May 24, 2007 

To: NIST and the Technical Guidelines Development Committee: 

 

I wish to record my disagreement with certain provisions of the VVSG Recommendations 

(Draft) of May 21-22, 2007; specifically those in Volume 3, Chapter 6, Voter Verified Paper 

Records. This chapter permits the use of post-vote printouts from DREs that are contained on a 

continuous roll of paper. In my opinion, this method of providing a voter-verified paper record 

is seriously defective and should not be permitted. 

 

It is a bad idea to standardize defective methods in the hope that the minimal requirements 

imposed will make a sufficient improvement to overcome the fundamental flaw. This procedure 

was tried in the 1990 voting-system standards published by the Federal Election Commission. In 

those standards, the use of pre-scored punch card ballots was permitted. The standards stated: 

 "When pre-scored ballot cards are used ... [the stylus] shall incorporate features ... to ensure 

that the chad (debris) is completely removed." 

No state that used pre-scored ballot cards, and they were used in many states, ever required a 

spring-loaded stylus, the only method that would have ensured that the chads were completely 

removed. The Florida debacle of 2000 resulted partly because of the failure of that state to carry 

out the provisions of the standards that they had adopted. It may be noted that no provision of 

the Help America Vote Act requires the elimination of pre-scored ballot cards, and they are still 

being used in Idaho by about 60% of the voters in that state. Idaho never requested HAVA 

money to replace them, and the federal government has no legal method of forcing their removal, 

despite their defective character. 

 

In my report to NIST of August 22, 2006, carried out under contract, and entitled "Independent 

Verification: Essential Action to Assure Integrity in the Voting Process," I listed several serious 

problems with post-vote printouts from DREs. I listed these in more detail elsewhere. These 

defects are: 

 

 (1) A Majority of Voters Do Not Review Their Printouts: An analysis of a 

videotape from an actual election using DRE printouts, carried out with experienced and 

respected individuals in attendance, demonstrated that a majority of voters did not review their 

printouts. A bill being considered in the House of Representatives mandates instructions to 

voters calling for them to review their printouts. Experience suggests the failure of this strategy. 

In the many years that pre-scored punch cards were repetitively used, instructions to remove all 

chads from the backs of ballot cards were routinely ignored. 

 

 (2) Printouts Should Not Be Identified as “Ballots of Record” of the 

Voters’ Choices: The concept behind implementation of printouts is that the computer 

program is not trusted to record the voters’ sets of choices correctly. By that very fact, then, if a 

voter fails to completely and thoroughly review the printout before accepting it, the printout 

remains just a piece of paper produced by a computer program that is not trusted. No claim can 

be made that these printouts, if not completely reviewed, exactly represent the voters’ choices. It 

is meaningless and a waste of time and resources to recount these printouts. Furthermore, as 
these printouts cannot be guaranteed to be exact copies of their respective summary screens, it is 

improper to declare the printouts the ballots of record, as has been done in some states. 

 

 (3) Human Factors Prevent Effective Reviews of Printouts, Even When 

Reviews are Attempted: In verifying that the computer has recorded his or her vote correctly, a 

voter would have to compare the DRE summary screen against the printout. Both the 

Caltech/MIT Voting Technology Project and the Center for American Politics and Citizenship at 

University of Maryland - College Park have noted serious human factors issues that prevent an 

effective comparison. The MIT researchers have written that the different formats, graphical 

layouts and lighting conditions make comparison difficult. They stated further that “comparing 

dozens of selections on voter-verified paper receipts will take special care. Complications of 

comparing a separate paper trail in a different ballot format might add extra difficulty for people 

with learning or reading difficulties.” The researchers at College Park have written that 

“questions were raised about the paper record’s utility when used for a long ballot.” 

 

 (4) The Time to Vote is Increased: The addition of a paper trail to a DRE and 

the necessary comparison of the printout with the electronic screen increases the time to vote. 

This fact was noted in a recent study of some vote-verification technologies carried out by 

Donald F. Norris and associates at University of Maryland at Baltimore County. The increase in 

voting time is a serious concern for the use of DREs, in that a voter must monopolize the 

equipment during the voting process. The likelihood of waiting lines is greater. Election 

administrators know that increasing the time to vote is unacceptable to voters. The increased 

time is one reason that many of voters do not review their printouts. 

 

 (5) A Voter’s Loss of the “Secret Ballot” Occurs if an Error is Discovered:

The reason for requiring a printout is to attempt to determine if the computer’s printed record is 

different from the votes shown on the DRE summary screen. If a voter finds a difference, that 

voter must lose his or her right to a secret ballot in the demonstration of the difference to a poll 

worker and to other election administrators who must assure the correctness of what the voter is 

protesting. Since the right to a secret ballot is typically required in law, the demonstration of an 

error would put the voter and the election administrators in a double bind. The determination of 

a computer error would be very important to be revealed, and yet it would be a violation of a 

fundamental right of a voter. The use of these printouts requires voters to serve as the front line 

against computer error and to be severely wounded if the enemy appears. 

 

 (6) Blind Persons Cannot Use the Printouts: The American Association for 

People with Disabilities has strongly opposed the use of the printouts as discriminatory and 

unlawful. The Help America Vote Act requires that persons with disabilities be given the same 

opportunity to vote independently as non-disabled persons. The requirement that voters read 

their printouts to determine if they exactly represent the voters’ choices cannot be carried out by 

blind persons. The requirement that blind persons use a different system than sighted persons to 

cast their votes stigmatizes this community. 

 

 (7) An Extra Onus for Verification is Placed on the Voter: The requirement 

that a voter review a printout from a DRE in order to verify correctness of his or her choices is an 

unnecessary extra requirement imposed on the voter. In a different implementation for a DRE, a 
voter can review and approve an instantaneously appearing printed copy, on a hard-copy 

ballot, of each vote cast, as it is cast. This latter method adds no time and no human-factor 

difficulty to the verification process. If independent verification is established in law, it becomes 

the duty for the election administrators to carry out this important responsibility. Then, 

independent verification becomes an aspect of “due process” in determining the results of 

elections. 

 

Therefore, I request that the TGDC eliminate the use of post-vote printouts from DREs as an 

acceptable method of voter-verification. With DREs, if the voter is not permitted to touch and 

handle the hard-copy printout, the only acceptable method, in my opinion, is one in which the 

voter sees the selected candidate's name printed on the ballot immediately following the 

candidate's selection on the touch-screen or with a pushbutton or micro-switch. I have seen a 

system with this characteristic; it is being proposed for use in New York state. Furthermore, this 

system cuts off each voter's set of selections on the hard-copy ballot from the continuous roll and 

drops them in a large ballot box, thereby eliminating the issue of loss of privacy that could result 

from a matching of the sequence of voters with the sequence on the continuous roll. 

 

Roy G. Saltman 

Consultant and Author on Election Technology 

5025 Broken Oak Lane 

Columbia, MD 21044 

Phone: 410-730-4983 

Fax: 410-997-4355