Comments on Testimony by League of Women Voters President Kay Maxwell before the Election Assistance Commission, May 5, 2004.

 

We the undersigned LWV members agree with President Maxwell that concerns about electronic voting must be dealt with through real-world safeguards that ensure Americans that their votes will, in fact, be protected.  We also share her concern that the DRE debate not scare voters away from the polls.

 

However, ignoring or underestimating the very serious accuracy and security risks of paperless DREs is not a solution.  Instead, the LWV must address those risks directly and responsibly.  That is the only way that we can, as President Maxwell says, “ensure that every vote will count.”

 

Because Maxwell’s statement is very long, we address only those points with which we differ most strongly.  Quotes from Maxwell’s statement are indented; our responses are not.

 

To tamper with a DRE someone would need to know each of the security systems within the machine, including codes, formats and storage capacities, and be able to manipulate them undetected after first gaining sufficient access to spend the necessary time with the machine.

 

It is technically wrong to claim that one would need to know each of the security systems within a DRE in order to tamper with the machine.  In fact, it is easy to write code that changes the voting information on the touch screen before that information is stored in the computer.  If the vote has been modified, it doesn’t matter how it is subsequently stored or what format is used to store it.  It is still modified, and will not accurately reflect the will of the voter.

 

The statement also ignores the very real possibility that errors (bugs) in the software will cause the vote to be modified before the now incorrect version is stored. We note that testing and certification done on DREs is totally inadequate, as demonstrated by numerous failures of “certified” DREs in recent elections.

 

Under HAVA, there must be a paper record of each vote from a DRE voting system. In well-run systems, the printouts with vote totals are taken throughout Election Day and compared to the total number of votes cast at the machine, to ensure security. The paper records then provide a backup for official tabulations of election results.

 

In most elections using DREs the paper printouts are produced at the end of the day.  Unless a machine has a major failure, the paper printouts will match the DRE counts.  The paper reflects only what is inside the machine.  If the information in the machine is incorrect, either because of bugs or malicious code, the paper printouts will be equally incorrect.  It is misleading to refer to such a paper printout as an audit.

 

The only way that any paper printout can be trusted is if the voter has had an opportunity to check that it correctly reflects his or her choices.  Printing out ballot images at the end of the election, or even during the election, is simply a regurgitation of what is in the machine – not an audit check.

 

A VVPT is an add-on system that prints out the voter’s individual ballot choices after they have been cast on the DRE…. The term is used interchangeably to refer to systems that simply provide the individual paper record for the voter to look at if she or he wishes, and systems that would require that each voter actually verify the paper record of his or her vote.

 

Maxwell’s definition, given above, of a voter-verified paper trail (VVPT) completely ignores the fact that optical scan voting machines, as well as other machines discussed below, create a voter-verified paper ballot.  Furthermore, there are no DRE based systems using VVPT that require the voter to actually verify the paper record of his or her vote.

 

For the VVPT system to work as a backup for counting the vote accurately, it seems that every voter must verify every ballot. Otherwise there is no assurance that the paper trail is accurate. Unverified pieces of paper don’t add accuracy or security. They may, or may not, reflect the voter’s intent.

 

Ironically, Maxwell’s complaint about paper ballots applies much more directly to paperless DREs.  It would be very easy for a machine to display one thing on the screen and store a different result internally.  In that case there is no chance that the voter could catch the cheat, because the voter could not see how his or her ballot is being stored internally.  However, if a reasonable percentage of voters verify their paper ballots, then it’s likely that cheating would be detected.

 

Maxwell refers to the ballot counting problems from Florida 2000 and asks, somewhat rhetorically:

 

With these well-known problems with paper recounts, is it more likely that the paper recount would be in error than the electronically cast ballots from DREs?

 

This is a meaningless question, since there is no way to determine if the ballot tallies stored in the DREs accurately reflect the collective will of the voters.

 

By contrast, we are capable of accurately counting paper.  Banks do it all the time.  Other countries such as Canada and the UK hold paper based elections and accurately count the ballots.  There were many problems with Florida 2000, but it is incorrect to infer from that experience that it’s not possible to count paper ballots.

 

Maxwell’s entire discussion of VVPT ignores optical scan paper ballots.  Since the computer-based machine used to tabulate optical scan ballots might also have problems or be manipulated, a certain percentage of optical scan or other VVPT ballots should be recounted manually.  California law mandates a 1% manual recount.  If the recount does not match the machine count, then all of the ballots should be manually counted.

 

First, if a malicious programmer or an outside “hacker” can change the electronic record of the vote, certainly such a skilled person can make the printer provide a paper record that doesn’t expose any error.  In other words, if I vote for candidate A, but the malicious programmer makes it so the electronic record says candidate B, the programmer could also make the paper record for candidate A.  Under this scenario, the voter and the poll worker are not alerted to the problem. So, in this example, the paper record does not indicate a problem with the machine, and does not provide a safeguard.

 

While factually correct, Maxwell’s statement ignores the fact that some percentage of voter-verified ballots should be manually counted, as we have discussed above.

 

The following statement by Maxwell raises a legitimate concern and exposes the fundamental problem with all DREs, even those with voter verified paper ballots:

 

Second, what happens if nine voters choose not to look at their paper record, but the tenth voter reports that her or his paper record is wrong? Should we assume that the previous nine votes were also wrong?  Do we need to call those voters back and ask them? Do we need to somehow retrieve their votes from the system? Under the optional verification system, we clearly cannot rely on those unverified pieces of paper for a later recount.

 

Those who do not verify their paper ballot risk that their votes will be incorrectly counted. Obviously, a protocol must be developed to take action when a voter claims an incorrect paper ballot. The task is achievable, but this is not the place to do it.

 

We note that a DRE with no voter verified paper ballot might be faulty, but no one would know and the incorrect tabulation would be assumed to be correct.

 

We agree with Maxwell that standards are needed for machines that produce voter verified paper ballots.  DREs were rushed to market with grossly inadequate standards, poor security, and testing that was so shoddy that it didn’t even uncover rudimentary security problems.  We should not repeat that mistake.  The State of California is currently working on developing standards for VVPT machines.  Congress should also provide funding for NIST so that they can develop meaningful national standards for voting machines.

 

Finally, we are concerned that the VVPT system can reduce access for persons with disabilities, limited English proficiency and low literacy. The VVPT system provides for the voter to verify the paper ballot, which historically disenfranchised voters will find difficult to do if they cannot see or if they have difficulty reading the paper verification.  Private and independent voting is important, and, at this juncture, seems inconsistent with the VVPT system for significant numbers of voters.

 

The US Department of Justice disagrees.  In an opinion dated Oct. 10, 2003, the DoJ determined that a VVPT system does not discriminate against people with disabilities.  Furthermore, all voters would benefit from having some voters verify their ballots as a check against software bugs and fraud. 

 

Furthermore, it is technically possible to have voter verified paper ballots that can be verified by people with vision problems, limited English proficiency, and low literacy.

 

For example, a machine has been developed (Vogue Election Systems) that can be used by people with vision and language problems just as they would use a DRE.  Instead of tabulating and counting the votes, the VES machine marks an optical scan ballot.  That ballot can be read through an optical scanner with attached earphones and verified by the blind.  It can also be verified by the sighted and counted, both by an optical scan machine and by hand.

 

A somewhat different approach is taken by Populex.  Rather than marking an already printed optical scan ballot, as is done by the VES, the Populex system, which also provides attached earphones, prints an optical scan ballot containing the voter’s selections that can be verified by both the sighted and the vision impaired.

 

But it’s not even necessary to spend a lot of money on computer based voting machines to allow blind voters to vote unassisted, as Rhode Island has demonstrated with low tech tactile ballots for vision-impaired voters.

 

Finally, we agree with Maxwell’s statement below, but perhaps not for the same reasons as she:

 

If only the paper record is corrected when the voter affirmatively rejects the first paper record, then the DRE mechanism itself is superfluous. In effect, the costly internal mechanisms of the DRE would be disregarded and the DRE system would be reduced to being a paper-record generating device.

 

The DRE mechanism should indeed be superfluous.  Many of these machines have been found to be faulty, and some are grossly insecure.  We cannot trust our democracy to such devices.  If people insist on using DREs, at a minimum the DREs should be required to produce a voter verified paper ballot.  As Maxwell correctly observes, there may be problems with a DRE combined with a VVPT.  Unfortunately, the alternative with no VVPT, is far worse.

 

The LWVUS should be working with election officials to aid them in obtaining refunds and using that money to purchase secure and reliable machines.

 

 

Barbara Simons, Ph.D. Computer Science, LWV Palo Alto, CA
Janet Anderson, LWV Seattle, WA
Tanya Baumgart, Immediate-past Co-President, LWV Bellinghim/Whatcom County, WA

Marion Beddill, LWV Bellingham/Whatcom County
Judy Bertelsen, Ph.D., M.D., LWVBAE (Berkeley, Albany, Emeryville), CA

Roberta Bradbury, LWV Member since 1957, former President LWV Colorado, current member Pikes Peak LWV, CO
Barbara Calef, President, LWV Los Alamos, NM
Katherine Campbell, LWV Los Alamos, NM
Ernest J. Dieterich, LWV Winchester, MA
Carma D. Forgie, LWV Arlington, MA
Linda Freedman, LWV Marblehead, MA
Shirley M. Jin, Co-President, LWV Space Coast, FL

Genevieve Katz LWV Oakland, CA
Lee Mondale, President LWV Marblehead, MA
Jo Morgan, Immediate Past Co-President, Board Member, LWV Bellingham/Whatcom Co., WA

Richard Neavel, Ph.D., LWV Austin, TX
Debbie L. Nuss, President, LWV Manhattan/Riley County, KS
Diane Park, LWV San Joaquin County, CA

Mary E. Porter, Board Member, LWV Worcester, MA
June A. Rusten, LWV Ann Arbor Area, MI
Samuel A. Scharff, Leader, Southend Evening Unit, LWV Seattle, WA
Rebecca Shankland, LWV Los Alamos, NM
June A. Rusten, LWV Ann Arbor Area, MI

Lee Ziegler, Spokesperson, LWV Pikes Peak Region, CO