Revised Voting Machine Standards Introduced

On Tuesday, 2/14/06 the State Board of Elections met in public and executive session. At the meeting, the Second Draft of the Voting Machine Regulations was formally introduced. This revision is the State Board’s response to the public commentary on the Draft Voting System Standards.

The proposed final standards are now available for public comment. The final 10 day public comment period will end on Friday, 2/24/06. Details about how the public can submit comments on the proposed final standards can be found below, as well as a link to the document.

NYVV Comments on the Revised Regulations
Unfortunately, the proposed final standards do little to improve the many weaknesses present in the original version of the Draft Standards. It is disappointing, and a cause for concern, to see how much of the detailed technical commentary the State Board received was simply ignored in the latest revision.

One welcome addition is a lengthy section describing requirements for voter verified paper ballots (VVPAT), which was notably absent from the Draft Standards. But overall, nothing substantive has changed. Among many crucial issues not addressed in the Final Standards are:

• The certification and testing process is vendor driven and managed. Far too much discretion is given vendors to define and influence the certification process.
   
• Allows the State Board to waive any requirements without cause.
   
• Does not require vendors to submit both DRE and scanner systems.
   
• Does not require that all written procedures used to conduct testing, the tests themselves, and the results of such testing be fully and readily available and open to the public.
   
• Poor acceptance test requirements.
   
• No requirement for comprehensive security testing of voting systems such as “Red Team” tests.
   
• No requirement for the usability and accuracy of the system to be demonstrated to the public. Each system must be required to pass a multi-machine Public Mock Election Test.
   
• No requirement for a challenge system under which independent experts can petition the Board to perform a test in order to prove system shortcomings.

NYVV and several noted security experts will be submitting detailed commentary on the Second Draft of the Regulations. As currently written, the revised regulations do little to protect our right to vote. The State Board of Elections must recognize that the voters are the primary stakeholders in elections, and we require adequate security safeguards, comprehensive and extensive testing of voting systems, and a fully visible and transparent process.

Submitting Comment on the Final Standards
The public can submit comments on the proposed final standards by Friday, 2/24/06 by sending them to:

NYS Board of Elections
40 Steuben Street
Albany, NY 12207-2108

Or via email:

info@elections.state.ny.us

Download the Second Draft of the Voting Machine Regulations: http://www.elections.state.ny.us/hava/2ndDraftVotingMachineRegs.pdf