# Insert

## Usability, Accessibility, and Privacy Requirements

### Overview

The importance of usability and accessibility in the design of voting
systems has become increasingly apparent. It is not sufficient that the
internal operation of these systems be correct; in addition, voters and
election officials must be able to use them effectively and efficiently.

There are some properties of voting systems that make good design
especially difficult:

-   The voting task itself can be fairly complex; the voter may have to
    navigate an electronic ballot, choose multiple candidates in a
    single contest, understand the effect of party-line voting, or
    decide on ballot questions written in legal language;

-   Voting is performed infrequently (compared with tasks such as using
    an ATM), so there is relatively limited opportunity for voters and
    poll workers to gain familiarity with the process;

-   Changes in the election process, including new voting equipment, may
    require voters and poll workers to use new and unfamiliar
    procedures; and

-   The set of \"users\" for voting equipment is exceptionally diverse.
    The voting public encompasses a broad range of factors, including
    physical and cognitive abilities, language skills, and technology
    experience.

#### Purpose

The challenge, then, is to provide a voting system that voters can use
comfortably, efficiently, and with justified confidence that they have
cast their votes correctly. The requirements within this section are
intended to serve that goal. Three broad principles motivate this
section:

1.  All eligible voters are to have access to the voting process without
    discrimination. The voting process must be accessible to individuals
    with disabilities. The voting process includes access to the polling
    place, instructions on how to vote, initiating the voting session,
    selecting among contest choices, review of the ballot, final
    submission of the ballot, and getting help when needed.

```{=html}
<!-- -->
```
1.  Each cast ballot must accurately capture the selections made by the
    voter. The ballot must be presented to the voter in a manner that is
    clear and usable. Voters should encounter no difficulty or confusion
    regarding the process for recording their votes.

2.  The voting process must preserve the secrecy of the ballot. The
    voting process should preclude anyone else from determining the
    content of a voter\'s ballot, without the voter\'s cooperation. If
    such a determination is made against the wishes of the voter, then
    his or her privacy has been violated.

Note that these principles refer to the entire voting process. The VVSG
applies only to voting systems; other aspects of the process (such as
administrative rules and procedures) are outside the scope of the VVSG,
but are nonetheless crucial for the full achievement of the principles.

#### Special terminology

Several uncommon terms are used in this section. For the convenience of
the reader, they are defined below. Many other technical terms
frequently used throughout the VVSG are defined in Appendix A. Note in
particular the distinctions among these terms: voting process, voting
system, voting device, voting session, and voting station.

-   Accessible Voting Station (Acc-VS) - the voting station specially
    equipped for individuals with disabilities referred to in HAVA 301
    (a)(3)(B).

-   Audio-Tactile Interface (ATI) - a voter interface designed not to
    require visual reading of a ballot. Audio is used to convey
    information to the voter and sensitive tactile controls allow the
    voter to convey information to the voting system.

-   Common Industry Format (CIF) - the format to be used for summative
    usability test reporting, described in ISO/IEC 25062:2006 \"Common
    Industry Format (CIF) for Usability Test Reports\" \[ISO06e\].

-   Summative Usability Testing - evaluation of a product with
    representative users and tasks designed to measure the usability
    (defined as effectiveness, efficiency and satisfaction) of the
    complete product. The purpose of a summative test is to evaluate a
    product through defined measures, rather than diagnosis and
    correction of specific design problems, as in formative testing.

-   Voter-Editable Ballot Device (VEBD) - voting systems such as DREs
    and EBMs that present voters with an editable ballot (as opposed to
    manually-marked paper ballots), allowing them easily to change their
    votes prior to final casting of the ballot. \"VEBD-V\" denotes the
    visual interface of such systems and \"VEBD-A\" denotes the audio
    interface.

-   Voting Performance Protocol (VPP) - a carefully defined method for
    measuring how well subjects perform various voting tasks within a
    controlled experiment.

#### Interaction of usability and accessibility requirements

All the requirements in Section 3 have the purpose of improving the
quality of interaction between voters and voting systems. Please note
how Sections 3.2 and 3.3 \[XREF\] work together:

-   The requirements for general usability in Section 3.2 \[XREF\] apply
    to ALL voting systems as indicated by their "Applies to" clause,
    *including the* Acc-VS*.* They cover the features that are
    applicable both to the general population and to voters with
    disabilities. In particular, note that the Acc-VS is classified as a
    Voter-Editable Ballot Device and therefore all VEBD requirements
    apply to the Acc-VS. Requirements for any alternative languages
    required by state or federal law are also included under Section 3.2
    \[XREF\].

-   The requirements for accessibility in Section 3.3 \[XREF\] cover
    only those features that are mandatory for the accessible voting
    station (Acc-VS) *in addition* to the general usability
    requirements. For instance, an audio interface would be of interest
    mainly to those with vision or other reading disabilities, but not
    to those who can use a visual interface. Therefore, to determine
    what usability features are required of the Acc-VS, one must examine
    both Sections 3.2 \[XREF\] and 3.3 \[XREF\]. The features of the
    Acc-VS may also assist those not usually described as having a
    disability, e.g., voters with poor reading vision or somewhat
    limited dexterity.

### General Usability Requirements

The voting system should support a process that provides a high level of
usability for all voters. The goal is for voters to be able to negotiate
the process effectively, efficiently, and comfortably.

Many of the mandatory voting system standards in HAVA Section 301
\[HAVA02\] relate to the interaction between the voter and the voting
system:

a\. Requirements.\--Each voting system used in an election for federal
office shall meet the following requirements:

1\. In general.\--

> A. Except as provided in subparagraph (B), the voting system
> (including any lever voting system, optical scanning voting system, or
> direct recording electronic system) shall\--
>
> i\. Permit the voter to verify (in a private and independent manner)
> the votes selected by the voter on the ballot before the ballot is
> cast and counted;
>
> ii\. Provide the voter with the opportunity (in a private and
> independent manner) to change the ballot or correct any error before
> the ballot is cast and counted (including the opportunity to correct
> the error through the issuance of a replacement ballot if the voter
> was otherwise unable to change the ballot or correct any error); and
>
> iii\. If the voter selects votes for more than one candidate for a
> single office -
>
> I. Notify the voter that the voter has selected more than one
> candidate for a single office on the ballot;
>
> II\. Notify the voter before the ballot is cast and counted of the
> effect of casting multiple votes for the office; and
>
> III\. Provide the voter with the opportunity to correct the ballot
> before the ballot is cast and counted.
>
> B. A state or jurisdiction that uses a paper ballot voting system, a
> punch card voting system, or a central count voting system (including
> mail-in absentee ballots and mail-in ballots), may meet the
> requirements of subparagraph (A)(iii) by -
>
> i\. Establishing a voter education program specific to that voting
> system that notifies each voter of the effect of casting multiple
> votes for an office; and
>
> ii\. Providing the voter with instructions on how to correct the
> ballot before it is cast and counted (including instructions on how to
> correct the error through the issuance of a replacement ballot if the
> voter was otherwise unable to change the ballot or correct any error).
>
> C. The voting system shall ensure that any notification required under
> this paragraph preserves the privacy of the voter and the
> confidentiality of the ballot.

The requirements of this section are intended to support these basic
usability standards of HAVA.

#### Performance Requirements

Usability is defined generally as a measure of the effectiveness,
efficiency, and satisfaction achieved by a specified set of users with a
given product in the performance of specified tasks. In the context of
voting, the primary user is the voter (although the equipment is used by
poll workers as well), the product is the voting system, and the primary
task is the correct recording of the votes (although other tasks are
associated with poll workers as users, e.g. system setup).

Additional requirements for task performance are independence and
privacy: the voter should normally be able to complete the voting task
without assistance from others, and the votes should be private. Lack of
independence or privacy may adversely affect effectiveness (e.g., by
possibly inhibiting the voter\'s free choice) and efficiency (e.g., by
slowing down the process).

General usability is covered by both high-level performance-based
requirements (in this section) and design requirements (in following
sections). Whereas the latter require the presence of specific features
generally thought to promote usability, the former *directly* address
metrics for effectiveness (e.g., correct capture of voter selections),
efficiency (e.g., time taken to vote), and satisfaction. The voting
system is tested by having groups of people (representing voters)
attempt to perform various typical voting tasks. The requirement is met
only if those tasks are accomplished with a specified degree of success.

##### Overall performance metrics

The requirements of this section set benchmarks for the usability of the
voting system as a whole. There are three performance requirements that
deal with effectiveness and two reporting requirements, one for
efficiency and one for satisfaction. The metrics are defined as follows:

-   Total Completion Score -- the proportion of users who successfully
    cast a ballot (whether or not the ballot contains erroneous votes).
    Failure to cast a ballot might involve problems such as a voter
    simply "giving up" during the voting session because of an inability
    to operate the system, or a mistaken belief that one has
    successfully operated the casting mechanism.

-   Perfect Ballot Index -- the ratio of the number of cast ballots
    containing no erroneous votes to the number of cast ballots
    containing one or more errors (either a vote for an unintended
    choice, or a missing vote).

-   Voter Inclusion Index -- a measure of both voting accuracy and
    consistency. It is based on mean accuracy and the associated
    standard deviation. Accuracy per voter depends on how many "voting
    opportunities" within each ballot are performed correctly. A low
    value for the standard deviation of these individual accuracy scores
    indicates higher consistency of performance across voters..

-   Average Voting Session Time -- mean time taken per voter to complete
    the process of activating, filling out, and casting the ballot.

-   Average Voter Confidence -- mean confidence level expressed by the
    voters that the system successfully recorded their votes.

Because of the statistical nature of the testing, numerical results must
be interpreted very carefully. The numbers have meaning only within the
context of the Voting Performance Protocol (VPP). Note especially that
the tests associated with these requirements are designed as *repeatable
controlled experiments* and not as "realistic" measures of voting
behavior, as might be found in a wide variety of voting contexts. Please
see \[XREF forthcoming white paper describing the VPP\] for full
details.

The three following requirements are templates to illustrate how
benchmarks for effectiveness metrics might be incorporated into the
VVSG.

-   **3.2.1.1-A**Number range req_subreq Total completion performance

The system ***[shall]{.smallcaps}*** achieve a total completion score of
at least XXX% as measured by the VPP.

Applies to: Voting System

Test Reference: Performance

-   **3.2.1.1-B**Number range req_subreq Perfect ballot performance

The system ***[shall]{.smallcaps}*** achieve a perfect ballot index of
at least XXX as measured by the VPP.

Applies to: Voting System

Test Reference: Performance

-   **3.2.1.1-C**Number range req_subreq Voter inclusion performance

The system ***[shall]{.smallcaps}*** achieve an voter inclusion index of
at least XXX as measured by the VPP.

Applies to: Voting System

Test Reference: Performance

**Note:** It is the intention of the TGDC to establish requirements for
voting systems based on the usability metrics for effectiveness
described above. Specifically, systems will be required to meet certain
benchmarks for Total Completion Score*,* Perfect Ballot Index and Voter
Inclusion Index.

Preliminary research at the direction of the TGDC that included
experimentation with a variety of voting systems has allowed the Human
Factors Subcommittee of the TGDC to judge that the following benchmark
values would allow better systems to pass the test, while preventing
certification of poorer systems:

-   Total Completion Score : 98%

-   Perfect Ballot Index: 2.33

-   Voter Inclusion Index: 0.35

These tentative values may be adjusted based on planned research to be
conducted with additional systems. The TGDC may also consider whether
the benchmarks should be strengthened in anticipation of improvements in
the design of future voting systems.

-   **3.2.1.1-D**Number range req_subreq Usability metrics from the
    Voting Performance Protocol

The test lab ***[shall]{.smallcaps}*** report the metrics for usability
of the voting system, as measured by the VPP.

Applies to: Voting system

Source: New requirement

-   **3.2.1.1-D.1** Effectiveness metrics for usability

The test lab ***[shall]{.smallcaps}*** report all the effectiveness
metrics for usability as defined and measured by the VPP.

Applies to: Voting system

Source: New requirement

-   **3.2.1.1-D.2** Voting session time

The test lab ***[shall]{.smallcaps}*** report the average voting session
time, as measured by the VPP.

Applies to: Voting system

Discussion

This requirement encourages systems to enable voters to vote with
reasonable speed. Note that this requirement does not apply to the audio
interface of a system, nor to the use of special input devices for
voters with dexterity disabilities.

Source: New requirement

-   **3.2.1.1-D.3** Average voter confidence

The test lab ***[shall]{.smallcaps}*** report the average voter
confidence, as measured by the VPP.

Applies to: Voting system

Source: New requirement

##### Manufacturer testing

-   **3.2.1.2-E**Number range req_subreq Usability testing by
    manufacturer for general population

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests on the voting system using individuals who are representative of
the general population and ***[shall]{.smallcaps}*** report the test
results, using the Common Industry Format, as part of the TDP.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

Discussion

Voting system developers are required to conduct realistic usability
tests on the final product before submitting the system to conformance
testing. This is to encourage early detection and resolution of
usability problems.

#### Functional capabilities

The usability of the voting process is enhanced by the presence of
certain functional capabilities. These capabilities differ somewhat
depending on whether or not the system presents an editable interface
within which voters can easily change their votes (typically an
electronic screen) or an interface in which voters must obtain a new
ballot to make changes (typically a manually-marked paper ballot).

-   **3.2.2-F**Number range req_subreq Notification of effect of
    overvoting

If the voter selects more than the allowable number of choices within a
contest, the voting system ***[shall]{.smallcaps}*** notify the voter of
the effect of this action before the ballot is cast and counted.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

In the case of manual systems, this may be achieved through
appropriately placed instructions. This requirement has no force for
VEBD systems, since they prevent overvoting in the first place.

-   **3.2.2-G**Number range req_subreq Undervoting to be permitted

The voting system ***[shall]{.smallcaps}*** allow the voter, at the
voter's choice, to submit an undervoted ballot without correction.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.2-H**Number range req_subreq Correction of ballot

The voting system ***[shall]{.smallcaps}*** provide the voter the
opportunity to correct the ballot for either an undervote or overvote
before the ballot is cast and counted.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

In the case of manual systems, this may be achieved through
appropriately placed written instructions. Some corrections may require
the voter to obtain a new paper ballot from a poll worker. Also, note
the requirements on precinct-count optical scanners in \[XREF Section
3.2.2.2\] below.

-   **3.2.2-I**Number range req_subreq Notification of ballot casting

If and only if the voter successfully casts the ballot, then the system
***[shall]{.smallcaps}*** so notify the voter.

Applies to: DRE, PCOS

Test Reference: Part 3 Section 3.2

Discussion

The purpose of this requirement is to provide feedback to voters to
assure them that the voting session has been completed. Note that either
a false notification of success or a missing confirmation of actual
success violates this requirement.

##### Editable interfaces

Voting systems such as DREs and EBMs present voters with an editable
interface, allowing them to easily change their votes prior to final
casting of the ballot.

-   **3.2.2.1-J**Number range req_subreq Prevention of overvotes

The VEBD ***[shall]{.smallcaps}*** prevent voters from selecting more
than the allowable number of choices for each contest.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

This requirement does not specify exactly how the system must respond
when a voter attempts to select an \"extra\" candidate. For instance,
the system may prevent the selection and issue a warning, or, in the
case of a single-choice contest, simply change the vote.

-   **3.2.2.1-K**Number range req_subreq Warning of undervotes

The VEBD ***[shall]{.smallcaps}*** provide feedback to the voter, before
final casting of the ballot that identifies specific contests for which
the voter has selected fewer than the allowable number of choices (i.e.,
undervotes).

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

For VEBD systems, no allowance is made for disabling this feature. Also,
see requirement below on \"Clarity of Warnings.\"

-   **3.2.2.1-L**Number range req_subreq Independent correction of
    ballot

The VEBD ***[shall]{.smallcaps}*** provide the voter the opportunity to
correct the ballot before it is cast and counted. This correction
process ***[shall]{.smallcaps}*** not require external assistance. The
corrections to be supported include modifying an undervote or overvote,
and changing a vote from one candidate to another.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

-   **3.2.2.1-M**Number range req_subreq Ballot editing per contest

The VEBD ***[shall]{.smallcaps}*** allow the voter to change a vote
within a contest before advancing to the next contest.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

The point here is that voters using an editable interface should not
have to wait for a final ballot review screen in order to change a vote.

-   **3.2.2.1-N**Number range req_subreq Contest navigation

The VEBD ***[shall]{.smallcaps}*** provide navigation controls that
allow the voter to advance to the next contest or go back to the
previous contest before completing a vote on the contest(s) currently
being presented (whether visually or aurally).

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

For example, voters should not be forced to proceed sequentially through
all the contests before going back to check their votes within a
previous contest.

-   **3.2.2.1-O**Number range req_subreq Notification of ballot casting
    failure (DRE)

If the voter takes the appropriate action to cast a ballot, but the
system does not accept and record it successfully, including failure to
store the ballot image, then the DRE ***[shall]{.smallcaps}*** so notify
the voter and provide clear instruction as to the steps the voter should
take to cast the ballot.

Applies to: DRE

Test Reference: Part 3 Section 3.2

Discussion

If a DRE fails at the point of casting a ballot, it must clearly
indicate to the voter and to election officials responding to the
failure whether or not the ballot was cast. Otherwise, election
officials may be unable to provide substantial confirmation that the
vote was or was not counted, possibly resulting in disenfranchisement or
the casting of two ballots by a single voter.

A device that \"freezes\" when the voter attempts to cast the ballot,
providing no evidence one way or the other whether the ballot was cast,
would violate this requirement.

Source: 2002 VSS I.2.4.3.3.k / VVSG\'05 I.2.3.3.3.m

##### Non-Editable interfaces

Non-Editable interfaces, such as manually-marked paper ballots (MMPB) do
not have the same flexibility as do editable interfaces. Nonetheless,
certain features are required, especially in the case of precinct-based
optical scanners. Note that the technical definition of \"marginal
mark\" may be found in Appendix A. Basically, a marginal mark is one
that, according the manufacturer specifications, is neither clearly
countable as a vote nor clearly countable as a non-vote.

-   **3.2.2.2-P**Number range req_subreq Notification of overvoting

The voting system ***[shall]{.smallcaps}*** be capable of providing
feedback to the voter that identifies specific contests for which the
voter has made more than the allowable number of votes (i.e,.
overvotes).

Applies to: PCOS

Test Reference: Part 3 Section 3.2

-   **3.2.2.2-Q**Number range req_subreq Notification of undervoting

The voting system ***[shall]{.smallcaps}*** be capable of providing
feedback to the voter that identifies specific contests for which the
voter has made fewer than the allowable number of votes (i.e.,
undervotes). The system ***[shall]{.smallcaps}*** provide a means for an
authorized election official to deactivate this capability entirely and
by contest.

Applies to: PCOS

Test Reference: Part 3 Section 3.2

-   **3.2.2.2-R**Number range req_subreq Notification of blank ballots

The voting system ***[shall]{.smallcaps}*** be capable of notifying the
voter that he or she has submitted a paper ballot that is blank on one
or both sides. The system ***[shall]{.smallcaps}*** provide a means for
an authorized election official to deactivate this capability.

Applies to: PCOS

Test Reference: Part 3 Section 3.2

Discussion

One purpose of this feature is to detect situations in which the voter
might be unaware that the ballot is two-sided. This feature is distinct
from the ability to detect and warn about undervoting.

-   **3.2.2.2-S**Number range req_subreq Ballot correction or submission
    following notification

If the voting system has notified the voter that a potential error
condition (such as an overvote, undervote, or blank ballot) exists, the
system ***[shall]{.smallcaps}*** then allow the voter to correct the
ballot or to submit it as is.

Applies to: PCOS

Test Reference: Part 3 Section 3.2

Discussion

This requirement mandates that the equipment be capable of allowing
either correction or immediate submission. For instance, a questionable
paper ballot might be physically ejected for possible correction. This
requirement does not constrain the *procedures* that jurisdictions might
adopt for handling such situations (e.g., whether poll worker
intervention is required).

-   **3.2.2.2-T**Number range req_subreq Handling of marginal marks

Paper-based precinct tabulators ***[should]{.smallcaps}*** be able to
identify a ballot containing marginal marks. When such a ballot is
detected, the tabulator ***[shall]{.smallcaps}***:

-   Return the ballot to the voter;

-   Provide feedback to the voter that identifies the specific contests
    for which a marginal mark was detected; and

-   Allow the voter either to correct the ballot or to submit the ballot
    \"as is\" without correction.

Applies to: Precinct tabulator

Test Reference: Part 3 Section 3.2

Discussion

The purpose of this requirement is to provide more certainty about the
handling of poorly-marked ballots. If a given candidate or option is
clearly marked as chosen, or left completely unmarked, then there is no
ambiguity to resolve. But each manufacturer should define a \"gray
zone\" (with respect to location, darkness, etc.) in which marks will be
actively flagged as ambiguous.

-   **3.2.2.2-U**Number range req_subreq Notification of ballot casting
    failure (PCOS)

If the voter takes the appropriate action to cast a ballot, but the
system does not accept and record it successfully, including failure to
read the ballot or to transport it into the ballot box, the PCOS
***[shall]{.smallcaps}*** so notify the voter.

Applies to: PCOS

Test Reference: Part 3 Section 3.2

Discussion

See also \[XREF: Requirement 7.7.4-B, "Paper-based tabulator, indicate
status of misfed ballot"\].

#### Privacy

The voting process must preclude anyone else from determining the
content of a voter\'s ballot without the voter\'s cooperation. Privacy
ensures that the voter can cast votes based solely on his or her own
preferences without intimidation or inhibition.

##### Privacy at the polls

-   **3.2.3.1-V**Number range req_subreq System support of privacy

The voting system ***[shall]{.smallcaps}*** prevent others from
determining the contents of a ballot.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

The voting system itself provides no means by which others can
\"determine\" how one has voted. Of course voters could simply tell
someone else for whom they voted, but the system provides no evidence
for such statements, and therefore voters cannot be coerced into
providing such evidence.

It is assumed that the system is deployed according to the installation
instructions provided by the manufacturer. Whether the configuration of
the voting system protects privacy may well depend on proper setup.

-   **3.2.3.1-V.1** Visual privacy

The ballot, any other visible record containing ballot information, and
any input controls ***[shall]{.smallcaps}*** be visible only to the
voter during the voting session and ballot submission.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

This requirement may involve different approaches for electronic and
paper interfaces. In both cases, appropriate shielding of the voting
station is important. When a paper record with ballot information needs
to be transported by the voter, devices such as privacy sleeves may be
necessary. This requirement applies to all records with information on
votes (such as a vote verification record) even if that record is not
itself a ballot.

-   **3.2.3.1-V.2** Auditory privacy

During the voting session, the audio interface of the voting system
***[shall]{.smallcaps}*** be audible only to the voter.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

Voters who are hard of hearing but need to use an audio interface may
also need to increase the volume of the audio. Such situations require
headphones with low sound leakage.

-   **3.2.3.1-V.3** Privacy of warnings

The voting system ***[shall]{.smallcaps}*** issue all warnings in a way
that preserves the privacy of the voter and the confidentiality of the
ballot.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

HAVA 301 (a)(1)(C) mandates that the voting system must notify the voter
of an attempted overvote in a way that preserves the privacy of the
voter and the confidentiality of the ballot. This requirement
generalizes that mandate.

-   **3.2.3.1-V.4** No receipts

The voting system ***[shall]{.smallcaps}*** not issue a receipt to the
voter that would provide proof to another of how the voter voted.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

##### No recording of alternative format usage

When voters use non-typical ballot interfaces, such as large print or
alternative languages, their anonymity may be vulnerable. To the extent
possible, only the logical contents of their ballots should be recorded,
not the special formats in which they were rendered. In the case of
paper ballots, where the interface *is* the record, some format
information is unavoidably preserved.

-   **3.2.3.2-W**Number range req_subreq No recording of alternative
    languages

No information ***[shall]{.smallcaps}*** be kept within an electronic
cast vote record that identifies any alternative language feature(s)
used by a voter.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.3.2-X**Number range req_subreq No Recording of Accessibility
    Features

No information ***[shall]{.smallcaps}*** be kept within an electronic
cast vote record that identifies any accessibility feature(s) used by a
voter.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

#### Cognitive issues

The features specified in this section are intended to minimize
cognitive difficulties for voters. They should always be able to operate
the voting system and understand the effect of their actions.

-   **3.2.4-Y**Number range req_subreq Completeness of instructions

The voting station ***[shall]{.smallcaps}*** provide instructions for
all its valid operations.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

Discussion

If an operation is available to the voter, it must be documented.
Examples include how to change a vote, how to navigate among contests,
how to cast a straight party vote, how to cast a write-in vote, and how
to adjust display and audio characteristics.

-   **3.2.4-Z**Number range req_subreq Availability of assistance from
    the system

The voting system ***[shall]{.smallcaps}*** provide a means for the
voter to get help directly from the system at any time during the voting
session.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

The voter should always be able to get help from the system if needed.
The purpose is to minimize the need for poll worker assistance. VEBD
voting systems may provide this with a distinctive \"help\" button. Any
type of voting system may provide written instructions that are separate
from the ballot.

-   **3.2.4-AA**Number range req_subreq Plain Language

Instructional material for the voter ***[shall]{.smallcaps}*** conform
to norms and best practices for plain language.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

Although part of general usability, the use of plain language is also
expected to assist voters with cognitive disabilities. The plain
language requirements apply to instructions that are inherent to the
voting system or that get generated by default. To the extent that
instructions are determined by election officials designing the ballot,
they are beyond of the scope of this requirement.

-   **3.2.4-AA.1** Clarity of warnings

Warnings and alerts issued by the voting system
***[should]{.smallcaps}*** clearly state:

-   the nature of the problem;

-   whether the voter has performed or attempted an invalid operation or
    whether the voting equipment itself has malfunctioned in some way;
    and

-   the set of responses available to the voter.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For instance, "You have not interacted with the system for the past
three minutes. Please press the 'Need more time' button right away to
tell the system that you're still here -- Thank you." rather than
"System detects imminent timeout condition." In case of an equipment
failure, the only action available to the voter might be to get
assistance from a poll worker.

-   **3.2.4-AA.2** Context before action

When an instruction is based on a condition, the condition
***[should]{.smallcaps}*** be stated first, and then the action to be
performed.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For instance, use \"In order to change your vote, do X\", rather than
\"Do X, in order to change your vote.\"

-   **3.2.4-AA.3** Simple vocabulary

The system ***[should]{.smallcaps}*** use familiar, common words and
avoid technical or specialized words that voters are not likely to
understand.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For instance, \"\... there are more contests on the other side \...\"
rather than \"\...additional contests are presented on the reverse
\...\"

-   **3.2.4-AA.4** Start each instruction on a new line

The system ***[should]{.smallcaps}*** start the visual presentation of
each new instruction on a new line.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

This implies not \"burying\" several unrelated instructions in a single
long paragraph.

-   **3.2.4-AA.5** Use of positive

The system ***[should]{.smallcaps}*** issue instructions on the correct
way to perform actions, rather than telling voters what not to do.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For example, "Fill in the oval for your write-in vote to count" rather
than "If the oval is not marked, your write-in vote cannot be counted."

-   **3.2.4-AA.6** Use of imperative voice

The system\'s instructions ***[should]{.smallcaps}*** address the voter
directly rather than use passive voice constructions.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For example, \"remove and retain this ballot stub\" rather than \"this
ballot stub must be removed and retained by the voter.\"

-   **3.2.4-AA.7** Gender-based pronouns

The system ***[should]{.smallcaps}*** avoid the use of gender-based
pronouns.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For example, \"\...write in your choice directly on the ballot\...\"
rather than \"\... write in his name directly on the ballot\...\"

-   **3.2.4-BB**Number range req_subreq No bias among choices

Consistent with election law, the voting system
***[shall]{.smallcaps}*** support a process that does not introduce bias
for or against any of the contest choices to be presented to the voter.
In both visual and aural formats, the choices ***[shall]{.smallcaps}***
be presented in an equivalent manner.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

Discussion

Certain differences in presentation are mandated by state law, such as
the order in which candidates are listed and provisions for voting for
write-in candidates. But comparable characteristics such as font size or
voice volume and speed must be the same for all choices.

-   **3.2.4-CC**Number range req_subreq Ballot design

The voting system ***[shall]{.smallcaps}*** provide the capability to
design a ballot with a high level of clarity and comprehensibility.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.4-CC.1** Contests split among pages or columns

The voting system ***[should]{.smallcaps}*** not visually present a
single contest spread over two pages or two columns.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

Such a visual separation poses the risk that the voter may perceive one
contest as two, or fail to see additional choices. If a contest has a
large number of candidates, it may be infeasible to observe this
guideline.

-   **3.2.4-CC.2** Indicate maximum number of candidates

The ballot ***[shall]{.smallcaps}*** clearly indicate the maximum number
of candidates for which one can vote within a single contest.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.4-CC.3** Consistent representation of candidate selection

The relationship between the name of a candidate and the mechanism used
to vote for that candidate ***[shall]{.smallcaps}*** be consistent
throughout the ballot.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For example, the response field where voters indicate their votes must
not be located to the left of some candidates\' names, and to the right
of others\'.

-   **3.2.4-CC.4** Placement of instructions

The system ***[should]{.smallcaps}*** display instructions near to where
they are needed.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For instance, only general instructions should be grouped at the
beginning of the ballot; those pertaining to specific situations should
be presented where and when needed.

-   **3.2.4-DD**Number range req_subreq Conventional use of color

The use of color by the voting system ***[should]{.smallcaps}*** agree
with common conventions: (a) green, blue or white is used for general
information or as a normal status indicator; (b) amber or yellow is used
to indicate warnings or a marginal status; (c) red is used to indicate
error conditions or a problem requiring immediate attention.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.4-EE**Number range req_subreq Icons and language

When an icon is used to convey information, indicate an action, or
prompt a response, it ***[shall]{.smallcaps}*** be accompanied by a
corresponding linguistic label.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

Discussion

While icons can be used for emphasis when communicating with the voter,
they must not be the sole means by which information is conveyed, since
there is no widely accepted \"iconic\" language and therefore not all
voters may understand a given icon.

#### Perceptual issues

The requirements of this section are designed to minimize perceptual
difficulties for the voter. Some of these requirements are designed to
assist voters with poor reading vision. These are voters who might have
some difficulty in reading normal text, but are not typically classified
as having a visual disability and thus might not be inclined to use the
accessible voting station.

-   **3.2.5-FF**Number range req_subreq Screen flicker

No voting system display screen ***[shall]{.smallcaps}*** flicker with a
frequency between 2 Hz and 55 Hz.

Applies to: VEBD-V

Test Reference: Part 3 Section 3.1

Discussion

Aside from usability concerns, this requirement protects voters with
epilepsy.

-   **3.2.5-GG**Number range req_subreq Resetting of adjustable aspects
    at end of session

Any aspect of the voting station that is adjustable by the voter or poll
worker, including font size, color, contrast, audio volume, or rate of
speech, ***[shall]{.smallcaps}*** automatically reset to a standard
default value upon completion of that voter\'s session. For the Acc-VS,
the aspects include synchronized audio/video mode and non-manual input
mode.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

This ensures that the voting station presents the same initial
appearance to every voter.

-   **3.2.5-HH**Number range req_subreq Ability to reset to default
    values

If any aspect of a voting system is adjustable by the voter or poll
worker, there ***[shall]{.smallcaps}*** be a mechanism to reset all such
aspects to their default values.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

The purpose is to allow a voter or poll worker who has adjusted the
system into an undesirable state to reset all the aspects and begin
again.

-   **3.2.5-II**Number range req_subreq Minimum font size

voting systems ***[shall]{.smallcaps}*** provide a minimum font size of
3.0mm (measured as the height of a capital letter) for all text intended
for voters or poll workers.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

-   **3.2.5-JJ**Number range req_subreq Available font sizes

A voting station that uses an electronic image display
***[shall]{.smallcaps}*** be capable of showing all information in at
least two font sizes, (a) 3.0-4.0 mm and (b) 6.3-9.0 mm, under control
of the voter. The system ***[shall]{.smallcaps}*** allow the voter to
adjust font size throughout the voting session while preserving the
current votes.

Applies to: VEBD-V

Test Reference: Part 3 Section 3.2

Discussion

While larger font sizes may assist most voters with poor vision, certain
disabilities such as tunnel vision are best addressed by smaller font
sizes. Larger font sizes may also assist voters with cognitive
disabilities. This requirement mandates the availability of at least two
font sizes, but additional choices (including continuous variability)
are allowed.

-   **3.2.5-KK**Number range req_subreq Use of sans serif font

text intended for the voter ***[should]{.smallcaps}*** be presented in a
sans serif font.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

Discussion

Research has shown that users prefer such fonts.

-   **3.2.5-LL**Number range req_subreq Legibility of paper ballots and
    verification records

Voting systems using paper ballots or paper verification records
***[shall]{.smallcaps}*** provide features that assist in the reading of
such ballots and records by voters with poor reading vision.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

While this requirement may be satisfied by one of its sub-requirements,
other innovative solutions are not precluded.

-   **3.2.5-LL.1** Legibility via font size

The system ***[may]{.smallcaps}*** achieve legibility of paper records
by supporting the printing of those records in at least two font sizes,
3.0 - 4.0mm and 6.3 - 9.0mm.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

Although the system may be capable of printing in several font sizes,
the use of various font sizes in an actual election may be governed by
local or state laws and regulations.

-   **3.2.5-LL.2** Legibility via magnification

The system ***[may]{.smallcaps}*** achieve legibility of paper records
by supporting magnification of those records. This magnification
***[may]{.smallcaps}*** be done by optical or electronic devices. The
manufacturer ***[may]{.smallcaps}*** either: 1) provide the magnifier
itself as part of the system, or 2) provide the make and model number of
readily available magnifiers that are compatible with the system.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

The magnifier(s) either provided or cited must, of course, provide
legibility for the paper as actually presented on the system. For
instance, if the paper record is under a transparent cover to prevent
the voter from touching it, the means of magnification must be
compatible with this configuration.

-   **3.2.5-MM**Number range req_subreq Contrast Ratio

The minimum figure-to-ground ambient contrast ratio for all text and
informational graphics (including icons) intended for voters or poll
workers ***[shall]{.smallcaps}*** be 3:1.

Applies to: Voting device

Test Reference: Part 3 Section 3.1

-   **3.2.5-NN**Number range req_subreq High contrast for electronic
    displays

The voting station ***[shall]{.smallcaps}*** be capable of showing all
information in high contrast either by default or under the control of
the voter. The system ***[shall]{.smallcaps}*** allow the voter to
adjust contrast throughout the voting session while preserving the
current votes. High contrast is a figure-to-ground ambient contrast
ratio for text and informational graphics of at least 6:1.

Applies to: VEBD-V

Test Reference: Part 3 Section 3.1

-   **3.2.5-OO**Number range req_subreq Accommodation for color
    blindness

The default color coding ***[shall]{.smallcaps}*** support correct
perception by voters with color blindness.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

Discussion

There are many types of color blindness and no color coding can, by
itself, guarantee correct perception for everyone. However, designers
should take into account such factors as: red-green color blindness is
the most common form; high luminosity contrast will help colorblind
voters to recognize visual features; and color-coded graphics can also
use shape to improve the ability to distinguish certain features.

-   **3.2.5-PP**Number range req_subreq No reliance solely on color

Color coding ***[shall]{.smallcaps}*** not be used as the sole means of
conveying information, indicating an action, prompting a response, or
distinguishing a visual element.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

While color can be used for emphasis, some other non-color mode must
also be used to convey the information, such as a shape or text style.
For example, red can be enclosed in an octagon shape.

#### Interaction issues

The requirements of this section are designed to minimize interaction
difficulties for the voter.

-   **3.2.6-QQ**Number range req_subreq No page scrolling

Voting systems ***[shall]{.smallcaps}*** not require page scrolling by
the voter.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

That is, the page of displayed information must fit completely within
the physical screen presenting it. Scrolling is not an intuitive
operation for those unfamiliar with the use of computers. Even those
experienced with computers often do not notice a scroll bar and miss
information at the bottom of the \"page.\" Voting systems may require
voters to move to the next or previous \"page.\"

-   **3.2.6-RR**Number range req_subreq Unambiguous feedback for
    voter\'s selection

The voting system ***[shall]{.smallcaps}*** provide unambiguous feedback
regarding the voter's selection, such as displaying a checkmark beside
the selected option or conspicuously changing its appearance.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

-   **3.2.6-SS**Number range req_subreq Accidental Activation

Input mechanisms ***[shall]{.smallcaps}*** be designed to minimize
accidental activation.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

Discussion

There are at least two kinds of accidental activation. One is when a
control is activated as it is being "explored" by the voter because the
control is overly sensitive to the touch. A second issue is the problem
of having a control in a location where it can easily be activated
unintentionally. An example would be a button in the very bottom left
corner of the screen where a voter might hold the unit for support.

-   **3.2.6-SS.1** Size and separation of touch areas

On touch screens, the sensitive touch areas ***[shall]{.smallcaps}***
have a minimum height of 0.5 inches and minimum width of 0.7 inches. The
vertical distance between the centers of adjacent areas
***[shall]{.smallcaps}*** be at least 0.6 inches, and the horizontal
distance at least 0.8 inches.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

-   **3.2.6-SS.2** No repeating keys

No key or control on a voting system ***[shall]{.smallcaps}*** have a
repetitive effect as a result of being held in its active position.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

Discussion

This is to preclude accidental activation. For instance, if a voter is
typing in the name of a write-in candidate, depressing and holding the
\"e\" key results in only a single \"e\" added to the name.

##### Timing issues

These requirements address how long the system and voter wait for each
other to interact. For the purposes of this section we define the
following terms:

-   **Initial system response time:** the time taken from when the voter
    performs some detectible action (such as pressing a button) to when
    the voting system *begins* responding in some obvious way (such as
    an audible response or any change on the screen).

-   **Completed system response time:** the time taken from when the
    voter performs some detectible action to when the voting system
    completes its response and settles into a stable state (e.g.,
    finishes \"painting\" the screen with a new page).

-   **Voter inactivity time:** the amount of time from when the system
    completes its response until there is detectible voter activity. In
    particular, note that audio prompts from the system may take several
    minutes and that this time does not count as voter inactivity.

-   **Alert time:** the amount of time the equipment will wait for
    detectible voter activity after issuing an alert before going into
    an inactive state requiring poll worker intervention.

    -   **3.2.6.1-TT**Number range req_subreq Maximum initial system
        response time

The initial system response time of the voting system
***[shall]{.smallcaps}*** be no greater than 0.5 seconds.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

This is so the voter can very quickly perceive that an action has been
detected by the system and is being processed. The voter never gets the
sense of dealing with an unresponsive or \"dead\" system. Note that this
requirement applies to VEBD-A (audio) as well as to VEBD-V (visual)
systems.

-   **3.2.6.1-UU**Number range req_subreq Maximum completed system
    response time for vote confirmation

When the voter performs an action to record a single vote, the completed
system response time of the voting system ***[shall]{.smallcaps}*** be
no greater than one second in the case of a visual response, and no
greater than five seconds in the case of an audio response.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

For example, if the voter touches a button to indicate a vote for a
candidate, a visual system might display an \"X\" next to the
candidate\'s name, and an audio system might announce \"You have voted
for Smith for Governor\".

-   **3.2.6.1-VV**Number range req_subreq Maximum completed system
    response time for all operations

The completed system response time of the voting system for visual
operations ***[shall]{.smallcaps}*** be no greater than 10 seconds.

Applies to: VEBD-V

Test Reference: Part 3 Section 3.2

Discussion

Even for \"large\" operations such as initializing the ballot or
painting a new screen, the system must never take more than 10 seconds.
In the case of audio systems, no upper limit is specified, since certain
operations may take longer, depending on the length of the text being
read (e.g., reading out a long list of candidates running in a contest).

-   **3.2.6.1-WW**Number range req_subreq System response indicator

If the system has not completed its visual response within one second,
it ***[shall]{.smallcaps}*** present to the voter, within 0.5 seconds of
the voter\'s action, some indication that it is preparing its response.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

For instance, the system might present an hourglass icon indicating that
it is \"busy\" processing the voter\'s request. This requirement is
intended to preclude the \"frozen screen\" effect, in which no
detectible activity is taking place for several seconds. There need not
be a specific \"activity\" icon, as long as some visual change is
apparent (such as progressively \"painting\" a new screen).

-   **3.2.6.1-XX**Number range req_subreq Voter inactivity time

The voting system ***[shall]{.smallcaps}*** detect and warn about
lengthy voter inactivity during a voting session. Each system
***[shall]{.smallcaps}*** have a defined and documented voter inactivity
time, and that time ***[shall]{.smallcaps}*** be between two and five
minutes.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

Each type of system must have a given inactivity time that is consistent
among and within all voting sessions. This ensures that all voters are
treated equitably.

-   **3.2.6.1-YY**Number range req_subreq Alert time

Upon expiration of the voter inactivity time, the voting system
***[shall]{.smallcaps}*** issue an alert and provide a means by which
the voter may receive additional time. The alert time
***[shall]{.smallcaps}*** be between 20 and 45 seconds. If the voter
does not respond to the alert within the alert time, the system
***[shall]{.smallcaps}*** go into an inactive state requiring poll
worker intervention.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

#### Alternative languages

HAVA Section 301 (a)(4) states that the voting system shall provide
alternative language accessibility pursuant to the requirements of
Section 203 of the Voting Rights Act of 1965 (42 U.S.C. 1973aa-1a).
Ideally every voter would be able to vote independently and privately,
regardless of language. As a practical matter, alternative language
access is mandated under the Voting Rights Act of 1975, subject to
certain thresholds (e.g., if the language group exceeds 5% of the voting
age population). Thus, election officials must ensure that the voting
system they deploy is capable of handling the languages meeting the
legal threshold within their districts.

While the following requirements support this process, it should be
noted that they are requirements only for voting systems to be
*certified*. It is anticipated that jurisdictions will apply additional
requirements appropriate for their particular circumstances for
procurement and deployment.

-   **3.2.7-ZZ**Number range req_subreq General support for alternative
    languages

The voting system ***[shall]{.smallcaps}*** be capable of presenting the
ballot, contest choices, review screens, vote verification records, and
voting instructions in any language declared by the manufacturer to be
supported by the system.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

For example, if the manufacturer claims that a given system is capable
of supporting Spanish and Chinese, then it must do so.

-   **3.2.7-ZZ.1** Voter control of language

The system ***[shall]{.smallcaps}*** allow the voter to select among the
available languages throughout the voting session while preserving the
current votes.

Applies to: VEBD

Test Reference: Part 3 Section 3.2

Discussion

For instance, a voter may initially choose an English version of the
ballot, but then wish to switch to another language in order to read a
referendum question.

-   **3.2.7-ZZ.2** Complete information in alternative language

Information presented to the voter in the typical case of
English-literate voters (including instructions, warnings, messages,
contest choices, and vote verification information)
***[shall]{.smallcaps}*** also be presented when an alternative language
is being used, whether the language is written or spoken.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

Therefore, it may not be sufficient simply to present the ballot *per
se* in the alternative language, especially in the case of VEBD systems.
All the supporting information must also be available in the alternative
language.

-   **3.2.7-ZZ.3** Auditability of records for English readers

Any records, including paper ballots and paper verification records,
***[shall]{.smallcaps}*** have sufficient information to support
auditing by poll workers and others who can read only English.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

Even though the system must be easily available to voters without a
command of English, any persistent records of the vote must also be
fully available to English-only readers for auditing purposes. In the
case of paper, this does not imply a fully bi-lingual ballot. For
instance, the full text of a referendum question might appear only in
the alternative language, but the content of the vote (e.g., "yes" on
ballot question 106) needs to be readable by English-only readers.

-   **3.2.7-ZZ.4** Usability testing by manufacturer for alternative
    languages

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests for each of the system\'s supported languages, using subjects who
are fluent in those languages but not fluent in English and
***[shall]{.smallcaps}*** report the test results, using the Common
Industry Format, as part of the TDP.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

#### Usability for poll workers

Voting systems are used not only by voters to record their votes, but
also by poll workers who are responsible for set-up, operation while
polls are open, light maintenance, and poll closing. Because of the wide
variety of implementations, it is impossible to specify detailed design
requirements for these functions. The requirements below describe
general capabilities that all systems must support.

-   **3.2.8-AAA**Number range req_subreq Clarity of system messages for
    poll workers

Messages generated by the system for poll workers in support of the
operation, maintenance, or safety of the system
***[shall]{.smallcaps}*** adhere to the requirements for clarity in
\[XREF Requirement 3.2.4 "Plain Language"\].

Applies to: Voting system

Test Reference: Part 3 Section 3.2

##### Operation

Poll workers are responsible for opening polls, keeping the polls open
and running smoothly during voting hours, and closing the polls
afterwards. Operations may be categorized in three phases:

**Setup** includes all the steps necessary to take the system from its
state as normally delivered to the polling place, to the state in which
it is ready to record votes. It does not include ballot definition.

**Polling** includes such functions as:

-   voter identification and authorization

-   preparing the system for the next voter

-   assistance to voters who wish to change their ballots or need other
    help

-   system recovery in the case of voters who abandon the voting session
    without having cast a ballot

-   routine hardware operations, such as installing a new roll of paper

**Shutdown** includes all the steps necessary to take the system from
the state in which it is ready to record votes to its normal completed
state in which it has captured all the votes cast and the voting
information cannot be further altered.

-   **3.2.8.1-BBB**Number range req_subreq Ease of normal operation

The procedures for system setup, polling, and shutdown, as documented by
the manufacturer, ***[shall]{.smallcaps}*** be reasonably easy for the
typical poll worker to learn, understand, and perform.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

This requirement covers procedures and operations for those aspects of
system operation normally performed by poll workers and other
\"non-expert\" operators. It does not address inherently complex
operations such as ballot definition or system repair. While a certain
amount of complexity is unavoidable, these \"normal\" procedures should
not require any special expertise. The procedures may require a
reasonable amount of training. Also, see requirements for usability of
system documentation in \[XREF Part 2: Section 4.4.6 "Documentation for
poll workers"\].

-   **3.2.8.1-CCC**Number range req_subreq Usability testing by
    manufacturer for poll workers

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests on the voting system using individuals who are representative of
the general population and ***[shall]{.smallcaps}*** report the test
results, using the Common Industry Format, as part of the TDP. The tasks
to be covered in the test ***[shall]{.smallcaps}*** include setup,
operation, and shutdown.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

-   **3.2.8-DDD**Number range req_subreq Documentation usability

The system ***[shall]{.smallcaps}*** include clear, complete, and
detailed instructions and messages for setup, polling, and shutdown.

Applies to: Voting system

Discussion

This requirement covers documentation for those aspects of system
operation normally performed by poll workers and other \"non-expert\"
operators. It does not address inherently complex operations such as
ballot definition. The instructions would usually be in the form of a
written manual, but could also be presented on other media, such as a
DVD or videotape. In the context of this requirement, \"message\" means
information delivered by the system to the poll worker as he or she
attempts to perform a setup, polling, or shutdown operation.

Source: New requirement

-   **3.2.8-EEE.1** Poll Workers as target audience

The documentation required for normal system operation
***[shall]{.smallcaps}*** be presented at a level appropriate for
non-expert poll workers.

Applies to: Voting system

Discussion

For instance, the documentation should not presuppose familiarity with
personal computers.

Source: New requirement

-   **3.2.8-FFF.2** Usability at the polling place

The documentation ***[shall]{.smallcaps}*** be in a format suitable for
practical use in the polling place.

Applies to: Voting system

Discussion

For instance, a single large reference manual that simply presents
details of all possible operations would be difficult to use, unless
accompanied by aids such as a simple \"how-to\" guide.

Source: New requirement

-   **3.2.8-GGG.3** Enabling verification of correct operation

The instructions and messages ***[shall]{.smallcaps}*** enable the poll
worker to verify that the system

1.  Has been set up correctly (setup);

2.  Is in correct working order to record votes (polling); and

3.  Has been shut down correctly (shutdown).

Applies to: Voting system

Discussion

The poll worker should not have to guess whether an operation has been
performed correctly. The documentation should make it clear what the
system \"looks like\" when correctly configured.

Source: New

##### Safety

All voting systems and their components must be designed so as to
eliminate hazards to personnel or to the equipment itself. Hazards
include, but are not limited to:

-   fire hazards

-   electrical hazards

-   potential for equipment tip-over (stability)

-   potential for cuts and scrapes (e.g., sharp edges)

-   potential for pinching (e.g., tight, spring-loaded closures)

-   potential for hair or clothing entanglement

    -   **3.2.8.2-HHH**Number range req_subreq Safety certification

Equipment associated with the voting system ***[shall]{.smallcaps}*** be
certified in accordance with the requirements of UL 60950-1, Information
Technology Equipment -- Safety -- Part 1 \[UL05\] by a certification
organization accredited by the Department of Labor, Occupational Safety
and Health Administration's Nationally Recognized Testing Laboratory
program. The certification organization's scope of accreditation
***[shall]{.smallcaps}*** include UL 60950-1.

Applies to: Voting system

Test Reference: Part 3 Section 3.1

Discussion

UL 60950 is a comprehensive standard for IT equipment and addresses all
the hazards discussed above under Safety.

### Accessibility requirements

HAVA Section 301 (a) (3) \[HAVA02\] reads, in part:

ACCESSIBILITY FOR INDIVIDUALS WITH DISABILITIES.\--The voting system
shall\--

\(A\) be accessible for individuals with disabilities, including
nonvisual accessibility for the blind and visually impaired, in a manner
that provides the same opportunity for access and participation
(including privacy and independence) as for other voters;

\(B\) satisfy the requirement of subparagraph (A) through the use of at
least one direct recording electronic voting system or other voting
system equipped for individuals with disabilities at each polling place;

The voting process is to be accessible to voters with disabilities
through the use of a specially equipped voting station. A machine so
equipped is referred to herein as an accessible voting station (Acc-VS).

The requirements in this section are intended to address this HAVA
mandate. Ideally, every voter would be able to vote independently and
privately. As a practical matter, there may be some number of voters
who, because of the nature of their disabilities, will need personal
assistance with any system. Nonetheless, these requirements are meant to
make the voting system independently accessible to as many voters as
possible.

This section is organized according to the type of disability being
addressed. For each type, certain appropriate design features are
specified. Note, however, that a feature intended primarily to address
one kind of disability may very well assist voters with other kinds.

There are many other requirements that apply to the Acc-VS besides those
in this section. Please see \[XREF Section 3.1.3 "Interaction of
Usability and Accessibility Requirements"\] for a full explanation.

#### General

The requirements of this section are relevant to a wide variety of
disabilities.

-   **3.3.1-III**Number range req_subreq Accessibility throughout the
    voting session

The Acc-VS ***[shall]{.smallcaps}*** be integrated into the
manufacturer's complete voting system so as to support accessibility for
disabled voters throughout the voting session.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This requirement ensures accessibility to the voter throughout the
entire session. Not only must individual system components (such as
ballot markers, paper records, and optical scanners) be accessible, but
they must work together to support this result.

requirement

-   Number range req_subreq**3.3.1-JJJ.1** Documentation of
    Accessibility Procedures

The manufacturer ***[shall]{.smallcaps}*** supply documentation
describing 1) recommended procedures that fully implement accessibility
for voters with disabilities and 2) how the Acc-VS supports those
procedures.

Applies to: Acc-VS

Discussion

The purpose of this requirement is for the manufacturer not simply to
deliver system components, but also to describe the accessibility
scenarios they are intended to support.

-   **3.3.1-KKK**Number range req_subreq Complete information in
    alternative formats

When the provision of accessibility involves an alternative format for
ballot presentation, then all information presented to non-disabled
voters, including instructions, warnings, error and other messages, and
contest choices, ***[shall]{.smallcaps}*** be presented in that
alternative format.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

-   **3.3.1-LLL**Number range req_subreq No dependence on personal
    assistive technology

The support provided to voters with disabilities
***[shall]{.smallcaps}*** be intrinsic to the accessible voting station.
It ***[shall]{.smallcaps}*** not be necessary for the accessible voting
station to be connected to any personal assistive device of the voter in
order for the voter to operate it correctly.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This requirement does not preclude the accessible voting station from
providing interfaces to assistive technology. (See definition of
\"personal assistive devices\" in Appendix A..) Its purpose is to assure
that disabled voters are not required to bring special devices with them
in order to vote successfully. The requirement does not assert that the
accessible voting station will eliminate the need for a voter's ordinary
non-interfacing devices, such as eyeglasses or canes.

-   **3.3.1-MMM**Number range req_subreq Secondary means of voter
    identification

If a voting system provides for voter identification or authentication
by using biometric measures that require a voter to possess particular
biological characteristics, then the system ***[shall]{.smallcaps}***
provide a secondary means that does not depend on those characteristics.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For example, if fingerprints are used for voter identification, another
mechanism must be provided for voters without usable fingerprints.

-   **3.3.1-NNN**Number range req_subreq Accessibility of paper-based
    vote verification

If the Acc-VS generates a paper record (or some other durable,
human-readable record) for the purpose of allowing voters to verify
their votes, then the system ***[shall]{.smallcaps}*** provide a means
to ensure that the verification record is accessible to all voters with
disabilities, as identified in \[XREF Section 3.3\].

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

While paper records generally provide a simple and effective means for
technology-independent vote verification, their use can present
difficulties for voters with certain types of disabilities. The purpose
of this requirement is to ensure that all voters have a similar
opportunity for vote verification. Note that this requirement addresses
the special difficulties that may arise with the use of paper.
Verification is part of the voting process, and all the other general
requirements apply to verification, in particular those dealing with
dexterity (e.g. 3.3.4-C "Ballot Submission and Vote Verification"),
blindness (e.g. 3.3.3-E "Ballot Submission and Vote Verification"), and
poor vision issues (e.g. 3.2.5-G "Legibility of Paper Ballots and
Verification Records").

-   **3.3.1-NNN.1** Audio readback for paper-based vote verification.

If the Acc-VS generates a paper record (or some other durable,
human-readable record) for the purpose of allowing voters to verify
their votes, then the system ***[shall]{.smallcaps}*** provide a
mechanism that can read that record and generate an audio representation
of its contents.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Sighted voters can directly verify the contents of a paper record. The
purpose of this requirement is to allow voters with visual disabilities
to verify, even if indirectly, the contents of the record. It is
recognized that the verification depends on the integrity of the
mechanism that reads the record to the voter. The audio must be
generated via the paper record and therefore not depend on any
electronic or other \"internal\" record of the ballot. Note that the
paper record and its audio representation may be rendered in an
alternative language.

#### Low vision

These requirements specify the features of the accessible voting station
designed to assist voters with low vision.

Low (or partial) vision includes dimness of vision, haziness, film over
the eye, foggy vision, extreme near-sightedness or far-sightedness,
distortion of vision, color distortion or blindness, visual field
defects, spots before the eyes, tunnel vision, lack of peripheral
vision, abnormal sensitivity to light or glare and night blindness. For
the purposes of this discussion low vision is defined as having a visual
acuity worse than 20/70.

People with tunnel vision can see only a small part of the ballot at one
time. For these users it is helpful to have letters at the lower end of
the font size range in order to allow them to see more letters at the
same time. Thus, there is a need to provide font sizes at both ends of
the range.

People with low vision or color blindness benefit from high contrast and
from a selection of color combinations appropriate for their needs.
Between 7% and 10% of all men have color vision deficiencies. Certain
color combinations in particular cause problems. Therefore, use of color
combinations with good contrast is required. Note also the general
\[XREF requirement 3.2.5-J \"Accommodation for Color Blindness\"\].

However, some users are very sensitive to very bright displays and
cannot use them for long. An overly bright background causes a visual
white-out which makes these users unable to distinguish individual
letters. Thus, use of non-saturated color options is an advantage for
some people.

It is important to note that some of the requirements in \[XREF Section
3.2.5 -- Perceptual Issues\], also provide support for voters with
certain kinds of vision problems.

-   **3.3.2-OOO**Number range req_subreq Usability testing by
    manufacturer for voters with low vision

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests on the voting system using individuals with low vision and
***[shall]{.smallcaps}*** report the test results, using the Common
Industry Format, as part of the TDP.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.2-PPP**Number range req_subreq Adjustable saturation for color
    displays

An accessible voting station with a color electronic image display
***[shall]{.smallcaps}*** allow the voter to adjust the color saturation
throughout the voting session while preserving the current votes. At
least two options ***[shall]{.smallcaps}*** be available: a high and a
low saturation presentation.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

It is not required that the station offer a continuous range of color
saturation. \"High saturation\" refers to bright, vibrant colors. \"Low
saturation\" refers to muted (or grayish) colors.

-   **3.3.2-QQQ**Number range req_subreq Distinctive buttons and
    controls

Buttons and controls on accessible voting stations
***[shall]{.smallcaps}*** be distinguishable by both shape and color.
This applies to buttons and controls implemented either \"on-screen\" or
in hardware. This requirement does not apply to sizeable groups of keys,
such as a conventional 4x3 telephone keypad or a full alphabetic
keyboard.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

Discussion

The redundant cues assist those with low vision. They also help
individuals who may have difficulty reading the text on the screen.

-   **3.3.2-RRR**Number range req_subreq Synchronized audio and video

The voting station ***[shall]{.smallcaps}*** provide synchronized audio
output to convey the same information as that which is displayed on the
screen. There ***[shall]{.smallcaps}*** be a means by which the voter
can disable either the audio or video output, resulting in a video-only
or audio-only presentation, respectively. The system
***[shall]{.smallcaps}*** allow the voter to switch among the three
modes (synchronized audio/video, video-only, or audio-only) throughout
the voting session while preserving the current votes.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This feature may also assist voters with cognitive disabilities.

#### Blindness

These requirements specify the features of the accessible voting station
designed to assist voters who are blind.

-   **3.3.3-SSS**Number range req_subreq Usability testing by
    manufacturer for blind voters

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests on the voting system using individuals who are blind and
***[shall]{.smallcaps}*** report the test results, using the Common
Industry Format, as part of the TDP.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.3-TTT**Number range req_subreq Audio-tactile interface

The accessible voting station ***[shall]{.smallcaps}*** provide an
audio-tactile interface (ATI) that supports the full functionality of
the visual ballot interface, as specified in \[XREF Section 6.2 Voting
Variations\].

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Note the necessity of both audio output and tactilely discernible
controls for voter input. Full functionality includes at least:

-   Instructions and feedback on initial activation of the ballot (such
    as insertion of a smart card), if applicable

-   Instructions and feedback to the voter on how to operate the
    accessible voting station, including settings and options (e.g.,
    volume control, repetition)

-   Instructions and feedback for navigation of the ballot

-   Instructions and feedback for contest choices, including write-in
    candidates

-   Instructions and feedback on confirming and changing votes

-   Instructions and feedback on final submission of ballot

    -   **3.3.3-TTT.1** Equivalent functionality of ATI

The ATI of the accessible voting station ***[shall]{.smallcaps}***
provide the same capabilities to vote and cast a ballot as are provided
by its visual interface.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For example, if a visual ballot supports voting a straight party ticket
and then changing the vote for a single contest, so must the ATI.

-   **3.3.3-TTT.2** ATI supports repetition

The ATI ***[shall]{.smallcaps}*** allow the voter to have any
information provided by the voting system repeated.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This feature may also be useful to voters with cognitive disabilities.

-   **3.3.3-TTT.3** ATI supports pause and resume

The ATI ***[shall]{.smallcaps}*** allow the voter to pause and resume
the audio presentation.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This feature may also be useful to voters with cognitive disabilities.

-   **3.3.3-TTT.4** ATI supports transition to next or previous contest

The ATI ***[shall]{.smallcaps}*** allow the voter to skip to the next
contest or return to previous contests.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This is analogous to the ability of sighted voters to move on to the
next contest once they have made a selection or to abstain from voting
on a contest altogether.

-   **3.3.3-TTT.5** ATI can skip referendum wording

The ATI ***[shall]{.smallcaps}*** allow the voter to skip over the
reading of a referendum so as to be able to vote on it immediately.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This is analogous to the ability of sighted voters to skip over the
wording of a referendum on which they have already made a decision prior
to the voting session (e.g., \"Vote yes on proposition #123\").

-   **3.3.3-UUU**Number range req_subreq Audio features and
    characteristics

Voting stations that provide audio presentation of the ballot
***[shall]{.smallcaps}*** do so in a usable way, as detailed in the
following sub-requirements.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

These requirements apply to all voting system audio output, not just to
the ATI of an accessible voting station.

-   **3.3.3-UUU.1** Standard connector

The ATI ***[shall]{.smallcaps}*** provide its audio signal through an
industry standard connector for private listening using a 3.5mm stereo
headphone jack to allow voters to use their own audio assistive devices.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

-   **3.3.3-UUU.2** T-Coil coupling

When a voting system utilizes a telephone style handset or headphone to
provide audio information, it ***[shall]{.smallcaps}*** provide a
wireless T-Coil coupling for assistive hearing devices so as to provide
access to that information for voters with partial hearing. That
coupling ***[shall]{.smallcaps}*** achieve at least a category T4 rating
as defined by \[XREF: ANSI01\] American National Standard for Methods of
Measurement of Compatibility between Wireless Communications Devices and
Hearing Aids, ANSI C63.19.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

Note that \[XREF requirement 3.3.6-C "No Electromagnetic Interference
with Hearing Devices"\] protects the use of hearing devices.

-   **3.3.3-UUU.3** Sanitized headphone or handset

A sanitized headphone or handset ***[shall]{.smallcaps}*** be made
available to each voter.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.1

Discussion

This requirement can be achieved in various ways, including the use of
\"throwaway\" headphones, or of sanitary coverings.

-   **3.3.3-UUU.4** Initial volume

The voting system ***[shall]{.smallcaps}*** set the initial volume for
each voting session between 40 and 50 dB SPL.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

A voter does not \"inherit\" the volume as set by the previous user of
the voting station. See \[XREF requirement 3.2.5-B \"Resetting of
Adjustable Aspects at End of Session\"\].

-   **3.3.3-UUU.5** Range of volume

The audio system ***[shall]{.smallcaps}*** allow the voter to control
the volume throughout the voting session while preserving the current
votes. The volume ***[shall]{.smallcaps}*** be adjustable from a minimum
of 20dB SPL up to a maximum of 100 dB SPL, in increments no greater than
10 dB.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

-   **3.3.3-UUU.6** Range of frequency

The audio system ***[shall]{.smallcaps}*** be able to reproduce
frequencies over the audible speech range of 315 Hz to 10 KHz.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

The required frequencies include the range of normal human speech. This
allows the reproduced speech to sound natural.

-   **3.3.3-UUU.7** Intelligible audio

The audio presentation of verbal information ***[should]{.smallcaps}***
be readily comprehensible by voters who have normal hearing and are
proficient in the language. This includes such characteristics as proper
enunciation, normal intonation, appropriate rate of speech, and low
background noise. Candidate names ***[should]{.smallcaps}*** be
pronounced as the candidate intends.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

This requirement covers both recorded and synthetic speech. It applies
to those aspects of the audio content that are inherent to the voting
system or that get generated by default. To the extent that the audio
presentation is determined by election officials designing the ballot,
it is beyond of the scope of this requirement.

-   **3.3.3-UUU.8** Control of speed

The audio system ***[shall]{.smallcaps}*** allow the voter to control
the rate of speech throughout the voting session while preserving the
current votes. The range of speeds supported ***[shall]{.smallcaps}***
include 75% to 200% of the nominal rate.

Applies to: VEBD-A

Test Reference: Part 3 Section 3.2

Discussion

Many blind voters are accustomed to interacting with accelerated speech.
This feature may also be useful to voters with cognitive disabilities.

-   **3.3.3-VVV**Number range req_subreq Ballot activation

If the voting station supports ballot activation for non-blind voters,
then it ***[shall]{.smallcaps}*** also provide features that enable
voters who are blind to perform this activation.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For example, smart cards might provide tactile cues so as to allow
correct insertion.

-   **3.3.3-WWW**Number range req_subreq Ballot submission and vote
    verification

If the voting station supports ballot submission or vote verification
for non-blind voters, then it ***[shall]{.smallcaps}*** also provide
features that enable voters who are blind to perform these actions.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For example, if voters using this station normally perform paper-based
verification, or if they feed their own optical scan ballots into a
reader, blind voters must also be able to do so.

-   **3.3.3-XXX**Number range req_subreq Tactile discernability of
    controls

Mechanically operated controls or keys on an accessible voting station
***[shall]{.smallcaps}*** be tactilely discernible without activating
those controls or keys.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Note also the more general \[XREF Requirement 3.2.5-C, "Accidental
Activation\] against accidental activation of controls.

-   **3.3.3-YYY**Number range req_subreq Discernability of key status

The status of all locking or toggle controls or keys (such as the
\"shift\" key) ***[shall]{.smallcaps}*** be visually discernible, and
also discernible either through touch or sound.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

#### Dexterity

These requirements specify the features of the accessible voting station
designed to assist voters who lack fine motor control or use of their
hands.

-   **3.3.4-ZZZ**Number range req_subreq Usability testing by
    manufacturer for voters with dexterity disabilities

The manufacturer ***[shall]{.smallcaps}*** conduct summative usability
tests on the voting system using individuals lacking fine motor control
and ***[shall]{.smallcaps}*** report the test results, using the Common
Industry Format, as part of the TDP.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.4-AAAA**Number range req_subreq Support for non-manual input

The accessible voting station ***[shall]{.smallcaps}*** provide a
mechanism to enable non-manual input that is functionally equivalent to
tactile input. All the functionality of the accessible voting station
(e.g., straight party voting, write-in candidates) that is available
through the conventional forms of input, such as tactile,
***[shall]{.smallcaps}*** also be available through the non-manual input
mechanism.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This requirement ensures that the accessible voting station is operable
by individuals who do not have the use of their hands. Examples of
non-manual controls include mouth sticks and \"sip and puff\" switches.
While it is desirable that the voter be able to independently initiate
use of the non-manual input mechanism, this requirement guarantees only
that the voter can vote independently once the mechanism is enabled.

-   **3.3.4-BBBB**Number range req_subreq Ballot submission and vote
    verification

If the voting station supports ballot submission or vote verification
for non-disabled voters, then it ***[shall]{.smallcaps}*** also provide
features that enable voters who lack fine motor control or the use of
their hands to perform these actions.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For example, if voters using this station normally perform paper-based
verification, or if they feed their own optical scan ballots into a
reader, voters with dexterity disabilities must also be able to do so.
Note that the general \[XREF requirement for privacy when voting
(3.2.3.1-A "System Support of Privacy")\] still applies.

-   **3.3.4-CCCC**Number range req_subreq Manipulability of controls

Keys and controls on the accessible voting station
***[shall]{.smallcaps}*** be operable with one hand and
***[shall]{.smallcaps}*** not require tight grasping, pinching, or
twisting of the wrist. The force required to activate controls and keys
***[shall]{.smallcaps}*** be no greater 5 lbs. (22.2 N).

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Controls are to be operable without excessive force.

-   **3.3.4-DDDD**Number range req_subreq No dependence on direct bodily
    contact

The accessible voting station controls ***[shall]{.smallcaps}*** not
require direct bodily contact or for the body to be part of any
electrical circuit.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

This requirement ensures that controls are operable by individuals using
prosthetic devices.

#### Mobility

These requirements specify the features of the accessible voting station
designed to assist voters who use mobility aids, including wheelchairs.
Many of the requirements of this section are based on the ADA
Accessibility Guidelines for Buildings and Facilities (ADAAG).

-   **3.3.5-EEEE**Number range req_subreq Clear floor space

The accessible voting station ***[shall]{.smallcaps}*** provide a clear
floor space of 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum
for a stationary mobility aid. The clear floor space
***[shall]{.smallcaps}*** be level with no slope exceeding 1:48 and
positioned for a forward approach or a parallel approach.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5-FFFF**Number range req_subreq Allowance for assistant

When deployed according to the installation instructions provided by the
manufacturer, the voting station ***[shall]{.smallcaps}*** allow
adequate room for an assistant to the voter. This includes clearance for
entry to and exit from the area of the voting station.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Disabled voters sometimes prefer to have an assistant help them vote.
The setup of the voting station should not preclude this.

-   **3.3.5-GGGG**Number range req_subreq Visibility of displays and
    controls

Labels, displays, controls, keys, audio jacks, and any other part of the
accessible voting station necessary for the voter to operate the voting
system ***[shall]{.smallcaps}*** be easily legible and visible to a
voter in a wheelchair with normal eyesight (no worse than 20/40,
corrected) who is in an appropriate position and orientation with
respect to the accessible voting station.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

Discussion

There are a number of factors that could make relevant parts of the
accessible voting station difficult to see, such as: small lettering;
controls and labels tilted at an awkward angle from the voter\'s
viewpoint; and glare from overhead lighting.

##### Controls within reach

The requirements of this section ensure that the controls, keys, audio
jacks and any other part of the accessible voting station necessary for
its operation are within easy reach. Note that these requirements have
meaningful application mainly to controls in a fixed location. A
hand-held tethered control panel is another acceptable way of providing
reachable controls.

-   **3.3.5.1-HHHH**Number range req_subreq Forward approach, no
    obstruction

If the accessible voting station has a forward approach with no forward
reach obstruction then the high reach ***[shall]{.smallcaps}*** be 48
inches maximum and the low reach ***[shall]{.smallcaps}*** be 15 inches
minimum. See Figure 1-2.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-IIII**Number range req_subreq Forward approach, with
    obstruction

If the accessible voting station has a forward approach with a forward
reach obstruction, the following sub-requirements
***[shall]{.smallcaps}*** apply (See Figure 1-3).

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-IIII.1** Maximum size of obstruction

The forward obstruction ***[shall]{.smallcaps}*** be no greater than 25
inches in depth, its top no higher than 34 inches and its bottom surface
no lower than 27 inches.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-IIII.2** Maximum high reach over obstruction

If the obstruction is no more than 20 inches in depth, then the maximum
high reach ***[shall]{.smallcaps}*** be 48 inches, otherwise it
***[shall]{.smallcaps}*** be 44 inches.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-IIII.3** Toe clearance under obstruction

Space under the obstruction between the finish floor or ground and 9
inches (230 mm) above the finish floor or ground
***[shall]{.smallcaps}*** be considered toe clearance and
***[shall]{.smallcaps}*** comply with the following provisions:

-   Toe clearance depth ***[shall]{.smallcaps}*** extend 25 inches
    (635 mm) maximum under the obstruction

-   The minimum toe clearance depth under the obstruction
    ***[shall]{.smallcaps}*** be either 17 inches (430 mm) or the depth
    required to reach over the obstruction to operate the accessible
    voting station, whichever is greater

-   Toe clearance width ***[shall]{.smallcaps}*** be 30 inches (760 mm)
    minimum

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-IIII.4** Knee clearance under obstruction

Space under the obstruction between 9 inches (230 mm) and 27 inches (685
mm) above the finish floor or ground ***[shall]{.smallcaps}*** be
considered knee clearance and ***[shall]{.smallcaps}*** comply with the
following provisions:

-   Knee clearance depth ***[shall]{.smallcaps}*** extend 25 inches
    (635 mm) maximum under the obstruction at 9 inches (230 mm) above
    the finish floor or ground

-   The minimum knee clearance depth at 9 inches (230 mm) above the
    finish floor or ground ***[shall]{.smallcaps}*** be either 11 inches
    (280 mm) or 6 inches less than the toe clearance, whichever is
    greater

-   Between 9 inches (230 mm) and 27 inches (685 mm) above the finish
    floor or ground, the knee clearance depth ***[shall]{.smallcaps}***
    be permitted to reduce at a rate of 1 inch (25 mm) in depth for each
    6 inches (150 mm) in height. (It follows that the minimum knee
    clearance at 27 inches above the finish floor or ground
    ***[shall]{.smallcaps}*** be 3 inches less than the minimum knee
    clearance at 9 inches above the floor.)

-   Knee clearance width ***[shall]{.smallcaps}*** be 30 inches (760 mm)
    minimum

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-JJJJ**Number range req_subreq Parallel approach, no
    obstruction

If the accessible voting station has a parallel approach with no side
reach obstruction then the maximum high reach ***[shall]{.smallcaps}***
be 48 inches and the minimum low reach ***[shall]{.smallcaps}*** be 15
inches. See Figure 1-4.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-KKKK**Number range req_subreq Parallel approach, with
    obstruction

If the accessible voting station has a parallel approach with a side
reach obstruction, the following sub-requirements
***[shall]{.smallcaps}*** apply. See Figure 1-5.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

Discussion

Since this is a parallel approach, no clearance under the obstruction is
required.

-   **3.3.5.1-KKKK.1** Maximum size of obstruction

The side obstruction ***[shall]{.smallcaps}*** be no greater than 24
inches in depth and its top no higher than 34 inches.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

-   **3.3.5.1-KKKK.2** Maximum high reach over obstruction

If the obstruction is no more than 10 inches in depth, then the maximum
high reach ***[shall]{.smallcaps}*** be 48 inches, otherwise it
***[shall]{.smallcaps}*** be 46 inches.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.1

######### Figures 3-1 through 3-4

+--------------------------+-------------------------------------------+
| !                        | ![](medi                                  |
| [](media/image1.png){wid | a/image2.png){width="4.096527777777778in" |
| th="2.423611111111111in" | height="1.96875in"}                       |
| height                   |                                           |
| ="1.3423611111111111in"} |                                           |
+--------------------------+-------------------------------------------+
| ########  Un             | ########  Obstructed forward reach        |
| obstructed forward reach |                                           |
|                          | \(a\) for an obstruction depth of up to   |
|                          | 20 inches (508 mm)\                       |
|                          | (b) for an obstruction depth of up to 25  |
|                          | inches (635 mm)                           |
+--------------------------+-------------------------------------------+
| ![                       | ![](medi                                  |
| ](media/image3.png){widt | a/image4.png){width="4.094444444444444in" |
| h="2.4229166666666666in" | height="1.8145833333333334in"}            |
| height                   |                                           |
| ="1.8993055555555556in"} |                                           |
+--------------------------+-------------------------------------------+
| #                        | ########  Obstructed side reach           |
| #######  Unobstructed si |                                           |
| de reach with an allowab | \(a\) for an obstruction depth of up to   |
| le obstruction less than | 10 inches (254 mm)\                       |
|  10 inches (254 mm) deep | (b) for an obstruction depth of up to 24  |
|                          | inches (610 mm)                           |
+--------------------------+-------------------------------------------+

#### Hearing

These requirements specify the features of the accessible voting station
designed to assist voters with hearing disabilities.

-   **3.3.6-LLLL**Number range req_subreq Reference to audio
    requirements

The accessible voting station ***[shall]{.smallcaps}*** incorporate the
features listed under \[XREF requirement 3.3.3-C \"Audio Features and
Characteristics\"\] for voting equipment that provides audio
presentation of the ballot.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Note especially the requirements for volume initialization and control.

-   **3.3.6-MMMM**Number range req_subreq Visual redundancy for sound
    cues

If the voting system provides sound cues as a method to alert the voter,
the tone ***[shall]{.smallcaps}*** be accompanied by a visual cue,
unless the station is in audio-only mode.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

For instance, the voting equipment might beep if the voter attempts to
overvote. If so, there would have to be an equivalent visual cue, such
as the appearance of an icon, or a blinking element. If the voting
system has been set to audio-only mode, there would be no visual cue.

-   **3.3.6-NNNN**Number range req_subreq No electromagnetic
    interference with hearing devices

No voting equipment ***[shall]{.smallcaps}*** cause electromagnetic
interference with assistive hearing devices that would substantially
degrade the performance of those devices. The voting equipment,
considered as a wireless device, ***[shall]{.smallcaps}*** achieve at
least a category T4 rating as defined by \[XREF: ANSI01\] American
National Standard for Methods of Measurement of Compatibility between
Wireless Communications Devices and Hearing Aids, ANSI C63.19.

Applies to: Voting device

Test Reference: Part 3 Section 3.2

Discussion

\"Hearing devices\" include hearing aids and cochlear implants.

#### Cognition

These requirements specify the features of the accessible voting station
designed to assist voters with cognitive disabilities.

-   **3.3.7-OOOO**Number range req_subreq General support for cognitive
    disabilities

The accessible voting station ***[should]{.smallcaps}*** provide support
to voters with cognitive disabilities.

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

Discussion

Because of the highly varied nature of disabilities falling within the
\"cognitive\" category, there are no design features uniquely aimed at
helping those with such disabilities. However, many of the features
designed primarily for other disabilities and for general usability are
also highly relevant to these voters:

-   the synchronization of audio with the displayed screen information
    (\[XREF 3.3.2-D\])

-   the general cognitive usability requirements (\[XREF 3.2.4\]) and,
    in particular, the use of plain language (\[XREF 3.2.4-C\])

-   large font sizes and legibility of paper (\[XREF 3.2.5-E and
    3.2.5-G\])

-   the ability to control various aspects of the audio presentation
    (\[XREF 3.3.3-B and 3.3.3-C\]) such as pausing, repetition, and
    speed

#### English proficiency

These requirements specify the features of the accessible voting station
designed to assist voters who lack proficiency in reading English.

-   **3.3.8-PPPP**Number range req_subreq Use of ATI

For voters who lack proficiency in reading English, the voting equipment
***[shall]{.smallcaps}*** provide an audio interface for instructions
and ballots as described in \[XREF Section 3.3.3-B \"Audio-Tactile
Interface\"\].

Applies to: Acc-VS

Test Reference: Part 3 Section 3.2

#### Speech

-   **3.3.9-QQQQ**Number range req_subreq Speech not to be required by
    equipment

No voting equipment ***[shall]{.smallcaps}*** require voter speech for
its operation.

Applies to: Voting system

Test Reference: Part 3 Section 3.2

Discussion

This does not preclude voting equipment from offering speech input as an
option, but speech must not be the only means of input.