September 29, 2005 

Allan Eustis 

Thank you for inviting me to attend today’s Technical Guidelines Development 

Committee in Boulder. It was good to meet you in person. 

I have two requests: 

1. Please forward a copy of this letter and its attachments to members of the TGDC, 

and to anybody else that you wish. 

The first attachment is my August 24th letter to Ms. Hillman. I do not believe that 

she has had a chance to respond to. The second is a sketch of a brochure that 

outlines the level of documentation that we expect. The final technical guidelines 

should fit in a small pamphlet. 

2. Please ensure that my letter to Ms. Hillman is posted to the comments data base, 

is not rejected, is available to reviewers online, and will receive proper 

consideration and a response. If you wish, follow this instruction: (a) DELETE 

VOLUME I, (b) DELETE VOLUME II, and INSERT this document including its 

attachments. 

It is clear to me that the TGDC has not spent enough time considering the audience for 

the guidelines. We believe that the audience includes: judges, attorneys, district 

attorneys, attorneys general, secretary of state, county clerks, election officials, 

legislators, political parties, political campaigns, Election workers, poll watchers, 

vendors, application developers, application and system testers, independent testing 

authorities, the public and the press. A summary of the document is not a solution. For 

example, the Court, in order to decide a case being litigated before it, must comprehend 

and make its determination on the official document itself. The current work product 

does not meet the needs of its audience. 

A trivial example of what is needed might be helpful. Consider what the individual 

members of the TGDC would write if they were asked to document their personal 

requirements for a car. I would anticipate that their individual requirements could be 

grouped into fairly regular categories such as: comfort, safety, performance, price, 

operating cost, service, and warrantee. I anticipate that few, if any, members would 

differentiate between the type of ignition system used to start the engine. The current 

guidelines are aimed at the wrong things, because they are not aimed at the right 

audience. 

The direction that the work is heading would be prohibitively expensive to maintain and 

impossible to litigate. 

Al Kolwicz, Executive Director, CAMBER 303-494-1540 AlKolwicz@qwest.net 

Al Kolwicz, CAMBER to Allan Eustis, EAC Page 1 of 5
August 24, 2005 

Ms. Hillman, 

Again I compliment you for your wonderfully insightful questions of panelists at 

yesterday’s EAC hearing in Denver. I deduce from your questions that you truly want to 

represent the interests of the public. 

You don’t know me, so you won’t know how much weight to attribute to the following 

comments. I hope that you will take them seriously. 

1. The problem that you and the other commissioners appear to sense with the VVSG is 

that the VVSG is both voluminous and complex. I concur with this appraisal. In fact, 

I would go a step further and say that the VVSG is unusable because of its volume 

and complexity. 

Writing a superficial overview will not suddenly make the VVSG useable. Editing 

the VVSG will not make it useable. The problem with the guide is fundamental -- it 

is aiming at the wrong target, and it is using the wrong ammunition. 

a. The guide is incomplete (wrong target). The election system involves many 

components – the VVSP addresses very few of them. For example, the guide 

does not address public oversight, yet public oversight is a fundamental 

component of a trustworthy election process. The guide does not address 

procedures, such as authentication that a voter is the person who they claim to 

be. All of the components of the election system must be identified, and must 

be documented in a high-level systems diagram supplemented with a high 

level systems description. The diagram and description must be void of 

specific implementation details, and must not require change for different 

implementations. The current guide violates these precepts. 

 

b. The guide addresses implementation-level details (wrong ammo). The VVSG 

should specify only: required results, measurement specifications for each 

result, acceptable performance for each result, and consequences when the 

required result is not achieved. HOW the result is achieved must be invisible 

in the VVSG. Instead, this guide is burdened with detailed descriptions of 

how things are to be done for specific implementations. For example, there is 

no general requirement that people and procedures be tested and measured. 

One of the problems with the approach taken in the VVSG is that it will 

require revision every time a new technology is introduced. Remember, it 

will take years before any VVSG change will be reflected in a majority of the 

nation’s voting systems. Unless changed to reflect principles rather than 

implementations, the VVSG will fail in its goal of returning public trust to the 

election system. 
2. The proposal for accreditation of Testing Laboratories and the testing process itself is 

headed in the wrong direction. 

 

a. Missing, for example, is a way to pay for the testing. The vendors should not 

pay, because that would compromise the integrity of the Testing Labs. The 

people should not pay for overly expensive or frivolous tests, and should be 

compensated through penalty fees, for poor vendor performance. 

b. There is nothing proposed that will motivate vendors to withhold certification 

requests until they have a very high degree of confidence that the certification 

process will not discover a deviation between requirements and the 

implementation. 

c. The role of the public, and in particular the interested professional computer 

scientists, is missing. 

d. There is no penalty when a Testing Lab fails to detect problems that make it 

into production. How is a lab de-certified? 

e. Who is accountable for the quality of the election process? 

f. Also, because of the fundamental problems with the VVSG, described above, 

the Testing Labs are going to be testing the wrong stuff. There is a difference 

between systems testing that is aimed at requirements and architecture (what), 

and implementation testing that is aimed at implementation specifications 

(how). 

Few people have the skills needed to draw the elegant line between 

requirements/architecture and the implementation specifications. The VVSG desperately 

needs these skills. Unless the VVSG is revamped, I anticipate that it will become a 

burden on the public. It will generate enormous costs, fail to deliver quality, and be 

rejected by the public as a solution to their concerns. 

Finally, yesterday it was suggested by staff that only public comments that are specific to 

a page and line number will be considered. In my opinion, the VVSG problems are so 

severe that it is way premature to inspect spelling errors. Until focused on the correct 

target, and using the correct ammunition, it is too way early to do any fine tuning. 

Is there anything you would like me to do to amplify these points?

Thank you for conducting your hearing in Denver. I look forward to working with you. 

Al 

Al Kolwicz

CAMBER - Citizens for Accurate Mail Ballot Election Results

2867 Tincup Circle 

Boulder, CO 80305 

303-494-1540

AlKolwicz@qwest.net

www.users.qwest.net/~alkolwicz

http://ColoradoVoter.blogspot.com
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Citizens for AccurateMail Ballot Election Results 2867 Tincup Circle Boulder, CO 80305 Phone: 303-494-1540 E-mail: AlKolwicz@qwest.net www.ColoradoVoter.blogspot.com