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Technical Guidelines Development Committee

# C/O National Institute of Standards and Technology

100 Bureau Drive, Stop 1070

Gaithersburg, MD 20899-1070

April 17, 2005

Dear Technical Guidelines Development Committee:

In their letter dated April 7, 2005, the U.S. Election Assistance
Commission (EAC) advised the states that the National Institute of
Standards and Technology (NIST) and the EAC Technical Guidelines
Development Committee will issue its first set of recommendations at the
TGDC Plenary Meeting on April 20-21, 2005. According to the EAC, among
the recommendations will be guidelines for testing a voting systems with
a Voter Verified Paper Audit Trail (VVPAT). The VVPAT guidelines will be
directed to those states that have already legislated the use of a VVPAT
and are intended to provide guidelines so that the VVPAT products can be
adequately tested.

The elections community welcomes the involvement of NIST and looks
forward to improved voluntary voting system standards. Improved
standards are needed as the direct recording electronic voting system
(DRE) technology represents the next generation of voting system
technology and traditional methods of testing and auditing voting
systems are based on paper systems. NIST can help the elections
community develop public trust and confidence with this technology by
issuing new procedures for logic and accuracy testing, audits, voter
verification, and recounts. We believe that state legislatures need
technical guidance from you and the TGDC regarding these new policies
and procedures. However, we are concerned that by issuing VVPAT
standards to the exclusion of any other standards, it will appear that
NIST tacitly endorses VVPATs as THE solution to public confidence and
trust in electronic voting systems.

We understand that VVPAT standards are necessary in light of several
states\' mandates for them. However, all states are required to employ
accessible voting systems by January 1, 2006, and the only federally
certified voting systems that are considered accessible are DREs.
Although a handful of states have mandated VVPATs, most states have not
mandated VVPATs and are waiting on guidance from NIST and TGDC for
comprehensive standards for DRE use. For many, the VVPAT represents a
cumbersome, expensive, and partial answer to questions about DRE
security and voter verification. In addition to being able to verify
that their vote was cast properly, voters need confidence that their
vote will be recorded correctly BEFORE they cast their ballot.

Before any VVPAT standards are released, we strongly encourage you to
clearly state:

1\. VVPAT is not the only solution for voter verification;

> 2\. NIST will continue to explore alternative voter verification
> solutions, which may include private receipt audit trail technologies;
>
> 3\. NIST will issue guidelines for comprehensive logic and accuracy
> testing for DRES;

4\. NIST will issue guidelines for parallel testing;

5\. NIST will issue guidelines for HASH code monitoring by the states;
and

6\. NIST will issue these guidelines by a date certain.

NIST provides technical leadership for vital components of the nation's
technology infrastructure. Because of your well- deserved reputation
throughout the nation and the world, any guidelines you issue will be
compelling. When you issue the VVPAT guidelines please clarify that
VVPAT is a partial solution and the guidelines are being issued in
response to the demands from a handful of states. Please clarify that
NIST has only begun its work to develop standards for Security and
Transparency, Human Factors and Privacy, and Core Requirements and
Testing. Strong public trust and confidence in the nation\'s voting
systems is essential to our democracy, and the public needs to know that
VVPAT is certainly not the only solution, and probably not the best
solution.

Sincerely,

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Linda Lamone

President, National Association of State Election Directors

Administrator of Elections, Maryland State Board of Elections