Holt Letter E-Voting BillsDownload PDF
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.
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
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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.