, here.

Comment by Nick Polimeni (General Public)

As a software developer and Database developer I understand that computer counting can be flawless, unless tampered in some way by access to the database through unauthorized entry, or other means. Any voting and counting machine, particularly where the source code is to be proprietary of a single company, must produce a physical record of what the voter selected. The voter in turn, must verify that the printout conforms with his choices. This card, then, must be readable by any number of different readers, whether bar code reader, punch hole reader, etc. So counts can be visually confirmed on spot check by any other third party with counting equipment. It further preposterous that counting software should be proprietary, since voting is a public function, and code must be verified by third parties to be accurate and can produce accurate counts. The public pretty much believed that the Diabold machines used in the last elections were sabotaged, and electronic information was deliberately lost or altered . . . There are many ways of doing this sort of thing, and to not programmer, this can be invisible and demonstration results can appear accurate, but can in the end be flawed. Bottom line is that NO ONE single company can own all the components of a voting system, and any one of them responsible for the actual voting record should produce a card that can be confirmed by the voter, and counted by third parties, and many cards must be confirmed as accurate by sampling checking against the paper record. If there are errors between what a computer reads, and what the card said, the entire group of cards must be counted manually. Counting by computer is too simple to suggest that an error is "unintentional."

Comment by Nick Fankhauser (Local Election Official)

I am president of the Union County Election Board in Indiana. I have chaired 3 recount commissions. I am also a computer professional with 21 years of experience supporting local government systems. This it the most important and sensible addition I have seen in this document. It is simply not possible to devise a system that cannot be compromised if it is not based on a record that the voter verifies and that a recount commission can read without the aid of computer equipment. If you do nothing else, keep this provision.

Comment by Melissa McCullough (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Voters want a paper trail, not a digital one. Thank you.

Comment by Sue Singer (Voter)

Independent voter-verifiable records are crucial to restoring our free fair elections. As a poll worker, I've seen enough screw ups to know votes have been lost. Reading reports of other areas, it seems obvious there has been intentional hanky panky through the software. Removing both the temptation and the opportunity to circumvent the will of the voters is mandatory and must be made a top priority.

Comment by Thema Mawusi (Voter)

With all that is being done in our election system that raises doubt and possible fraud, I feel that the voting system should be free of anything that could jeopardize the voters vote. Software Independence is one of the ways to free the voting experience from this. To depend on a technology that could be fraught with design problems that could invaildate the voter vote and possibly derail the entire election of a said community would be counter productive, and I feel that the system should be software independent. Thema Mawusi Brooklyn, NY

Comment by Martha Koester (Voter)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Furthermore, paper ballots are the only acceptable solution to this problem because they do not freeze ordinary citizens who do not have software expertise out of the auditing process. As a scientist, I find it absolutely appalling that we do not require all voting tabulation methods to be audited. You can trust my results in analytical chemistry because our lab constantly audits the performance of every piece of equipment from simple lab scales and refrigerators to the most complex mass spectrometers. You can trust us precisely BECAUSE we don't trust our equipment. Every data set I send out has at least one hand calculation to check that our data manipulation systems have not been corrupted. If applying common scientific protocol to voting srikes anyone as overkill, they have just said that while it is important to have a reasonable degree of certainty about how much benzo(a)pyrine is in our drinking water, it is pointless to know for sure who really wins elections. As the renowned computer security expert David Dill once said, "It is not enough that elections BE accurate; we havc to KNOW that they are accurate, and we don't"

Comment by D Devereux (Voter)

Vote security and accuracy is a critial requirement for the US to maintain it's rights, freedoms, and obligations. Voter particiaption and inclusiveness have been seriously damaged by vote tampering and supreme court intervention, and vote management manipulation in recent elections. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by john papandrea (Voter)

Speaking for the Chatham County [NC] Ad Hoc Committee on Voting Integrity which won a lawsuit over related issues, our election system must be software independent, and the paper ballot must be the official record. Anyone who has seen their computer lose or mangle [corrupt] important files can attest to the importance of this principle. With the corrupting influence of big money in our elections, it becomes ever more important for the intent of each voter to be safeguarded with vigilance and skepticism over the compromises that technology introduces. Finally, hand-eye verification of a significant percentage of the votes is essential to sustaining and demonstrating system integrity. Jerry Markatos 919 542-2139, 800 Rock Rest Road, Pittsboro, NC 27312

Comment by Howard Wapner (Voter)

We wouldn't think of depositing our money into an ATM machine without a paper record. Why should we have to deposit our votes without a voter-verifiable paper record? You can get a receipt from the gas pump, the ATM, even the self-checkout at the supermarket. Aren't the same companies who make gas pumps and ATMs manufacturing our voting machines? What is so hard about preserving integrity in our voting system? Even the little bit of integrity we had before we farmed out our machines to private contractors at least gave the "appearance" of legitimacy in our elections....

Comment by Verona Tuten (General Public)

I want voter verifiable records made on every voting machine in this country. Wal-mart gives you a paper receipt for a quarter pack of chewing gum, how much more important is the citizens voting record?

Comment by Lynda J Claypool (Voter)

Too many questions have been raised in the last decade to exclude software independence from any voting reform. There will be no perfect system, but these guidelines have to be implemented to reestablish the integrity of the overall system.

Comment by NAN MARKEL (Voter)

It is imperative for us to be able to conduct a recount of any election, and only voter-verified records will give us an accurate way to do it. The legitimacy of our electoral system rests on it.

Comment by frances hirsch (Advocacy Group)

anyone who uses a computer, software & chips knows of its myriad potential problems of error, manip- ulation, & hacking & phishing. I urge you, the commissioners in the name of DEMOCRACY to draft rules to make our one man/woman vote count that among other things strongly advise every election machine have SOFTWARE INDEPENDENCE & INDEPENDENT VOTER-VERIFIABLE RECORDS (PAPER BALLOTS),& to urge our legislators to pass laws to this effect. thank you

Comment by Kim Hughes (General Public)

Absolutely the way US citizens vote should be independent of software, because as was shown in Ohio during the last election, software allows for inaccuracies and worse in the tallying of votes.

Comment by Mark Hoffman (Voter)

Software independence is crucial to the integrity of the electoral process. Any software based process is subject to error through malfunction or tampering.

Comment by Jean Taggart (Voter)

I want my vote to count and to be accountable and trackable should there be yet another problem with mechanized voting machines. Lets get back to the tried and true.

Comment by Philip Ratcliff (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of softwareAll computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Collin Lynch (Advocacy Group)

The requirement for software independence is a basic minimum for reliable voting systems. No advance examination process may be relied upon to find, or ameliorate all security problems even for systems developed with far more advance auditing than present systems. This is especially true for hardware problems where verification is practically intractable. Moreover, even if a perfect examination system were possible the fact remains that no guaranteed link can be made between that clean-room examination and the systems as deployed. Leaving aside the prospect of software corruption and the substitution of new hardware the conditions under which every local election are performed are impossible to anticipate in a clean-room inspection. Only a software-independent system can be reliably audited "in the field" both before and after an election to detect problems and identify election issues both before and after the fact.

Comment by B Hillard (General Public)

Thank you for this opportunity to comment. All computer systems are subject to subtle errors. In fact, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. So it is vital to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Marita Loftus-Strong (Voter)

There is no way to be certain that a computer has not been corrupted whether by malfunction or deliberately manipulated. It is imperative that there be a way to verify the vote by way of a written record. The software should not be the sole means of counting the vote since it is not a foolproof system.

Comment by Barbara Laxon (Voter)

Software independence is truly achievable only by hand counted ballots in the full view of the public, at the time of the election, and before the ballots have been removed from the actual voting site!

Comment by Alex Sera (Voter)

Having worked in the Computer Industry for over 25 years I am quite familiar with the Software Life Cycle and Security concerns. Even software that is well designed and developed has the possibility of failure. Having seen demonstrations of how some of the Voting Systems record and calculate the totals I can say with complete certainty that they could be easily compromised and provide incorrect calculations. We must provide a verifiable audit trail, independent of the software alone. Voter Verifiable paper records would give us this auditing ability and insure the security of our voting system.

Comment by Christopher Carlson (General Public)

I fully agree that software independence is crucial to our voting systems. There must be some kind of verifiable record, through a paper trail or other means, that is independent of potential software flaws. Please ensure that software independence remains a key part of this provision. Christopher Carlson Laurel, Mississippi

Comment by Eileen Gottschalk (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mr. David Mondejar (Voter)

I do hope that you can see the pitfalls of having "hidden" software programs handling our most valuable electoral process. After the last two (2) Presidential Elections, this country desperately needs to regain confidence in its democratic system. A very simple solution to regain the public trust is to have "paper ballots" which will be verifiable. Many others that I know, would also want no less !

Comment by s (Voter)

80% of all votes are computerised in some way in the USA. I am a professional computer programmer. No self-respecting computer programmer would ever advocate for the use of computers in elections. There are too many ways that the vote can be subverted with computers. Current electronic voting machine manufacturers make the simplest programming errors when they develop voting machines but seldom make such simple mistakes when they develop an ATM machine at a bank. The well-publicised hanging-chad fiasco was an obvious ploy to lend plausible deniability to the subverters of the popular vote who subsequently advocated for electronic voting to avoid hanging chads. If electronic voting must be brooked, which I strongly advise against, then software independence is a small step toward a more representative reliable vote tallying.

Comment by Jenny Jeffries (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by barbara leon (Voter)

There must be a separate entity or unrelated system that has the ability to track a voter's vote. A paper trail of some sort would give me the most confidence. If there is ever a need for a recount, the voting machine must enable the inspector to gain a clear, honest representation of what votes were cast.

Comment by Rose Howe (Voter)

As more and more states move into electronic voting machines, it has become a noticeable problem that there are no voter-verifiable way to determine the accuracy of the vote count and whether there has been tampering with the machine software or hardware. I ma in favor of independent audits of electronic voting systems and that the system is software independent__ i.e., that an undetected error or fault in the voting system's software is not capable of causing an undetectable change in election results. I particularly favor voter-verifable records, often referred to as a "paper trail" or some other reliable, tangible evidence supporting the vote counts. If any new technological advances are made to try to improve current systems, these innovations should be subject to the same standards for testing and supporting election results.

Comment by Carol L. Haddad (Voter)

I recognize that all computer software is subject to error, either by an undetected error or deliberate manipulation! Only an independent voter verifiable record will satisfy the software independence requirement. I want every American to feel that our vote cOUNTS1

Comment by Bill Storey (Voter)

I support IVVR as the only acceptable solution.

Comment by Mallika Henry (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Brian Karpin (Voter)

Computer systems are subject to a multitude of errors. They can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. Premeditated corrupted design can be almost impossible to detect after deployment. Its of dire importance in the name of preserving fair elections that the voting systems provide an uncorruptible means of recording and recovering voter intent that does not depend on the software quality or integrity.

Comment by Fred Conner (Voter)

It is important to me that there always be a way ("Plan B") to record and count my vote accurately and legitimately even when there's evidence of software failure or other malfunction with the primary voting mechanism ("Plan A").

Comment by David B Taylor, II (Voter)

During the 2004 my vote "disappeared" in a Unilect Patriot DRE. I have since learned more than I ever cared to about electronic voting devices,hanging chad, paper ballots and politics in general. The ONE thing that I feel very strongly about is having verifiable voting and if the software used to count votes is a manufacturer's secret concoction then it is NOT something that WE THE PEOPLE should be forced to use in our elections. Every step involved in elections must be open and verifiable othewise the system is not trustworthy.

Comment by Andrea Wolper (Voter)

Is there anyone who hasn't learned the hard way that computer systems are fallible, that they can crash, scramble information, fail, lose data, be hacked? Votes are too precious and important to be subject to this kind of risk.

Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

oftware Independence We have mentioned our support for the principle of software independence described in the VVSG. We include with our comments the letter [1] we sent to the then-Chairman of the TGDC, Dr. William Jeffrey, expressing our support for Software Independence and other recommendations made to the TGDC. Given the shortfalls of security testing, it is our long-standing belief that voting systems should also enable each voter to inspect a physical (e.g., paper) record to verify that his or her vote has been accurately cast and to serve as an independent check on the result produced and stored by the system. We are pleased that the TGDC recommends that voting systems must have an independent way of verifying a voter’s selections. An important part of ensuring a software independent system is developing both an effective test and definition for determining software independence. We find both lacking in this version of the VVSG. We recommend that you define software independence as meaning that an error or fault in the voting system’s software is not capable of causing an undetectable change in election results. This will help provides state and local elections officials, as well as vendors, with the knowledge they need to help ensure that their systems are software independent. Without a specific test or a more specific definition, other groups will object to the principle on the grounds that the concept is too vague and indistinct to be effectively implemented. Given that many states currently do not conduct effective post-election audits, there is a need for software independence, together with clear guidance as to what makes a voting system software independent.. We recommend you include in the VVSG a process akin to the hypothetical example we outline in Appendix B — a process that demonstrates both the production of Independent Voter Verifiable Records and Software Independence. [1] http://usacm.acm.org/usacm/PDF/USACMCommentsSTSPaper.pdf

Comment by katharine cartwright (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots.

Comment by Dottie Whitlock (Voter)

I consider Software independence to be the bedrock of the process. No Ifs, Ands nor Buts.

Comment by Nancy S. Murphy (Voter)

It is very important that we be able to rely on the accuracy of our voting machines. The only reliable way to be able to do a recount is with paper that the voter has actually seen, not something that is produced by the software that may have been the problem in the first place. We need a means of reording and recovering voter intent that does not depend on the reliability of software. Americans have lost faith in the reliability of the voting process because of known errors in numerous recent elections. To encourage voter participation and to restore faith in the democratic process itself, it is crucial that voting systems be considered reliable.

Comment by Joan Walker (Voter)

Computer systems are vulnerable to errors and to hacking. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Daniel Lopresti (Academic)

Software independence is a critically important property to have in our computerized voting systems. As a computer security expert, I am well aware of the flaws that are inherent in large, complex software systems, and the ways in which such systems can become compromised through malicious and/or unintended acts. The conduct of an election should always result in a set of physical records that are completely trustworthy, full-auditable, and manually recountable without depending on software provided by the vendor or a third party. The alternative is to assume that computerized voting systems do not contain flaws, which is beyond the realm of possibility. It has already been demonstrated, on a number of occasions, that current government certification and testing processes are inadequate when it comes to detecting such flaws. Indeed, I suspect that designing a fool-proof evaluation procedure is not feasible. Transparency in processing election records is key, and the only way to achieve such transparency is through software-independence. At the present time, we can equate this to each voter marking a paper ballot which is then processed by a precinct-based optical scan system. The paper ballots are manually recountable and provide software independence. The output of the precinct scan can be considered the unofficial results of the election (and provides a check on attempts to manipulate the election through old-fashioned "ballot box stuffing") until a full and/or random recount of the paper ballots confirms the correct functioning of the equipment. While this requires a bit more time and perhaps a bit more expense than simply believing the output from a DRE system with no such integrity checks, the result will be election results that are much more trustworthy.

Comment by Bruce Lueckenhoff (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Robin Wilson (General Public)

Please use a software independent system that has a paper trail. Thanks, Robin

Comment by Monica Hutton (Voter)

All computers are subject to mistakes - accidental or otherwise. We need to have independent verifiable checks on computer votes. Protect our democracy!

Comment by G. C. (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Mary Francis (Voter)

Oklahoma, where I live, uses voter-marked paper ballots. This system provides a record which shows the voter intent and does not depend on software which has been shown in multiple studies to subject to deliberate corruption at any stage of their design, manufacture, and use. Electronic malfunction is another common problem with DREs. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software or the honesty of the programmer and corporation, which manufactures the machines. I urge you to ensure honest election results by the use of voter-marked paper ballots and a random audit of all close elections.

Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

USACM Comment #3. Software Independence Demonstration [incomplete] USACM recommends that the VVSG include a step-by-step demonstration of a software independence assessment. An example of such a demonstration is included as Appendix B to these comments. DISCUSSION: The process for demonstrating Software Independence is not clearly delineated in the document, and it is unclear how such an assessment would proceed from the document as it is written. Without such precision, the guidelines are open for a wide variety of interpretation as to what would demonstrate software independence. This would allow for groups to argue the requirement is overly broad, or that it is already demonstrated by existing voting systems — which is currently only true for voting systems with IVVR. Appendix B. SAMPLE Demonstration Procedure for Software Independence This test is meant as a hypothetical example, is for illustrative purposes only, and is not an endorsement of a particular process or technology for use in voting systems. The following example illustrates how IVVR may be determined. We are assuming a single-issue election and a unique Compact Disk (CD) for each voter. By "visible surface," we mean the outside of the CD where, for example, movie titles currently are written or where someone could write information about a CD he or she has recorded. In this voting system, the vote-capture device is an electronic writing pad. A voter display screen lists the candidates and the voter writes his or her selection on the writing pad. The vote capture device captures each vote (recognizing the script) and translates it into an electronic ballot that is written to a CD. The system also prints the written vote in the voter’s handwriting on the visible surface of the CD in view of the voter. The vote is recorded from the signature pad and the CD is retained for audit purposes. The following details apply: 1. The voter is asked to verify and approve what is printed on the outside of the CD before casting the ballot. 2. The device marks the CD as "accepted", in view of the voter, when the voter approves it and the device marks the CD as "rejected", in view of the voter, if the voter rejects it. 3. If the handwriting is not legible, the system will reject the vote and prompt the voter to try again. 4. The printed vote record is durable enough to remain unchanged and legible for a period of 22 months. 5. The CD does not contain any information about the time at which the vote was cast or the ordering of this vote compared to all other votes cast on this voting machine. 6. Information printed on the CD also reveals the polling place, precinct, set of contests the voter was eligible to vote on, and the date of the election. 7. The format of the data stored on the CD is fully disclosed to the public. We start with the IVVR requirements (cf. Section 4.4 of the VVSG). We list the example assessment of whether this system (with the clarifications above) meets that requirement, and some discussion explaining the conclusion. Here the IVVR is the printed copy of the vote, as printed on the outside of the CD. 4.4.1-A.1: Complies. 4.4.1-A.2: Complies. Here we assume that if the device can interpret the voter’s handwriting, then so can an auditor. Alternatively, if the device will accept records that will not be legible to election officials and auditors, then such a system would not comply with 4.4.1-A.2. 4.4.1-A.3: Complies. 4.4.1-A.4: Complies. 4.4.1-A.5: Complies. See durability assumption above. 4.4.1-A.6: Complies. 4.4.1-A.7: Complies. Same issues as VVPAT. 4.4.1-A.8: Complies. Handwriting is a publicly available format. 4.4.1-A.9: Complies, under the assumption that the device prints the additional information listed above. If the CD does not show that additional information in human-readable form, then the device may not comply. 4.4.1-A.10: Complies. 4.4.1-A.11: Complies. IVVRs do not span multiple media. 4.4.1-A.12: Complies. 4.4.1-A.13: Complies. 4.4.1-A.14: Complies. 4.4.1-A.15: Complies. Depending upon how we interpret this requirement, compliance may require the device to include an electronic bitmap image of the scanned handwriting as part of the data stored electronically on the CD, but that should be straightforward to arrange. 4.4.1-A.16: Complies. 4.4.1-A.17: Complies. Based on this analysis, we can conclude that the example voting system satisfies requirement 4.4.1-A (the primary requirement that is specific to IVVR vote-capture devices). Note that there are some additional requirements that must also be met if the device is submitted for approval as an accessible voting system (Acc-VS), e.g., 4.2.4-A, 4.2.4-B. Finally, we can ask whether this system meets the SI requirement. In this case, there is a shortcut: IVVR systems in general qualify as SI (Sections 2.7, 4.1), so as we have determined that the system is an IVVR system it meets the definition of SI. If the system did not meet the requirements for IVVR, we would have to separately determine whether it meets the SI requirement. Here we look to requirement 2.7-A. To determine whether the system complies with 2.7-A, we would have to consider all possible changes or faults in the software to see whether there are any that could cause an undetectable change or error in the election outcome. In this case, all such errors can be detected, via observational testing, post-election statistical audits, recounts, pollbook reconciliation, and/or the official canvass. Note also that the voting system vendor, as part of the submission of the system for certification, must declare what conformance classes to which the vendor wants to claim the system complies. For instance, the vendor must decide whether to claim that the device is an "IVVR vote-capture device", whether to claim that it is an "Acc-VS", etc. The testing that is done is determined by what claims the vendor makes. (See Sections 2.3, 2.4 of the VVSG II.)
2.7-A Software independence

Voting systems SHALL be software independent, that is, an undetected error or fault in the voting system’s software SHALL NOT be capable of causing an undetectable change in election results.

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

DISCUSSION

The requirement applies to the voting system class, meaning that all voting systems that conform to the VVSG must be software independent.

Source: New requirement

400 Comments

Comment by Stephen Ballou (Voter)

I urge that paper validation for the electoral process be mandated nationally - the accuracy of our voting process forms the cornerstone of our democracy. The legitimacy of this process goes to the heart of who we are as a nation and must be safeguarded. The mechanics of our voting procedure is in the fundamental interest of ALL parties and ALL voters, and MUST be verifiable!

Comment by Valerie Guinan (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Patricia Peckham (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. We, the voters, must be able to have confidence in the voting system. Our democracy depends on this. Thank you.

Comment by Patricia Peckham (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. We, the voters, must be able to have confidence in the voting system. Our democracy depends on this. Thank you.

Comment by Joy Marx-Mendoza in Phoenix AZ (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Alice Bryan (Voter)

Having worked in many capacities with computer software & hardware, I strongly urge you to insist upon an independent paper trail of each vote so that corruption cannot occur and the integity of our elections is above reproach. We must insure that our elections are always above board and data unbreachable. Please do the right and moral thing by insuring that we all voters have an infallable voting system. Sincerely, Alice Bryan

Comment by Robert Byrne (General Public)

As the CEO of a software company, I am well aware of the challenges of producing software and the opportunities to subvert it. Please ensure that our voting systems have a means of recording and retrieving votes that does not rely on software.

Comment by aron shevis (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Adair DeLamater (Voter)

I understand that no system is perfect, but I believe the only way to protect the integrity of each citizen's vote is to have a means of recording and recovering votes that does not rely on software. It would be a tragedy for our nation if voters lost faith in the voting system, and came to believe that their vote could be miscounted or manipulated.

Comment by Anna Burton, MD (Voter)

At home when I want to have something to check carefully and be safe against computer blips, I print it out. Votes deserve the same hard-copy backup.

Comment by Robert Brown (Voter)

Voting devices MUST be software-independent. Both errors in program codes and the insertion of malicious codes intended to skew election results will tend to weaken and even destroy our free voting system. In fact, paper ballots are still the most reliable form of voting. Machines of any kind can be rigged or can fail. But if we do use software-based machines, then the programs that run them MUST be able to be examined by independent experts, and NOT "protected" as proprietary. Any company that manufactures such machines must automatically give up proprietary rights, in order to safeguard voters' rights.

Comment by Daniel R. Quintiliani (Voter)

Computer glitches happen all the time, and it is no different for computerized voting machines. Computerized voting machines are also subject to hacking and other malicious activity, as many academics have shown. Elections using computerized voting machines are contracted out to companies, and many of these companies have political agendas. For these reasons, it is crucial to have secure and verifiable elections, as our democratic republic depends on it.

Comment by Theresa Koster (Voter)

To whom it may concern, Please mandate a voting system that does not rely solely on computer software. There are too many risks with computer systems as we have seen in the 04 elections. Thank you. -Theresa Koster "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Alan Carlson (Voter)

All computer software is subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend solely on the reliability of software.

Comment by Rush Hood, PE (Voter)

I am responding as a senior systems engineering professional and Registered Professional Engineer. Any computer system is subject to subtle errors. Any computer system can malfunction or be deliberateley corrupted at any stage of its design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Maryanne P. Heath (Voter)

It is absolutely necessary to have software independance in electronic voting systems. There must be NO chance that a software flaw, whether mistaken or intended, be able to change an election outcome. There MUST be voter-verifiable records in ALL voting systems. We can not ever again have debacles like the 2000 and 2004 elections! We cease to have a democracy when its' key element, the vote, is not counted as it was intended.

Comment by Corinna Lewis (General Public)

I want my vote to be verifiable independently. Voting machines have been proven to be vulnerable. For the sake of votes that are not tampered with, software independence is necessary.

Comment by James Flan (Voter)

It is imperative that the reliability of our vote does not depend on the computer software. We need a way to record and recover votes that is not dependent on the software. The integrity of our system is at stake. Thank you.

Comment by Sally Olds (Voter)

As a computer user in my work, I know that any computer system can malfunction or be deliberately corrupted to result in voting fraud. Therefore, it is crucial that every voting system has some means of recording votes that is not dependent on the reliability of software. It is vital for our system that every vote cast represent the voter's intention.

Comment by Kevin P. Brown (General Public)

I worked as an informations system professional for a number of years. I know from experience that computer systems are fallible and that software can be corrupted or "hacked" with little chance of detection. Because of the potential fallibility and vulnerability to manipulation, I strongly recommend that all election systems include a hard-copy audit trail so that 1) the proper recording of an individual's votes can be determined by each voter, and 2) the voting system can be reliably verified as accurate through the use of old-fashioned tallies, both as requested and periodicallly at random to ensure the correspondence of the computer-recorded results with the hard copy.

Comment by Paul Lyman (General Public)

I strongly support a requirement that results be software independent. We all know that with complex systems, undetected errors may lurk even after many hours of testing. There must be a way, independent of software, for voters' intent to be ascertained. Regards, Paul Lyman

Comment by Christine Kelley (Voter)

All voting machines should produce a paper receipt to verify a person's vote. This is to assure the voter that his choices are correctly tabulated and to aid against tampering.

Comment by Evelyn Krueger (None)

Nothing is more important than the integrity of our democracy via our election system. We must have verifiable paper because electionic systems are subject to corrupt and especially in the hands of one party. They must also be owned and overseen by our government, not private corporations.

Comment by Renate Ryan-Jeppeson (Voter)

Free and fair elections are only possible when results are verifiable independent of any software program. Software is inherently susceptible to hidden flaws or even to deliberate manipulation. No amount of scrutiny or security can eliminate these inherent problems with software. It is critical that some sort of voter-verifiable, paper record be included in any voting system. The future of the free world depends on it.

Comment by Lisa Tait (Voter)

I think software independence is crucial. There have been too many stories of computer anomalies such as votes recorded exceeding votes cast. Without a separate reliable way to recount these votes, I'm one of many citizens who has come to doubt the results of our recent national elections. If citizens don't trust the voting system, the democracy begins to erode.

Comment by Anne B. Farrell, Del Mar, California (Voter)

Our nation and our democracy are built on the concept of one person, one vote. And the disasters of recent elections have alerted us all to the mischief that can be made if computer voting is unverified or somehow lose their integrity. Any of us who use computers know that systems can be subject to subtle errors, can break or malfunction, or even be intentionally corrupted. When? At ANY stage of their design, manufacture, or use. Because the methods used to do this can be extremely difficult to foresee and detect, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. We need verified voting, and we as voters need to know that our vote is sacrosanct - not liable for misuse or mistake. Thank you very much for making sure that voting machines have independently verifiable voting records!!!

Comment by Shelly Gold (None)

It would be much better, in fact necessary, to have software independence as a requirement for any and all voting systems that would otherwise conform to standards. No system of any kind, financial, or otherwise can be considered to adhere to "sound practices" criteria, unless it can be audited through an independent means; in this case, independence from the operational software.

Comment by Nancy Sosnove (General Public)

There is probably no software on the planet that can be guaranteed as totally free of bugs. Everyone who has used a computer knows about crashes. The only way that voting can be secure is with software independence. In our county, everyone votes by absentee ballot, which leaves no room for computer error, is cheaper than the upgrades on the voting machines, and can be recounted. High tech is not automatically better. Please require a voter-verified paper ballot in every election.

Comment by G. Gilberto (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Barbara Okonski (Voter)

Voting systems must be software independent since software can often have errors. Voting systems must have verifiable means of verification (i. e. paper records) to maintain the integrity of elections.

Comment by Daniel Paul (Voter)

As computer systems are subject to operational errors and "break-downs" it is imperative that a fool-proof vote verification record exists for any and all systems adopted for use. Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and/or use. The methods used to do this are extremely difficult or impossible to foresee and/or detect after the fact, therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Norman T. Burns (Voter)

Nothing in a democracy is more important than that the voting system be beyond suspicion of inaccuracy or fraud, and in voting systems nothing is more important than to eliminate even the suspicion of undetected error or fraud. Be sure that what you choose is verifiable and beyond reproach!

Comment by Leslie Fife, Ph.D. (Voter)

I am a computer scientist. I worked in industry for a number of years and now teach computer science at the university level. I have developed software and have taught software engineering. One thing I have learned is that subtle errors can be present in any system. These errors may be accidental or malicious. In either case, small errors may occur that could change the results of a close election from what the voters intended. Software Independence is a CRITICAL requirement. No amount of testing will ensure that complicated software is error free. Only that it is very reliable. That is not good enough for our voting systems. There MUST be a way to independently verify - through paper records - that the vote tally provided by the machine is accurate. Anything less will lead to a lack of trust in the voting systems and will erode the democratic process. Further, malicious changes to software are always possible and can be extremely difficult to detect. A talented programmer could rig an election. In this situation, the voter-verifiable record is the last protection against this type of voter fraud. I would NOT trust any voter system that does NOT provide software independence. My 20+ years as a computer scientist lead me to that conclusion. To ensure an accurate accounting of the will of the people, software independence is ABSOLUTELY required. Anything less is an election nightmare waiting to happen and a violation of the people's trust.

Comment by Dee Longenbaugh (Voter)

Our entire democracy was threatened when methods of miscounting ballots electronically became possible. Please return our credibility in the world by ensuring all votes will count. Thank you. Dee

Comment by Stiles Marion Najac (General Public)

It is important that all votes are verifiable and counted once. Software is not as reliable as some form of paper record or in conjunction with a form of recorded paper trail. Our Democracy is fragile enough, becoming more and more obvious with each passing confused election. Our goal must be to straighten out the mess we have made not to make our freedoms more insecure.

Comment by David B Wood (Voter)

I am an experienced software engineer, and I know firsthand that no computer system can be relied upon to be free of subtle (and not so subtle) errors. As a result, all computer systems handling mission critical data (of which votes are a prime example) must include methods for external verification, and for recovery from emergencies and mistakes. The requirement for Software Independence is an essential requirement.

Comment by Richard Low (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Jordan Papayupelo (Voter)

Elections are easily fixed when in the hands of the computer operators. The computers have no need to fix an election, but the computer has to be programmed by a human being and that's where the chance to fix the outcome of the election comes into play. On what side of the election is the programmer or the people hiring the programmer? One who knows even a little bit about writing code can see the difference between party affiliation and/or selection by viewing the code and can adjust the outcome of the vote within moments, leaving no evidence. Do you trust the voting process as much as you used to? Is your vote worth protecting? While the system was imperfect and cumbersome by comparison to the computer, we need to bring back the paper ballots. Please view this video: http://www.youtube.com/watch?v=vbysi62oFCc

Comment by Will Jackson (None)

We need clean elections and verifiable records; the people of the United States need to feel certain that the votes they cast are accurately tabulated. Since computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and usee, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mr. Merrill Bobele (Voter)

Keep in mind that all computer systems are subject to errors. In fact, they can be corrupted at any point in their design, manufacture or use. If such intervention is intentional, the methods used to do this are extremely hard to detect. Voting systems can provide election integrity if the means of recording voter intent is to be protected and the means recording and recovering is not dependent upon the reliability of software. The simplest solution is a paper trail!

Comment by Janet Jaidi (Voter)

It is very important that the voting machine be secure from hacking or software manipulation of any kind. Without fair elections, we have no democracy!

Comment by Geri Vasilia (Voter)

I am in the Pharmaceutical Research business auditing clinical trials. EVERY computer program we use has to, BY LAW, have a paper trail and back-up to verify the data that has been entered in the computer programs is complete and accurate. Why is our election process and voting exempt from this requirement? EVERY vote should be REQUIRED to be verified by a paper duplication system. Our voting system should be superficial to review and editing. Computer programs are too easy to be altered or designed and programmed to reach a predetermined outcome. Please make a paper back-up a legal requirement. Thank you

Comment by Tara Moira McBride (None)

Every day we learn that even the most secure computer systems are subject to error, whether deliberately corrupted or by flawed design, production, etc, making it impossible to guarantee integrity. This said, it is necessary that all electronic voting systems provide a way to recover and record voters intentions, and not rely or depend on software or hardware applications. It is your responsibilty to serve the best interests of the American people. Do your job responsibly or resign your post.

Comment by Joshua Holden (Academic)

I do not feel that computer software is sufficiently ready to be our sole source of voting system records. We do not have enough of a science and technology of software verification to be certain that errors, malfunctions, or deliberate corruption is not present in any given voting system. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Raymond C. Moulton (General Public)

This rule is essential for verifying the integrity of an electronic voting machine. A paper ballot printed by a voting machine at the time a citizen casts his or her vote is the only way to ensure honest elections. Otherwise, how do you audit the accuracy of the machine? The best way to detect fraud or error is a paper ballot reviewed or verified by the voter. Computers can be and probably will be manipulated to effect the outcome of an election. Without a paper ballot, how do you do a recount? Corrupt elections undermine the legitimacy of our government. Do not allow a whiff of percieved election fraud by political party partisans handling electronic voting machines.

Comment by Beryl Schwartz (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections and my vote that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Robert Steen (Voter)

As a person who has been involved with designing and implementing computer systems for nearly 30 years I understand just how complicated and prone to errors software systems can be. It is extremely important that we have a software independent means for the voter to verify that his/her vote is recorded correctly. As of now, the only solution that I am aware of is a paper print out of the voters selections that is kept by local/state election officials to be referred to if questions arise around the vote tally. Otherwise intentional or unintentional errors in voting software can go undetected and literally millions of voters can be disenfranchised.

Comment by Sharon Terry (General Public)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Helene R. Hass (None)

To whom it may concern, "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Barbara Schweisheimer, P.O. Box 1848, Woodruff, WI 54568 (Voter)

It is extremely important that voters have 100% confidence in our voting system. If the voter feels that his or her vote is not counted as they intended, they will stop voting and our democracy will be serious jeopardy. Any computer system is subject to errors, some obvious and some insidiously subtle. Even innocent coding errors can skew election results. Also, any computer system is subject to malicious manipulation. It is impossible to build a system that cannot be corrupted. Therefore, it is extremely important that our voting systems provide a means of recording and recovering voter intent that does not depend solely on the voting software. The argument for efficiency and speed does not outweigh the need for a verifiable system. A voting system that relies entirely on the software is asking for a repeat of the Florida fiasco, but with a more serious outcome. There will be nothing to verify the vote, not even a hanging chad. I have been around computers enough to know that their data can be corrupted, either incidentally or maliciously. As a voter, I need to feel that my vote will be counted as I intended it to count. Please only allow voting software systems that include a reliable means of recording and recovering voter intent that is totally separate and independent from the software.

Comment by Mr. D. Narveson (Voter)

Yes, software independence is critical! Software can have problems, subtle, gross, accidental, deliberate. These problems can arise or be caused in all kinds of ways at all stages -- design, implementation, & use -- and can be very hard to predict or detect. For election integrity, we HAVE TO HAVE a way, independent of the software, to record and recover every voter's intent.

Comment by Wind Vogel (Voter)

All computers can malfunction. In addition, it is entirely possible for persons or groups to deliberately sabotage them for illicit purposes. For elections to remain honest, there must be a system of checks and balances to ensure that voters' responses can be recorded and retrieved accurately, without the dependence upon software.

Comment by Dr Stephen Peppin (Academic)

It is imperitive that any voting system be obtjective and verifiable. A system based entirely on software can malfunction or be hacked. Please ensure there is a backup system to verify votes.

Comment by Joseph Dellinger (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Robin Schmidt (Voter)

To the Election Assistance Commission, Without an election system that can be independently verified, elections (and thus democracy) are meaningless. It is crucial to the integrity of elections that voting systems record and recover voter intent in a way that does not rely solely on software. Everyone who has ever used a computer or computerized device knows that they are all subject to errors - sometimes obvious, but sometimes more subtle. Furthermore, computer systems are subject not only to malfunctions, but also have the potential to be deliberateley manipulated - this can occur at any stage of their design, manufacture, and use. Because the methods used to do this can be extremely difficult to foresee, prevent, or even to detect, it is imperative that a system of verification independent of software be put in place. Thank you, Robin Schmidt

Comment by Judith Susan Langhans (Voter)

Election reform must include independence in software. We can't have another country or corporation come up with the software that records the votes of the U.S. citizentry. We'd love to trust but our obligation is for all voting systems to be verifiable.

Comment by Lynn A. Buffington (Voter)

I am very concerned that all voting methods should have a way of registering and calling back up votes in a way that is completely independent of the software. The method should allow voters to verify this record before finishing the voting process.

Comment by Nancy Haffner (Voter)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by James Israel (General Public)

Many types of errors can happen in computing systems, both unintentional and intentional. These errors can be extremely hard to forsee and detect. Therefore, it is critical to the integrity of elections that voting systems include a means of recording and recovering true voter intent, which does not depend on the reliability of the software.

Comment by cecile armor (Voter)

I worked for many years writing programs for computers so I know how easy it is to put hidden code that isn't easy to detect into the program. It is absolutely necessary to have a backup system in place to record the voter's intent should a recount be necessary. Our democracy rests upon the voter's having confidence in having their votes properly counted.

Comment by carl weiler (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Michael H Miller Jr (Voter)

We need software independence and a way to verify the vote in case of contested elections or recounts. We need voter-verifiable paper records or voter-marked paper ballots. And, I agree with this statement: "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software." -Mike Miller, Jr. 2200 Ben Franklin Pkwy, South 410 Phila., Pa. 19130-3601

Comment by Marcia Rock (General Public)

The fact that this problem has such an easy fix and hasn't been done is unacceptable. Any system can be hacked or hijacked and so we have to have a system we can rely on. We must demand a verification component to these machines. Florida in 2000 and Ohio in 2004 should be all the warning we need.

Comment by Daniel Kozminski (Voter)

I have been a computer programmer most of my life and I enjoy working with computers. But I would NEVER place our democracy in the hands of a computer software program without some way of accurately determine the voter's intent without relying on the computer software. It would be absolutely ludicrous to implement any electronic voting system without a myriad of safeguards, including but not limited to, a mandatory requirement that all the computer's software be opened to full public scrutiny and that a voter verifiable paper audit trail be produced. Voting safeguards should be tighter than the security at Fort Knox. At the fort they are only guarding gold, these voting machines are guarding our democracy.

Comment by Chris Winchell (General Public)

All Americans want to have truly transparent and fair elections. American values, from our founding fathers forward, have preserved this precious right. Now, we find this most precious right under seige. A critical component of fair and verifiable elections is that we not rely solely on the software. Software can make mistakes, can be hacked, can be maliciously programmed. (There are numerous examples of highly questionable results produced by electronic DRE voting systems.) If we do, the public will not have confidence in our electoral process. This would be a tragedy. This is why we must have an accurate paper trail for audits and recounts. We should not rely only on the software. Chris Winchell

Comment by Crawford MacCallum (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Crawford MacCallum (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Cindy Spring (Voter)

I strongly support software independence and verifiable records. I cannot understand why anyone would stand in the way of a totally verifiable and transparent election process.

Comment by Carolyn Waugh-Tandy (Academic)

The computer systems are subject to subtle errors. Moreover computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots.

Comment by bud sife (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Denise Sauter (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Nancy Hamilton (Voter)

Without a paper trail, it is impossible to have a recount that can be trusted. Any bugs in the software, whether accidental or because of interference by dishonest election workers, cannot be detected. It seems ironic to me that some people purport to be so worried about voter fraud that now they want everybody who votes to show an ID. Actually, the greater danger, judging from past elections, is that the software can be rigged to influence the final vote total and there is no recourse for people whose votes may have been ignored or changed. A discrepancy between exit polls on one hand and the announced election results on the other is a red flag that the machines have been tampered with.

Comment by Franz Fazakas (Voter)

In order to presrve the integrity of the voting system and therefore the integrity of the United States, software indepdence is plainly required. Any system dependent on, or involving software will be vulnerable to manipulation and threfore corruption. The overt hanky-panky which was apparent in the last Presidential election showed how dangerous unprotected balloting can be.

Comment by Bob Mazza (Voter)

In light of recent tests done by independent computer experts here in the US, I think that touch screen voting machines should be banned before the upcoming US general election 2008. If it is not possible to put optical scan machines in place by the election we could use paper ballots and they could be hand counted by volunteer poll workers. I've never worked the polls but I would gladly do so if they were shorthanded. We must immediately move to insure the people of this country that election results have not been tweaked. Touch screen voting machines, I think, are responsible for the mysterious voting results in Ohio in the 2006 Presidential election. If anything like that happens again, the American People will be up in arms and look out because I believe they'd revolt against the government. Please take action soon. Thank You.

Comment by Major John Parsels (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Jerry Woolpy (Voter)

We must have verifiable printed paper records for each voter so that they can see what they voted for and the referees can recount by hand if necessary.

Comment by Bonnie Korman (Voter)

My husband and I have been in volved in incidences of voter machine malfunction or disruption in New Mexico that definitely affects our trust and confidence in electronic voting that is not backed up by a voter verified record. We became so awaare and disturbed about this issue we have joined in with the voting integrity movement. In our now informed opinion, we understand how crucial to the integrity of elections it is that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Brian D. Gregory (Voter)

As demonstrated in recent elections, computer voting systems without manual verification can not be trusted. Rather than using proprietary software, manual systems need to be put back in place. The public can wait for results rather than getting "instant" results. We want honesty!

Comment by Paula James (Voter)

Software is subject to corruption and manipulation. We must have a paper means of verifying the voter's intent, independent of the software program. This provision is essential to honest elections.

Comment by John DuBois (Voter)

ALL computer systems are subject to subtle errors. In addition, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use as daily reports from any security system can attest. The methods used to do this can be extremely difficult to foresee and detect It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software, i.e. a paper record given to the voter showing how his vote was recorded.

Comment by David C. Buckle (Academic)

Trust of the Verification System for voting must be wide spread and in order to establish this the voting citiizens must be confident of indepence of Software for that verification. At this time in our history where so much software is so imperfect and complicated beyond requirements , ususally due to inadeguate testing and insufficient transparency to programmers, that it is impossible to verify its functionality. This Requires, in my mind, that there be maintained Paper records of the vote taken. There are currently in use such systems in the state of Virginia, and others that use such a marked ballot which is then scanned and counted electronicly. A version which could produce a copy for a voter to verify, at the time of voting, and then insert it into a scanner would be more expensive but would give both simplicity for voting and a dual counting system as well as the verifiable hard copy. Let us not generate more mistrust and anger in our election, but work to make it the best in the world.

Comment by manfred weidhorn (Voter)

There MUST be a paper trail or some other means of verifying computer driven vote counts, otherwise democracy is a farce, being subject to robots, hackers, and geeks.

Comment by Ron Currens (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Nathaniel Silber (Voter)

Nowhere else in government acquisition are vendors permitted to supply "proprietary" software that the government cannot access and verify, as is the case with Dieboldt, Sequoia, etc. This means that a partisan vendor could insert subroutines to display the voter's intentions, and even print out those intentions, yet report back to the tallying server a predetermined result different from the voter's wishes. Until the machine software is "open" and verifiable by an expert, independant third party, our elections are not secure. A good example is the discrepancy between exit polls, which are normally sopt-on accurate, with the actual tallied results in Ohio, but only WHERE THESE ELECTRONIC MACHINES WERE USED.

Comment by Terry Keith (Voter)

Software and systems can both be "hacked" to influence a result.Also computers can malfunction. I DO NOT believe we should use this method to record votes. Sincerely, Terry Keith

Comment by ANN E. HELLER (Voter)

Since all computer programs can be tampered with during use or manufacture, we need to be able to verify the voters choice without depending on software. The present proposal does not inspire trust as to accuracy. thank you

Comment by Raymond A. Coulombe (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Michael Wheeless (Voter)

As a retired computer programmer with over 20 years experience in a variety of corporate software projects, I know that errors can occur in any software program. It is a standard tenet of good data processing practice to always have an audit trail to restore correct and accurate processing functionality and recover lost or damaged data. The more important the system, the more audit logs and recovery points should be created. Thus a system as important as recording the votes of all citizens in an election or referendum should have an audit trail and process that will allow complete recovery and reconstruction of all votes cast. This can only be done with a voting system that is software independent.

Comment by Dale Newfield (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by E. A. Frishman (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Michael McClennen (Academic)

I believe this clause to be vital to the success of these standards. Computer systems are, in general, uniquely subject to unpredictable errors, and are vulnerable to deliberate corruption as well. The consensus among software engineering researchers is that there can exists no metric or methodology by which all errors can be eliminated from a given computing system, and that therefore all systems must be assumed to have undetected errors. Given this, software independence of voting results is an absolute necessity for preserving the integrity of our voting system and thus of our democracy.

Comment by JoAnn Dolan (Voter)

Citizens have a right to expect that our elections are structured to be absolutely fair and free from the possibility of corruption. Therefore, I strongly urge you to ensure that software independence remains part of the federal guidelines for voting systems. All computer systems are subject to subtle errors. Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Thank you, JoAnn Dolan

Comment by Stephen L. Japhe (Voter)

No software is totally capable of detecting errors or deliberate fraud. there MUST be a reliable way to verify a vote after it's been cast in case there is any doubt raised about the above possibilities. The Jennings/Buchanan election was an example of this.

Comment by Avi Okin (Voter)

All computer sysstems, no matter how new, are subject to either random or controlled (read software initiated by programming and/or programmer). The only means we have to insure voters that there are no undetected errors and all votes are as they were originally casts is with a paper trail. I would like to think that we can save trees and energy, and recycling may do this to a large entent, but we need the audit ability of paper versus electronic. Therefore, either do away with electronic voting, which I favor, or have a paper result that the voter can verify and that is available for vote auditing. Wholy electronic is NOT ACCEPTABLE and dangerous to our representative democracy.

Comment by Paul Winkler (General Public)

Software independence is essential. As a professional software engineer with 9 years field experience, I know that all software has flaws, most software is frankly quite bad, and perfection is non-existent. For something as important as elections, where the stakes for errors or sabotage are incalculably high, we need a separate system to fall back on.

Comment by Jacquie Lowell (Voter)

It has been well documented that errors can occur with any sort of computer voting system, whether through malfunction or deliberate corruption, as has been suspected in the past. To ensure a fair election it is essential that voting systems provide a method of recording and recovering voter intent that is software-independent. If we can get receipts for our ATM deposits, there is no reason we can't get paper receipts for our electronic votes. We must maintain citizen confidence in the results of elections and that is flat impossible with computers that lack a verifiable paper trail.

Comment by David August (Department of Computer Science, Princeton University) (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Kyle Curtis (Academic)

All computer systems commit errors. Any voting system needs to include a failsafe method to record the intention of the voters.

Comment by Penelope Arhar (Voter)

Anyone who owns a computer or works with a computer knows about errors. Anyone who's system has crashed, has tried to retrieve lost information or has even remotely been "exposed" to on-line identity theft knows full well how extreme system corruption can be. It is absolutely crucial to the integrity of elections to have the means to verify voter intent and not to merely rely on computer systems. There should be a hard copy just in case we need a recount!

Comment by Winifred Freund (General Public)

Independent verifiable voter records that are software independent are essential to a democracy that should ensure that all votes are counted fairly. Electronic voting can have errors or breakdowns. We cannot allow any vote to be uncounted if we are to protect our democracy.

Comment by Derek Gitelson (Voter)

As a programmer with over 40 years experience I know how easy it is to make a coding or design error that has subtile unexpected results. I also know how easy it is to subvert a program to do something not part of the official design therefore I consider it MANDATORY that some sort of non software audit trail be available to verify that the voters intent has been carried out. Derek Gitelson Member IEEE Computer Society

Comment by Matthew Clark (General Public)

I view the need for IVVR as paramount to electronic voting. Recorded and achived physical ballots with human marking must underwrite software-based voting systems as a bedrock principle of the american voting system in perpetua.

Comment by Mia Sole (Academic)

Please help to make software independence and verifiable elections a reality. Thank You.

Comment by mair (Voter)

Scared to vote using machines? You bet! Especially when they can be tallied by potentially corrupt government bureaucrats who might be control mongers. Let's get this thing straight before the upcoming crucial election where the people really do have the choice.

Comment by James E. Luce (Academic)

As a teacher of government organization and function, it has been my experience that no voter system is without error and/or malfunction. History has shown that the balloting process can be manipulated or corrupted at any point of its design or application and are difficult to identify and prevent. at the very least, any voting system needs to have a method of recording and recovering the intent of the voter that is independent of electronic software. Our nation advocates and sometime demands that other nations have verifiable and audited voting procedures as a basic element of a democratic process. Why can't we do the same for ourselves.

Comment by F. Michael Montgomery (Voter)

When there was a huge (over a million) undervote in 2006 and the exit polls were way out of wack with voting results, there is a clear need for software independence. Ironically, one of the largest makers of electronic voting machinery has as its primary business the making of ATM machines. If my bank operated at the poor performance that the voting machines have, I would no longer use that bank. We are supposed to be the very ideal of democracy in the world. If we do not have s truly verifiable and accurate ability to count every vote, we have failed to live up to the rights of every citizen.

Comment by Donna Clark (Voter)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by gil mayers (None)

I think it is necessary to have reviewable, intact paper ballots and software independent machines. The reason for my concern is that on voting machines like Diebold the information and progamming is propietary. We can't review it even though we have paid them MILLIONS for their machines. Secondly because the optical scan records the vote on separate cards for each machine the chances of inserting a virus into the entire system with one sabotaged uploaded entry is hugh and almost undetectable. It has been shown on HBO that a plus and minus mechanism can be effectively and undetectably inserted in machine programs to skewer the votes[ a -5 for one candidate a +5 for another giving an accurate voter count but an incorrect vote count]. The bottom line is that verified eyeball counts are only possible with paper trails.

Comment by Fred C Ingram (General Public)

Without Software Independence, the whole idea of electronic voting is a patent sham. Now that the general public has been educated on the issues regarding so-called "proprietary software" and the whole travesty of our election process being privatized, this sad chapter in our history will hopefully come to a close. No more statistically improbable election surprises, no more curious "anomalies", no more sham results that can not be challenged, investigated and overturned. As an American I deeply resent the cynical hijacking of our election process by private interests and their apologists and demand a return to transparent, publicly accessible and verifiable election results. Software independence should have been mandatory in the first place - there's absolutely NO EXCUSE for its exclusion.

Comment by Barbara Glassman (Advocacy Group)

As webmaster for CoalitionforVotingIntegrity.org, I have read and heard enough to understand, as you surely do, that software independence is essential to voting integrity. NIST is just one of the authorities on the subject that has taken this position. For this reason we advocate voter-marked paper ballots read by optical scanners with statistically significant random audits.

Comment by Scott Stoller (Academic)

As an instructor and researcher on software engineering, I know there are many subtle ways in which software systems can malfunction, through unintentional or intentional flaws. considering how high the stakes are in elections, it would be very risky to let the integrity of the outcome of the election be depend on the reliability of a software system. Scott Stoller Associate Professor of Computer Science Stony Brook University

Comment by Bernard R. Klinger (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Wayne Pollock (Academic)

All computer systems are subject to errors, can malfunction, or be deliberately corrupted at any stage of their design, manufacture, and use. Such flaws are extremely difficult to foresee and detect. Therefore voting systems must provide a means of recording and recovering voter intent that does not depend on software alone.

Comment by Catherine Ann Matt (General Public)

I was a Democratic Poll Watcher in 2004. Many ballots were not put into the box. They were put behind, beside or under the ballot box. Several democrats had a "stare down" with the woman in charge, refusing to leave until their ballot was put into the box. One known democrat was turned away, for no reason. Another democrat was turned away because he had been sent an absentee ballot. Provisional ballots were not available. Several people called out from inside the voting booth saying "How many of these am I supposed to fill out?" When there was a cross-checking of records, several democrats I had recorded as having voted, were not called. My numbers did not match the official numbers. My mother works at the polls in another state. She once said that without cheating, the Republicans would never win.

Comment by Mark D. West (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Marybeth Michelson-Thiery (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Todd Lockwood (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Julie Parker & Gary Anderson (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Margaret Corbett (Advocacy Group)

I am very concerned about the fact that in any computer, there is room for error. Software is like all other aspects, subject to subtle differences. Any selected voted machine MUST have the capability of a totally independent paper trail, in the event of any kind of problem, so that the count can be accomplished with as close to total accuracy as possible.

Comment by M. Lipschik (None)

Computer systems can have undetectable errors. Furthermore, they can breakdown or be sabotaged in ways that are next to impossible to predict and/or detect. Consequently, a way to record votes which does not depend on software is vital to maintain the integrity of the election.

Comment by Marvin Tow (Voter)

I am very concerned that software only voting systems are subject to errors that cannot be found during the voting process. A verifiable paper ballot, receipt, or some other written record must be created during the vote and kept safe in order to validate an individual's vote.

Comment by Julie Zimmerman (None)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Tom Leff (General Public)

It is extremely important that the public BELIEVE that the election results are fair and accurate. All computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect as has been shown time and again. Just as important, even if the experts foolishly insist that they can prevent this, the general public will always doubt their ability. It is not enough that that an election be uncorrupted, It is equally as important that the public believe that the election results are fair and accurate. Without non-electronic backup, this will never happen. There will a significant portion of the public that will never trust paperless voting and that is reason enough to ensure that it never happens. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Burnis E. Tuck (General Public)

Over the past few years I have been alarmed at how the integrity of our voting systems in this country have been compromised or outright misused. It is just too vulnerable to our democracy to have "high tech" voting systems that can malfunction or be corrupted and be extremely difficult to detect or correct before it is too late. I strongly feel it is critical that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Charles Rubio (Advocacy Group)

All computer systems are subject to all kinds of errors, and morth importantly in the voting process subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Sara Reiss (Academic)

All computer systems are subject to subtle errors and malfunctions, and can be corrupted at any stage of their design, manufacture, and use. The methods of corruption can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mary Ann Fleming (General Public)

our elections are too important to be put into the hands of technology enterprises alone. Only a paper trail can serve as a defense against misfunction, error, tampering, etc.

Comment by Charles C Tate (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Roberta E. Richardson (General Public)

Computers are not infallable, errors can occur at any time, and they are vulnerable to sabotage which may more likely pass unnoticed than with paper ballots. Elections are a crucial part of our democratic republic's function and their integrity should be safeguarded and verified independently with the greatest of zeal.

Comment by Ronald J. McMullin (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Rael Nidess, M.D. (None)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots.

Comment by Felicity Figueroa (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Nina Vought (Academic)

We all know that computer systems can malfunction or be corrupted at any stage of their design, manufacture, and use. If the corruption is deliberate, the ways used to do this can be very hard to determine before or after the occurance. The integrity of elections is crucial to our democracy and therfore voting systems MUST provide a verifiable method of tracking voter intent that does not depend solely on software."

Comment by Alice Bunnell (Academic)

The very important need for this nation's trust in our voting system is to have Software Independence that can be widely advertized to the many concerned activists as tamper-proof. There is a huge need for renewed trust in our government.

Comment by Mark Bendixen (None)

Computers are not perfect, they can crash, they can be corrupted intentionally or accidently. Every time I use a bank machine it shows me the action on the screen, then, most importantly, it gives me a receipt. All computer voting needs to have a real back up to ensure all votes are counted, even if the computer fails, for what ever reason.

Comment by Kent Wilson, Ph.D. (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Kay Peters (Academic)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Robert Shorin (Voter)

Electronic voting equipment is fallable "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Marilyn Stefano (Voter)

Since we all have experience with computers being down, how can we possibly trust them to reliably count our votes? There have been too many examples lately of peoples' votes not being counted because of computer glitches - it's foolish to depend on something that can be corrupted, & not be able to verify everyone's vote. So please make sure that each vote can be recorded and recovered so that the integrity of our votes cannot be broached. Thank you.

Comment by Mike Rosing (Voter)

Software independence is absolutely essential. As a programmer I am well aware that there is no such thing as bug free software. As an embedded systems developer I know there is no such thing as bug free electronics either. Everything can fail in unpredictable ways and it is very important to have backups at multiple levels for something as important as voting. Voter verified paper storage is the simplest, cheapest and most secure method of backup and must be a requirement in all electronic voting systems.

Comment by Robert Nelson (Academic)

In my long career as a systems administrator at a college, regardless of the computer system we were using, we routinely attempted to set up backups of various means, paper included. We viewed this as mission critical for the business of our college. Certainly the same approach should be part of the process of voting in our country, another mission critical process.

Comment by Vaughn Baker (Voter)

Software independence is integral to a democratic election system. This seems so evident that I can not understand opposition to it unless some groups have ulterior motives that are in antipathy to a free and open election sysztem. So, why do we have to fight for this if we truly want a free and verifiable election system. Software can be manipulatede either at its inception or subsequent to it. Therefore, we should not rely on any software system to provide us with tangible, reliable voting results. Only with a paper trail that can be verified will our election system and our democracy be insured. The optimal way to insure this is with paper ballots with optical scanners. Then, we always have the original document as a check against fraud. It is a shame and a disgrace that we are even considering farming out our election process to private companies.

Comment by Gene Douglas (Voter)

A paper trail should exist that would allow verification of a voter's intent, which does not depend on a computer having worked properly, any error being either intentional or unintentional.

Comment by Kevin Karplus (Academic)

Software independence is an absolute requirement for a voting system, but it does not go far enough. There must be mechanisms in place for detecting faults---manufacturers of voting equipment are not to be blindly trusted! This means that all software used for collecting or counting votes must be open source, with the source released months before the election. There must be mechanisms for verifying that the software being run is, in fact, the software that is claimed is being run. There must be required independent counting of some fraction of precincts, to detect potential problems with the software.

Comment by Paul Jakubik (General Public)

As a software professional I know that even under the best conditions software always has undetected errors. No one has ever produced bug free software, let alone bug free systems of software, hardware, networks, etc. When that software potentially controls the outcome of an election, relying solely on software is a tacit admission that the public's votes don't actually matter. There must be a software free way to audit and verify the results of an election. Every precinct should be required to perform a software free audit of a random sample of ballots, and if the results of that audit are not close enough to the software reported results, then a full software free recount of the votes in that precinct should be performed. Voting systems must provide a way of recording and recovering voter intent that does not depend on the reliability of software. The guidelines should require voter-verified paper ballots, required sampling of the paper ballots in every precinct, and full software free recounts of all votes in a precinct when the difference between the random sample and software reported results are not statistically acceptable.

Comment by Roger D. Easson, EA (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Teresa N Blaurock (Voter)

All voters want the assurance that their votes cast on an optical scan or other type of electonic recording machine will be recorded as intended, not corrupted by design or by accident. We must have a requirement in the laws to insure that either voter-marked paper ballots or voter-verifiable paper records are a component of each machine bought for and used by an entity: state, county, or precinct. We must not lower our standards in any way that could allow purposely corrupted election results.

Comment by Dr. Christopher Stanley (Academic)

I strongly urge that federal standards for voting machines be software independent and include a paper trail for each vote. There are too many potential dangers with machines that have no paper trail--their use could undermine our entire democratic system by throwing the legitimacy of the process into doubt. I fail to see how anyone (other than the companies who make the machines) would even consider a machine that has software that can be manipulated and no way to verify the votes.

Comment by Amy Harlib (Voter)

We cannot entrust one of the most vital functions of democracy to computers!All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Citizens MUST have verifiable paper voting records.

Comment by Eugen Dunlap (Academic)

One can not rely on the reliability of the software; so therefore the system must have a way of recovering the intent of the voter, a record of it

Comment by Felipe Vidal (Voter)

Software Independence must be required to ensure that results are accurate and reliable. Computer software code is subject to errors, corruption, or manipulation and should not be relied upon exclusively to provide election results. For the purposes of voting, software-based systems should only be used as a means of providing improved interfaces for voters and summary reporting but it must generate a separate, countable, and voter verifiable ballot. A software-based system for voting cannot be checked for accuracy if it can't be checked against a non-electronic ballot. As a matter of background I have a 15 years of professional IT experience in various roles. Please ensure the SI clause remains in the final rules. Thank you for taking the time to read my comment. Sincerely -felipe

Comment by Anthony Maresco (Voter)

A paper recording of each vote is the only way to insure proper - independent - oversight of voting results; this, couple with random, independent recounts of a statisticaly relevant percentage of votes cast will insure the accuracy of vote tallies.

Comment by Nancy Dobson (Academic)

In order to have a democracy we must have a verifable vote count. It would increase citizen confidence in government if software independence is requied in our voting systems. Please include this section in the law.

Comment by Julie Lambakis (Academic)

Software can be tampered with and is not reliable. We need a paper trail for an accurate count. Thank you, Julie

Comment by Dalya Massachi (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.Thank you.

Comment by Gayle Mills (Local Election Official)

As a citizen and clerk in local elections, I feel it is of utmost importance that each vote is verifiable. I need to know that my vote is recorded accurately and that those who come into my election site can be assured of the same accuracy. It is absolutely fundamental to our democracy that voting be verified by marks on paper made by the voter, not just computer feedback. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Barry G. D'Orazio (General Public)

As a Computer systems professional for over 50 years I am very aware that Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Lis Baumann (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. I want each vote to count, and if software glitches occur, I want a recorded tally of votes taken thus far to count.

Comment by William Pollak (Voter)

An independent, separate record of voting is ideal. Software, it's ultimate intent and installation is subject to manipulation. A paper or other independent recording system is essential to prevent any further decay in the present and proposed electoral system of our country. Thank you. William Pollak

Comment by Matt Morgan (Voter)

Software independence is essential in any voting system. Software can fail in unpredictable and difficult-to-detect ways. It can also be tampered with. It is therefore crucial that our voting systems provide a software-independent means of recording, reporting, and recovering voter intent.

Comment by Barry K. Miller (Local Election Official)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Claudia Leff (Voter)

As a database developer and programmer analyst, I know too well how software can contain errors that can go undiscovered for a long time. For our voting systems to count each vote *as the voter intended*, it is essential that the voting system has a way to record and report the vote *independent of the software*.

Comment by Michael Grimes (None)

You have got to be kidding. If there is one thing that we need it is voting that can be verified. Computers are not the answer as the old phrase still holds true: GIGO = Garbage In Garbage Out. Additionally, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use.

Comment by Kay A. Abraham (Local Election Official)

I agree with this new requirement

Comment by James H. Menasian (Voter)

As one who has been a professional Computer Programmer for the past 20 years, it is definitely clear that no software application is 100% immune to errors. In addition, computer hardware can malfunction (or be deliberateley manipulated!) at any stage of their design, manufacture and use. Testing and debugging, along with all forms of Q&A review, is never 100% perfect. Therefore it is absolutely essential that a physical paper trail (which was previously verified by each individual voter!) be available. Because there is no such thing as 100% Software Independence, without a paper trail backup, I will never feel confident that my vote has accurately been recorded.

Comment by Michael Owen (Voter)

I believe the integrity of elections depend on voting systems that provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Lois Mason (Voter)

It is imperative that we include this provision for software independence. I cannot imagine why we would not want to include it. Public trust in our election system is dramatically reduced, because of unverifiable results and the ease of software manipulation, as well as unintentional "computer error." The strength of our democracy depends on voter trust, so please, consider software independence a required ingredient of any election reform.

Comment by Helen Hanna (Voter)

It is a proven fact that all computer systems could malfunction or be corrupted at any time. It is therefore absolutely essential that there be a paper trail that does not depend on computer software. Without this kind of assurance, voters will not feel that the system is reliable.

Comment by Brian Napier (Voter)

As I have just most likely addressed my key concewrn in the wromng section of your "Comment Section" , tjis is probably an excellent , if inadvertent case in point , why ALL voting systems really must be Totally Software Independent !! Our Nation has suffered 2 Highly Dubious Election cycles in 2000 and 2004 and Public Confidence could hardly be lower !! The mistake I made a few minutes ago highlights what can go wrong without an adequste paper trail !! My background was in accounting and finance and I ALWAYS maintained my paper trail !!

Comment by Carl Zimmerman (None)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Carla Weiss (Voter)

I'm not very good with words. I spend a lot of time on the computer, and know the following to be true: All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Jeanne Hardy Miller (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections and to our country that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Severo M. Ornstein (Academic)

As one who helped design the world's first personal computer at MIT and later did the hardware design for the first router of what has become the Internet, I am all too familiar with the vulnerabilities of computer systems both to conceptual errors and to deliberate meddling. Sole reliance on software systems has time and again led to unanticipated and catastrophic failures. The only way to deal with this problem is to provide completely separate and redundant mechanisms against which results can be compared for validation. For a system as crucial as the voting system such redundancy must be an absolute requirement. Omitting it would ignore the realities of prior experience and amount to criminal neglect.

Comment by Angela Herring (Voter)

Even the best computers and operators can and often do have "glitches". I want a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by League of Women Voters of Orange, Durham, Chatham Counties in NC (Advocacy Group)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Rhonda R Granger (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. These corruptions could be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by David Finkelstein (Voter)

Software-based voting systems are inherently inappropriate for counting secret ballot votes. If voting systems rely on software, the public will NEVER have confidence in the outcome of elections. This is because the public cannot see the votes being counted, or understand the method of counting. We need hand counted paper ballots, which are the most reliable and appropriate technology to use.

Comment by Roger Leahy (General Public)

Despite the best intentions of software and computer systems, errors or corruption of results may happen. For that reason, it is essential to have an independent means of auditing the results and of verifying that the voter's intent has been realized. Such systems should store a hard copy of the results which is retained for future auditing, and we should not rely solely on the reliability of the software. Thank You.

Comment by Joan Abruzzo (Voter)

As a voter, as a teacher, and, most of all as a citizen, I am extremely concerned that we, as a nation, are rushing headlong into a catastophe. I am very aware (and as everyone who is computer savvy should be) of the inherent limits and very possible MISUSE of computerized voting WITHOUT A PAPER TRAIL. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Larry D. Sumner (Voter)

As a physicist working at a Navy lab I was in a position to write a significant amount of software. If there is one thing that I learned it is that the writer of the software (especially operating systems ) controls every action that the computer performs or can perform. I am confident in saying that there is NO software that can't be compromised. Elections are a fundamental element of our government and accurate counts AND accurate records of the counts must be obtained. In my opinion no computerized count should be utilized unless it has been independently verified. Independence requires by definition that the count can be repeated without any use of the computers used to provide the original count. At the very minimum, no count should be utilized that is not at least capable of independent verification.

Comment by Patricia Parsley (Voter)

It is crucial that our voting system remain independent of software which can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is absolutely necessary, for the preservation of fair and reliable and accurate elections, that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. This is crucial to the preservation of democracy.

Comment by Peter Belmont (Voter)

I write to ask that SOFTWARE INDEPENDENCE be an absolute requirement of all acceptable voting systems. I was a COMPUTER PROGRAMMER for 25 years. I know that there are many sources of error. (1) Even well-intentioned programmers make errors. (2) Even well-intentioned QA (quality assurance) people (and testers) fail to detect and correct all errors. (3) Malicious changes to software are possible at the SPECIFICATION LEVEL (management), DESIGN LEVEL (high-level programmers), IMPLEMENTATION LEVEL (lower level programmers), and QA-(testing) LEVEL. (4) Software can, in some cases, be altered from outside (by so-called 'hackers'). (5) In some systems, the ENTIRE SOFTWARE PACKAGE can be replaced at the polling place with a fraudulent SOFTWARE PACKAGE. (6) USERS of software (such as polling officials) can supply faulty input, BY ACCIDENT, which will invalidate the results of using the software. (7) USERS of software (such as polling officials) can supply faulty input, MALICIOUSLY, which will invalidate the results of using the software. With all of these sources of error, it should be a requirement of ALL VOTING SYSTEMS that the correctness of the entire voting process be INDEPENDENT of SOFTWARE. As so conceived, SOFTWARE would provide a REVIEWABLE resource, one among many, like exit-polling, but some other mechanism (such as a VOTER-REVIEWABLE PAPER TRAIL, would always exist to obtain an unchallengeably correct vote count. Thank you for accepting and considering this comment.

Comment by Thomas Vilms (Voter)

Software is prone to bugs and errors that escape detection and correction during the development process. In addition, software can be corrupted either inadvertently or maliciously one it is in use. In this regard, it is extremely important that electronic voting systems in use in the United States have a secondary or backup capability to verify a voter's selection that is independent of the software.

Comment by Richard O. Stevenson (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Susan K. Baritell (Advocacy Group)

In order to insure the integrity and transparency of our voting process, we need a verifiable, voter-marked paper ballot of record. This will also provide the ability to have a reliable audit, when needed. Hand counting at the precinct would take a little longer for results, but it would be the most efficient way to get the correct count the first time. Isn't this what we really want?

Comment by Susan Spivack (General Public)

Since there is no way for a voter or a poll worker to detect that a computer's software has been tampered with or malfunctioned if what appears on the monitor is what is expected to appear on the monitor, and since it has been amply demonstrated by many computer experts over and over, that voting machine software is definitely hackable and can be programmed to record votes differently than what the screen would show to a viewer, this provision (2.7A)is saying there must be a way to cast and count votes separate from and independent of any computer (including optical scan machines) and its software. Therefore, there must be a paper ballot for every vote (or some other voting system like NY State's old lever machines) to provide the means of verifying a vote. Why pay for very expensive touchscreen voting machines which must be stored in climate controlled spaces, maintained and updated frequently and replaced frequently as they get outmoded, when using paper ballots and hand counting them is going to be required anyway to guarantee voting integrity. Why not create very careful procedures for counting ballots that would minimize possibilities of fraud instead?

Comment by Joan L Griscom (Voter)

This is a crucial item, given extensive evidence about computer malfunction and abuse. Computers can be deliberately corrupted at any stage of their design, manufacture, and use. The methods can be extremely difficult to foresee and detect. To preserve the integrity of elections, voting systems must provide a means of recording and recovering voter intent that does not depend on software reliability.

Comment by Evalyn Bemis (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mary A. Crimmins (General Public)

All systems are subject to error which is sometimes very subtle. Computer systems can and do malfunction and they are also be deliberately corrupted.The voting systems must provide a means of recording & recovering intent of the voter that does not hinge on the reliability of the software. This is crucial. The integrity of the election depends on it.

Comment by Frank G. DeMarco (Voter)

Sirs: All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Frank G. DeMarco 241 Ave. of the Americas, #11C NY, NY 10014

Comment by Sean Bailey (General Public)

It seems to me that this requirement is of the utmost importance. Without the ability to double check the votes, without a redundant system in place to catch mistakes or vote fraud (though I would submit that it is not really fraud, but actually treason) we can not have faith in the results of our election day decisions. We need absolute confidence, or as close as is humanly possible, that our votes are actually counted. Thank you.

Comment by Linda Swindle (Voter)

Software indepandence must be mandatory and votes must be independently verifiable in order to insure that votes cannot be tampered with!

Comment by Stephen de Francesco (Voter)

Any voting system MUST have a voter-verifiable paper component. Computers make errors and can easily be tampered with.

Comment by Kris Vaitkus (Voter)

This topic seems so black and white to me. Computers don't always work properly. How can we know what the true results are of any vote unless there is some sort of independent way to be sure not only that the computers are doing what they are supposed to do, but in cases of any lost votes or votes that have been recorded wrong. There are errors based on machine failure and there have been those that have no problem with "beating" the system to win.... We call ourselves a democracy. Let's guarantee that we are by having all the votes be accountable for.

Comment by Marc Garber (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Micheal Berla, Ph.D. (Voter)

There is no requirement for voting systems that is more crucial than that of software independence. The numerous instances where lack of such independence has cast serious doubt over the announced results of an election testify to the urgent need. At present, and for the foreseeable future, nothing will provide this independence other than voter-verified paper records. While there may, some day, be alternative systems, VVPR with mandatory random hand-counted audits is presently the only KNOWN system for producing software-independent voting systems.

Comment by Hal March (Voter)

Unquestionably the public perceives a computer to be a machine that is extremely flawed, frustrating and prone to foul-ups. Using computers without paper backup is going to lessen public confidence in the voting process. To keep the public trust it is absolutely necessary to have voter verified paper ballots.

Comment by carlos bauza (Voter)

Our electoral process cannot rely on something as fallible and corruptible, by human intent, mechanical malfunction, and otherwise, as a computerized system. The hardware on which such a system would depend is not failsafe, and its software can miscalculate votes anywhere between the casting and the final report, by internal error or corrupt programming or use. We need physical proof of whom the public votes for so that the counting process cannot be manipulated. Paper ballots are possibly the best way to measure this.

Comment by Vesna Glavina (Voter)

Every computer I have ever known or read about is sensitive to human error and human intent both. But it is near impossible to determine whether questionable output is the resulte of unexpected input, and is genuine, or is the result of software corruption--especially when "trade secrets" are invoked. It is urgent and imperative that voting systems provide a means of recording and recovering voter intent which is incorruptible and independent of software, in order to give voters confidence in the voting process--and their elected government.

Comment by Margaret Cretzmeyer (Academic)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Michael McGee (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Without verification we can never expect the public to trust the vote. We have one of the lowest voter turnout percentages in the world among the industrialized nations, the reason why may well have to do with a public that sees it as pointless to vote within a flawed election system.

Comment by Dr. Paul E. Tartaglia (Academic)

Software Independence is a must have. Those of us who work with complex (and even simple ones) programs (e.g., CAD, finite element analysis, etc.) know that results MUST be verified independently of the results yielded by the software itself. Nowhere could this be more important than in voting.....

Comment by Christine Danell-Tepper (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Barbara J Brett (Voter)

All software is prone to error and malfunction, even, sometimes illegal manipulation. It is vitally important to have a paper trail to ensure that every vote will be counted and counted correctly. After our recent voting disasters, voters will not consider tallies credible that do not have paper trails.

Comment by James Carnelia (Voter)

Please see that software independence is required as you put together these policies. Computers are too vulnerable to error and, most importantly, corruption. I was very troubled by the questionable results of the 2000 presidential election and I have deep concerns as a voter and citizen that reliance on only electronic records of voting would only increase our vulnerability to manipulation of our votes. Democracy is a precious gift; we must safeguard it as best we can.

Comment by PhoeBe sorgen (Voter)

Democracy is at stake! Indeed, I know many voters who believe democracy in this country is already dead because they understand paper ballots but know that computer voting can be, and has been, hacked. All voting systems must provide a means of recording and recovering voter intent that does not depend on the reliability of software because computer systems are subject to subtle errors and can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. Deliberate corruption of systems can be done in an undetectible manner. Save the integrity of elections!

Comment by Carol Waser (Voter)

Any and all computers can make errors, detectable and not detectable. The threat of possible malfunction or fraud can occur anytime during design, manufacture, and utility. Methodology can be innovative and impossible to discover. If we are to have election outcomes in which voters can be confident, it is absolutely necessary that there be an independent system of recording and accessing voter intent.

Comment by Sherie Helstien (Voter)

All computer systems are subject to subtle errors. Morever computer systems can (and do) malfunction, or be deliberately corrupted at any stage of their design, manufacture and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this and what U.S. voters want, is voter-verified paper ballots.

Comment by Michael Cannella, Pleasant Ridge, MI (Voter)

I am a computer security professional, and much of my job deals with the issues surrounding voting systems: Access, auditing, and integrity Securing electronic data is generally expensive and complicated ----------------------------------------------------------------- Access and alteration of electronic data is fast, easy, and undetectable by appearance--these are some of the great strengths of computer software technology. These strengths can be at odds with security, because they can allow undetectable observation and modification of sensitive data. A software-based voting system that stores data purely electronically might be compromised and modified to misrecord or alter votes without detection. Software-based methods of auditing such a system, and ensuring system and data integrity, are subject to the same risk of alteration as the system they audit. Thus it rapidly becomes extremely costly and complex--if not a practical impossibility--to ensure system integrity and securely audit access via purely digital means. My view is that such assurance would require operating systems and software certified to a U.S. Military TCSEC trust level of B2 or better--an extremely costly and difficult proposition. Paper is well-understood, human-readable, inexpensive, and difficult to casually alter --------------------------------------------------------------------------------------- As a physical and human-readable representation of a vote, paper provides an instant, legible, tangible verification of vote, that can also provide machine-readable and hand-countable options for later audit. Maintaining physical security of paper voting records is more straightforward, and provides a check and balance to the electronic system. The use of paper voting records, in my belief, is the only practical way to assure the credibility of the American democratic system.

Comment by Coleen Christensen (Voter)

I've worked as a programmer--usually trying to fix someone else's code that was doing unexpected (and unwanted) things with the data. Computer code is written on several levels. C# and Visual Basic, for example, use English words with technical meanings in particular ways. But the C# programmer very likely does NOT understand the machine code that actually runs when he/she writes a bit of script. ANY and EVERY computer takes a user input, translates it through programming into machine code, performs the operation, and then translates the result back through machine code into the programming language, and finally outputs the result in the language of the user. There's an old story: when one translates "the spirit is willing but the flesh is weak" into Russian and back into English, one gets something like "the vodka is strong, but the meat is overcooked." Only true software independence can prevent that sort of translation happening to my vote--and yours!

Comment by Daniel M. Hunt (Voter)

It is absolutely imperative that ALL votes are verifiable and uncorrubtable. As software and electronic voting machines and software are corruptable, there must be a paper verifiable way of counting ALL votes. There are way too many "computer errors" already to allow electronic voting machines to be used. With the presidential election being as close as it was in 2000, we cannot afford to have ANY unverifiable or innacurate votes.

Comment by Carol Grenko (Voter)

I am now being trained on a web-based system at my workplace. It fails quite a bit. The rationale is that the system can be upgraded more cheaply and more rapidly with minor actions. When it locks up, much of my work is lost and I have to re-create it in the redundant, and more reliable system that is running beneath it. At least I'm able to see the problem and correct it. With my vote being counted, or not, I would not even begin know what occurred with my vote. The only way that computer voting systems should be allowed to exist is with a paper ballot back up record that can be manually verified in a close race.

Comment by Nedda Allbray (Academic)

Voting and having ones vote is the core value of our American citizenship. As citizens we must have absolute confidence that our vote counts and that it was not corrupted in the process. Computer software can inadvertently make errors in our vote count and it can be deliberately manipulated and corrupted to bring about a particular outcome. Therefore it is essential to the integrity of the voting process that all forms of computer based voting have a paper backup system. Each voter to verify their vote on a paper backup system and that paper backup should be available for all necessary recounts. Without it citizens will lose trust in our government.

Comment by Scott W Beckett (General Public)

It is crucial that any computer voting system have a way to register the intent of the voter that is software independent, since there is no way to control or predict in advance all the ways that software may be written to surreptitiously change a vote after it is registered. Thus, in case of recount, there must be a way to recover voter intent that does not rely on the software.

Comment by Lauren Rowland (Voter)

When I vote at my Fort Lee, NJ polling place, I am alarmed that there is no way to check my vote. I have no idea if it just evaporates or is definitely fairly counted, because there it registers only in a computer. You've probably heard this before, but all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. thank you, Lauren Rowland 242 Mccloud Drive Fort Lee, NJ 07024

Comment by Julie Carlson (Academic)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Please insure that everyone's vote is coounted correctly and that they can be varifiable.

Comment by Elizabeth Moore (Voter)

As a software engineer, I know that it is impossible to create a system that is free of errors. Problems involving data integrity, as opposed to system failure, can be very difficult to detect. For this reason, it's essential to have ways of checking the data that do not rely on the software itself.

Comment by Saul D. Raw (Voter)

All software and computer systems are subject to subtle failures and error. Therefore, it is essential that any voting system that relies on computers have an independent source of verification of voter intent.

Comment by Janet C. O'Flynn (None)

The performance of any software reflects the skill and intention of its author. All software is fallible. For the purpose of recording and verifying the actual intention of the voters, a separate back up system is necessary. Our nation's confidence in our ability to run free and fair elections depends on this provision.

Comment by Judith McElwain (Voter)

Voting systems should not rely solely on software which can malfunction or be corrupted without detection. Software independence must be part of federal guide lines for voting systems. Voter-verifiable paper records are essential to reliable election results.

Comment by

 

Comment by Roberta Belulovich (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Kathleen Maher (Advocacy Group)

As a software designer/developer, I know there is an infinite number of ways that software can be either deliberately or accidentally corrupted. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Paper ballots and random audits should be required.

Comment by Karen Lyons (Voter)

All computer systems are subject to blatant errors. Since working with computer systems which do malfunction periodically, there is NO WAY anyone can guarantee 100% error free. Due to the importance of the voting system and our democracy, voting machines should contain a paper trail backup system for EACH person’s vote. Computers can also be deliberately corrupted from design to even during the day of voting, and afterwards. My husband is a computer hardware designer and is very familiar with computer problems and manipulations to get things to work the way the company desires. Therefore, it is crucial to present population of the United States and the democracy in which we live to past on to future generations a voting system which provides a means of recording and recovering voter intent that does not depend on the reliability of software, and honest people who verify those results.

Comment by Beverly Emmons (Voter)

Software of ANY kind must be backed up by paper..voter verifiable and election officials countable.The ultimate power can only be with the people whose wishes must be CLEARLY understandable

Comment by Richard Frye (Academic)

Software independence which eliminates completely any possibility that deliberate programming, tampering, hacking, or any other failure of voting machines to perform accurately, reliably, and auditably can happen is absolutely essential for every voting machine system allowed to be used in any public election.

Comment by Neil Redding (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Harry W. Crosby (Academic)

Voting records must be verifiable and capable of review, that is, they must recorded in a tangible medium as well as whatever software driven tallies are made for immediate convenience. Software by itself is unacceptable because it not only may, and often does, contain design flaws, but it is susceptible to being illegally entered, change, and manipulated before or after the fact of voting in order to control and alter the recording or counting of votes in predetermined ways. Verifiable, material, durable voting records must be a goal of the rules covering the methods of marking, counting and reviewing ballots in the United States of America.

Comment by Lionel R. Logan (Advocacy Group)

All Computer systems are subject to errors either through normal use or intentional programming. The results can be difficult to detect. Therefore, I implore you to provide a means of recovering voter intent that does not depend on software reliability.

Comment by Jill Godmilow (Academic)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. They are also subject to subtle errors. Voting systems must provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by KarinMattone (Voter)

It is all too obvious that machines and malfunction or be corrupted as seen in past elections and demonstrations shown to the public. Our vote is the the basis of our democracy and must be kept as secure as possible. Therefore, it is crucial to the honesty of the results that there be some means of recording and recovering the voters intent that does not depend on the reliability of the software. A PAPER TRAIL MUST BE ACCESSIBLE FOR OUR ELECTIONS TO BE RELIABLE! At a time when it becomes easy to disfranchise citizens, we as a nation need assurance that all votes count.

Comment by Mary Ann Maikish (Voter)

Agree with 27A

Comment by Sonja Glavina (Voter)

Every computer I have ever known or read about is sensitive to human error and human intent both. But it is near impossible to determine whether questionable output is the resulte of unexpected input, and is genuine, or is the result of software corruption--especially when "trade secrets" are invoked. It is urgent and imperative that voting systems provide a means of recording and recovering voter intent which is incorruptible and independent of software, in order to give voters confidence in the voting process--and their elected government.

Comment by Lorien Phippeny (Academic)

Given that unscrupulous activity, or even simply computer failure , could all too easily misrepresent the will of the voters, we must preserve software independence and give ourselves a paper trail or the equivalent. Please do everything you can to ensure the accurate forwarding of Democracy.... the Love of Life asks that we do all we can to preserve the honest Democratic process, so we may best preserve our world. Thank You ! ~Lorien.

Comment by Tom and Mary Felkins (Voter)

We are well aware of computer glitches. Tom and I use computers at home and many times things do not go right. Sometimes it is due to our error hut more often than not, the computer system is at fault. Mary volunteers as financial secretary at our church and their computer system frequently has mix ups or mistakes. It is imperative our voting system be accurate so that our democracy will be maintained. Voting machines need independent means for processing correct votes. Thank you

Comment by David T. Wellman (Voter)

I believe that the integrity of the individual vote is the most fundamental component of the foundation of our democratic system. This integrity must be safeguarded so that it is absolutely clear that every vote cast is counted as it was cast, and that no other changes to the vote count are possible. This means that manual verification of voting is essential. Reliance only on software is not acceptable, since software is vulnerable to unintentional malfunction, as well as to intentional and malicious abuse. Some system of voter verification and post-vote auditing is necessary to ensure not only the integrity of the vote, but also the confidence of citizens such as myself in that integrity.

Comment by tom hodge (Voter)

As a resident of Florida, I looked on in horror in 2000 and 2004, when voting irregularites may have been responsible for results that did not conform with the majority of voters' intent. The idea of Software Independence would seem to minimize the possibility that such debacles could happen again. Thank you for listening to my concerns. Tom Hodge egdoht@yahoo.com

Comment by Craig Comstock (Voter)

I use my computer every day, but I want to vote using a method that is not subject to subtle errors, malfunction or mischief, any of which could produce errors that would be very difficult to detect. Thank you for restoring our faith in an accurate count by requiring a method of recovering voter intent that does not depend on software, let alone "proprietary software."

Comment by Stewart Wilber (Voter)

Ever since "HAL 6000" in Kubrick's immortal movie "2001", we have been familiar with the rogue computer which goes dangerously awry. However, not even Kubrick envisioned a situation in which our very freedoms might be threatened by the modern HAL's at our polls. This is why any and all voting systems MUST be software independent. Software is created and operated by people, working in an obscure, arcane, and exclusive realm that is inaccessible to most citizens. The opportunities for error and, worse, corruption, are both ample and very difficult to detect. Please protect our most basic democratic right, that of the secret ballot, from HAL 6000 and his sysops.

Comment by Anne Redfern (Voter)

The integrity of voting systems requires a means of recording voter intent and recovering it in an audit or recount, that does not rely solely on the reliability software.

Comment by Ellen Reitemeyer (Voter)

This is the most basic of American rights. Anyone who uses a computer knows how susceptible they are to problems, not to mention the proliferation of viruses and the ease at which evil-doers may manipulate elections. It is not brain surgery to create a paper trail so each voter may know how their vote was counted and have proof of their what their intended vote was. And of course any fault in the software must not be able to change election results, undetected or not.

Comment by Polly Scarvalone, PhD (General Public)

Computers are fallible and software is vulnerable to manipulation in ways that are hard to detect. All votes deserve to be counted so an independent paper copy of the voter's intent must be preserved.

Comment by Lani Evon (General Public)

Despite the belief of some in the infalable computer systems, they are proven to be capable of making errors, can malfunction and more importantly, can be manipulated. If we are to have a nation calling itself democratic and have a national and worldly population believing in our integrity, we must mandate a system of elections that provides an avenue of recording and retrieving all our voters' intent; we must have a paper trail in our voting system and one that does not rely on software.

Comment by Catherine C. Greene (Voter)

The ability for a citizen to cast a vote and know that it will count is the bedrock of a free and responsible society. Our voting machines must receive and record each vote accurately if the United States of America as we know it is to survive "free and brave". Without verifiable election results the ability to manipulate elections and subvert our freedom would be made too easy.

Comment by Donnella Mitchell (Voter)

Because mistakes and tampering can happen, it is absolutely essential that there be a way to verify and audit the votes and that method needs to be separate from the software. It is not acceptable that the software verify or audit itself.

Comment by Sandra Carter (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at ANY STAGE of their design, manufacture, or use. The methods used to do this can be EXTREMELY difficult to foresee and to detect. Therefore, it is crucial that voting systems provide a means of (1) recording and then (2) recovering voter intent; and it is crucial that both the recording and the recovery NOT depend on the reliability of software.

Comment by Linda Kay Russell (Voter)

All computer systems are subject to errors, most perniciously subtle errors. And computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by D. Iris Thor (Voter)

Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacturing, and use. The methods to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. As a voter I need this reassurance.

Comment by Gay Kramer-Dodd (General Public)

Since software of any kind can have errors that are difficult to detect it is very important, for the security of our elections, that all voting systems should be software-independent.

Comment by Jennifer Hathaway (Local Election Official)

I am a voting inspector. I am also a voter and concerned voting rights advocate. Computer systems are subject to subtle errors. Any computer system can malfunction or be deliberateley corrupted during their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. It is crucial to the integrity of elections in this country that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software or the supposed goodwill of a manufacturer.

Comment by Robert & Rose Mary Stearns (Voter)

We American voters have the fundamental democratic right to be confident that our votes are counted as cast. We cannot be certain of this if the voting system we have to use is governed by electronic software alone, with no independent paper record that verifies our voting intent. We urgently call for an EAC mandate that voting systems cannot depend solely on the reliability of software.

Comment by David S. Nichols (Voter)

The integrity of elections requires that voting recording, tabulation, and recovery systems not depend on corruptible or unreliable software. The determination of voter intent must follow means that are independent of computer software.

Comment by Mary Anne Fratelli (Voter)

No computer system is perfect. Even the most advanced systems are subject to subtle errors. We've seen government and private industry systems hacked into...therefore we need a system that will detect malfunctions or attempts at corrupting the data. In order to ensure the integrity of our elections, our voting systems must also provide a means of recording and recovering voter intent that does not rely on the reliability of software.

Comment by Donald Stillman, Fairfield, California (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Ella May T. Wulff (Voter)

It is absolutely essential that voting methods be software independent. There should ALWAYS be a paper trail. Computers are too susceptible to tampering or even simple malfunctioning, no fraud intended. Oregon's system of voting by mail with voter-marked paper ballots that are then counted by a machine reader is a good example of a software independent system that protects voter intent. In case of a very close election or suspicion of machine reader malfunction or fraud, the original paper ballots are available for a hand recount under the watchful eyes of observers from all political parties. The ability to hold a transparent recount that validates the original vote is imperative for a truly free and democratic election.

Comment by David Saperia (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by suzanne ostrom (Voter)

I strongly urge the establishment of safeguards against software fraud/error. Voters need to know that there choices will not be compromised because of a flaw in the system. There should be some type of paper trail or some other way to verify the voters' choices.

Comment by vicki howard berkofsky (Voter)

It is absolutely crucial to the integrity of the election process that voting systems provide a means of recording (ie, paper trail) that is verifiable. Voter intent must be recorded and it is irresponsible to rely solely on the software of voting machines.

Comment by Susan Harris (Voter)

Ever since the U.S. has been using electronic voting without some type of paper record of the voter's intent, I have been deeply concerned that voting results could be seriously impacted either by error or by deliberate fraud. Without anything to check against, we have no way of knowing EVER whether error or manipulation has occurred. As far as I am concerned, this would mean the death of democracy as we have known it. SOFTWARE INDEPENDENCE IS ABSOLUTELY ESSENTIAL for the integrity of our future voting processes, and therefore, for the future of our democracy.

Comment by James Arrigo Moscow Mills, Mo. (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Julia Tucker (Voter)

All votes must count and all votes must be able to be recounted; therefore, all votes must have a paper trail and all voting machines must be software independent.

Comment by Anka Heim (General Public)

As a voter I urge you to adopt a voting system that can not be tampered with and produces a receipt, a system that produces a meaningful recount that can correct mistakes, should it be necessary.

Comment by Frank Lutz (Voter)

If we are going to have computer voting, we must have verifiable voting, and a paper receipt for the voter. We must have a way to protect the integrity of the machines from partisan or manufactered corruption. Otherwise, paper ballots.

Comment by Gail Brock (None)

Software Independence is important. Since no software is sufficiently robust to be proof against minor corruption, it is also crucial to have a method of recording voter intentions that is itself independent of the software. Voter-verified paper ballots appear the most reliable method of doing so.

Comment by Mary Gardner (Academic)

We must have software independence to have reliable elections. Please see that the voting results are verfiable by some sort of paper back-up.

Comment by Robert Schwartz (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Rebecca Clark (General Public)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Terri Murray (General Public)

The integrity of elections has been compromised by turning the process of vote tabulation over to private companies who (at the taxpayer's expense) have manufactured and supplied voting software that obscures the whole process and ensures that the manipulation of results is undetectable. Not only does software need to be independent, but it needs to be non-existent. Canada hand count the votes for national elections in four hours. The most advanced country in the world can surely do the same.

Comment by Elizabeth E. Grimes (General Public)

We use computers for many reasons. We know that computer errors occur with some frequency. When an error is detected,the correction is to undo the damage caused by it: bank error can be corrected; a document can be re-typed, etc. But no method exists to adjust an election. Voting machine vendors tell us their systems are tested. What testing do they do?They say National Organization of State Election Directors qualified each voting machine as a result of testing done by Independent Testing Authorities. When ITAs "certify"the machines and software, the word "certified" suggests that they have conducted foolproof procedures which verifies vendor claims. What are these procedures? We are not told. It is impossible for any programmer to write bug-free code. Or a programmer could deliberately insert computer code to produce an election outcome to conform to whatever the programmer intends.Examples abound of election day screwups and evidence also exists that suggests there was malicious code. We are told that without voting machine systems, government and media and the public would have to wait for results, perhaps for weeks. But with something as important as an election, there is no greater need than to get it right. The vendors and the election officials who buy their voting machines should bear the burden of proof that their systems work correctly and deliver accurate results. We voters deserve to know, beyond any doubt, that the candidates elected and measures passed did, in fact, receive the required majority of votes.

Comment by Linda E. Nedderman-Eaton (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software, such as paper voting, which can be verified.

Comment by Marshall Gavre (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Dennis Turechek (Voter)

The most reliable system for voting is the old lever machine. It does not depend on soft ware to record results and is unhackable because it is mechanical. All voting systems should be software independent.

Comment by George Riley (Voter)

It is not controversial to note that software can contain errors or problems that are impossible to detect without an independent record of voter intent. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. There is no logical rationale for not supporting software independence.

Comment by Paula Blum (Voter)

All computers and computer systems can malfunction and/or be compromised or corrupted in some way - whether during their manufacture or use. Since these problems can be difficult, if not impossible to detect,it is critical that voting systems be able to record and recover the voters actual intent, without relying on the system's software, which can actually be part of the problem.

Comment by Bettie Blecke (Voter)

Computer systems and software programs are subject to errors, whether by malfunction and deliberate. The current systems have already been shown to display this. What we need is a voting system that does not depend on the reliability of software. Voting is our most precious right and that right has been stripped away.

Comment by Suzanne Harris (Voter)

A VOTER VERIFIABLE PAPER BALLOT is the only way an individual voter can be sure that her/his vote will been counted correctly. Computers are not error free, and the people who design/use them are even less so. It is THE MOST IMPORTANT REQUIREMENT. This cannot be left to doubt. Please, please, please, make it mandatory that all voting systems require a VOTER VERIFIABLE PAPER BALLOT to ensure voting integrity. Thank you.

Comment by Edmund Ballou, D.Sc. (Academic)

Thank you for considering my thoughts. After a 20-year career in software engineering for the most reliable computing platform in the world (the 5ESS switch: 2 minutes downtime per year), I can say with complete confidence that there WILL be failures in voting software and hardware that will not be recoverable unless software-independent mechanisms are in place. If we consider such failures and loss of voter intent to be unacceptable, we must ensure that every system incorporates a software-independent audit trail.

Comment by William R Ferrell (Academic)

The potential subtlety and complexity of software/hardware interaction is so great that any voting system that relies upon it must have a way of determining voter intent that has been obtained independently of the software. And, of course, that independent intent must be able to be compared with software output for verification. Software independence is an essential requirement.

Comment by Judith Childs (Voter)

Judging by my own experience and that of friends, my reaction is to be extremely doubtful about the reliability of a computerized system. Software corruption cannot be entirely predicted nor controlled.

Comment by J. Brown (Voter)

Electronic voting systems should be mandated to utilize voter-verifiable paper records or voter-marked paper ballots so that, should the need arise, the results can be software independent. It is essential to our elections and our nation that the convenience and speed of electronic voting machines also be backed up by paper ballots directly from the voters. The impact of computer glitches, tampering, power outages, natural disaster, human error, or other unforeseen events makes an electronic-only system unthinkable. We have to have unequivocal, verifiable voting with a clear paper trail. I live in Florida. I ought to know. [I submitted a similar comment earlier, but I don't see it in the Comments section. I guess there was an error. Point proven.]

Comment by Michael W Evans (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Marion Shulevitz (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Linda Lee Christenberry (Voter)

Please keep software independence. As a voter, I'm concerned that all votes are accurately recorded and counted.

Comment by Raoul Drapeau (Local Election Official)

Of all the aspects of voting equipment, the need to be independent of software in the capture og voting data is perhaps the most important. Whether by error or mischief, it is impossible with a virtual record to perform a true recount. The only way to be assured that the count or recount is accurate is to have a paper record of some kind. Precinct scanners of paper ballots are to be preferred over "receipts", since scanners give the voters and officials the opportunity to alert the voters about errors (overvote, undervote) before the ballot is cast, thereby leading to a more meaningful count.

Comment by Ray Padgett (Voter)

I spent over 5 years doing international computer audits for a major corporation. There is NO WAY to prevent computer fraud in an election process unless you have a paper audit trail of all votes and then actually require an audit. I agree that all election processes must be software independent.

Comment by louise meyers (Local Election Official)

All voting systems MUST be software independent We cannot continue to have citizens disenfranchised because the system is not verifiable!!!

Comment by George McKee (None)

As a Certified Information Systems Security Professional (CISSP) I am acutely aware of the myriad numbers of ways that systems incorporating software components can malfunction, either through well-intentioned error or through malicious interference. It is critical that voting systems not be subject to these errors. The simplest and most reliable way of assuring software independence is via a voter-verified paper copy of each ballot. Methods for assuring the integrity and confidentiality of paper ballots are well understood and can be easily incorporated into electronically-assisted election processes.

Comment by Tom Willner (Voter)

I have worked in information technology for over 16 years, and errors in computer systems, both unintentional and deliberate can be extremely difficult to foresee and detect. It it absolutely imperative that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Regina Saisi (General Public)

All computer systems can make mistakes. Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Or to put it simply please, please don't let our votes be susceptible to fraud. Computers and software can be tampered with and no one knows the difference.

Comment by Carol Hancock Gold, Ph.D. (Academic)

In my many years of experience with computer software, I have become more and more cognizant of the unknowns the occur behind the scene -- over which I have no control and and no knowledge. All computer systems are subject to subtle errors, intentional or unintentional. Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect, but computer experts have verified how easily they can happen or be carried out. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does NOT depend on the reliability of software. Thank you.

Comment by Roger E. Brumley (Voter)

My comments are in regard to maintaining software independence in voting systems. Voting systems must provide for a way or means to record and recover voter intent that is separate from computer software. Thank you for your consideration.

Comment by ellen Mason and Dudley HArtung (Voter)

To whom it may concern: We strongly urge Congress to continue Software independence in this legistation. The authority of our elections , and hence of our nation, depends on it. Thank you

Comment by Robin Arnold (Voter)

Everyone knows that computers make errors, whether there are defects in the hardware, software, or whether there is intended corruption. For the integrity of the voting system, it is imperative that we have voter verifiable paper trails for all machines used. Also, there needs to be a way to recover voter intent that's not reliant upon software.

Comment by Kacia Lee (General Public)

THANK YOU for including this section mandating software-independent systems! Computers are great, but there are so many ways for errors to be introduced that could go undetected if systems are electronic-only. Here in Minnesota, we use optical-scan machines AND audits to ensure that every vote is verifiable. Every citizen in the country deserves to have as much confidence in their voting system as I do in mine!

Comment by Judith C Zwald (Voter)

We MUST be able to verify votes and software is not a reliable method.

Comment by Eric Ogden (General Public)

I and everyone I know believe that the best way to ensure a secure and accurate voting system is to ensure software independence. In other words, because software and computers can be manipulated and can malfunction, there needs to be an alternative record of each vote such as a printed piece of paper. We have this on ATM's, why can't we have it for voting. This way the voter can check to see that his/her votes were recorded properly and there can be way of back checking in case of a recount or contested voting results. Thank you to all who work for the Common Good as I and all my friends do, Sincerely, Eric Ogden, Lab Technician.

Comment by Mark Newman (Academic)

Of all the shocks in the past 7 years -- and many have been bad and made me angry at the cynical 'efficiencies' of the Bush Admin -- undermining the structure of our elective systems is the worst. Proprietary rights and software that can't be traced and buddies of the people who give them contracts? Come on. Someone has to be able to track actual votes!

Comment by Evan Korth (Academic)

As a professor of computer science (at NYU) I understand the types of errors computer systems contain. They can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Jeanne Green (General Public)

Since electronic voting equipment can be very easily corrupted, it is necessary to leave a paper trail and not rely on electronic voting equipment unless there is a software-independence requirement. We cannot leave our votes at the mercy of Diebold or any other voting-machine company that may have ulterior motives to not count every vote. Thank you.

Comment by Robert Wheeler (General Public)

It is imperative that any tampering with the official vote count be eliminated. For this reason, no company that has any potential conflict of interest should be allowed to sell voting equipment or machines to electoral commissions or departments. In addition, the electronic voting machines, which can be programmed to change election results or be easily corrupted, should be phased out as quickly as possible. I also agree fully with the following statement from Veried Voting: "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by J. Brown (Voter)

Voting systems should utilize voter-verifiable paper records or voter-marked paper ballots so that the voting process is software independent. Electronic systems may be subject to errors or tampering or power outages or catastrophe. Only systems with an independent, paper backup process should be legally deemed suitable for the precious electronic process. I live in Florida. I should know.

Comment by Dr. Bruce Harshman (Voter)

It is my understand that all computer systems are susceptible to subtle errors and can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. It is also well known that that the ways (methods) to deliberately corrupt the system from design to use are extremely difficult to detect, much less forsee. It order to protect the public from malfunctions deliberate manipulations of voting equipment, it is extremely critical that voting systems can record and recover what the voter actually voted for and that these recordings and recoveries NOT DEPEND ON the reliability of the SOFTWARE used to perform these functons. There must be reliable back up systems not based on the system recording the vote, such as a paper trail with voting machines.

Comment by susan baldozier (Voter)

Due to limitations of computer systems - subject to subtle errors, can err or be purposely made to error, and at any part of design making or use processes. You can't always detect these errors and can't plan for every potential error or corruption. You HAVE to provide a voting system that ALSO provides recording and recovering of voter INTENT that doesn't depend just on the software.

Comment by Wade Vernon / Houston TX (General Public)

It is crucial that we have the software independence feature, and I insist on a paper back up. It's the only way we can be certain that voter fraud via malicious software--i.e., the kind that DIEBOLD loves to incorporate into their vote theft machines--is curtailed. Otherwise, we may as well be honest and acknowledge that the U.S. is now a totalitarian military police state (which I think it is already, under the loving guidance of Shrub, Chumley and their Neo-con neo-Nazi BUSHTAPO regime). Anybody remember how the President of DIEBOLD guaranteed Shrub Ohio's electoral votes in Part II of our national nightmare, long before the first voter buttons were pressed?

Comment by Janet F Patruno (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by George Showman (Voter)

This is just so crucial. I think Verified Voting says it well: "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software." There is nothing LESS transparent than software code. Its opacity has two levels: 1. Only 'experts' (programmers) can make sense of the code at all (i.e. 'read' it), in most cases. 2. Those experts almost all agree that hidden bugs (Verified Voting's "subtle errors", or, more relevantly, unintended consequences) are _inevitable_ in code. Voting system software probably has tens of thousands of lines of code at least. That is a lot of opportunity for error (see various industry estimates of how many bugs arise on average in X lines of code...). As a former software developer, I know very well how bugs can go undetected for years before certain fringe scenarios arise to trigger a malfunction. Why introduce this uncertainty into our democratic process, especially when creating 'software-independent' systems is relatively easy to do?

Comment by Nancy Nicholson (Voter)

It is important to not solely depend on the reliability of software.Independent verification must be available to prevent corruption of our most valuable democratic right.

Comment by Nancy Chiswick (General Public)

All computer systems can malfunction or be compromised. The public needs to be reassured that every vote counts and is counted accurately. Software must be backed-up by verifiable systems. This is crucial to our democracy.

Comment by Joan Braun (Voter)

It is imperative that there be independent paper verification of our votes. All of us that use computers know that they are capable of malfunction. We as voters are losing faith in the integrity of our voting system, which is the foundation of our democracy. To restor our trust we must have a back-u ballot independent of voting machines.

Comment by David Beirne, Executive Director, Election Technology Council (Manufacturer)

Removes 2005 VVSG classifications for two types of systems, software dependent and those that are software independent. This essentially mandates a VVPAT as an IVVR solution for any state who stipulates a requirement for "2009 VVSG" compliance until such time that products are submitted for certification under the "Innovation Class". Public comments from EAC Commissioners continue to point to the application of this version of VVSG to new voting systems in the future; however, a state that chooses to comply with this VVSG must incorporate a paper trail. This is too prescriptive and does not recognize the voluntary framework.

Comment by Joel Dworin (Academic)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Marion Perkus (General Public)

It is absolultely crucial that any voting system be verifiable by a paper trail. We all know that computers/software are prone to error, whether malicious or from innocent, unintended glitches.

Comment by Ralph W Sullivan (General Public)

"Those who vote decide nothing. Those who count the votes decide everything." Joseph Stalin If the ATM machine I use can produce a paper receipt why can't a voting machine? The answer to this question is stated in the above quote. Electronic voting was never intended to correctly count every vote. It's only purpose is to skew the vote tallies to the will of those who benefit financially from the out sourcing of citizens rights.

Comment by Shirley Barsky (Advocacy Group)

We must not depend on the reliability of software used in the DRES (electronic touch systems). Software can be invaded and many states have had great disparity in the number of votes recorded (Miami Dade County in Florida had more votes recorded than registered voters). Some DRES provide a paper ballot similar to ATM machines--on thin little sheeets of paper and with hardly visible print. Random Manual Audits are essential and must be uniform and dependable. Central Count Optical Scan Machines should be able to subtotal and store results for batches of ballots--expeccially for absentee and provisional ballots. And these machines are clearly more cost-effective. Software Independence is best accomplished by voter-marked paper ballots and voter-verifiable records.

Comment by Kaaren Hardy (Voter)

To ensure that we voters can be confident that our votes have been accurately recorded and tabulated, voting systems must provide a means of recording and recoviering voter intent that does not depend on the reliability of software. Since the best of computer software can fail or be deliberately corrupted, there must be some independent "paper trail" to verify that our votes were counted as we cast them.

Comment by Steven Orkin (Voter)

Despite advances in technology, computer systems remain subject to error, malfunction, sabotage, and subversion. Such problems can be extremely difficult to diagnose, let alone correct. In light of recent problems with voting machine technology, it is nothing short of moronic to rely on them without the use of paper ballots to ensure quality assurance. Let us exercise common sense. Our futures may well rely on it.

Comment by Susan R. Schnur (Voter)

It is absolutely vital that the vote be independently verifiable by paper trail. The recording and recovering of voter intent must not depend on the reliability of software. It is too easy to change, say, every onehundredth vote to "throw" an election unless a recount can also be made independently. Also, of course, we have all had computer crashes in which our data are lost. Thank you, Susan R. Schnur

Comment by RandalDoane (General Public)

All computer systems are subject to human error. Computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots. A paper trail is essential for the preservation of democracy.

Comment by Ina DeSoto (Voter)

Without a verifiable paper record of my vote I will never feel confident that my vote was recorded or recorded correctly. Do not accept a voting system without a verifiable paper record.

Comment by Dr. Mha Atma S Khalsa (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Carol Adams (None)

We need a traceable and verifiable votetracking system that assures the voter's intent is followed. This cannot be done with total reliance on computer software.

Comment by H. Richard Leuchtag, Ph.D. (Voter)

All computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Ann Hustvedt (Voter)

I personally believe we should only have paper ballots but if we must have computerized voting, then there needs to be software independence. This is because there can be so many cases of errors or deliberate corruption throughout the entire developmental process and use. The methods used to do this can be extremely difficult to foresee and detect. I believe it crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Rich Sims (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Only systems that utilize voter-verifiable paper records or voter-marked paper ballots make my vote honest, correct and verifiable. Please make sure implementation of this occurs immediately. Thank you

Comment by John McIntyre (Voter)

Whatever it takes, our voting should be as secure as possible. Software independence makes sense to me.

Comment by katherine randolph (None)

I oppose any system that does not allow for voter-verifiable paper records or voter-marked paper ballots. I have enough computer experience to know that they are extremely unreliable and corruptible.

Comment by Janet Ievins (Voter)

I am very concerned that the 'fix' actually be better than the perceived problem. Actually, here we have always used lever machines which have NO problems. But if we must have something 'other', then we must make sure that computer software is not involved. Computers can be hacked, changing the intended vote. Of course we would be assured that we can trust officials. I do not personally subscribe to this view, but if the software had been hacked, the reassuring official may well not be aware of it him/herself.

Comment by Boris Kofman (Voter)

As a software professional, I am well aware that software-based systems often malfunction. It is imperative, therefore, to mandate software independence for all voting systems.

Comment by Carol Smith (Voter)

Software independence is a must. Computer systems can develop errors without anyone tampering with them. But most importantly, WITHOUT A WRITTEN RECORD OF VOTES, IT WOULD BE POSSIBLE FOR ELECTIONS TO BE MANIPULATED BY CORRUPTING SOME OF THE SOFTWARE USED IN SOME OF THE MORE CRITICAL STATES OR DISTRICTS. It seems routine for hackers to break into systems including banks and credit card numbers, hospital files. If it can be done on the internet, it can be done with software. The election results are too important to be left entirely to computers without backup.

Comment by Iris Ciabattari (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Joyce McCloy (Advocacy Group)

"Every voting system (perhaps every system of any kind) is insecure. Making them more secure is a desirable secondary priority, but unless we focus everyone on ensuring both auditability and effective auditing, we're just going to create an impossible muddle." ~ Dr. David L. Dill, Founder of the Verified Voting Foundation . Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software Joyce McCloy, Founder - North Carolina Coalition for Verified Voting

Comment by Reveira Wilcove (Academic)

Software can malfunction or can be deliberately tampered with. It is essential that there be a system in place that can cross-check the electronic tabulations with a verifiable paper trail.

Comment by Susan Bannister (Voter)

It is essential to the integrity of elections that voting systems provide a means of recording AND recovering voter intent that does NOT depend on the reliability of software. Software can contain errors or problems that are impossible to detect without an independent record of voter intent. With present technologies, only systems that use voter-verifiable paper records or voter-marked paper ballots are software independent. It is critical that software independence be a key part of the federal guidelines for voting systems. Every vote must be counted as the voter intended. Please ensure this with software independence.

Comment by Todd Eddy (General Public)

I'm certainly not an expert on voting machines and systems, but it seems to me the property of "software independence" is very important to maintain. What could be more corrosive to public confidence in the voting process than the possibility that there is a gremlin in voting machine software that can't be detected? We all have had enough experience with inexplicable computer behavior to know they're not perfect. It would only take one kooky election return, with no independent method of checking it, to make people suspicious of elections in general, perhaps for a generation, perhaps longer. Why run the risk? What is the down side of keeping a paper record? Seems like a no-brainer to me.

Comment by Gary Coil (Voter)

Because of the inherent corruptibility and manipulability of computer systems software and hardware, it is crucial to the integrity of our elections that voting systems be designed to record and recover voter intent in a manner independent of the reliability of the software.

Comment by Jennifer Hathaway (Voter)

Every computer system is subject to subtle errors. Computer systems malfunction and can be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Maureen McCue MD PhD (Academic)

Evidence to date indicates that all computer systems are subject to subtle errors. Computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. We demand receipts from automated bank tellers for this very reason. Our electoral integrity is no less critical to our nation. It is crucial to the integrity of elections and democracy that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Nethaneal Blacklock (Voter)

As a computerized-system validation professional in the FDA-regulated industry of pharmaceutical manufacture, I am both dismayed and disturbed by the fact that paperless voting systems are somehow regarded as infallible. And as one who builds, maintains and enjoys computerized systems I have no reflexive fear of computers, rather I have ample knowledge and experience to know that all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Linda Seeley (General Public)

It is absolutely crucial to the integrity of our elections that voting systems provide a verifiable means of recording and recovering voter intent that does NOT depend on the software. Any software can be corrupted at any stage of design, and the corruption may be undetectable in testing. We need to be able to count the votes. It's the only tool we have as a democracy to prevent massive corruption.

Comment by Jay Sweeney (Advocacy Group)

Software must be open source, not proprietary.

Comment by Andrea A. Abbott (General Public)

A record of citizens' votes should not just "evaporate" subsequent to an election. There needs to be a reliable method in which votes cast can be confirmed/validated by all interested parties.

Comment by Mary Vollero (Advocacy Group)

In order for citizens to maintain confidence in the election process any and EVERY voting system needs to include a voter verified paper ballot AND random, mandatory audits of these ballots in all elections.

Comment by Andrea Radich (Voter)

I want only voter-verifiable paper records or voter-marked paper ballots for all my votes!

Comment by Ammiel Schwartz, MD (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Joshua Berk Knox (Voter)

I strongly support software independence, and I believe this is best accomplished through voter-marked paper ballots. It is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots. Thank You. Montague, MA

Comment by Eileen Gottschalk (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mary Lee Adamske (General Public)

It is vital to our right as citizens entrusted with the selection of our public servants that all ballots be verifiable independent of the computer systems used. While mistakes might be inadvertent, incorrect counts have the same chilling effect on our liberties!!!!! This is a concern felt by many regardless of political affiliation---I'm a lifelong conservative.

Comment by Carmela Estes (General Public)

We must have alternatives to software because of the possibilities of malfunctions that are so hard to predict. I would think it is much like being on a tightrope without a net. Not very smart.

Comment by William W. Wakefield (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Sincerely, William W. Wakefield P. O. Box 393 DeRuyter, NY 13052

Comment by Alan Hessler (Voter)

Software programs can be easily manipulated in such a way that it is impossible to even detect that such a manipulation occurred in the first place. It is imperative to maintain the integrity of all elections by keeping a "paper trail" so that fraud cannot occur.

Comment by Barbara D Gregory (Voter)

Any vote counting system must be software-independent. Otherwise it will not be trustworthy. This section must be left in the final document in order to ensure a transparent election.

Comment by Kent Ferguson (General Public)

We must have a paper record of votes cast on machines using software that has been the source of far too many problems in recent elections.

Comment by David Groisser (Voter)

The only sure way to ensure software independence is not to record votes only electronically. A PAPER ballot is ESSENTIAL.

Comment by David T. MacFarland (Voter)

I believe very strongly that voting systems MUST provide a way for recording and retrieving voter intent which does NOT depend on the reliability of software. There must be a paper trail.

Comment by Geoff Kuenning (Academic)

Software independence is critical to voting systems. History has shown (in both life-critical applications and in real commercial voting systems) that software systems are incredibly difficult to get right. Even systems that are thoroughly and expensively tested, such as aircraft control systems, are still deployed with bugs. In voting systems, there is no room for this sort of error. Thus, it is absolutely necessary to have software independence, so that we will be able to detect and correct for the inevitable bugs in the voting software. Anything less would be an affront to democracy.

Comment by Paul Moseley (General Public)

It is critical that any electronically-based vote-recording system include a paper trail that can be immediately verified by the voter. Ideally, the system would produce 2 copies of each vote; one for the voter to keep, the other to be placed in a 'backup ballot' box, to be used as an alternate way to count the votes in the event of a challenge.

Comment by Susan Anspach (Voter)

Software independence ("SI") should be required to be satisfied only by independent voter veriable records. The integrity of our elections cannot just be left up to computers and their software. The recent elections are replete with examples of technology failures undetected until it was too late. The FEC guidelines should state that SI requires a reliable backup for voter intent. Thank you. SA

Comment by d.s. kiefer (Voter)

For me, this is one of the most important requirements, since software/computer systems can contain errors or have problems not readily identifiable, whether intentional or unintentional. Being able to check on a voter's original intent is crucial, and shold not depend on the reliability of software

Comment by Jacqueline Callas (General Public)

From what I understand, ALL computer systems are subject to subtle errors. I am aware that computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. and the means to do this can be extremely difficult to foresee and detect. Understand this, it would make sense that voting systems provide a means of recording and recovering voter intent that does NOT depend on the reliability of software.

Comment by William Perkins (Voter)

Software Independence is a crucial part of creating a secure voting system. Undetected errors or faults can occur in computer systems. Even worse, it is probable that any computer system could be deliberately corrupted. So, voting systems must provide an independent means of recording and recovering a voter's intent. These independent recordings can then be checked, when necessary, against the software and computer reports of voting results. Without these recordings, the integrity of the elections cannot be confirmed.

Comment by Aaron Temin (Voter)

Software independence is a very important requirement. Software is difficult to write correctly, and it is easy to maliciously subvert in ways that are hard to detect. Without software independence, there will be little to justify having confidence in the outcome of an election held using DREs.

Comment by Christina Wadsworth (Voter)

All computer systems are subject to error. And computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Anybody who has an email account has received enough spam to know this is true. Therefore, it is crucial to the integrity of elections and the confidence of the voters that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by JOHN mCnULTY (Academic)

cOMPUTER SYSTEMS MAY MALFUNCTION OR BE CORRUPTED.vOTING SYSTEMS MUST PROVIDE A MEANS OF RECODING AND RECOVERING VOTER INTENT WHICH DOES NOT DEPEND ON SOFTWARW.tHANK YOU

Comment by Robin Ritter (None)

It is imperative that the voting system have a backup paper trail in the case of software malfunctions or breakdowns. We need to be able to record and recover each and every vote. Each persons' vote is a valued part of our democratic system. Not to ensure the counting of even one vote is against the values of our nation.

Comment by yoshaany rahm (Voter)

The public deserves their votes to be counted in an ethical manner, without having to worry about a group of individuals change the votes for selfish, greedy purposes.This is why I strongly support independent voter verifiable records, which include voter verifiable paper records.

Comment by Vicki Perlman (None)

It terrifies me to think that peoples votes will be lost without any paper trail or receipts. Look at the mess that was Florida. My parents went to a Diebold demonstration and the voting machine BROKE! They couldn't even fix it. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Julie Parisi (Voter)

All computer systems and software are subject to error, to malfunction and to deliberate tampering. It is therefore absolutely essential to protect our Democracy by making sure that every voting system have a voter created and verified paper trail.

Comment by Bill Storey (Voter)

If we are to insure the continuance of our Democratic process and insure that every voters intent is accurately recorded, and counted and further, can be verified, if necessary, at a later date, this measure is an absolute must. Every member of Congress is elected to represent the people and to uphold the Constitution, our laws, and the preservation of our Democracy. Any member of Congress who opposes Software independence should be charged with criminal intent. We want to know our vote counts, and that it can be verified. Further, we need voting uniformity across the United States that represents the will of the people, and will exclude forever, the unconscionable interference by the Supreme Court as it did in the 2000 election.

Comment by Jim Tappon (Advocacy Group)

I have worked with computer systems all my working life and I recognize that all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, or use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Bob Segal (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. A paper ballot, or even elimination of electonic voting until such time as a verifiable and uncorruptable system can be created may be a good solution.

Comment by Audrey Koester (Voter)

It is essential that voting systems provide a second method of accurately recording and verifying every vote.

Comment by mark phillips (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Richard P. Rust (Voter)

Obviously in order for democracy to function, the integrity of voting process must be beyond doubt. Modern technology can be an essential toll in facilitating the administration of election, however all computer systems have vulnerabilities of various types from mechanical to the potential for manipulation by corrupt individuals intent on thwarting the will of the voters. If you are to fulfill your obligation as arbters of the future computer voting systems, it is essential that you require u future e systems provide a means to record and recover voter intent that does not depend on the reliability of software."

Comment by Peter Leinau (Academic)

Absolutely critical to maintain a software independant paper trail as a check on the system functionality. In the absence of a direct voter-generated record of each voters intent there is no possibility of meaningful verification, no possibility of actual recount. Thank you for undertaking the critical task of bringing the new voting technologies into line with the public good and public trust.

Comment by Greg Wooster (Academic)

I strongly support a software independent paper or hard copy trail to protect our votes and to assure accuracy during an election. Our democracy cannot risk an election process that relies on electronic vote records only. These are too easily manipulated/corrupted or erased. Accountability now! Investigate, impeach, indict and imprison the treasonous war profiteers in the White House Administration and anybody who would threaten our democratic vote by opposing a "paper/hard copy record" of voters intent.

Comment by Don Hammen (Voter)

Voter intent cannot be guaranteed when voting software is written to allow votes to be altered. It is absurd that there is any debate on whether to allow computer based voting systems that have been deliberately corrupted. There is no place in America for any voting system that cannot record and retrieve voter intent. It is simply un-American.

Comment by Sandra Rando (Voter)

This is necessary to insure each voter that his vote registered properly as well as to help detect any errors or corruption of the software.

Comment by Judith Arnold (Voter)

I agree that - All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Mr. & Mrs. Clarence Vivlamore (Voter)

Most people today own a computer and learn really quickly their disadvantages and the safty guards we must keep current on them. Computer systems can malfunction and they can me manipulated at any stage of their manufacture and during their use. Each persons vote is too precious to take chances & no one should have to wonder if their vote was counted. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent and does not depend of the reliability of software.

Comment by Frank Garciarubio (General Public)

It seems to me that more is being done to usurp the popular vote than to keep it simple and transparent, as it ought to be. Software Independent. - the argument should be, among the thousands of things looked at, why not consider it instead of why consider it. The argument must weigh on the side of transparency, clarity, and simplicity, not on traditional (Republican) disenfranchising techniques. Again, since the counting is controlled by partisan corporations, who votes not longer matter. Just like (fascist) Joseph Stalin said... it is who counts the votes that determines who wins. And CLEARLY (at least) since the elections of 2000 until now, this has been very evident. Saddly so. One day, it would be nice to know that a .gov agency is 100% trustworthy and reliable - Of, For, By the people. Instead of trying to convince them to do the right thing. Prove it.

Comment by Barbara Coulson (Voter)

We have found in the past that ALL computer systems can be manipulated or can malfunction. Demonstrations have proved that this is very difficult to detect. I want a voting system that provides for recording votes that is independent of any software. We have had enough evidence of software that thwarts voters' intent.

Comment by Julie Stephens (Academic)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by L. R. Stevens (Voter)

I think there should be a PAPER TRAIL on "ALL Public" votes so as to keep any computer fraud done either by accident or on purpose to ZERO ! We have a paper ballot here in Arizona and it is simple to understand we fill in the space between the ends of an ARROW . . Like this >>>--- ---->>> With the name here ! You would have to be blind and dislextic to make a mistake on this ballot !

Comment by Steven Pothier (Voter)

I hold a degree in computer science and have been a software engineer for over 25 years. As such, I am very aware of how full of subtle, and major errors computer software is. People in the field don't ever seriously talk about "error free" software. The most we say is that there are "no known bugs". Given the general inability to insure error free software, it is crucial that voter intent can recorded and recovered independent of software.

Comment by Kathe Sandstrom (Local Election Official)

As a trained election machine custodian, may I first say that I mourn not being allowed to use the old lever-machines (which we in NY are still using), as they are reliable and allow for vote verification both physically and on paper. But we absolutely should not go to a system where votes cannot be verified -- using computer software by itself does not leave a paper trail where votes can be checked. It's lost in the electronic ether, and unethical programmers could manipulate the software to read whatever way they want it to read. The voting public deserves software-independence.

Comment by Arlene Easley (Voter)

Since computer systems are all subject to errors and can malfunction or be deliberateley corrupted at any stage of their design or implementation, it is vital to the integrity of elections that voting systems provide a backup means to record and recover voter intent that DOES NOT not depend on the reliability of software.

Comment by Irma Stinnett (Voter)

We will lose our democracy if we can not assure voters that votes are correctly counted.

Comment by Valerie Hebel (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems as a means of recording and recovering voter intent that does not depend on the reliability of software. Sincerely, Valerie Hebel

Comment by William Masters (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. I take that to mean a paper trail is necessary.

Comment by Natasha Borowiak (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by D. H. Brady (Voter)

We need a voting system whereby votes can be verified with a paper backup and can also be recorded and recovered reliably, independent of software issues. It is relatively easy to tamper with systems that depend on software alone for their operation, and we must have a process that is both transparent and as free as possible from the potential for fraud.

Comment by Victoria Usher (Voter)

It is vital for me to feel confident (which I presently am not) in our elections that there be a means of recording and recovering voter intent independent of the software originally used to count the vote.

Comment by Gail Raborn (Voter)

All computer/software voting machines are subject to error and/or tampering (hacking). For this reason, it's essential that voting machines have a secondary way to verify the votes cast, like paper ballots, that are not software based. Otherwise: there's no way to be SURE that the ballots cast are the ones actually recorded.

Comment by B. Erickson (Voter)

As all computer systems are capable of deliberate corruption, error or malfunction at any point along the line from design to actual use, and it may be difficult, if not impossible, to detect these "faults", it is imperative that ALL voter systems provide for a means to record voter intent (preferably so that the voter might check BEFORE his/her vote is recorded, as one might check a deposit receipt before leaving a bank)and to recover voter intent, which does NOT rely on the infallibility of the software.

Comment by Tom Slockett (Local Election Official)

Software independence is necessary for the legitimacy of voting. Nothing less than the legitimacy of government is dependent on voters and the general public having confidence that each vote is counted as intended by the voter. At this point in time a paper ballot or paper event log is the only method available by which an average person can verify that his or her vote was registered as intended. Event logs should be required to follow a standard format just as data formatting standards should be established for the way all elections software records information. The event logs and data recorded by any elections system should be able to be processed by any other vendor’s election system to allow verification of results across platforms. Event logs should also have a mandatory summary ballot for each voter at the end of the event log for each voter, for ease of hand recounts and/or audits. Methods of magnification of event logs should be required to be available to voters and recount or audit boards to save paper and to facilitate readability for those who have difficulty seeing small print. Research and study of more environmentally sound methods of software independence limiting or eliminating the destruction of trees, e.g. cryptographic systems, should continue to be pursued, keeping in mind the importance that they be designed so that an average citizen can understand them.

Comment by michael torkelson (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Karen McBride (Advocacy Group)

Based on my extensive reading and the actual experience of several states in the US, it's been shown that the direct recording electronic voting system does not necessarily provide a means of recording and recovering voter intent, since it relies on the dependability of software. It's been proven that compter systems can malfunction or be deliberately corrupted at any stage of their design, manufacture and use. Thus,I believe and urge you to concur that "software independence," (SI), is an important advance toward verifiable voting and should be remain part of the federal guidelines for voting systems. Thank you.

Comment by Fred Schloessinger (Voter)

Example Comment: "All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software." Also, a paper trail lessens the likelihood that anyone would bother to try to use the system to give a false vote count.

Comment by C. M. Pyle (None)

It is hard to imagine a less secure way to vote than by computer systems which are subject not only to subtle errors, but to tampering by devious anti-democratic people. Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, or use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Apart from the simple marked paper ballot, optically scanned paper ballots are found to be the most reliable and should be uniformly adopted across the nation. The fact that such unreliable software and machines are even permitted is scandalous and should call for the international supervision of elections in this country as in so-called "third world" countries.

Comment by Janet Asbury (General Public)

Software indendence must be part of our voting systems if we are to have any faith in the outcome of our elections.

Comment by Sarah Catherine Comfort (Voter)

It is necessary for the integrity of the voting system, that I, as a voter, know that my vote has been recorded as I intended it to be and that independent auditors have access to that record. All computer systems can err, malfunction or be manipulated thus affecting the outcome of the vote. Therefore I would like a voter verified paper trail to be mandatory in all states.

Comment by Richard Kayne (Academic)

As part of my work, I use my laptop and its software a great deal. On the whole, my experience has been that the software I use is by and large reliable, but not completely reliable. I think that voting systems should not depend solely on software, and that it is essential that there should be a backup system for recording votes that is independent of the voting system's software.

Comment by S. Benmosche (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by John Mahoney (Voter)

Please do your duty and correct the unjust and fraudulent voting systems in place all over the country.We need honest systems that are not subject to corporate software to be able to prove the outcomes ,results of fair elections.A transparent ,conclusive and uncorupted by software is what is needed .It's time we put a stop to all questionable practices and private corporate interests controlling our elections.Software independent with transparent voter verifiable records,no less. Thanks, John Mahoney (a voter)

Comment by Charles Wyrostok (Voter)

All computer systems are subject to error, therefore there must be a guaranteed backup system in place. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. This requirement is essential to assure a system that voters have confidence in. It is quite disturbing to me as a voter that after all these years, we do not have a system that is hassle-free.

Comment by Charles W. Ellis, III (Voter)

"To err is human, to really foul things up requires a computer." It is imperative that we maintain the integrity of the American electoral system by keeping it independent of software that can be tampered with in ways that are undetectable and that can alter the outcome of elections. It is in the best interest of all patriotic Americans that we insure a paper trail of votes so that an independent audit is possible. Reliance on computer software alone is simply asking for electoral corruption and an undermining of the American Way of life.

Comment by Bernard J. Hochman (Voter)

Without a system of verifiable paper ballots the danger to free and accurate elections is so great that it is a danger to our democracy.As we learn every day when" the commputers are down " that reliance on computer software only is the wrong way to go.

Comment by Christopher Lish (General Public)

As someone who frequently uses computers, I am very aware that all computer systems are subject to subtle errors. Just the thought of using computers to record and tally elections terrify me, knowing how regularly computer systems can malfunction and how easily computer systems can be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. I strongly support the use of independent voter-verifiable records—preferably paper ballots—which cannot be changed by software malfunction and deliberate corruption.

Comment by Eric J. Amundson (Voter)

I feel that a verifiable paper record is the requiremnet to prevent voting fraud. We need the system to be independent of software glitches or tampering.

Comment by Carole Simmons (Advocacy Group)

Even the best-designed computer systems, being human creations, are fallible. Malfunction and/or malfeasance can corrupt intended functioning in ways that may be extremely difficult to detect. It is crucial to the integrity of voting systems that they provide a means of recording voter intent that is independent of the software.

Comment by Marilyn Hoff (Voter)

Election software should not be proprietary. If voting machine manufacturers alone control the software, with no possibility of public oversight, then any accidental or intentional flaws in the tabulation of votes will never be publicly known and the validity of all elections employing such proprietary systems should be in question. This one potential problem alone makes a voter verified and recountable paper ballot essential for any election system, including electronic voting systems that have already been proven susceptible to hacking and distortion by persons with computer expertise. All such questionable proprietary election software systems should, in addition to voter verified paper ballots, likewise have the election provision of mandatory random audits. Better yet, these notoriously malfunctioning boondoggles should be forbidden, and the whole country should return to paper ballots alone.

Comment by David DeSante (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Electronic Privacy Information Center (Federal Agency)

We strongly support the language of this section—"voting systems shall be software independent, that is an undetected error or fault in the voting system shall not be capable of causing and undetectable change in election results."

Comment by Barbara Ulman (Voter)

Electronic voting is not safe from failing computer systems, hackers, or other criminal elements. Voting must have a paper trail: it must be software independent. We have read about voting fraud in other countries. Now, it appears that the U.S. is not immune to this. Optically scanned paper ballots are reliable and efficient. The idea of using unreliable software for voting is terrible. We are supposed to be able to vote in this country, and to have the vote we actually cast be the one that is recorded. The only way for this to be true is to cast paper ballots!

Comment by Daren Heatherly (Voter)

Software is not yet able to record votes.

Comment by Susan Worst (General Public)

For a voting system to be trusted by the American people, its results MUST be verifiable and independent of the software. Computer code can be accidentally or deliberately corrupted, so we must have a separate, verifiable record of voter intent. It is of utmost importance that people know that election results are an accurate representation of voters' will. We need a paper ballot or receipt that each voter can check to make sure his or her vote was recorded accurately. PAPER TRAIL!!!!!!! Thanks for all your hard work on this issue. It can't be easy, and I trust and appreciate that you folks are taking the time to do it right.

Comment by Charles Rawls (Voter)

I strongly hope that the Commission will maintain the requirement for software independence as stated in Section 2.7 and that the Commission will not cave in to pressure from voting machine manufacturers to delete or weaken this section. Any computer expert will attest to the fact that computer systems can be subject to malfunctions or be deliberately corrupted at any stage in their design and use. Errors and corruption can be very difficult to predict and detect absent constant vigilance by trained experts. In light of these facts it is absolutely critical that all voting systems provide reliable means easily ascertained and read by the voters of recording and recovering voter intent without depending on the reliability of the software in use.

Comment by Michael Monroney (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Marge Acosta (Advocacy Group)

Dear Commissioners, Comments on 2.7A Software Independence: Since the implementation of HAVA-compliant electronic voting systems, we have seen major problems in election results ranging from hundreds of thousands of phantom votes to extremely high rates of undervotes in counties and states across the country. Unfortunately, especially with paperless DREs, there has been no software-independent means of ascertaining what the actual, correct vote tallies were and of correcting these flawed results. Examples are Alaska’s 100,000 phantom votes in the 2004 election, New Mexico’s high rates of undervotes in the 2004 election and Sarasota’s over 18,000 undervotes in the 2006 Congressional race. In each case the irregularities could not be corrected and the obviously flawed results were certified. Such instances have been numerous over the last five years, and are a blight on US election history. The only way to correct such flaws is to have a software-independent means of verifying results, i.e., votes cast were counted as intended. I believe this is best accomplished through voter-marked paper ballots. While voter verified paper audit trails (VVPATs) may seem adequate, they are computer-generated, and, as long as the VVPATs are on a paper roll they are controlled by the computer software. These paper records can be compromised while still in a functional mode, attached to the DRE. We have seen this in numerous instances, e. g, in the 2006 Tom Green County, TX primary where a recount was suspended because up to 20% of the VVPATs were missing and in the 2006 Cuyahoga County, Ohio review. The $1.9 million review found large and unexplained discrepancies between the machine count and that of the paper trail. Nearly 10 percent of the paper records were destroyed, blank, illegible, or otherwise compromised. While NIST and other studies say these errors can be corrected, they have not been. The California Top to Bottom review found that while most problems are "fixable" the vendors would probably have to redesign the entire voting machine. Studies have also shown that in the case of VVPATs produced by DREs, only about one-third of voters actually check these paper trails. This is partially due to the fact that the paper and font are small and difficult to read and the VVPAT is in a different format than the DRE screen. On the other hand, voter-marked paper ballots are inherently verified and are on large paper in a familiar format, which are easier for audits and recounts. After extensive research, NIST has found EBM or voter-marked paper ballots used in paper-based systems such as Optical Scan systems to be a better choice: "To a large extent, though, the usability of the paper record depends on how well the voting system in question has been designed to work with a paper record or whether the paper record is an afterthought. Current examples of DRE-VVPAT are a good example: current DRE-VVPAT is basically a DRE with a printer grafted on. Current implementations of DRE-VVPATs using relatively small paper rolls with unreliable mechanisms are not as usable or accessible as they could be if designed from the ground up to use paper. Some studies assert that use of EBMs might be a more usable and accessible approach than DRE-VVPAT, for example, because the EBM is designed specifically to be usable, accessible, and to produce a larger, more complete and legible paper ballot" We cannot risk the continuance of obvious voter disenfranchisement. The EAC must set guidelines that meet the highest standards for software-independent records, which are EBM or voter-marked paper ballots used in paper-based systems such as Optical Scan systems. Thank you for considering my comments. Sincerely, Marge Acosta Long Island representative for New Yorkers for Verified Voting 4 Harbor Park Court Centerport, NY 11721

Comment by Julie E. Coryell (Voter)

My view is that software independence is essential to both intent and effect of verifiable voting. Accurate voting is the heart of democracy.

Comment by Susan Kuehn (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to forsee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Sandra A. Nistico (Voter)

It is crucial to have an extremely reliable system with the means of recording and recovering voter response. Computer systems alone are not reliable. Crashes can occur, losing vital voting records. Manipulation can occur through hacking of system. Unforeseen malfunctions may occur within the design of the software. Questions do arise occasionally regarding voter fraud. Voters need recording and recovery methods to ensure their votes are respected.

Comment by Stephen J. Strahs (Voter)

It is vital that software independence be required for meeting the guidelines. The reality is that there are simply too many possibilities for volatile software to be subject to errors or manipulation. The need for a permanent record of voter-intent independent of the software is crucial to maintaining faith in the integrity of our elections.

Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

Section 2.7.A. Software Independence USACM Comment #1. Software Independence Definition [imprecise] USACM strongly supports voting systems that demonstrate software independence — where the results of the election can be verified independently of the voting system software. It is important that for software independence to be effectively implemented that it is clearly defined and that tests for demonstrating software independence are also clearly defined and described. To that end, USACM recommends that the first use of the word "undetected" be removed from the Software Independence definition. The definition would then read: Voting systems SHALL be software independent, that is, an error or fault in the voting system’s software SHALL NOT be capable of causing an undetectable change in election results, even if the software fault(s) are not detected. DISCUSSION: As currently written, the software independence definition focuses on undetectable software faults. The more important problem is undetectable changes in election results, which could result from detectable or undetectable software faults. It is clear to us that the intent of software independence is to comprehensively protect election results from software faults. Thus, deleting the qualifier "undetectable" related to software faults captures the true essence of software independence. We suspect that the reference to "undetectable software faults" may have resulted from an intent to emphasize that even the onerous category of "undetectable software faults" must not be able to affect election results. That notwithstanding, the proposed definition ensures that no software fault — including those that may be undetectable — can affect election results in an undetectable manner.

Comment by Neil Hertz (Academic)

This is a very important provision, and must be kept in the final set of guidelines. Without software independence, how is anyone to be sure that the machines haven't malfunctioned or been tampered with? We need to restore confidence in our electoral machinery--otherwise, our electoral results will be as suspect as those of some breakaway former S.S.R.--or of Russia itself, for that matter!

Comment by Meg Holmberg (Voter)

As a voter and longtime poll worker, I STRONGLY support this requirement for Software Independence. It makes no sense to me that we would entrust our voting systems — the most basic tool of our democracy — to software that could hide undetectable problems.

Comment by Karma Pippin (Academic)

We know that all computer systems are vulnerable to even undetectable errors. We also have heard repeatedly of computer systems that malfunction on election day. In fact they can fail or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to tamper with computers can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide to us a means of recording and recovering voter intent that does not depend on the reliability of software. The creators of these systems have enormous responsibility. We have put the technology of private entities between our precious voting privilege as U.S. citizens and election outcomes.

Comment by Steven Blaisdell (Academic)

Computer systems, no matter how well designed, are always capable of SOP errors, can break down, or be hacked at any point in the design process, manufacture, and implementation of the machine. More to the point, hackers are very good at what they do and their work can be extremely difficult to anticipate and detect. When it comes to the viability and security of the heart of American democracy, i.e. voting, vote recording systems MUST have an alternate method to record and recover a voter's intent independent of inherently unreliable software. Thank you.

Comment by Charlene Woodcock (General Public)

Anyone who uses a computer knows that they are susceptible to both intentional corruption—the work of an individual to take over or change the output—and manufacturer and software error. It is totally unacceptable for the very foundation of democracy in the US to be threatened by the use of voting machines that can be manipulated or that can malfunction. So the voting citizens must have voting systems that record our votes accurately and keep an accurate record of each vote. We cannot subject our elections to fraud by allowing the use of fallible machines, insecure software, and criminals intent on controlling our elections.

Comment by A.E.Bryant (Academic)

All computers can experience errors, malfunction or be deliberately corrupted. Any of these factors plus others, when using computer voting, can be difficult to anticipate, detect or correct in a timely and reliable fashion, and thus undermines voters' confidence in the voting process and in the results. Therefore, it is CRUCIAL to the integrity of elections that a voting system provide a means of recording and recovering voter intent that does NOT depend on the reliability of software. Thank you in advance for securing a voting system that can give voters confidence in the process and where the results that can be varified.

Comment by David DeSante (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mary C. Eberle (Advocacy Group

As a member of Coloradoans for Voting Integrity, Colorado Voter Group, and Paper Tigers, I strongly support voter-verified paper ballots as the means to software independence. Only the likelihood of examination of voter intent on paper ballots by election officials, in a bipartisan group, stands between the country and the domination of our elections by hackable, or inadvertently mistake-ridden, computer election systems.

Comment by C.C. Beroza (Voter)

Since any computing system and its software can malfunction or be subject to malfeasance, and resulting errors can be difficult, if not impossible, to detect, and since the voting data misrecorded by such computers likely would be difficult to restore after-the-fact, it is essential that all voting systems use one or more methods to record and, if necessary, recover the actual intent of every voter. These methods obviously must not rely on the reliability of software, since software is intrinsically vulnerable to subtle, potentially undetectable error.

Comment by Ann Harbeson (Voter)

"Software Independence" is an absolute MUST for our computer-enhanced voting systems. We are in serious danger of losing our democracy unless we get this right. We're counting on the EAC; don't let us down!

Comment by Paul Armstrong (Voter)

Votes need to be verifiable and paper ballots are the best way to validate votes.

Comment by Nellie Clark (Voter)

Computers can malfunction. Even more important, the ease with which they could be purposely manipulated is mind boggling. It is crucial that the voting system contain a "paper trail" or system of recording and retrieving the actual intent of the voters.

Comment by Sukey Barnhart (Voter)

It is absolutely vital to our democracy that there is a varifiable paper record of every single vote cast. In other words, software independent. The world has witnessed the chaos in America of a system which has no paper record and we must now insure that from now on every voting station in America is required to be able to provide a paper record of the votes cast.

Comment by Kay Beth Avery (Academic)

The bill will have no teeth without Software Independence. The American people will have no protection against voter fraud. The most fundamental aspect of a republic/democracy is a fair voting system. Do not disenfranchise the voters again. Please insure Software Independence by incorporating SI protections into the bill. Every voting machine used in America must have a paper trail; and that paper trail must be tamper proof. Software Independence is a vital aspect to insure that the machine's software will not be tampered with. Honest, fair, verified voting is essential and possible. Why has it taken eight years; and we still don't have it yet!!

Comment by Hans von Briesen (Academic)

All computer systems are subject to subtle errors. Debugging programs is a major effort for any software engineer, and is never guaranteed to be complete. In addition, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Furthermore, the principal voting machine manufacturers have a proven record of dishonest responses to problems encountered by election officials. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Debra Jenkins (General Public)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Sincerely, Debra Jenkins Port Townsend, WA

Comment by Shawn G. Folsom (None)

Dear Sirs; After enormous amounts of time and money, it seems that paper ballots have to be re-instated for voting, as there are no computer voting systems that are not subject to various corruptive influences, somewhere in the data stream. These subtle (and not so subtle) problems have undermined the public confidence in our elections, at the local, state, and national levels. Therefore I beg you to consider the return to paper which is not free of mistakes, by any means, however "paper" is within the "range of expertise" of most polling personel, to contend with. Yours truly Shawn G.Folsom U.S.Citizen

Comment by Joe Melhado (Voter)

I've been a software developer for over 35 years, and I know that all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Even if I write the software, I couldn't guarantee it will be 100% accurate, or that someone won't find a way to corrupt it in ways I can't detect. Voter verifiable paper backup records are a must if I am to trust the voting system.

Comment by Carolyn Cunningham (Voter)

I don't want any voting machines to be entirely software, as it has been proven already that such machines (DREs) are vulnerable to manipulation and error. There MUST be some verifiable paper trail in our voting process! This is incredibly important.

Comment by Norma Chavez (General Public)

When a consumer purchases a good or service, it is almost standard practice that the consumer is provided with a receipt of the transaction. This simple document allows both parties to verify what exactly has been exchanged. Furthermore, it establishes trust between the parties involved. However, in one particular activity that consumers engage in from time-to-time, where trust is assumed, is in the voting process. Voters were fairly confident that the vote they punched or bubbled-in would be counted. But past elections have shown that these methods of voting can be unreliable. Recently, efforts have been made across the country to use electronic paperless ballots. These ballots appear to be more reliable, but as anyone familiar with software can tell you, problems can and will occur. The integrity of an election should not be solely dependent on software. A potential measure that should be used to safeguard the voting process from software-related problems is to require voter-marked paper ballots or voter-verifiable paper records – records that would be software independent. A paper record is important for the voter as well as the election administrator. A vote should not be lost or miscounted due to a software glitch or manipulation. As voting is a right, voters have a right to verify that the votes that are being tallied are the votes that they cast. This is a unique opportunity to re-establish public trust and faith in our voting process. We should not squander it.

Comment by Carl Schoellkopf (Voter)

Computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. It can be extremely difficult to foresee and detect. Therefore, voting systems should provide a means of recording and recovering voter intent that does not depend on the reliability of software. Software Independence is an important advance toward verifiable voting. Of present technologies, only systems that utilize voter-verifiable paper records or voter-marked paper ballots would be software-independent. After reviewing the facts I believe Software Independence is crucial to the integrity of elections.

Comment by Deborah Massachi (Voter)

Recent history shows us the importance of software independence for our elections. Please help us maintain the basis for our democracy in these modern times and ensure election accountability.

Comment by Marybeth Kuznik (Local Election Official)

Software Independence is CRUCIAL to our having any confidence at all in the accuracy of our elections. Computers and their sofware are subject to errors and failures. We absolutely must have a way of accurately counting the votes in the event of this happening, and because we don't always know that a software or hardware failure is happening we must be able to audit elections independent of the software. I believe this is the most important requirement in the entire new VVSG. Marybeth Kuznik Elected Majority Inspector of Elections Penn Township, Westmoreland County PA

Comment by Nancy W. Munkenbeck (General Public)

I have been working with computer and software systems since 1970. While such systems can be efficient, detecting errors or deceptions in software can be extraordinarily difficult. Software based systems allow a fast accounting of the voting record, but the importance of the popular vote in a democratic society requires that a non-software based system be in place to record and store voting records for later review and auditing of the electronic system.

Comment by Joanne D. Lind (Academic)

Ready BEFORE election time in Novembr 2008 we must have all U.S. voting systems secure and ready to function smoothly. For God's sake, get moving on this. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Present software has been DEMONSTRATED to be accessible to deliberate manipulation -- producing in plain sight a different vote count from the votes cast minutes previously, in plain sight. I have seen this (Bev Harris investigation). PLEASE GET MOVING on getting our voting system for November 2008 SECURE AND ACCURATE.

Comment by Joel Saks (Voter)

As a software developer for over 25 years, I recognize the fallibility of computers and the programs they run. Both hardware and software fail in unexpected ways at unexpected times, and remain vulnerable to tampering despite the best efforts of the best minds in research and industry. Just as we demand manual failsafe and override capabilities for life-critical computer systems in medicine, automobiles, airplanes, nuclear power plants, and elsewhere, so should our voting systems--essential to the integrity and vitality of our democracy--provide the crucial redundancy for recording, verifying, and recovering each vote in a way that does not depend on computers and software.

2.7.1 Achieving software independence via independent voter-verifiable records

Voting systems that use independent voter-verifiable records can satisfy the software independence requirement and thus achieve conformance to the VVSG. Such systems include systems that use voter-verifiable paper records (VVPR), such as (a) VVPAT and (b) optical scan used in conjunction with Manually-Marked Paper Ballots or with paper ballots that are electronically marked by an EBP or EBM.

52 Comments

Comment by ted selker (Academic)

That are electronically marked by an EBP or EBM" should be changed to: "That are electronically marked by an EBP, EBM, or use another verification system."

Comment by Brit Williams (Academic)

Why only paper? A better approach would be to specifiy the functional requirements for an 'independent voter-verifiable record' and then allow any record, paper or otherwise, that can meet the requirements. This would also eliminate the requirement for the proposed 'innovation class' voting system.

Comment by Richard Sonnenfeld (Academic)

I teach physics and scientific programming at the university level and spent 15 years working for computing companies such as IBM. I love computing and programming, but am also cognizant of the almost limitless and unforseeable possibilities for error or tampering in complex software systems. The software independence requirement is to me THE critical requirement in the proposed standards and furthermore SHOULD be implemented via voter-verified paper ballots. I am one of a large number of Americans who believes that important elections have ALREADY been subject to fraud via electronic voting machines (e.g. Ohio, 2004). Absent a paper ballot, this fraud is fundamentally undetectable. There are those who say that we trust electronic banking, so why not electronic voting? In electronic banking, the consumer receives regular statements, and can keep independent records. So recurring large errors WOULD be detected and result in negative business consequences for the bank. So electronic banking provides a means of verifiability and a consequence that leads banks to strive for reliability. Since voters know only their own vote, and have no way to know that it was counted (and remained counted), there is no means of verifiability of purely electronic voting. Further, cheating benefits the cheater, so their are incentives to strive AGAINST reliability. With a paper ballot, each voter can see that their vote was properly recorded, and observers can see the physical object entering a physical box. Recounts, when called, will serve to sample the accuracy of electronic results -- so widespread cheating should be detected, though individual instances of tampering with counters might not be. In addition to providing voter-verified paper ballots, future machines should provide precinct-verified paper subtotals. This prevents cheating from escalating to the point at which individual votes are agregated. Thus software independence should extend all the way up and down the line from individual voter, to precinct, to state, to nation. While paper recounts are expensive and time-consuming, they are the price we must pay to preserve democracy. If a significant fraction of Americans come to believe that our leaders, whether they agree with their views or not, are not elected by the majority of the voters, the leadership will lose legitimacy and America will become ungovernable. Courageous leadership can establish that election accuracy is more important than "instant results" on television. Should America routinely have to wait 30-60 days after an election for certification, it is a wait worth having. Please ASSURE that the software independent requirement is included in the ongoing standards for electronic voting machines.

Comment by Isabelle Wasserman (General Public)

A vote is too important to lose. We all know computers can have glitches. It's imperative to have a paper trail if a mishap should occur.

Comment by Martha Blackwell (Academic)

Since all computer systems are subject to errors, and computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their creation, manufacture and/or use, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots.

Comment by Henriette Groot, PhD (Voter)

We all know about the disturbing reports of election computers malfunctioning, the stories about hacked computers and computers miscounting results or recording the opposite of what the voter intended. We MUST make sure that our elections are fair and above any suspicion. We MUST have a system where the voter can immediately check what the computer recorded, and we MUST have the ability to do recounts.

Comment by harvey buchbinder (General Public)

Almost daily we read about the consequences of software problems in various areas. It should therefore be imperative that software independence be mandated if we are to have any confidence in our elections which are, of course, the heart of our democracy. thank you,

Comment by Nydia Leaf (Voter)

Because all computer systems are vulnerable to glitches and malfunctions during their production stage and during use, our election process must be safeguarded by a means of recording a vote that doesn't rely on software.

Comment by Ann Luckett (Voter)

Printed back-up is imperative to avoid repeats such as the debacles in Florida.

Comment by John O'Meara (Voter)

Voting is the centerpiece of democracy. Counting our votes is essential to the successful continuation of our government. This country has never had a more stark illustration of that fact than the 2000 presidential election. If any lesson was to be learned from that fiasco, it is that we must be able to count and re-count votes. Therefore, our voting systems must have a means of recording and recovering votes that is not dependent on potentially unreliable and easily manipulated software programs.

Comment by Jan Groh (General Public)

As a former computer programmer and Access database developer (ran my own consulting business in Portland, OR for 5 years until 2005, former active member of www.paug.com) I cannot agree more with the need for Software Independence and a means to verify the voter record - independent of the original voting system, and on paper. All programs are written by humans who are inherently organic and flawed, and thus even if they are not being actively amoral and deceptive, may just plain be accidentally wrong. There is no such thing as a bug free program. Just programs that do enough to satisfy most users most of the time. Thus it is absolutely critical to have a voter-verifiable paper backup to every ballot. I say this as one who has programs running in the City of Milwaukie, OR and elsewhere in the Portland area still (over 6 years since I wrote them in 2001). But none is more critical to me than the issue of tracking voters choices. For even if I could claim to write a more secure program than those put out so far, even I wouldn't deign to claim they were infallible or without flaws inadvertent or otherwise. And the voter themselves absolutely must be able to verify quickly and easily that their choices are truly and accurately being recorded in a system somewhere, which I feel can only be done on paper. If we can produce ATM machines that spit out paper receipts that people trust for the last 20 years, surely we can produce paper verifiable voting machines. I cannot be convinced otherwise. And I believe the fate of the free world rests on the outcome. Nothing is more important to me than accurate, open and fair elections - even if my own candidate loses. I will accept the result - if and only if it has been audited, or can be on paper. Thank you.

Comment by Cathe Giffuni (Voter)

Computers are too easy to hack. Touch-screen voting machines have also been repeatedly proven hackable. Therefore, to prove that one's vote is actually being casted, an independent, i.e., paper ballot must be provided.

Comment by Lawrence S. White (Voter)

Printed, paper records are currently the only reliable method for voting verification, printed immediately at the time of voting, with a carbon copy to be placed in a lock box for potential recounts. Additionally the composition of the paper should be 100% post-consumer recycled, and the ink should be fade-proof and non-toxic. Thank you for your consideration and good work on this critical legislation.

Comment by Cynthia Hilts (Voter)

Voter-verifiable records are the only reasonable choice. It has been demonstrated that voters may end up with a vote contrary to their wishes as a result of software glitches or corruption of voting machines. Of course the voter must be able to verify her/his vote. This will also make sure that the paper on which the vote is recorded actually exists, and is not jammed, forged, or otherwise compromised.

Comment by robert k gilland (General Public)

With the importance of the up coming election all measures should be taken to certify insure the correct counting of the votes. Verification is the most important step in achieving this

Comment by Karen Sullivan (Academic)

Computers are convenient, fast and great at crunching numbers, but they can be unreliable and unscrutable for the average person. The problematic history of recent elections demands that any changes to our voting system address both convenience, cost and reliability. A voting system that cannot be independently verified by the voting public is a step backwards no matter how many bells and whistles it contains. This is one of the most crucial changes in our election history and it is imperative that you get it right. If there is no voter verifiability, the plan should not go forward. PERIOD.

Comment by Dale Axelrod (Voter)

Trust in elections is central to trust in government. All electronic voting systems must provide, with secure chain of custody, a tangible ballot which is the ballot of record. Only with a tangible ballot, such as a paper ballot which is the ballot of record, can a voter be confident that there is something to count.

Comment by Jennifer Jolly (Academic)

Software independence is essential. Computer systems are subject to subtle errors, whether due to human error, malfunction, or malicious corruption. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Thank you for the opportunity to comment.

Comment by Sam Brush (Voter)

To Whom it May Concern, I see no greater current threat to our democracy than the control of our voting systems by computer systems subject to subtle errors and manipulation. Moreover, computer systems can malfunction or be deliberateley corrupted at ANY stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Based on the already abominable track record of computerized voting machines it is crucial to the integrity of our elections and more so to any legitimacy to our claim to DEMOCRACY that voting systems provide a means of recording and recovering voter intent that does not depend AT ALL on the reliability of software or the questionable moral integrity of the corporations operating these systems. PLEASE protect the integrity of our Democracy with transparent voting processes that provide an immediatley verifiable paper record of every vote caste. Sincerely, Samuel Brush Georgetown, Maine

Comment by W H Chapman (Voter)

A voter verification system seems to be necessary. A marked, saved paper ballot would ensure that there be a method of checking electronic voting systems.

Comment by Fred and Betty Krueger (Voter)

Independent Voter Verifiable Records are absolutely essential to the democratic election process. This must be done in a way that is not and could not become vulnerable to any kind of unverifiable and uncorrectable human error, whether intentional or otherwise. Preserving a record of the actual vote is necessary - either a paper record or scanned vote record, verified by the voter before the vote is cast, and available for review in case of question or dispute.

Comment by Richard Frye (Academic)

Every voting machine must generate a VVPR at the time the vote is cast, and which is immediately safeguarded and saved for audit as necessary. No electronic system can provide the reliability of a VVPR.

Comment by Joseph Neiman (General Public)

Verification must be independent of software in the computer programs. Software is always subject error or corruption. Paper verification is one method of determining voter intent. Under all circumstances voter intent must be available independent of the computer software.

Comment by Barabara S Smith (General Public)

It is essential that criteria for voting systems address errors of past elections. The only way to ensure this is to provide a means of recording & recovering voter intent that does not depend on software reliability. Computer systems can malfunction & are subject to deliberate corruption at any stage of their design, manufacture & use.

Comment by Marilyn M Myers (Advocacy Group)

It is extremely important to have verifiable paper ballots to back up the electronic voting.

Comment by Thor Myhre (Voter)

As a democracy we need a reliable vote counting method which we can have faith in. I believe the voter-verifiable paper records (VVPR) are essential. Thank you, Thor Myhre

Comment by Roland Tec (Voter)

There is no substitute for a paper record of a voter's intent, DIRECTLY MARKED BY THE VOTER, not the computer. If we want to be certain that all vote counts are verifyable, we must insist on manually-marked paper ballots such as those in use in the Commonwealth of Massachusetts, for example. Anything that relies on the computer to mark the paper falls short of what we need after the nightmare scenarios of both 2000 and 2004. Voter confidence is too important and crosses all boundaries of Party affiliation, gender and ethnicity. All citizens have a vested interest in elections that are clean and transparent.

Comment by Miriam Hochberg (Voter)

We must have a back up check like paper ballots.

Comment by Schuyler Hilts M.D. (General Public)

There have been serious questions about the integrity of software systems, which CAN be manipulated. To avoid such questions, software-independent systems ONLy should be allowed.

Comment by D. Karen Wilkerson (Voter)

I have never used any computer system which is free from the eventual error. Computers can malfunction or be deliberateley altererd during design, manufacture, and/or use. The ways these errors creep in are probably extremely difficult to foresee and detect. Certainly, there is no way the voter will be able to determine that his or her vote is recorded and reported accurately. In our county, there have been several instances of malfunction during voting, and the system we use is supposedly among the "best" of electronic voting systems available. I believe that a means of recording and recovering voter intent which is not dependent upon the reliability of software is crucial to the integrity of elections.

Comment by Linda Finlay (General Public)

It is crucial to require (rather than make it optional) language that states that the IVVR cannot be changed by a software failure, and that election officials will be able to review the IVVR without using a computer program. It is also crucial that results be kept for several years.

Comment by John V. Rafalak (Academic)

I have worked with computers for over 20 years. In that time I have seen that there is no system created by human beings that can't be changed (hacked) by human beings and there is no software that is not prone to mistakes and failures. It is not acceptable to rely only on electronic data as a sole means of checking the accuracy of an election. There MUST be a paper trail if we are to trust the accuracy of our election process. Without that trust, Americans will no longer be able to fully support their system of government.

Comment by David Beirne, Executive Director, Election Technology Council (Academic)

The use of an optical scan ballot or vvpr does not make a voting system software independent unless the intent is to require a 100% audit of the paper records after each election or for the election’s initial count. The idea being that the initial tabulation would be software driven. The use of an optical scan ballot or vvpr should be only be used for providing an independent voter verifiable record, but not as indicator of software independence.

Comment by Brian Levin (Voter)

All computer systems are created by human beings and therefore they can malfunction or be deliberateley corrupted at any stage of their design and manufacture. Detection of system corruption is often difficult. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software or the integrity of the designer/manufacturer.

Comment by john Chapman (Voter)

Every one knows that computer systems are subject to malfunction and more important they can be deliberateley corrupted. This can be almost impossible for the volunteer poll worker to difficult to detect. Therefore, I am registering my opinion that voting systems must provide a separate and independent means of recording and recovering voter intent so that my vote does not depend entirely on the reliability of software. We already have a model for this in the ATM and credit card technology. Who would trust their financial transactions were being recorded accurately without a paper receipt?? Indeed! The most important tool of the people in a democracy is the vote. Let's not undermine the integrity of this gift of free people.

Comment by Nancy Simons (Voter)

I strongly urge software independence through systems that use voter-verifiable paper records (VVPR), such as (a) VVPAT and (b) optical scan used in conjunction with Manually-Marked Paper Ballots or with paper ballots that are electronically marked by an EBP or EBM. It is so important to have a voting system that is understood and trusted by voters. Keeping faith in the fairness of our voting systems is worth extra expense.

Comment by Ron Kuhler (Voter)

Elections and voting machine computer software are prone to errors, many of which may not be detected until months after an election is over and decided. This is why we must have a backup system of paper ballots. Each voter's vote must be recorded on paper at the same time it is recorded in a computer, in case there is a computer error. The paper records are extremely important and must be maintained in case of a close election, a recount, or in any instance of suspected fraud or error. Please, we must have paper ballots or a paper trail of voter intent. Thank you. Ron Kuhler, Lutz, FL

Comment by Janet F Patruno (Voter)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Voter-verifiable paper records can insure the integrity of our voting rights.

Comment by Donnella Mitchell (Voter)

It is crucial that our Federal, State, and local elections be verifiable and auditable, along with the absolute necessity that related computer software be independent. These must be requirements for all American elections nationwide.

Comment by David Beirne, Executive Director, Election Technology Council (Manufacturer)

The use of an optical scan ballot or vvpr does not make a voting system software independent unless the intent is to require a 100% audit of the paper records after each election or for the election’s initial count. The use of an optical scan ballot or vvpr should be only be used for purposes of providing an independent voter verifiable record, not as an indicator of software independence.

Comment by David Groisser (Voter)

"Software independence" is unachievable with electronic-only ballot recording. ONLY systems using voter-verifiable paper records should be allowed.

Comment by Tom Borawski (Voter)

I am a Software Engineer currently employed in the field of high-reliability process control devices. In my field, many Electrical systems used in explosive environments must be certified as INTRINSICALLY SAFE. The concept behind Intrinsic Safety is simple: the electrical nature of the physical interface precludes explosive hazards. In my opinion, voting equipment which does not provide a voter verified paper record is INTRINSICALLY FRAUDULENT. It is impossible to guard against the spectrum of attacks available-- both hardware and software. John Kelsey of NIST has done an excellent summary of Software Vulnerabilities of Electronic Voting Machines (vote.nist.gov/threats/papers/stategies_for_software_attacks.pdf). I believe that hardware vulnerabilities which would be impossible to detect-- most notably Covert Wireless Vote Tampering Capabilities-- forces paperless DRE voting equipment to be classified as INTRINSICALLY FRAUDULENT. The fact that the majority of microprocessors and other electronics are manufactured outside of the United States also makes paperless DRE equipment a threat to national security. I live in the City of Philadelphia. The city uses Intrinsically Fraudulent paperless DRE voting equipment. I walked away from the machines in 2004 and have not voted on them since. My polling place is a block away from the grave of Benjamin Franklin. It is a few blocks away from the location where he flew his famous kite to discover electricity. It is ironic that Franklin's discovery of Electricity is being used to subvert the democracy he founded. Thomas Borawski Philadelphia, PA.

Comment by M Connolly (Voter)

"All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by Marybeth Kuznik (Local Election Official)

Because we have had so many problems with computerized voting machines (most recently in our Pennsylvania primary, a machine in my precinct was not recording votes correctly and had to be recalibrated mid-day), I believe that Software Independence is absolutely crucial to achieving an accurate election and voter confidence in the results. Again, in my opinion this is the most important part of this entire version of the VVSG. Marybeth Kuznik Elected Majority Inspector of Elections Penn Township, Westmoreland County PA

Comment by Marybeth Kuznik (Local Election Official)

From conversations with my own constituents I believe a voter-verified paper ballot, marked by the voter either by hand or ballot marker, is the current method of choice to achieve this requirement. Marybeth Kuznik Elected Majority Inspector of Elections Penn Township, Westmoreland County PA

Comment by Raymond Kim DiPino (Academic)

Given the problems that can occur with any computer system, I believe that a verifiable paper trail is essential to the voting system that is used. The more open the system and the more transparent the process, the less the chance for error or fraud.

Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

USACM Comment #2. Overlap between Sections 2.7 and 4.4 [ambiguous] USACM recommends replacing Section 2.7.1 with the following subsection added to section 2.7: 2.7-B. Achieving Software Independence. Voting systems that use Independent Voter-Verifiable Records (IVVR) as described in Part 1, Section 4.4 below can satisfy the software independence requirement and thus achieve conformance to the VVSG. IVVR is currently the only approach for achieving software independence in this VVSG without going through the innovation class process for approval. Applies to: Voting system Test Reference: Part 3:4.1 "Initial Review of Documentation", Requirement Part 3:4.2-C Source: New requirement DISCUSSION. Details specified in Section 2.7.1 overlap extensively with data in Section 4.4. In addition to the unnecessary forward reference, this overlap creates confusion within the document and the potential for conflicting requirements, particularly if revisions occur.

Comment by Jerome McIntire (Voter)

Yes, software independence is vital to produce election results that are accurate and trustable, and independent, voter-verifiable records is the only sure way to achieve software independence. Adopt an IVVR requirement!

Comment by Peter Birk (Voter)

I'm a voter. I don't write software. The only vote verifiable by this voter is paper.

Comment by George Ripley (Voter)

If "we, the people", using "eternal vigilance", are to have any faith in our democracy, our proudest national birthright, the loss of which will unquestionably lead to the loss of our freedom, and are to defend ourselves against possible "enemies within", then we must have transparent verifiable elections. Software independence is the foundation of an auditable voting system. I strongly support software independence, and believe this is best accomplished through voter-marked paper ballots. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be accidentally or deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is critical to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. The best way to achieve this is voter-verified paper ballots.

Comment by Vincent J Colletti (General Public)

Computer systems present a vulnerable point in the voting process. System failure, software glitches and bugs and hacking leave our votes in question. If these systems are to be used at all, there must be a way to positively verify voter intent independently of software.
2.7.1-A Independent voter-verifiable records may be software independent

software independence MAY be achieved through the use of independent voter-verifiable records or it MAY be achieved through an innovation class submission.

Applies to: IVVR

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

DISCUSSION

This requirement is implied by Requirement Part 1: 2.5.3-A, which requires the implementation statement to include an IVVR voting system or an innovation class submission. Use of IVVR is the only method specified by requirements in the VVSG for achieving software independence. By using MAY instead of SHALL, this requirement does not preclude other methods for achieving software independence. When new methods are developed, additional subrequirements of this form will need to be added for those methods.

Source: New requirement

2.7.1-B IVVR voting system requires IVVR vote-capture device

In a voting system of the IVVR class, every Vote-capture device SHALL be an IVVR vote-capture device.

Applies to: IVVR

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

DISCUSSION

Voting systems that satisfy the IVVR voting system class requirements must include an IVVR vote-capture device, e.g., VVPAT, EBM, or MMPB. Conversely, voting systems of the IVVR class must not include any vote-capture devices that are not of the IVVR vote-capture device class.

Source: New requirement

18 Comments

Comment by Peter Belmont (Voter)

I was a system programmer for 25 years and have a deep suspicion of any system which might fail because of political-maliciousness (election-rigging) or from carelessness or ignorance. Where dealing with NEW SYSTEMS, the voting-officials will have reasons to be MALICIOUS or IGNORANCE or CARELESS or all of these. The necessity for pre-election TRAINING and post-election TESTING and VERIFICATION is clear. Accordingly, I recommend that there be a STANDARD for TESTING all election mechanisms including systems which count votes by SOFTWARE and also systems which ALLOW "recounts" based on voter-verifiable paper representations of the voters votes. The USE of a non-software vote-capture system is as important as the AVAILABILITY of a non-software vote-capture system. If the system requires BOTH a SOFTWARE initial-vote-count and also a voter-verified paper-trail (or other non-software voter-verification system), then the voter-verified paper-trail MUST BE COUNTED OFTEN ENOUGH TO PROVIDE A STATISTICAL CHECK on the correctness of the SOFTWARE initial-vote-count. MACHINES WHICH COUNT paper ballots should be manufactured by a DIFFERENT MANUFACTURER than the machines which MARK THE paper ballots. PAPER BALLOTS should be counted "by hand" OFTEN ENOUGH TO PROVIDE A STATISTICAL CHECK on the correctness of the post-election paper-ballot counting (if this is done by machine). EXAMPLE: if 100 voting stations use a SOFTWARE SYSTEM for an initial-vote-count and also prepare and retain a voter-verified paper-trail, then 10 of the paper-trails, chosen at RANDOM, should be machine-counted (immediate RECOUNT) in the immediate post-election period, and 1 of these 10, again chosen at RANDOM, should be counted BY HAND to verify BOTH the accuracy of the SOFTWARE initial-vote-count and also of the immediate RECOUNT Thank you for receiving and considering this comment.

Comment by ann e. houston (General Public)

To anyone dedicated to true democracy enough to listen: One of the most depressing days of my life came a few days ago when I read an article about a Florida computer programmer approached by a Florida legislator (Ney?) to write a program to UNDETECTABLY throw a machine's votes to the selected candidate. Whether this story is true or not (evidence seems to be that it is true), it illustrates the fear that many American voters have - that "somebody" can steal their vote. How can we go into another country to spread democracy, with lives lost on both sides, when we can't even prove that we have a democracy in THIS country?? It seems the height of irony, & hypocrisy.

Comment by George Zimmerman (General Public)

There should be a paper record of an individual's vote, to insure a check and balance on software errors for electronic voting.

Comment by Margaret Albert (Voter)

I agree with this petition that we must have a voter inspection system with a verifiable paper record.

Comment by Barbara DiTommaso (Advocacy Group)

On behalf of the Commission on Peace and Justice of the Roman Catholic Diocese of Albany, I urge you to use a means of recording and recovering each vote, such as a paper ballot and optical scanner. We unfortunately have all experienced faulty computer programming, and the possibility of someone hacking into the system is real. We are opposed to relying only on computer hardware and software, such as touch-screen voting.

Comment by Maura McNulty (General Public)

The only way to ensure free, fair and accurate elections is require additional, non-digital verification of all votes.

Comment by David Beirne, Executive Director, Election Technology Council (Manufacturer)

Under current technologies, every DRE system would have to have a VVPAT unless a future system is submitted under the innovation class. This is too prescriptive of a requirement and provides an example of how this new draft of the VVSG is focusing too much on the design of voting systems rather than the performance.

Comment by Jim Simons (General Public)

I strongly urge software independence through systems that use voter-verifiable paper records (VVPR), such as (a) VVPAT and (b) optical scan used in conjunction with Manually-Marked Paper Ballots or with paper ballots that are electronically marked by an EBP or EBM. It is so important to have a voting system that is understood and trusted by voters. Keeping faith in the fairness of our voting systems is worth extra expense. Jim Simons

Comment by Bill Storey (Voter)

This is a must!

Comment by Tom Slockett (Local Election Official)

Software independence is necessary for the legitimacy of voting. Nothing less than the legitimacy of government is dependent on voters and the general public having confidence that each vote is counted as intended by the voter. At this point in time a paper ballot or paper event log is the only method available by which an average person can verify that his or her vote was registered as intended. Event logs should be required to follow a standard format just as data formatting standards should be established for the way all elections software records information. The event logs and data recorded by any elections system should be able to be processed by any other vendor’s election system to allow verification of results across platforms. Event logs should also have a mandatory summary ballot for each voter at the end of the event log for each voter, for ease of hand recounts and/or audits. Methods of magnification of event logs should be required to be available to voters and recount or audit boards to save paper and to facilitate readability for those who have difficulty seeing small print. Research and study of more environmentally sound methods of software independence limiting or eliminating the destruction of trees, e.g. cryptographic systems, should continue to be pursued, keeping in mind the importance that they be designed so that an average citizen can understand them.

Comment by Mary Francis (Voter)

Independent voter-verifiable records which are generated by a printer often jam, are difficult to read and are a poor substitute for Voter-marked paper ballots. IVVRs become part of the problem, not a solution.

 

2.7.2 Innovation class submissions

The innovation class is for the purpose of ensuring a path to conformance for new and innovative voting systems that meet the requirement of software independence but for which there may not be requirements in the VVSG.

The following high-level principles apply to the innovation class:

  • Technologies in the innovation class must be different enough to other technologies permitted by the VVSG so as to justify their submission. In particular, it should be clear in submissions that the "standard" path towards achieving conformance to the VVSG is not appropriate for the proposed technology;
  • A reasonable case must be made that deployment of the new technology does not present excessive logistical complexities. In particular, if the proposed technology is based on multiple interacting components (e.g., cryptographic key certification authorities, public electronic bulletin boards, smart witness devices, multiple holders of shared keys, etc.), then deployment of these components, interoperability testing, and control and maintenance of the various communication paths should not present insurmountable problems.
  • A reasonable case must be made that the new technology does not present an excessive burden on election administration. More generally, the technology should help rather than hinder election administrators in their goal of producing timely, accurate, and trustable election results.
  • Technologies in the innovation class must meet the relevant requirements of the VVSG as well as further the general goals of holding fair, accurate, transparent, secure, accessible, timely, and verifiable elections. They must be as secure, transparent, and auditable as existing systems permitted by the VVSG.

A review panel process, separate from the VVSG conformance process, will review innovation class submissions and make recommendations as to eventual conformance to the VVSG.

In terms of conformance to the VVSG class structure, an innovation class submission is a voting system that includes one or more distinct innovative devices. The manufacturer must follow the same procedures that any manufacturer of a voting system must follow except that the manufacturer must also request and justify that a new device class be created in the VVSG for each distinct innovative device in the submission. For each new device class requested, the manufacturer must show where in the device class structure the new class is to be created. In listing the specific requirements of the new class, the manufacturer is expected to follow all rules of class hierarchy and requirement inheritance from Section 2.6.

18 Comments

Comment by Carolyn Coggins (Voting System Test Laboratory)

It is unclear if the VSTL performs usability tests or reports based upon a review of the manufacturer's tests. How are the numbers for Perfect Ballot index and Voter Inclusion calculated? What is the benchmark ballot? Should there be a control ballot against which are metrics are judged?

Comment by Carolyn Coggins (Voting System Test Laboratory)

The implementation statement is prepared by the manufacturer, correct? Why would the manufacturer determine the test requirements? I can understand the manufacturer identifying the requirements that guided development and addressing compliance but shouldn't determination of test requirements be identified by the review panel?

Comment by Brit Williams (Academic)

This section is so poorly defined that it should be eliminated from the VVSG. According to this section "A review panel process, separate from the VVSG conformance process, will review innovation class submissions and make recommendations as to eventual conformance to the VVSG". This implies that we are going to suspend the entire VVSG and the EAC Certification Program and turn the certification of these systems over to some unspecified 'review panel'.

Comment by Frank Padilla (Voting System Test Laboratory)

What is the review panel process? Who will make the determination whether a system falls into this class or not? Is this process prior to any submission for testing?

Comment by Premier Election Solutions (Manufacturer)

It is important that Innovation Class Submissions be treated in a fashion equitable to standard submissions for certification to the VVSG. There cannot be a double standard. This point seems to be addressed in the requirements of this section, but it would be prudent for those reviewing Innovation Class Submissions to keep this point in mind. Proposed Change: None.

Comment by Paul Jakubik (General Public)

Innovation class submissions should not be permitted. The techniques described sound like things that only a very small number of computer science professionals could verify are actually adequately secure. Even though I'm a computer science professional with over 16 years of experience, I don't think I could verify the security of one of these systems, nor do I expect to be able to verify that my vote was correctly counted using a system like this. Even if the general public is way more computer savy than I am, I doubt that 80% of voters would be able to verify that their intent was correctly recorded by one of these systems, and I fear that much less than 20% of voters would be able to verify that their intent was recorded. Voter-verifiable paper ballots are required. These can be scanned into electronic systems as long as the original paper ballot is retained for required sampling audits and full recounts when the error between the sample and the reported results are too high.

Comment by Marian Shapiro (None)

Without confidence in the integrity of our voting system, our whole democracy is at risk!!! All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. Unfortunately the hackers can outsmart all kinds of safety measures. We have to take all the precautions we can.

Comment by David Beirne, Executive Director, Election Technology Council (Manufacturer)

This review panel process needs to be clearly defined or simply include current EAC model with the use of the TGDC, Standards Board, and Board of Advisors. Since the EAC is not a rule-making agency, no variant procedure should be codified with the inclusion of a separate review panel unless specifically authorized or at such time the EAC becomes a rule-making agency.

Comment by David Beirne, Executive Director, Election Technology Council (Manufacturer)

The innovation class review panel process is undefined-the EAC process should be strictly adhered to as provided under federal law; The VSTL should have a clear set of basic criteria for considering submittals under the innovation class submissions; Section 2.7.2 needs to be aggressively reworked as it is too ambiguous; If all references to IVVR compliance in the form of an optical-scan ballot or vvpr are removed, the innovation class subset becomes unnecessary.

Comment by Andrew Gray (General Public)

Any electronic software system has the ability to fail or be manipulated at multiple points in an election process. Independent voter verifiable records should be required of any election including a federal office, and should consist of a physical (i.e. paper) record that can be used to verify the integrity of an election. Anything less will not guarantee a functioning democracy.

Comment by Collin Lynch (Advocacy Group)

In defining the innovation subclass all documentation and inspections should take care to a) identify the minimal necessary components for the verification process, b) clearly specify the trust and implementation level required for each and c) consider the human factors of use by specifying clearly the required procedures and human involvement in system security. Voting systems are complex items and, while such systems contain large scale components not all of those components will touch directly on the auditability of the system. In all too many cases the high complexity of a system masks, whether intentionally or unintentionally, the unworkable or unreliable nature of its implementation. Additionally decisions made in implementing one component of the system often invalidate the security assumptions made by others. For example the decision made with the ES&S iVotronic system to place the cryptographic key on the PEB making it publicly accessible thus invalidating the cryptographic security of the system as a whole. In submitting an innovation class the designer must take care to identify the minimally necessary components for the class and their interaction absent all other components. Such a validation will enable the clear examination of the security of the proposed system with a minimum of obfuscation. Such an examination and the documentation that accompany it must include a clear statement of the system and process requirements necessary for the security to work. As a simple point private key cryptography requires a secure key distribution mechanism and, unless such requirements are spelled out in advance they may be all too easily, and all to fatally assumed to be present when not. Compliant system classes to the innovation class are then defined to be systems (including user procedures) that meet the security and implementation requirements of the minimal security components. Once that is completed a similar validation in the context of the system, and election processes assumed or required for system use. This is necessary to determine whether or not any conflicting design decisions (such as the PEB key distribution discussed above) that invalidate the security requirements of the minimum component. Considering the human factors includes both the implementation requirements for elections staffers and the end-user requirements. You correctly discuss below a case for the practical deployability of the system but a separate case or clause of that case, must include the requirements for the voter both in the level of voter involvement required and the security case for the voter on which the system rests. By level of involvement we touch on the practicability of the system. Systems that require the voters to produce, on the spot, secure passwords must spell out that requirement and, in forming the argument, vendors need to consider both the consequences of poor choices and the anticipated rate of security failures (e.g. voters who choose the same simple passwords). Additionally systems requiring optional processes or two step processes (e.g. checking a website to verify the vote later) need to correctly spell out both the anticipated effort that would require and, with it, the potential usability of the process, this would include the number of voters anticipated to take advantage of it, and the number required to make security guarantees, e.g. such a system would fail if less than a statistically significant sampling of voters check their votes. Such a system would also rest on the security guarantees of the examination process including the verifying website which, if compromised could be a venue for vote selling, voter intimidation, or the compromise of voter privacy. Such a system, if compromised could also be used to report false verification information. Therefore such processes must be considered as part of the minimal security components of the system itself. With respect to security case it is necessary to specify why the voter is expected to trust the system. While this may sound like a non-technical exercise in advertising it is not. The use and reliability of a vote system are directly governed by the promise made to the voters about how they work and the act of rendering a technical security system into nontechnical language is often revealing when considering the actual security. To take an example systems that require a voter to trust that the ticket they are handed contains a unique prime number require the trust of the voter that a) they are given such a number, b) they can verify that it is prime, and c) that it is unique. While a system based upon this may be technically feasible it is not voter-verifiable in any practical sense. I support the existence of the innovation class so long as all such innovations are held to high standards of verifiability and practical utility, not merely taken as a home for snake oil sales. We must remember well that the democracy belongs to every voter and any system that overly obfuscates its contents or is unusable or unverifiable for the end user does not deserve entry.

Comment by Electronic Privacy Information Center (Advocacy Group)

A review process for consideration of voting systems under innovation class must be developed before further endorsement of this proposed guidance can be provided.

Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

USACM Comment #4. Section 2.7.2 Innovation Class Process [incomplete] E-voting faces numerous challenges and is a field ripe for further research. Federal and private investments should continue to be made and new, innovative approaches should continue to be developed. However, until the fundamental constraints of security testing can be adequately addressed, these systems should have to meet a high bar for independent voter-verification before they are certified. Without a definitive testing procedure, this process runs the risk of being an end-run around existing principles such as software independence. Any system intended for certification in the innovation class must demonstrate that it is at least as good, if not better, than other election systems. USACM believes that the innovation class proposal and evaluation process is critical to effective implementation of new voting technologies and recommends that the document be expanded to include a detailed process description for determining what qualifies for the innovation class and how voting technologies can be effectively tested as part of the innovation class. This description should include who should decide whether a device or voting system qualifies for the innovation class and what criteria that device or system must meet to be certified as all or part of a voting system that meets the VVSG.

Comment by David Chaum (None)

The VVSG is to be commended for recognizing the need for an "Innovation Class" to accommodate voting systems that offer real advantages but that don’t fit neatly within the particular architectures underlying the VVSG proper. The VVSG does little more, however, than suggest a need for a way to evaluate such innovative systems and clearly leaves open the question of how to address that need. The present document is a first attempt to propose an answer, albeit in rough outline. The solution sketched here does, however, draw on well established practices in other parts of government and can leverage expertise across major institutions. The approach sketched also holds promise for several advantages over the VVSG beyond allowing innovation. For one thing, flexibility in scope may allow it to accommodate a broader range of procedures and back-end systems (allowing, e.g., coverage of vote-by-mail systems). For another, it may streamline parts irrelevant to core requirements (for instance, ballot authoring in some systems). It may even allow certification of new components for use in previously certified systems. Furthermore, it can reduce risk and provide stepwise progress for those submitting systems, thereby fostering innovation. Additional properties are also possible, including transparency, openness, modularity and even accumulativeness of precedent. The current VVSG has for the first time recognized the need, even within the particular system architectures that it considers, for open ended evaluation for security and end-user usability testing. This can be interpreted as supporting the need for the solution presented here, since it acknowledges that today’s systems can no longer be effectively evaluated by static criteria. It also starts to bring the VVSG into alignment with best practices long adhered to by other branches of government. The solution presented here in fact has strong roots in the techniques that were developed through a decade long effort, lead by NIST, and successfully applied by many countries to certify security aspects of information technology systems. These "common criteria" techniques are used in this country for systems with very low assurance levels, well below that required by voting systems, up through the very highest levels of assurance, far beyond anything foreseen for voting systems. The approach is based in essence on the submitters of a system convincing a committee that the proposed system design satisfies the desired criteria and that certain test procedures are sufficient to verify its implementation. While rigorous, the technique is flexible. It leaves the heavy lifting primarily to those who propose a system, but breaks the process for them into manageable steps. The role of the evaluators is limited to approving the form of submissions and, only once an approved version is arrived at, actually checking its assertions. Important Caveat There is one important notion that must accompany this proposal in any incarnation: The VVSG raises the bar by establishing some absolute performance criteria and where those absolute criteria are relevant, no implementation of the present proposal should allow their circumvention. Process A three phase process is outlined. A submitted system must satisfy the first phase before moving on to the second, and so forth. However, each phase may become an iterative process in which issues with a submission are pointed out by the evaluators until an acceptable revision is approved. For each of the three phases the parts required of a submission are sketched: 1) System architecture (a) The high-level "architectural" description of the voting system mechanism as a collection of component parts with defined interfaces. (b) The claimed level of resistance to tampering with election results, violations of vote secrecy, and disruption of elections. (c) Properties required of the various component parts of the voting system mechanism in order to achieve 1b. (d) The procedures and legal setting required overall by the architecture. 2) Test plan (a) Detailed security, privacy and reliability test plan for an implementation of the architecture. (b) Argumentation for why the test results would imply the properties claimed in 1b above. (c) Usability test experimental design, with actual voters and officials. (d) Argumentation for why any aspect of the test procedure is not taken directly from the VVSG. 3) Test results (a) Argumentation for why the tests performed conform with parts 2a and 2c of the test plan. (b) Argumentation for why the test results satisfy 2b. Committee composition A key component of the approach is the committees and its success depends on the quality of their composition. A sketch of an example procedure for selecting committees is as follows: Each committee is to be composed of a chairman and one member representing each specialty. Specialties might include, for example, computer security, cryptography, physical security, reliability, usability, voters with disabilities, and election administration. For each specialty, a set of institutions is identified. For instance: published surveys and the like generally rank universities relative to various academic fields; the National Academy and professional organizations maintain lists of fellows and the like; and DOE national laboratories, NIST, and the intelligence community all have known expertise in relevant areas. NASED comprises state election directors. Arbitration organizations have members that might make ideal chairpersons, owing to their legal backgrounds and skills in mediating technical issues. Each institution is allocated one or more slots to which they can nominate their best experts for their assigned specialty. A core committee preferably follows a proposal through the three phases described above, but it may bring in or consult additional experts from time to time. A board can provide continuity, corporate memory, and an appeals procedure. Experts within a specialty would elect two members from their specialty to sit on the overall board, subject to EAC approval. Additional Properties In addition to being practical and flexible in scope, as has been described, four additional properties may be desired. Transparency is readily achieved by making submissions and proceedings a matter of public record. Openness can be obtained by allowing the analog of so-called "friend of the court" briefs and even third-party challenges as with issued patents. Modularity, and hence re-usability, of approved architectures as well as their component parts can help lower the entry cost for superior products or components and reduce the work of the committees. Precedent established by earlier approved architectures and their properties can allow for a relative ranking system to be constructed organically, providing overall fairness and comparability, which may further stimulate competition.

Comment by Ariel J. Feldman, Harlan Yu (Princeton University) (Academic)

In our view, this section does not go into sufficient detail about the process by which an innovation class submission would be evaluated. It does not specify the makeup of the review panel, nor does it adequately explain the criteria that the panel would use. The innovation class approval process must be rigorous so that the innovation class does not just become a loophole that allows the current flawed generation of paperless voting systems to be certified.

Comment by Marybeth Kuznik (Local Election Official)

While new research and development is generally a good thing, I hope that "Innovation" will not be used to foist more junk and headaches on our local elections and our local election boards. Please keep any "innovation" in compliance with Software Independence. Marybeth Kuznik Elected Majority Inspector of Elections Penn Township, Westmoreland County PA

Comment by ACCURATE (Aaron Burstein) (Academic)

In the broad contours presented in this section, the innovation class represents a sensible solution to the problem of excluding (future) technologies that do not fit the currently defined classes. The current innovation class requirements, however, would benefit from some amendments. First, this section should make it absolutely clear that innovation class devices must be software-independent. Second, it is unclear why an innovation class submission must separately justify a device's innovativeness (requirement 1:2.7.2-B). It would seem to be a sufficient demonstration of innovativeness that a device performs or supports one or more recognized voting activities, and that it does so in a manner that is not contemplated by other specific classes. As the draft's discussion of requirement 1:2.7.2-B states, the threshold consideration for an innovation class submission is "whether the creation of a new class is justified" based on a description of the device's "functionality, boundaries, and interactions with other devices." This description actually provides a more concrete guide to the identification of innovativeness than does the text proposed for requirement 1:2.7.2-B. Accordingly, we recommend that the requirement incorporate the concrete language of the discussion. Third, the EAC should consider using the innovation class to support a more nuanced view of interpreted code than is set forth in the current VVSG draft. See ACCURATE's narrative comments on Part 1:6.4.1.7-A.4 for further explanation. (http://www.accurate-voting.org/) Fourth, making the innovation class work in practice will require a clear plan for ongoing institutional support from the EAC. This support is critical to managing the development of the innovation class. Ways that the EAC might produce this support include: (a) maintaining the TGDC/NIST relationship or a similar body as a source of technical, elections and scientific expertise on voting systems in order to evaluate innovation class submissions; and (b) either creating a set of procedural guidelines to accompany the substantive requirements in the VVSG, or modifying the VVSG to include these procedures. For example, the EAC will need procedures to manage the confidentiality of innovation class submissions, and to gather public comment and publish decisions about innovation class submissions.

 

2.7.2-A Innovation class submissions follow same procedures as standard

For each distinct innovation class submission, the manufacturer SHALL adhere to the same submission procedures and requirements as for standard submissions.

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation"

Source: New requirement

3 Comments

Comment by Rita Reisman (General Public)

Because all computer systems are subject to errors, and computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use, and because this can be exremely difficult to find, we MUST have verifiable voting machines. Each voter MUST receive a printout of his/her vote (similar to ATM machines) to be sure that all votes can be counted if a malfunction is thought to have occurred. THIS is crucial to the integrity of democratic elections - voting systems MUST provide a means of recording and recovering a voter's intent that does not depend on the reliability of software.

Comment by Janice Ulangca (General Public)

All computer systems are subject to errors. Computer systems can also malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide ways to record and recover voter intent that does not depend on the reliability of software.

Comment by Jerome McIntire (Voter)

I think the standard submission procedures and requirements will keep the systems "clean" and that the standard requirements must be rigorous enough that any innovative solution will still provide independent, voter-verifiable results.

 

2.7.2-B Identification of innovativeness

Each distinct innovation class submission SHALL include additional documentation that provides an explanation as to why the voting system and its accompanying devices are innovative and how they differ from voting technology that implements other voting device classes in the VVSG.

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation"

DISCUSSION

The submission in effect requests the creation of a new device class for each distinct innovative device included in the voting system. This requirement is for the purpose of evaluating whether the creation of a new class is justified. To satisfy this requirement, the submitter may provide an overview of the device describing its functionality, boundaries, and interactions with other devices.

Source: New requirement

3 Comments

Comment by Craig Burton (Manufacturer)

Innovation should allow for new devices, combinations of devices and software techniques and protocols for processing and transmission of election-related data. Innovation class should allow for entire new frameworks which new protocols require such as the interchangeable granularity of system components proposed in EMLv5 and earlier. Innovation class should not be limited to single devices. It would be good if the process for assessing innovation did not seek to impose the VVSG standards entirely as the end point of the submission. New systems will lend themselves to new techniques, such as new kind of auditing and new audit artefacts. This may in fact lead to revisions in the current VVSG if the new device or new technique implies considerable change.

Comment by Craig Burton, CTO, EveryoneCounts.com (Manufacturer)

As a voter, I believe that any software system of voting must be backed up with a verifiable paper trail. There are too many opportunities for the data being corrupted or tampered with to rely solely on software to tabulate voting results.

Comment by ACCURATE (Aaron Burstein) (Academic)

See ACCURATE's comment for 1:2.7.2.

 

2.7.2-C Innovation class submission creates new device class

For each distinct innovation class submission, the manufacturer SHALL request and justify that a new device class be created in the VVSG for each distinct innovative device in the submission

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

Source: New requirement

1 Comment

Comment by ted selker (Academic)

"Identify the new device classes to be created and where they fit into the device class hierarchy" This statement seems to contradict 2.7.2.

 

2.7.2-C.1 Innovative device class submission

For each distinct innovation device class submission included In the voting system, the implementation statement for the voting system SHALL identify the new device classes to be created and where they fit into the device class hierarchy.

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

Source: New requirement

2 Comments

Comment by Al Giles (Voter)

Voting is a fundamental and important right in the US. All voting systems need to be open, accurate, transparent, trustworthy, and honest. We need to have a paper trail of all votes so that they can be checked for accuracy. We also need open systems, so that all can know what is involved. Please ensure these things.

Comment by Karen L.Stoddard (Voter)

As a voter, I believe that any software system of voting must be backed up with a verifiable paper trail. There are too many opportunities for the data being corrupted or tampered with to rely solely on software to tabulate voting results.

 

2.7.2-C.2 Innovation device class identification of requirements

For each distinct innovation device class submission included in the voting system, the implementation statement for the voting system SHALL identify all requirements that apply to the new class and suggested test methods.

Applies to: Voting system

Test Reference: Part 3: 4.1 "Initial Review of Documentation", Requirement Part 3: 4.2-C

DISCUSSION

Identification of applicable requirements may occur through inheritance from superclasses or it may occur through reuse of requirements from other, similar classes.

Source: New requirement

31 Comments

Comment by Chris Tiffany (Voter)

PAPER! PAPER! PAPER! Machines "broke" in Durham (sabotaged?) and the Courts demanded the evidence be protected (it was destroyed before the FBI experts got here) and the Courts demanded that paper ballots be provided (they were not) and there were other cheats that year (thousands of Black Democrats were threatened with post-cards pretending to be from the Board of Elections, threatening $500 fine or 90 days in jail for unspecified (false) registration problems, keeping voters from the polls (no one responsible for obstructing voting nor those guilty of voter intimidation went to prison) (and when I was chased from the polls by some thug with a baseball bat, my complaints disappeared and the police said I should take my complaint to the CIA). Anyway, when there was later a "squeaker" after we switched to paper ballots, the recount verified that the system worked (and found a few uncounted ballots -- oops). Bottom Line? REQUIRE VOTER_VERIFIABLE PAPER BALLOTS! (And send election criminals to prison.)

Comment by James H. Smith (Voter)

Paper ballots should be the method for voting. Counting should be performed at the precinct level. Suspect counting should be manually. State Supreme Court should have final say in voting matters. Thanks, James H. Smith

Comment by Russell Hallberg (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberately corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Mary Martinez (None)

I've voted in nearly every election for the last 40 years, but we can no longer have any confidence in our votes being counted correctly or counted at all, nor can you, your children or grandchildren. We MUST NOT have election recording dependent on any software!

Comment by Daniela Gioseffi (Academic)

As a retired professor of communications, and a voter, I attest to the fact that computer systems are subject to error in that they can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter receipts or intent which doesn't depend on fallible nature of software. WE MUST UPHOLD SYSTEMS OF VOTING IN WHICH VOTERS CAN HAVE COMPLETE CONFIDENCE OR WE UNDERMINE DEMOCRACY AND DESTROY THE INTEGRITY OF OUR NATIONAL PURPOSE. FEW BELIEVED WHOLEHEARTEDLY IN THE RESULTS OF THE LAST TWO ELECTIONS BECAUSE OF THE TOUCH SCREEN, NO VERIFIABLE RECEIPTS, OF THEIR VOTES. MANY BELIEVED THAT THE MACHINERY WAS MISUSED AND 'HACKED INTO" AND RESULTS DISTORTED AWAY FROM THE WILL OF THE PEOPLE. NEARLY EVERY PERSON ONE MEETS, BOTH HERE AND ABROAD, EXPRESSES DOUBT IN THE AMERICAN VOTING SYSTEM. THE REPUTATION OF THIS NATION AS A TRUE DEMOCRACY THAT IS RULED BY THE MAJORITY VOTE IS GREATLY DEGRADED.

Comment by Marie W. Puckett (Voter)

I am in favor of having some type of backup system, preferably paper, for the electronic voting machine. It is my belief that there is always a possibility that electronic equipment can fail and that to be absolutely sure of the correct vote, a paper trail would certainly be advantageous just in case.

Comment by Gerald R. Lotierzo (Voter)

There is one sure way to satisfy the voting public that our votes will count. Paper ballots with an optical scanning device and a ballot marking device for the disabled. The paper ballots will be available for a hand recount if necessary. Trusting DRE systems with our votes has proven unreliable and they can be tampered with to influence the count. We don't need election systems we cannot trust. That will deal a blow to our participatory democracy.

Comment by Jane Hardy (Voter)

"Computerized voting equipment is inherently subject to programming error, equipment malfunction, and malicious tampering. It is therefore crucial that voting equipment provide a voter-verifiable audit trail, by which we mean a permanent record of each vote that can be checked for accuracy by the voter before the vote is submitted, and is difficult or impossible to alter after it has been checked. Many of the electronic voting machines being purchased do not satisfy this requirement. Voting machines should not be purchased or used unless they provide a voter-verifiable audit trail; when such machines are already in use, they should be replaced or modified to provide a voter-verifiable audit trail. Providing a voter-verifiable audit trail should be one of the essential requirements for certification of new voting systems."

Comment by Carol Morrison (Academic)

My husband is a software engineer. Knowing what he and I know about computer software, we are adamantly opposed to computerized voting mechanisms without a verifiable paper trail, because all computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Beverly L. Schwartz (Academic)

There should be federal uniform rules for elections with forms supplied by the federal government on uniform paper. Hand marked paper ballots are preferred. If machines are used, thered must be software independence and voter verifiable paper which should be printed and given to the voter to check and deposit into the ballot box. All ballots should be hand counted at precincts with interested parties observing and results should be posted. All precinct tallys and absentee ballots should be counted at the registrar's office with observers from interested parties. Regular audits should be required. Democracy deserves and requires honest elections.

Comment by Mara Alper (Voter)

It is essential for our democracy that voting systems be Software Independent with verifiable paper trails. Without these, we no longer have a true democracy. I value my country for its democracy. Let us up hold that with Software Independent voting systems

Comment by Mary Schneider (Voter)

All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. DAH!

Comment by bradley Sherman (Voter)

The bottom line is that registration doesn't impede the process, while requiring the minimum criteria of eligiblity without leaving the process open to fraud. And that a paper or hard copy is produced when using electronic voting machines to allow for certification and confirmation of each vote.

Comment by Allison Tupper (General Public)

So-called voter-verified paper trails are not enough because they are not reliably verifiable. There are too many windows for error or fraud. We need 1) voter-marked ballots and 2) chain of custody guarantees and 3) public, immediate, audits of more than 3 percent of election districts, and the districts must be chosen publicly, randomly, and after the polls have closed.

Comment by sholey argani, M.D. (Voter)

We know computer systems are vulnerable to errors. Computer systems can also malfunction or be deliberately corrupted at any stage of their design, manufacture, & use. Indeed, such manipulation can be extremely difficult to foresee & detect. Thus, it's essential that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by arlene coulter (Voter)

all states are in desperate need of verified voter intent aside from the software offered by mfg companies of the systems...without separate paper verified records of the vote our the national election coming up in november is in big trouble...we have had too many instances in the past few years of questionable results to rest with current policy

Comment by Doug Bullock (Voter)

Most electronic voting machines have no paper trail and can be easily hacked into by a computer specialist. Since there is no paper trail, ther is no way to record how a person voted or if the vote indicated beloned to the voter. Computer Independence is a solution to electronic machines. There can be no genuine recount or audits with electronic touch screen machines Otherwise Optical Scan/Paper ballot is a verifiable voting machine that can utilize recounts & audits

Comment by jeff saunders (Voter)

All computer software and related hardware is subject to human error and manipulation. There is a growing body of evidence that the last few elections where results reported by electronic voting machines have been corrupted, possible intentionally, to alter the outcome. Without a paper trail there is no possible way to audit or recount results where problems are suspected. For the life of me I cannot understand why this is so hard to do. When you make a purchase somewhere you get a reciept. Why not a receipt when you vote? I guess someone out there wants to control the outcome of elections to their benefit. Now who could that be? I think you only have to look at who is opposed to a paper trail.

Comment by Nancy Chapman (General Public)

It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software. All computer systems are subject to subtle errors. Moreover, computer systems can malfunction or be deliberateley corrupted at any stage of their design, manufacture, and use. The methods used to do this can be extremely difficult to foresee and detect.

Comment by Barbara Rexilius (Voter)

I just tried to read this report but of course I have only a Masters degree in Nursing with 3 statistic classes and found it was beyond me. I do use computers as evidenced by this message, however I am not a geek about it. The point is that the standards and the system used need to be 1.)understandable to the general population, 2)the results must be varifiable. A system that is strickly computerized can not be varified. There has to be a paper trail for varification...a paper that the voter can look at to see that the computer correctly reported the vote and a paper or duplicate that is returned to a recepticle that can be used to varify the correctness of the computer's entry, based on need or as a random check. As we all know computers at their best make mistakes...just yesterday I had one tell me I did not have a valid zip code...wrong. Computers crash. Computers can be programed incorrectly intentionally or unintentionally. We have to have a voting sytem that we all have faith in...

Comment by Martin Kupferberg (Voter)

Ad a voter and election inspector, I am fully in support of software independence as a part of the federal guidelines for voting systems. The voter needs to be certain that his/her vote was the vote cast. That requires voter-verifiable paper records or ballots that are software independent. Also, there should be standard data reporting format for the auditing of elections. No electronic machine is exact enough to be perfect all the time and it is those times of imperfection that a paper trail is needed to validate ones vote.

Comment by Ray Padgett (Voter)

Based on my over 25 years of work in computer technology (over five years spent in computer systems audit), with a major international corporation; I believe it is impossible to ensure error free voting systems unless you have a paper trail and required audits. In general, your guidelines are to complex, and thus try to cover to many areas of a voting system that are not needed. Also, guidelines are not what we need - we need MANDATORY requirements. I believe any system must be cheap, auditable by each voter and easy to understand by all voters. Based on my experience, the following Citizen Verified Voting system provides all of these. 1. All votes are on paper ballots, scanned, counted and placed on-line so that each citizen can verify that their vote was recorded correctly and that all citizens can verify the total count. This requires that each citizen has a "receipt" or copy of their ballot and that the ballot number is included on-line. An adequate time (3 or 4 weeks) must be allowed for vote accuracy challenges. The cheapest way to vote is by mail. Vote by mail also supports the Citizen Verified Voting proposal. Thanks you! Ray Padgett ray88padgett@earthlink.net 850-859-2257

Comment by Bernadette Egen (Voter)

I am not technologically savvy enough to understand all the provisions detailed above, but I do know that if we want to keep the USA a democracy, nothing is more important than to have a way to double check accurately election results and that a system independent of private companies interests is the only way. We cannot afford another disaster like Florida in 2000. The trust of voters in our government is being seriously eroded by the seeming reluctance of our elected officials to insure fair elections.

Comment by Ben Aldridge (General Public)

Voting machines must all have a software-independent means of verification. There must be a paper receipt, copy, "trail" - whatever you want to call it - for EVERY vote cast.

Comment by Carol Lapetino (Voter)

Computer systems can malfunction or be tampered with or corrupted at any stage of design, manufacture and use. The methods used todo this can be almost impossible to foresee and detect. Therefore, it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software.

Comment by Margarita Denevan (Voter)

Verifiable election results are absolutely necessary. Anything less, even by a fraction, is totally unacceptable. Any software than can in any way be tampered with IS TOTALLY UNACCEPTABLE because it would utterly defeat the DEMOCRATIC PROCESS OF FREE ELECTIONS.

Comment by Hilda Wilcox (Academic)

It is essential to the reliability of our voting apparatus that we have optical scanners and/or paper ballots to verify the vote we have cast. Software alone cannot be trusted to deliver our intentions accurately: we need a verifiable system to have complete trustworthiness in registering our vote.

Comment by Brenda Smith (Voter)

I would like to know the republicans and president threatened to derail the original voter protection will unless there was NOT a paper trail. This tells me that someone intended to cheat. Computers can be rigged, can fail or record incorrectly. Fraud is difficult to prove when a private company is trusted and will not allow government scrutiny. It is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software

Comment by Jane Telfair Stowe (Voter)

Computer software can contain errors and is subject to being corrupted or altered. Therefore SOFTWARE INDEPENDENCE is very important for maintaining our democratic voting integrity. This means there must be a paper record of the votes cast so the voter can make sure he or she voted as intended, i.e. that the computer recorded the vote the way the voter intended. Without this both tecnical errors or deliberate manipulation of the software could mess up the vote.

Comment by James Dunlop (Voter)

All computer systems are subject to errors. Computer systems can malfunction or tampered with at many stages of their design, manufacture, and use. These can be difficult to detect. I believe it is crucial to the integrity of elections that voting systems provide a means of recording and recovering voter intent that does not depend on the reliability of software."

Comment by linda Brenner (Voter)

I strongly support keeping a paper trail within our voting. The machines used could simply have their cutting blades SHARPENED. WE SHOULD STAY SOFTWARE INDEPENDENT. Please note the film "MAN OF THE YEAR" We MUST be able to recount votes. Otherwise, one more questionable election outcome and the American people will loose ALL faith in our system of government.