Public Comments by Vendors

This web page lists vendor public comments from the Secretary of State's web site, with selective highlights from each. Of special interest are the ES&S comments which discuss what will be submitted.

General observations on comments from vendors:

• They want the exact methodology of the testing published in advance.
• They want to know what qualifications are needed for reviewers.
• They mention accuracy, reliability, and security as essentials of an election system (but never mention transparency).
• They talk about previous federal and state testing, but don't realize or acknowledge that that testing does not include security testing.
• They often mention compliance with federal law or federal certification, when in fact there is no applicable federal law and is no federal certification (only NASED certification, which is not federal).

Disclaimer: These highlights are by Jerry Berkman, not by the Secretary of State's office.

Avante thinks DREs should not use read/write media such as Flash memory: "It should be WRITE-ONCE-READ-MANY media (e.g. CD-R or DVD) only)". (This is often called WORM media.)

There should be a one-one relationship between paper records and electronic ballots, as required in 2005 VVSG.

All optical scanners should take "pictures" of the ballots.

Avante believes "Each of the paper ballots should have a machine-readable unique and random identifier that can allow for FULL AUTHENTICATION." and that the privacy concern is not valid due to widespread no-fault absentee voting.

Diebold believes the draft criteria are "reasonable if the review is done with the intent to determine if there are any realistic issues, as compared to purely theoretical issues."

Diebold wants more consideration of election procedures in protecting security.

They believe the current Draft Criteria language could be interpreted to exclude non-computerized voting solutions, and they offer alternate language.

Hart is the only vendor who endorses transparency.

Hart is concerned that the Draft Criteria lacks objective criteria, that it adds new requirements, that any required changed could not be implemented, approved, and deployed in time for the 2008 Presidential primary, and that it might make the systems to expensive for their customers.

Sequoia has many of the same concerns as other vendors.

These letters are dated April 24, 2007 and April 25, 2007, a month after the original date for public comment. They are titled:

Re: Response to Request for Submission of Working Models and Source Code

Apparently, Secretary Bowen has sent requests to the vendors, and this is ES&S's response. The "Costs" section discusses how much this will cost ES&S and what ES&S personnel will be required. The other sections discusses the Draft Criteria, with much the same concerns as the other vendors.

The letters appear to be identical except for the last few paragraphs discussing what system ES&S intends to submit for review.

The first letter concerns the review of the AutoMARK and the Unity application. ES&S proposes submitting Unity 3.0.1.1 which is NASED certified, and certified and used in other states, and tested by California in September 2006, but apparently not yet California certified. This would be instead of Unity 2.4.3, which is currently certified and deployed in California.

The second letter concerns the review of the InkaVote Plus used with the LA County MTS Central Tabulation system. ES&S will submit the InkaVote Plus system currently in use. It does not mention submitting the MTS Central Tabulation system for review.