02/07/02 letter to the Senate Rules and Administration Committee on the IEEE Voting Systems standards effort (SCC38/P1583)

07 February 2002

The Honorable Robert C. Byrd
United States Senate
Washington, DC 20510

Dear Senator Byrd:

On behalf of the Institute for Electrical and Electronics Engineers Standards Association (IEEE-SA) Coordinating Committee on Voting Systems (SCC 38), I am writing to acquaint you with the IEEE initiative Project 1583 (P1583) to develop technical standards for voting equipment and to offer our recommendations for legislation now pending in the Congress regarding the development of such standards.

We congratulate your committee and the Congress for giving the vital issues of voting equipment reliability, usability and accessibility the attention they both require and deserve. In this letter, we offer our thoughts on how these aspects, critical to the integrity of voting systems, might best be addressed in conjunction with the proposed legislation.

In parallel with Congressional action regarding voting equipment and voting standards, the IEEE was petitioned by some of its members to contribute its technical expertise to the resolution of this important issue. In essence, the IEEE initiative (see attached description) shares goals identical with those of both Senate Bill 565 and House Bill 3295.

The IEEE-SA, an internationally recognized standards-setting body, develops standards through an open, consensus-based process. IEEE-SA has a portfolio of more than 850 active standards and more than 400 under development. A significant percentage of the 375,000 IEEE members worldwide voluntarily participate in standards activities. For further information on the IEEE-SA, visit our Web site at: www.standards.ieee.org. In June 2001, the IEEE-SA inaugurated P1583 to develop a series of related technical standards addressing voting equipment. In December 2001, the IEEE-SA Board formed SCC 38 to manage the interdisciplinary aspects of the project and participation from several of IEEE's 37 technical societies and other organizations. Currently, there are over 135 IEEE members and other volunteers contributing their time and expertise to the effort (see the attached membership roster). Engineers and experts in the fields of security, reliability and electromagnetic compatibility are working on the cross functional aspects of the project. There is also strong representation from the disability community and those interested in ensuring access to the voting system.

We are working in close coordination with the Federal Election Commission (FEC), the National Association of State Election Directors (NASED), the US Architectural and Transportation Compliance Board (Access Board), and other public and private sector organizations (including the major voting system manufacturers). At its last meeting, NASED invited the IEEE-SA SCC 38 to serve ex-officio on its Voting System Standard (VSS) Board. This invitation enables the IEEE-SA SCC 38 to provide technical support to federal, state and local officials and the independent testing authorities of the VSS, and assures that the IEEE-SA addresses the needs of election officials and administrators. We believe that the excellent working relationships established with all of the entities demonstrate great promise and serve the intent of the pending legislation.

Thus, we urge you to support the IEEE-SA initiative to bring together the best technical expertise available for developing these technical standards. In considering your support, we would ask that you take the following aspects of the current legislation into account:

HR 3295 specifically mentions the role of the American National Standards Institute (ANSI) in the development of technical standards for voting equipment. As you know, ANSI is the accrediting institute for U.S. standards developing organizations, but is not itself a standards developer. IEEE is proud to be one of the largest of the 263 ANSI-accredited organizations, and a founding member of ANSI. We are pleased that ANSI supports our effort, and confirms that IEEE is the only ANSI accredited body currently creating voting equipment standards.
Given the breadth of involvement and support for P1583, it is our hope that any legislation would delineate a role for the IEEE-SA in order to assist the federal agencies currently working with the IEEE and to achieve the common goal of consensus-based technical standards for voting equipment.
Both H.R. 3295 and S. 595 create a new commission, the Election Administration Commission (EAC), which would support and guide the replacement of outdated voting systems. This development on the federal level notwithstanding, many states have already begun the process of review and replacement of existing voting equipment, and would benefit greatly from making their purchasing decisions based on an updated set of precise technical guidelines. Because we are concerned that valuable time might be lost during the transition to this new commission, and that the input of so many engineers and organizations be brought to bear as expeditiously as possible, we suggest that the legislation support the involvement of the FEC, the Access Board and NIST in the work of IEEE P1583; particularly during the time in which the EAC is being established.

If you have any questions or need additional information about IEEE P1583, please feel free to contact me at (512) 864-3365, or visit our project web site at: http://grouper.ieee.org/groups/scc38/1583. You can also contact Deborah Rudolph, Manager, Technology Policy, IEEE-USA, in our Washington office at (202) 785-0017 x8332, or Edward Rashba, Manager, New Technical Programs at IEEE Headquarters at (732) 465 6449. Thank you again for your consideration of these issues. We look forward to the passage of this legislation.

Sincerely,

Stephen Berger
Chair, Voting Equipment Standards Coordinating Committee (SCC38)

(Letter Sent to Senate Rules and Administration Committee members)

Last Update: 1 February 2002
Staff Contact: Deborah Rudolph, d.rudolph@ieee.org

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