Holt Letter E-Voting Bills

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July 10, 2009


The Honorable Rush Holt
United States House of Representatives
1214 Longworth Building
Washington, DC 20515


Dear Representative Holt:


On behalf of the U.S. Public Policy Council of the Association for Computing Machinery

(USACM), we wish to thank you for the opportunity to review and comment on the Voter

Confidence and Increased Accessibility Act of 2009. The Association for Computing Machinery

(ACM) - the leading society for computing professionals - and USACM are committed to

educating the public and policymakers about technical issues associated with electronic voting.


We appreciate your continued attention to issues of increased voter confidence and

accessibility. Your initiative resonates with USACM's positions on electronic voting - that

accurate, honest elections are one of the foundations of our democracy. We want to ensure support

for the development and deployment of trustworthy voting systems, and this bill can help

accomplish this goal.


USACM supports the provisions of the bill requiring that voters have an independent means

of verifying their votes. Paper-based audit trails are currently the only transparent means for voting

systems to be auditable independent of the underlying software. The approach taken for

independent verification in this legislation has both important similarities with, and differences

from, the proposed Voluntary Voting System Guidelines (VVSG) 2.0 currently being considered

by the Election Assistance Commission. In particular, the VVSG 2.0 approach for independent

voter verification is by way of a Software Independence1 standard. It also specifically states that

independent voter-verifiable paper records meet that standard. This approach is similar to the one

in the proposed legislation.


Unlike the proposed legislation, the VVSG 2.0 anticipates that other approaches might

achieve the SI standard in the future and describes a procedure for approving systems as an

"Innovation Class." To encourage both the integrity of elections and future innovation in voting

systems, USACM supported both the Software Independence standard and the Innovation Class.

We recommend that this legislation include an approach similar to the Innovation Class.


This legislation can help strengthen the voting system in the United States. We hope that you

will be able to incorporate our recommendations as the legislation moves through the legislative

process. Thank you for your continued involvement. We are pleased to continue to work with you

and should you have any questions, please contact Cameron Wilson, ACM's Director of Public

Policy at 202-659-9711.

Sincerely,
Eugene H. Spafford, Ph.D.
Chair, U.S. Public Policy Council
Association for Computing Machinery

cc: Representative Robert Brady, Chair, Committee on House Administration
Representative Dan Lungren, Ranking Member, Committee on House Administration


ABOUT ACM



ACM, the Association for Computing Machinery www.acm.org, is the world's largest educational

and scientific computing society, uniting computing educators, researchers and professionals to

inspire dialogue, share resources and address the field's challenges. ACM strengthens the

computing profession's collective voice through strong leadership, promotion of the highest

standards, and recognition of technical excellence. ACM supports the professional growth of its

members by providing opportunities for life-long learning, career development, and professional

networking.


ABOUT USACM



The ACM U.S. Public Policy Council (USACM) http://www.acm.org/usacm serves as the focal

point for ACM's interaction with U.S. government organizations, the computing community, and

the U.S. public in all matters of U.S. public policy related to information technology. Supported by

ACM's Washington, D.C., Office of Public Policy, USACM responds to requests for information

and technical expertise from U.S. government agencies and departments, seeks to influence

relevant U.S. government policies on behalf of the computing community and the public, and

provides information to ACM on relevant U.S. government activities. USACM also identifies

potentially significant technical and public policy issues and brings them to the attention of ACM

and the community.


____________________

1 Software Independence is defined in section 2.7 of the proposed VVSG 2.0; however, USACM proposed an amended definition,
which is on page 13 of our comments submitted to the Commission
(http://usacm.acm.org/PDF/USACM_VVSG_Comments_Final.pdf): Voting systems shall be software independent, that is, an error
or fault in the voting system's software shall not be capable of causing an undetectable change in election results, even if the
software fault(s) are not detected.

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