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New Version of Holt Bill: A Giant Step Backwards

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Well, the Standards Board resolutions came about following the Standards Board review of all references to sections identified with the numbers 2.2.7.xxx in the 2005 Draft VVSG. These sections all referred to the text conversion guideline,which had been inserted into the draft VVSG that the Standards Board had reviewed. As you can see, per the Standards Board recommendation, the text-to-digital data conversion guideline was to be removed from the VVSG.

The Standards Board made this recommendation because they understood the financial cost of this guideline (expecting every polling place in the country to have a device to convert text to digital media), and they also knew that it would compromise the integrity and transparency of PAPER BALLOT-based election systems.

However, in a move oddly reminiscent of its appearance late in the game during the drafting of the 2007 Holt Bill, the text conversion guideline had mysteriously been reinserted into the VVSG that was released and approved by the EAC in December 2005.

We can't say for sure how this happened, but we know that, by the EAC's own rules, Executive Director of the EAC, Tom Wilkey, had the final authority on what would be included in the released version of the VVSG.

So it would appear that 110 Standards Board members decided one thing, and one EAC Executive Director decided another.

And democracy lost.

December 2005


So when the VVSG 2005 guidelines were released, here is how the text conversion guideline magically reappeared:

4.7.4 Availability Test The accredited test lab shall assess the adequacy of system availability based on the provisions of Volume I, Section 4.

As described in this section, availability of voting system equipment is determined as a function of reliability, and the mean time to repair the system in the event of failure. Availability cannot be tested directly before the voting system is deployed in jurisdictions, but can be modeled mathematically to predict availability for a defined system configuration. This model shall be prepared by the vendor, and shall be validated by the accredited testing laboratory.

The model shall reflect the equipment used for a typical system configuration to perform the following system functions:

For all paper-based systems: Recording voter selections (such as by ballot marking)

Scanning the marks on paper ballots and converting them into digital data

February 2007

The requirement appears in the new Holt Bill. An unfunded federal mandate that every polling place in the United States purchase and use a new technological device that will convert ballot text into digital data to be converted into "accessible media".

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Nancy Tobi is best known as a national leader in the voting rights movement for her seminal work exposing the dangers and fallacies in various election reform efforts past, present and future. Nancy is co-founder and former Chair of Democracy for (more...)

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