## Discussion of VVSG Requirements for Personal Assistive Technology

September 20, 2005

Human Factors and Privacy TGDC Subcommittee

NIST

### 1. Introduction

Many persons with disabilities employ *personal assistive technology*
(PAT) to help them perform various tasks which they would otherwise find
difficult or impossible. Hearing aids, eyeglasses, and pneumatic
switches are some examples. The purpose of this paper is to outline and
clarify various points of view about PAT for voting stations that arose
after the release of the draft VVSG.

**1.1 Basic concepts: sufficiency and interoperability**

There are two distinct concepts in considering PAT. These two issues are
related, but independent: sufficiency requirements do *not* determine
interoperability requirements or vice versa.

-   **Sufficiency:** What access features (unrelated to PAT) must a
    voting system contain to meet accessibility requirements under the
    VVSG (and HAVA)?

-   **Interoperability:** What features must a voting system provide to
    allow the Acc-VS to interact with various types of PAT?

In VSS 2002 (and the TGDC draft of the VVSG), there is a general
*sufficiency* requirement. In the draft VVSG, this is stated as a broad
*interoperability* requirement. This change has caused some debate at
EAC and industry meetings, as well as some confusion about the different
concepts and their implications for the VVSG. \[Note: the rationale for
the original sufficiency requirement and very limited interoperability
requirements in the VSS 2002 originated from the recommendation by the
US Access Board to prefer a closed, self contained system.\]

We hope that this paper will clear up some of this confusion so that a
decision can be made about the general approach to sufficiency and
interoperability for the VVSG.

### 2. Current Status in the VVSG

#### 2.1 TGDC VVSG draft

Subsection 2.2.7.1 (Accessibility) of the TGDC VVSG draft addressed
certain issues about the Acc-VS and PAT, based on similar wording in the
2002 VSS. In particular, the TGDC draft included:

-   A general sufficiency requirement stating that \"1.2 An Acc-VS shall
    provide direct accessibility such that voters\' personal assistive
    devices are not required for voting.\"

-   A specific sufficiency requirement 2.2.3.4 stating that users of the
    Acc-VS should be provided with a "sanitized headphone or handset".

-   Certain specific interoperability requirements:

    -   \"2.2.3.1 The ATI shall provide its audio signal ...using a
        3.5mm stereo headphone jack\...\"

    -   \"2.2.3.2 When a voting station utilizes a telephone style
        handset/headset \... it shall provide a wireless T-Coil coupling
        for assistive hearing devices \...\"

    -   \"2.2.3.3 No voting station shall cause electromagnetic
        interference with assistive hearing devices \...\"

#### 2.2 EAC VVSG draft

The EAC VVSG draft altered requirement 1.2 to read: \"An Acc-VS shall
provide accessibility to voters using their own personal assistive
devices\" thereby creating a general interoperability requirement.

The detailed sufficiency and interoperability requirements listed above
are unchanged.

**2.3 Implications of the differences**

As it stands, the requirement is somewhat ambiguous between the two
concepts:

1)  The Acc-VS will provide enough interoperability so as to ensure
    accessibility to all/most voters, and

2)  The Acc-VS will provide interoperability to any device that a voter
    brings along.

Either, or both, may be desirable requirements. Both have implications
in many areas: the hardware features required for a system, the level of
effort provided or flexibility available to voters, and support or
training requirements for poll workers.

### 3. Requirements for Sufficiency

A "sufficient" system is one that provides, within itself, the features
or functions needed to meet the requirements for accessibility. The
Access Board defines such a system as a "self contained system," in
Section 508 of the US Rehabilitation Act:

\"Self contained products shall be usable by people with disabilities
without requiring an end-user to attach assistive technology to the
product. Personal headsets for private listening are not assistive
technology.\" Section 508 1194.25(a)

For discussion, we list some possible strategies for specifying
sufficiency.

#### 3.1 Restore general requirement

The original wording from the TGDC could simply be restored. This
wording, however, is quite general and it is not clear how it might be
rigorously tested, since no features are explicitly mentioned. Perhaps
it promises more than can really be delivered.

#### 3.2 No general requirement

An argument could be made that any sort of general sufficiency
requirement is unachievable and that the particular features required
elsewhere in section 2.2.7.1 (audio interface, various font sizes,
tactile buttons, etc.) already address sufficiency in a feasible and
testable way. What *additional* features are actually required by a
general statement to the effect that \"a voter needs no PAT to vote\"?

#### 3.3 Refine the general statement

The general requirement could be treated as a high-level \"goal\"
statement, rather than as a specific testable requirement. This approach
would imply the development of sub-requirements that describe the
specific disabilities which the voting station can handle \"on its
own\". The US Access Board's Section 508 standard has a list that could
be used as a basis for such sub-requirements. (See § 1194.31 Functional
performance criteria.)

### 4. Requirements for Interoperability

An "interoperable" system is one that provides features to allow
external PAT to be connected to the voting system, adding accessibility
beyond what is provided by the base system. These features would be
available only to voters who provided their own equipment, and relies on
their being able to connect them reliably.

A general consideration to keep in mind is that certain kinds of
interoperability may pose a security threat, although there has been
little analysis of the degree of threat. For example, an audio jack for
head phones is an output connection (and, hence, not a security threat)
and is considered an exception to the closed system assumption by the US
Access Board. In general, allowing for interoperability would require an
input/output port.)

For discussion, we list some possible strategies for specifying
interoperability.

#### 4.1 Retain the general requirement

The current requirement for general interoperability could be retained,
although it is unclear how it might be tested. Substantively, the
question is whether to encourage the development, within the Acc-VS, of
several PAT device interfaces. Note that the US Access Board has
discouraged this approach.

#### 4.2 Drop the general requirement

Omitting the requirement would mean that only the specific
interoperability requirements under 2.2.3 (noted above) would still be
in effect. And, of course, the VVSG would be open to proposals requiring
interoperability with additional specific devices.

#### 4.3. Clarify the general requirement

The requirement could be modified by including qualifying phrases such
as "where possible" and "does not compromise the integrity of the voting
system". Or, the requirement could be refined with more specific
sub-requirements.

In addition to the security considerations mentioned above,
comprehensive interoperability requires standard communication
protocols, port, and compatible software which may pose substantial
technical and feasibility barriers to implementation.

Before attempting such clarification, a review of currently available
PAT and their technical requirements would be needed. Part of this
review would include technical input from the Access Board, industry,
and advocacy groups.

### 5. Recommendations

The Human Factors and Privacy Subcommittee of the TGDC recognizes that
innovation to improve accessibility to larger segments of the disabled
population should be encouraged and addressed in future versions of the
VVSG.

However, at the present time the committee recommends that the VVSG
require general sufficiency and a closed, self-contained system with
very limited interoperability exceptions.

The committee also recommends that the EAC and NIST together review the
final draft carefully, to ensure that the VVSG technical language
accurately reflects the intention of the requirements.