ES&S Comments on the Draft Standard for Accessibility: Augmentation to
the 2002 Voting Systems Standard, Draft Version March 2, 2005

+----------+-----------------------------------------------------------+
| **Ref    | **Comment**                                               |
| erence** |                                                           |
+----------+-----------------------------------------------------------+
| 1        | The use of the word \"all\" conflicts with the separately |
|          | stated intent of the requirement. By using the word       |
|          | \"ALL\" in the requirement it could be implied that 100%  |
|          | of voters must be able to vote. The writer notes in the   |
|          | document that this is an ideal, but practically speaking  |
|          | there will be some voters with severe disabilities that   |
|          | will require assistance. A suggestion would be to change  |
|          | the word \"all\" to \"as many as possible\" and add some  |
|          | verbiage that indicates that as technologies become       |
|          | available in the future, each will be reviewed and        |
|          | incorporated if possible in order to reach the ultimate   |
|          | goal of 100%.                                             |
+----------+-----------------------------------------------------------+
| 1.1.1    | This requirement is too general to cover all of the       |
|          | ranges of disabilities. It is also not performance based  |
|          | and could be interpreted subjectively. A suggestion that  |
|          | would help to reach a set performance requirements would  |
|          | be to break down each disability group (visual, hearing,  |
|          | physical). The IEEE 5.3.7 section does address this and   |
|          | could be used as a foundation.                            |
+----------+-----------------------------------------------------------+
| 1.1.1.1  | A standard assistive device technology that could be      |
|          | provided to disabled voters is not available today as     |
|          | there are currently there are 3+ standards used by        |
|          | \"assistive device industry\" and all are not compatible. |
|          |                                                           |
|          | Suggestions:                                              |
|          |                                                           |
|          | -   Determine what assistive technology can be provided   |
|          |     now such as sip 'n puff and define performance based  |
|          |     requirements.                                         |
|          |                                                           |
|          | -   Define the term assistive technology (eye glasses are |
|          |     an assistive device).                                 |
|          |                                                           |
|          | -   Determine a progressive plan to incorporate assistive |
|          |     technology as it becomes available.                   |
+----------+-----------------------------------------------------------+
| 1.1.2    | This requirement is too general to cover all of the       |
|          | ranges of disabilities. It is also not performance based  |
|          | and could be interpreted subjectively. There are several  |
|          | different types (ex. color blind, low visual acquity,     |
|          | tunnel vision) of visual disabilities each requiring      |
|          | different methods and performance. As stated in item      |
|          | 1.1.1, in order to determine the performance              |
|          | requirements, the larger disability group should be       |
|          | divided into sub groups in order to determine the         |
|          | requirements. NASED addressed some of these in the        |
|          | Technical Bulletin - section 2-2-7.                       |
+----------+-----------------------------------------------------------+
| 1.1      | Practically speaking this will be cost prohibitive for    |
| .2.3.2.4 | the jurisdictions. Rather than stating that new earphones |
|          | be provided, stating that a means of sanitary protection  |
|          | must be reached (e.g., sanitary earphone covers).         |
+----------+-----------------------------------------------------------+
| 1.1.7    | This requirement as it stands is too general and is not   |
|          | performance based. This disability group also has many    |
|          | sub-groups. A suggestion would be to define the           |
|          | sub-groups and determine the necessary performance        |
|          | requirements based on the needs of the voters within the  |
|          | sub group. The IEEE did not address specifically in the   |
|          | requirements sections, but it was addressed in the 6.3    |
|          | (usability testing) section of the IEEE Draft.            |
+----------+-----------------------------------------------------------+