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Comments on draft RFP 4717-06


Mr. Liss, Ms. Salas:
Please accept these slightly tardy comments regarding your draft RFP 4717-06, regarding voting systems. I encountered some difficulty with submitting them through the provided form on your web page, 

http://www.co.boulder.co.us/clerk/elections/_vti_bin/shtml.dll/RFP/471706.htm

I ask your forbearance and appreciate the consideration.


- Paul


To whom it may concern,

These comments pertain to the draft of RFP 4717-06 posted on Boulder
County's web site [1].  As a Boulder County election judge who served
in the 2004 general election, I appreciate the opportunity to comment
on the RFP before it is finalized.

These comments are, by necessity, brief, given the abbreviated time
available to inspect the draft; and are not a comprehensive review.


1. Boulder County's draft RFP unnecessarily restricts the types of
   voting systems that are considered acceptable responses.  The draft
   RFP requires responders to "provide proposals for both [optical
   scan/digital imaging and direct recording electronic (DRE)] voting
   methods." [2] There are other technologies, such as ballot-marking
   devices [3], that do not require a DRE component to serve disabled
   voters.  At least one of the ballot-marking system vendors is
   seeking or planning to seek certification in Colorado [4].  Boulder
   County should not refuse to receive proposals from vendors who may
   wish to take advantage of ballot-marking systems.  Similarly,
   Boulder County should not refuse to receive proposals that rely on
   hand-counted ballots, rather than computerized optical scanners.
   The sections of Boulder's draft RFP which artificially restrict the
   types of eligible voting systems should be removed.

2. Similarly, Section 8 of the draft RFP should not specifically
   address DRE systems, but should instead address any computerized or
   electromechanical ballot display and vote input system.  This is by
   similar reasoning as item one (above).

3. The technical requirements of the draft RFP are inadequate and
   are missing many crucial requirements.  A few examples:

   (a) Boulder County has been criticized for the delay in ballot
       counting in the 2004 general election.  Yet the draft
       apparently contains no performance requirements, apparently
       relying on the inadequate performance requirements of the
       Colorado Secretary of State's Rule 45 [5], [6].  The draft RFP
       should contain concrete performance criteria for Boulder
       County's voting system.

   (b) The draft RFP does not require voting systems to support
       independent audit processes which operate on live ballots
       during the actual election (see [7], [8], [9] as examples).
       These live audit processes are crucial to validate that the
       voting systems are working as specified, as current logic and
       accuracy test procedures only operate on test ballots.  Live
       audit processes were recommended for incorporation by the
       Boulder County Election Review Committee's final report [10].
       Boulder County should add requirements to the RFP to ensure
       that voting systems must support any live audit procedures that
       the County chooses to implement.

   (c) The draft RFP should require vendors to implement the federal
       Voluntary Voting System Guidelines [11] as mandatory requirements.
       While hardly ideal, these guidelines represent many 'best
       practice' guidelines that Boulder County should incorporate
       by reference as requirements into its own document.

4. The draft RFP prevents public inspection of some of the most
   crucial components of the voting system: its security requirements.
   As demonstrated over the past several years, the citizens of
   Boulder County have exercised crucial oversight over the County
   Clerk's voting system purchases.  Section 4.6.4(c) specifically
   restricts this crucial information from being available for public
   inspection.  This section is not referring to passwords or
   encryption keys that must remain private in order for the system to
   remain secure.  Rather, it pertains to the general security
   procedures and systems that must not rely on 'security through
   obscurity' - they must be reviewable by Boulder County's public.
   The draft RFP errs in including section 4.6.4(c) - it should be
   removed from the final RFP.



Sincerely,



Paul Walmsley
Boulder, Colo.



Footnotes:

1. RFP 4717-06 Draft (30 December 2005 19:58:54 GMT file modification
   date).
   http://www.co.boulder.co.us/clerk/elections/PDF/RFP%20DRAFT%20MASTER.pdf

2. ibid, page 5.

3. The ES&S AutoMark - http://www.automarkts.com/

4. 4 January 2006 private communication with Vogue Election Systems'
   eastern and central states sales representative.

5. Colorado Secretary of State Rule 45.
   http://www.sos.state.co.us/pubs/rule_making/rule_45_voting_standards.pdf

6. Walmsley, Paul.  Comments on Colorado Secretary of State Election Rule
   45 (Corrected), 29 October 2005.
   http://www.booyaka.com/~paul/ea/cosos-20051029/rule-45-comments-corrected.txt

7. http://www.booyaka.com/~paul/ea/eac-20050930/live-audit-overview.txt

8. http://www.booyaka.com/~paul/ea/eac-20050930/interpretation-live-audit.txt

9. http://www.booyaka.com/~paul/ea/eac-20050930/tabulation-live-audit.txt

10. Boulder County Election Review Committee final report.
    http://coloradovoter.net/ercdocs/ERCReportFinal.pdf

11. EAC 2005 Voluntary Voting System Guidelines.
    http://guidelines.kennesaw.edu/vvsg/intro.asp