To: Technical Guidelines Development Committee 

From: Sandy Steinbach, NASED Voting System Chairperson 

Re: Current Draft VVSG 

Date: May 18, 2007 

It is extremely difficult for me, as an election administrator, to have any 

confidence in this document when its authors clearly have so much confusion 

and obvious misunderstanding of the process they are trying to facilitate. For 

example, many of the definitions in Chapter 2 are simply wrong. 

“Absentee ballot” is not “a ballot resulting from absentee voting.” It is the ballot 

provided to an absent voter. Even if the voter does not mark the ballot, it is still 

an absentee ballot. 

“Absentee voting” is not “voting than can occur unsupervised at a location 

chosen by the voter.” Absentee voting is the process by which a voter may 

request and receive a ballot before election day. In some states (Iowa is one) 

absentee voting can occur at the office of the local election administrator, at a 

location chosen by the local election administrator, or the administrator can mail 

the ballot to the voter. The difference between absentee voting and “early voting” 

is that absentee ballots are enclosed in envelopes and are subject to challenge 

until they are opened and counted (usually on or immediately before election 

day.) The ballots cast in early voting are deposited directly into ballot boxes and 

are, therefore, cast before election day. Because they have been cast, 

challengers cannot effectively raise questions about the eligibility of these voters; 

there is no way to remove the secret ballot from the tally. 

“Crossover vote” is defined as “scratch vote.” Scratch vote is not a term I have 

heard used in 25 years as an election administrator. Beware of local terminology 

that may not be in general use. 

“General election” is not an “election in which there are no partisan contests” --far 

from it. The general election is the most partisan of elections. It is the election at 

which federal offices, such as President & Vice President, US Senators, and US 

Representatives are chosen. Many other offices are voted upon at that election: 

state, county, and local. It is held on the first Tuesday after the first Monday in 

November of even-numbered years. 

“Nonpartisan contest” is not one in which “eligibility to vote in that contest is 

independent of political party affiliation, or lack thereof.” A nonpartisan contest is 

a race in which the party affiliation of the candidates is not noted on the ballot. 

“Partisan contest” is not one in which the eligibility to vote in that contest is 

restricted on party affiliation.” A “partisan contest” is one in which the party 

affiliation of the candidates, if any, is noted on the ballot. 
“Primary election” is not an “election in which there are partisan contests.” 

Primary elections may be either partisan, or nonpartisan, or both. A primary 

election is held to select candidates for the next, usually final, election. 

“Straight party voting” is selection of all candidates that have been nominated by 

(or endorsed in some states) a political party by selecting the name of the 

political party in the designated area of the ballot. Voters may override their 

straight party votes (in Iowa anyway) by selecting candidates of other parties, or 

candidates who are not affiliated with a political party. Laws regarding overriding 

a straight party vote in a vote for n-of-m race vary from state to state. See 

“crossover vote.” 

VVPAT: (Voter-Verified Paper Audit Trail). This is more accurately a “voter 

verifiable paper audit trail.” See below. 

VVPR: (Voter-Verified Paper Record) If the voter does not actually review the 

VVPAT, it is not “voter verified.” This is more accurately a “voter verifiable paper 

record.” Use of the term “voter-verified” is an assumption, not a description based 

on facts. “Voter verification” is not a testable feature. Presenting something for a 

voter to verify is very different from the voter actually performing the task. 

The use of the term “voter verified” implies that some features of voting systems 

may make voting equipment more reliable by providing additional opportunities 

for voters to review their ballots. Presenting one more opportunity for a voter to 

review a ballot does not mean that the voter will actually do it. Describing the 

process as “voter-verified” is dishonest, and it is certainly not a testable feature. 

The following terms are not defined, and should be: 

Audit 

Ballot 

Trusted build 

Volume test 

Witnessed build 

Much of the actual text of the guidelines is written in technical language. Despite 

a promise to “disambiguate” the language of the guidelines, it is not accessible to 

the non-technical reader. Taken with the apparent ignorance displayed in the 

definitions section, this leads me to be suspicious of whether this set of 

guidelines is actually useful to the states. 

Within the text there are numerous assumptions that may well be based upon 

election laws somewhere, but they are not applicable everywhere. For example, 

the concern expressed in 1.5.1 about the lack of secrecy afforded to some voters 

in the selection of a political party ballot in a primary election. In Iowa, for 

example, this is not a private matter. The voter’s choice of a political party is a 

matter of public record. 
Reconciliation of write-in votes (2.6.3.1) also includes the outrageous assumption 

(at least in Iowa) that write-in votes are counted “only if the election is close 

enough to warrant the effort.” Under Iowa law all votes are counted in order to 

determine the outcome. At the time the votes are counted (largely on election 

night) there is no way to know whether any individual vote will make a difference. 

Further, any voter may write in the name of any person for any office. Under this 

process it would be impossible for the voting equipment to reconcile write-in 

votes. 

There are numerous places that read, “Source: Click here to add the source.” Or 

“Impact: Click here to add the impact.” I presume that these gaps will be 

available for comment at some time. 

The table of contents appears to be in need of editorial attention. The table of 

contents in Volume One includes three chapters called “Chapter 1” and two 

chapters called “Chapter 2.” The organization is confusing at best. Following 

Chapter 14 in the table of contents, there is another set labeled “Chapters 1 

through 6,” which is followed by a third series beginning with Chapter 1 again. 

This document is hardly ready for final adoption.