December 26, 2004
Memo To: Election Assistance Commission (EAC),
EAC Technical Guidelines Development Committee (TGDC),
Chairs IEEE SCC 38 and P1583
From: Al Kolwicz, IEEE P1583 committee member, Executive Director CAMBER- Citizens for Accurate Mail Ballot Election Results.
Re: IEEE standards project P1583 Standards for Voting Equipment
Occasionally committees produce a great work product. More often they do not. The work product of the IEEE P1583 project is not suitable for adoption as a national standard consequently, it should be rejected.
Implementation of this draft standard would not move our nation toward secure, accurate and verifiable elections. In fact it would do the opposite.
Methodology - A voting system consists of numerous components. Each of these components must work correctly in order to achieve a trustworthy election. One way to do this is to perfect individual components and then try to glue them together. A more successful way is to first perfect a framework and then develop components.
Requirements - Before considering the P1583 component a precise and comprehensive statement of requirements for the entire voting system must be developed and adopted by the public – not just some insiders. From the legislative process used to create election laws and rules, to the canvass procedures used to verify results of each election, the system needs wholesale reform.
System Architecture – Given the requirements, the nation should adopt an abstract architecture of a voting system, a tight set of requirements for each element of the system, a specification of the primitive functions, a set of metrics, and a set of acceptable methods to prove compliance. The architecture and primitives should be used to construct two or three reference implementations (at the high level) and include complete tests that verify each implementation.
Resources - This is a task that takes motivation, time, talent and money. It cannot be accomplished by amateurs – no matter how motivated and good intentioned. It cannot be accomplished by lawyers or typical legislators. It cannot be accomplished by the sitting Secretary of State and/or staff. And it cannot be accomplished by the county clerks and their people. It should not be accomplished by voting system vendors.
Recommendation - The P1583 draft should be rejected. A project should be authorized to develop the requirements and architecture of our voting system.
