BILL ANALYSIS �
SB 360
Page 1
Date of Hearing: August 13, 2013
ASSEMBLY COMMITTEE ON ELECTIONS AND REDISTRICTING
Paul Fong, Chair
SB 360 (Padilla) - As Amended: August 6, 2013
SENATE VOTE : 27-9
SUBJECT : Certification of voting systems.
SUMMARY : Makes significant changes to procedures and criteria
for the certification and approval of a voting system. Expands
the use of Voting Modernization Fund monies and authorizes a
county to use those monies to purchase a conditionally approved
voting system, as specified, for research and development of a
nonproprietary voting system that uses disclosed source code, as
specified, or to manufacture a limited number of voting system
units for use in a pilot program, as specified, or for
submission to the Secretary of State (SOS) for certification, as
specified. Requires the SOS to adopt and publish regulations,
as specified, governing the experimental use of a voting system
in a pilot programs. Specifically, this bill :
1)Provides all of the following are the intent of the
Legislature:
a) All voting systems be certified or conditionally
approved by the SOS, independent of voluntary federal
qualification or certification, before they are used in
future elections to ensure that the voting systems have the
ability to meet accuracy, accessibility, and security
standards;
b) The SOS adopt and publish testing standards that meet or
exceed federal voluntary standards set by the United States
Election Assistance Commission (EAC) or its successor
agency;
c) The SOS study and encourage the development of voting
systems that use nonproprietary source code and that are
easy to audit;
d) A local jurisdiction may use available public funds to
purchase and maintain any certified or conditionally
approved voting system or part of a voting system;
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e) California receives the benefits of the publicly funded
development of a nonproprietary voting system in the state;
and,
f) A local jurisdiction may use available public funds to
research and develop a nonproprietary voting system that
uses disclosed source codes, including the manufacture of a
limited number of voting system units, for use in a pilot
program or for submission to the SOS for certification.
2)Recasts and revises various procedures and criteria for the
SOS's approval of voting systems by changing the term
"approval" to the term "certification" and authorizes the SOS
to certify, conditionally approve, or withhold approval of a
voting system.
3)Clarifies that the SOS is responsible for certifying voting
systems for use in this state.
4)Requires the SOS to adopt and publish voting system standards
and regulations governing the use of voting systems. Requires
the standards to meet or exceed federal voluntary voting
system guidelines set forth by the EAC or its successor
agency. Provides that until state standards are adopted,
Voluntary Voting System Guidelines Draft Version 1.1, as
submitted to the EAC on August 31, 2012 shall be used as state
standards to the extent that they do not conflict with the
provisions of this bill. Permits the SOS to require
additional testing to ensure that voting systems meet the
requirements of this code. Requires voting system standards
adopted by the SOS to include, but not be limited to, all of
the following requirements:
a) The machine or device and its software shall be suitable
for the purpose for which it is intended;
b) The system shall preserve the secrecy of the ballot;
c) The system shall be safe from fraud or manipulation;
d) The system shall be accessible to voters with
disabilities pursuant to existing law and; and,
e) The system shall be accessible to voters who require
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assistance in a language other than English if the language
is one in which a ballot or ballot materials are required
to be made available to voters pursuant to existing law.
5)Requires the SOS to study the performance of voting systems in
use in the state.
6)Provides that any voting system that has been tested and
approved for use in all elections by the SOS before January 1,
2014, shall be deemed certified or conditionally approved by
the SOS and may be used in an election subject to any
conditions placed on the use of the voting system by the SOS
before January 1, 2014, including conditions imposed in the
reapproval documents issued by the SOS in 2007 and 2008
following the Top-to-Bottom Review, and its subsequent
revisions. Requires the voting systems described above to
remain subject to review and decertification by the SOS at any
time.
7)Provides that any vendor or county that has submitted a voting
system for federal qualification before August 1, 2013, upon
obtaining federal qualification before January 1, 2015, may
request approval of the voting system from the SOS based upon
examination and review requirements in place prior to January
1, 2014.
8)Prohibits a jurisdiction from purchasing or contracting for a
voting system unless it has been certified or conditionally
approved by the SOS. Permits a local jurisdiction,
notwithstanding the above restriction, to contract and pay for
the following:
a) Research and development of a new voting system that has
not been certified or conditionally approved by the SOS and
uses only nonproprietary software and firmware with
disclosed source code, except for unmodified commercial
off-the-shelf software and firmware, as defined; or,
b) Manufacture of the minimum number of voting system units
reasonably necessary for either of the following purposes:
i) To test and seek certification or conditional
approval of the voting system; or,
ii) To test and demonstrate the capabilities of the
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voting system in a pilot program as specified.
9)Permits the SOS to grant conditional approval to a voting
system or part of a voting system under either of the
following circumstances:
a) A voting system or part of a voting system was
decertified as a result of a review by the SOS; or,
b) A certified voting system or part of that voting system
is modified to comply with voting system standards or
changes in statute.
10)Permits the SOS to withdraw conditional approval of a voting
system at any time, as specified.
11)Repeals a requirement for the SOS to notify the EAC or its
successor of a defect, fault, or failure of voting system, as
specified.
12)Repeals provisions of law that permits the SOS to employ
three expert technicians to examine a voting system, and
instead requires the SOS to use a state-approved testing
agency, as defined, or expert technicians, to examine and test
voting systems or parts of voting systems proposed for use or
sale in the state.
13)Requires the SOS to publish and make publicly available on
his or her Internet Web site a quarterly report of regulatory
activities related to voting systems.
14)Requires the SOS, prior to publishing a decision to certify,
conditionally approve, or withhold certification of a voting
system, to provide for a 30-day public review period and
conduct a public hearing. Requires the SOS to provide notice
of the hearing on his or her Internet Web site. Requires the
SOS to provide written notice of the hearing at least 14 days,
instead of 30 days, prior to the public review period and
hearing, as specified.
15)Requires the SOS to make publically available a report
stating whether a voting system has been certified,
conditionally approved, or withheld, within in 60 days,
instead of 30 days, after the completion of the examination.
Requires the SOS, within 10 days after issuing the above
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report, to make available to the public a full and complete
copy of the certification report and all associated
documentation. Prohibits portions of the report or
documentation that contain information that the SOS determines
to be confidential or proprietary from being made publically
available.
16)Defines the following terms for purposes of this bill:
a) "Commercial off-the-shelf" to mean mass-produced,
readily available hardware devices, including card readers,
printers, or personal computers, and their firmware or
software products, including operating systems, programming
language compilers, or database management systems;
b) "Incorrect in part" to mean a full manual tally of the
votes cast on the pilot system would reveal rates of error
in the pilot system tally that, if extrapolated to the
entire contest, would alter the electoral outcome;
c) "Partial risk-limiting audit" to mean a procedure that
guarantees a large minimum chance of a full manual tally of
the votes cast on the pilot system if the electoral outcome
is incorrect in part; and,
d) "Risk-limiting audit" to mean a procedure that ensures a
large, predetermined minimum chance of requiring a full
manual tally whenever a full manual tally would show an
electoral outcome that differs from the outcome reported by
the voting system for the audited contest.
17)Authorizes a governing board, without formally adopting a
voting system, to provide for the experimental use of a voting
system in a pilot program held in one or more precincts at a
single election or, in the case of a special election, the
special primary election and the special general election, if
the voting system complies with either of the following:
a) The voting system is certified or conditionally approved
prior to its experimental use; or,
b) The voting system meets all of the following
requirements:
i) Uses only software and firmware with disclosed
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source code, except for unmodified commercial
off-the-shelf software and firmware;
ii) Meets the requirements set forth in the SOS's voting
system standards and regulations governing the use of a
voting system, as specified;
iii) Meets the requirements set forth in pilot program
regulations adopted by the SOS pursuant to this bill;
and,
iv) Implements risk-limiting audits.
18)Provides that a voting system that meets all of the
requirements above does not need to be certified or
conditionally approved prior to its experimental use in a
pilot program if the number of voting system units deployed in
the pilot program is limited to the number necessary to test
and demonstrate the capabilities of the voting system in a
limited number of precincts of locations, including a prudent
number of reserve units to ensure that sufficient working
units will be available to conduct the pilot program.
Provides that in no event shall the number of voting system
units exceed 50 percent of the estimated number of units that
would be required for full deployment of the voting system at
every polling place and early voting site in a statewide
election throughout the jurisdiction. Provides that the
capabilities that may be taken into account in determining the
number of voting system units include, but are not limited to,
all the following:
a) The capability of the voting system to accommodate
voting in all languages in which the jurisdiction is
required to provide ballots, as required by state and
federal laws;
b) The capability of the voting system to accommodate
voting by persons with a broad range of physical and
cognitive disabilities, as required by state and federal
laws;
c) The current and projected number of voting-eligible
individuals in the jurisdiction; and,
d) The geography and distribution of the population in the
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jurisdiction.
19)Requires a governing board, no later than nine months before
the election at which the pilot program of a voting system is
proposed to be conducted, to submit a plan for the pilot
program to the SOS. Requires the SOS to approve or reject the
plan no later than three months after receipt of the plan.
20)Requires votes cast on the voting system during the pilot
program to be subject to risk limiting audits. Requires the
jurisdiction conducting the pilot program, for each contest
conducted entirely on the pilot voting system, to conduct
risk-limiting audits with at least a 90 percent chance of
requiring a full manual tally of the contest whenever a full
manual tally would show an outcome that differs from the
outcome reported by the pilot voting system. Requires the
jurisdiction conducting the pilot program, for each contest
partially on the pilot voting system, to conduct a partial
risk-limiting audit of the portion of the contest in which the
voters cast their votes on the pilot voting system, with at
least 90 percent chance of requiring a full manual tally of
all votes cast using the pilot voting system whenever the
outcome is incorrect in part. Provides that if a
risk-limiting audit of a contest leads to a full manual tally
of all of the ballots cast in the contest, then the contest
outcome according to that manual tally shall become the
official result. Provides that if a partial risk-limiting
audit of a contest leads to a full manual tally of the ballots
cast using the pilot voting system, the vote counts according
to that manual tally shall replace the vote counts reported by
the pilot voting system for the purpose of determining the
official contest results. Requires risk-limiting audit
procedures to comply with all other requirements in
regulations adopted by the SOS.
21)Requires the governing board, upon completion of the pilot
program, to notify the SOS in writing of any defect, fault, or
failure of the hardware, software, or firmware of the voting
system or a part of the voting system. Prohibits a voting
system pilot program from being conducted in a legally binding
election without prior the approval of the SOS. Requires the
SOS to adopt and publish regulations governing voting system
pilot programs.
22) Defines "state-approved testing agency," for the purposes of
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this bill, to mean a person or entity that is authorized by
the SOS to conduct the testing and examination of a voting
system in connection with certification or conditional
approval of the voting system pursuant to this bill.
23)Requires the SOS to do the following:
a) Publish requirements for the approval of state-approved
testing agencies that are authorized to conduct the testing
and examination of voting systems. Provides that until
requirements are published, federally accredited voting
system laboratories shall be used to conduct testing and
examination; and,
b) Approve and publish a list of authorized state-approved
testing agencies.
24)Provides that a person, corporation, or public agency
applying for certification of a voting system is responsible
for all costs associated with the testing of the voting
system.
25)Permits the SOS to contract with one or more expert
technicians to assist with the certification of a voting
system, including testing and examination of the voting
system.
26)Deletes outdated intent language pertaining to voters with
visual disabilities and instead provides that it is the intent
of the Legislature that California voting system standards and
elections comply with the provisions of the federal Help
America Vote Act of 2002 (HAVA) that require voting systems be
accessible for individuals with disabilities, including
nonvisual accessibility for the blind and visually impaired,
in a manner that provides the same opportunity for access and
participation, including privacy and independence, as provided
to other voters who are not disabled.
27)Authorizes Voting Modernization Fund monies to be used to
purchase systems certified or conditionally approved by the
SOS, instead of only systems certified by the SOS. Permits a
county to use fund moneys to contract and pay for the
following:
a) Research and development of a new voting system that has
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not been certified or conditionally approved by the SOS and
uses only nonproprietary software and firmware with
disclosed source code, except for unmodified commercial
off-the-shelf software and firmware, as defined;
b) Manufacture of the minimum number of voting system units
reasonably necessary for either of the following purposes:
i) To test and seek certification of conditional
approval for the voting system pursuant to the provisions
of this bill; or,
ii) To test and demonstrate the capabilities of the
voting system in a pilot program pursuant to this bill.
28)Makes technical and conforming changes for ballot marking
systems.
29)Makes other technical and conforming changes.
EXISTING LAW :
1)Defines a "voting system" as any mechanical,
electromechanical, or electronic system and its software, or
any combination of these used to cast or tabulate votes, or
both.
2)Requires the SOS to study and adopt regulations and
specifications governing the use of voting machines, voting
devices, vote tabulating devices, and ballot marking systems
and any software used for each, including the programs and
procedures for vote tabulating and testing. Requires the
criteria for establishing the specifications and regulations
to include, but not be limited to, the following:
a) Requires the machine or device, and its software, to be
suitable for the purpose for which it is intended;
b) Requires the system to preserve the secrecy of the
ballot; and,
c) Requires the system to be safe from fraud or
manipulation.
3)Prohibits a voting system, in whole or in part, from being
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used unless it has received the approval of the SOS prior to
any election at which it is to be first used.
4)Prohibits a jurisdiction from purchasing or contracting for a
voting system, in whole or in part, unless it has received the
approval of the SOS.
5)Permits a person or corporation owning or being interested in
a voting system or a part of a voting system to apply to the
SOS to examine it and report on its accuracy and efficiency to
fulfill its purpose.
FISCAL EFFECT : Unknown
COMMENTS :
1)Purpose of the Bill : According to the author:
California has long been a leader in expanding voter access
and participation as well as ensuring the transparency and
integrity of elections.
Transparency of the voting process is important for the
public's ability to verify and trust election outcomes. And
this trust rests in the systems and machines we use to cast
and count votes.
In California, voting systems are a patchwork of different
technologies that are developed, leased and sold to 58
counties by half a dozen different vendors. Counties only
partially own their systems which limits access and
transparency of the hardware and software. Election
equipment is subject to licensing agreements, which means
counties must hire the vendor for repairs and maintenance.
Just as we can't repair our home computers without breaking
the warranty, counties can't repair their own voting
systems. Voting system vendors change ownership and can
even go out of business leaving counties without election
support. Vendors can also [have] conflicts of interest in
an election their systems administer.
I have introduced SB 360 to ensure the public can own their
vote and have full access to every part of their voting
system. We trust election officials to conduct our
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elections, we should trust them to create and maintain our
voting systems.
SB 360 will allow counties to develop and own voting
systems that meet federal and state standards and are
certified by the Secretary of State. SB 360 maintains
current standards that voting systems:
" Produce an auditable paper trail.
" Allow access for voters with special needs.
" Require a full public review before
certification a voting system.
One of the driving forces behind the public ownership of
voting systems is the Los Angeles County
Registrar-Recorder/County Clerk. L.A. County is the most
populated and geographically expansive county in the U.S.
and the most complex election jurisdiction in the nation.
The county has 10 million residents spread across 4,000
square miles and over 500 elected offices. The County is in
the process of developing a voting system that meets their
unique needs. The development of the system has been open,
transparent, and included many political stakeholders,
including political parties and election protection
advocates.
1)United States Election Assistance Commission : In 2002, the
EAC was established by HAVA to serve as an independent,
bipartisan commission responsible for developing guidance to
meet HAVA requirements, and to accredit testing laboratories
and certify voting systems, as well as audit the use of HAVA
funds. However, the EAC has been without a quorum of
commissioners since 2011. In addition, there are three bills
pending in the House of Representatives which eliminate the
EAC altogether.
On November 19, 2012, United States Senator Barbara Boxer sent a
letter to congressional leaders calling for the appointment of
EAC Commissioners. Her letter states, "The EAC, which
currently has no commissioners and no executive director, has
not held a public meeting since 2011. Staff members have
continued to perform the day-to-day functions of the EAC, but
without Senate-confirmed leaders, the Commission can do
nothing of importance." As a result, the EAC is currently
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unable to approve new voting systems in a timely manner.
2)Voting System Review Process : Current law requires a voting
system and any modification to a voting system to be approved
by the SOS before it can be used in any election.
Additionally, electronic voting systems must be certified at
the federal level by the EAC before they can be submitted to
the SOS's office for review. When a voting system is brought
to California for review, the SOS conducts a thorough
examination and review of the proposed system that includes: a
review of the application and documentation, end-to-end
functional examination and testing, volume testing under
election-like conditions of all voting devices used by the
voter, security testing that includes a full source code
review and penetration testing, accessibility examination and
testing, a public hearing, and public comment period. The
SOS's review process is designed to augment, not duplicate,
the EAC review and approval process.
This bill, which removes the federal pre-certification or
qualification requirement, makes a significant policy change
to California's voting system review process. This bill
allows a person, corporation or county owning or having
interest in the sale or acquisition of a voting system to
bypass federal review and approval and instead only seek
certification or conditional approval from the SOS.
Proponents argue that due to uncertainty about the operations
of the EAC, it may be some time before the federal review and
approval processes resume and new guidelines are adopted.
Consequently, jurisdictions seeking to replace their voting
system with a new system are stalled. Furthermore, voting
system vendors may be reluctant to build new systems because
there is uncertainty as to when new standards will be adopted.
In addition, while the state testing process is designed to
complement, not duplicate the EAC testing, proponents argue
that California's testing, which includes penetration testing
and volume testing, is more stringent and goes beyond federal
testing.
Others argue that while the federal testing requirements may
not be as robust as California's requirements, they do have
value. According to Verified Voting's June 2013 report,
"Changes Ahead: A Look at Voting System Testing and
Certification," federal testing and certification programs
enable states to know that a voting system with federal
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certification has met certain requirements before being
submitted to state testing, acceptance and deployment. In
addition, the EAC program requires that testing laboratories
be inspected and meet certain conditions to be accredited and
ensures transparency by posting online test plans and test
result reports which is useful information for stakeholders
interested in voting system technology.
In an effort to retain the federal testing and approval
processes, this bill requires the SOS to adopt and publish
voting system standards and regulations governing the use of
voting systems that meet or exceed federal voluntary voting
system guidelines set forth by the EAC or its successor.
Furthermore, the bill requires the state to use the latest
updated EAC guidelines until state standards are adopted.
3)Voting Modernization Bond Fund : In September 2001, AB 56
(Shelley), Chapter 902, Statutes of 2001, also known as the
Voting Modernization Bond Act of 2002, provided $200 million
in state bond funds to help counties pay for new voting
equipment and established a Voting Modernization Board to
carry out this task. Governor Gray Davis signed the bill and
AB 56 became Proposition 41 and was placed on the March 2002
ballot. Voters approved Proposition 41 with a 52 percent vote
in favor of the measure. However, the text of Proposition 41
states that, "Fund money shall only be used to purchase
systems certified by the Secretary of State" and that counties
receiving funds must match "fund moneys at a ratio of one
dollar of county moneys for every three dollars of fund
moneys."
At the federal level, Congress passed and President George W.
Bush signed HAVA. Among its provisions, HAVA provided federal
matching grants to states to help pay for modernizing voting
equipment.
In April 2003, California received $265 million in HAVA funds;
including $75 million for new voting equipment and $40 million
for a new statewide voter database. These voting equipment
funds were distributed to each county beginning in 2004.
California counties were then authorized to purchase a new
voting system. Nearly all California counties purchased their
voting systems from five different vendors. The vendors
offered a variety of systems and upgrades resulting in a
patchwork of technologies throughout California.
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As mentioned above, current law only authorizes Voter
Modernization Bond funds to be used to purchase voting systems
certified by the SOS. This bill makes a significant change to
policies that were approved by voters. The bill authorizes
fund monies to be used to purchase voting systems that are
conditionally approved by the SOS and allows a county to use
fund monies to contract and pay for the research and
development of a new nonproprietary voting system that uses
disclosed source code and has not been certified or
conditionally approved by the SOS. In addition, this bill
permits a county to use public funds to manufacture a limited
number of voting system units that are reasonably necessary to
test and seek certification or conditional approval as well as
test and demonstrate the capabilities of the voting system in
a pilot program, as specified. These policy changes are
significant departures from how fund monies have been used in
the past.
Proponents of the bill argue that county voting systems in
California are aging rapidly and the process for approving
voting systems is doing little to help approve new innovative
systems or spur new approaches to voting system development.
This bill, which allows counties to use public funds to own,
develop, and operate a voting system will ensure counties have
the opportunity to be innovative and create systems that will
meet the needs of their jurisdiction while being transparent
and open to the public.
4)Los Angeles County Voting Systems Assessment Project (VSAP) :
Due to Los Angeles County's size, diversity, complexity, and
the limited voting systems market, it is extremely challenging
for Los Angeles to reasonably consider a commercial
off-the-shelf voting system. Consequently, in 2009, the Los
Angeles County Registrar-Recorder/County Clerk (RR/CC)
launched the VSAP in response to the growing voting system
needs and challenges faced by Los Angeles County. According
to VSAP background documents, the vision of the VSAP is to
identify and implement a new voting system in a transparent
and participatory manner that takes into account the needs and
expectations of current and future Los Angeles County voters.
VSAP background documents state that a VSAP Advisory Committee
was established in response to a motion adopted by the Los
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Angeles County Board of Supervisors in September of 2010,
establishing a more participatory approach to the acquisition
and implementation of a new county voting system. The
Committee provides a formal platform for continued citizen
participation and transparency. The purpose of the Committee
is to help analyze and comment on the project's initial
research findings and to provide the RR/CC input and guidance
for the establishment of principles and general requirements
of a voting system and for the development of acquisition
models the County intends to employ. The Committee is
composed of a group of sixteen members representing experts,
stakeholders, and community leaders from critical constituency
groups and communities of interest, including voters with
disabilities, language minority groups and ethnic minorities.
Also represented are critical stakeholders such as local
election officials, political parties, and academic
institutions.
The VSAP is noteworthy because it is attempting to first define
the kind of voting system it wants and then to be directly
involved in the system's development. The VSAP process that
the RR/CC is proceeding with could make Los Angeles the first
county in the United States to develop, operate, and own its
voting system.
5)New Voting System Pilot Program : Current law permits a
governing board to provide for the experimental use of a
voting system at an election in one more precincts. This
allows a county the ability to test the fit of a certified
voting system before committing to the full purchase of such a
system. This bill expands on that premise and establishes a
pilot program which allows a governing board, without formally
adopting a voting system, the experimental use of a voting
system in a pilot program held in one or more precincts at a
single election, as specified. To ensure the security and
integrity of the pilot program, the bill sets up two paths by
which the pilot program may work. First, a jurisdiction may
use a voting system that is certified or conditionally
approved prior to its experimental use. The second option
allows a jurisdiction to use a voting system that is not
certified or conditionally approved if certain requirements
are met. For example, the bill requires the system to use
only software and firmware with disclosed source code, as
specified. In addition, the bill requires the system to meet
all the SOS's voting system guidelines and regulations,
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including federal guidelines, to implement risk limiting
audits, as defined, and limit the number of units used in the
pilot to the number necessary to test and demonstrate the
capabilities of the voting system in a limited number of
precincts or locations, as specified. Furthermore, the bill
requires the governing board to submit a plan of the pilot
program to the SOS for approval. These strict requirements
will ensure the integrity and transparency of the pilot
program.
The limited scope of any pilot programs will not only ensure the
integrity and transparency of such pilot programs, but is will
also provide some much needed flexibility and innovation into
voting system development.
6)Arguments in Support : VerifiedVoting.org writes in support:
Thirty-five states involve federal testing and /or
standards at some level. Federal standards can thus set a
floor to which most states have a relationship, even if
those states do not require federal certification.
California supplements federal standards testing with state
testing that actually exceeds much of what is done in other
states around the country. We examine source code for
security purposes, and we conduct penetration testing to
identify security vulnerabilities. We also do volume
testing under election-like conditions to ensure systems
perform in real-world conditions. And we go beyond the
current federal requirements to test for voting system
accessibility.
In that respect, we already lead in this arena, but we are
stymied by the fact that our standards for testing no
longer can be improved because the federal agency that
approves those standards lacks the necessary quorum to do
so. This means states like California become increasingly
limited in the choices available to them in the current
voting system marketplace, and vendors, uncertain about
whether or when a new iteration of the standards will be
adopted, do not know what to design to.
If we can establish our own standards, and govern the
testing process for ourselves, we can enable better systems
as we move forward. With our own standards, California can
lead the shift to requiring common data format in voting
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system design: a real game-changer for better systems in
future, improving post-election auditing and statistical
analysis of elections, as well as enabling component-based
systems that are more flexible and less costly.
REGISTERED SUPPORT / OPPOSITION :
Support
Los Angeles County Board of Supervisors (Sponsor)
California Association of Clerks and Election Officials
California Common Cause
California Forward Action Fund
California State Association of Counties
California State Council of the Service Employees International
Union
National Association of Latino Elected and Appointed Officials
Educational Fund
PowerPAC.org
Secretary of State Debra Bowen
VerifiedVoting.Org
Opposition
Santa Monica Democratic Club
Analysis Prepared by : Nichole Becker / E. & R. / (916)
319-2094