Comment by U.S. Public Policy Committee of the Association for Computing Machinery (USACM) (None)

Software Independence We have mentioned our support for the principle of software independence described in the VVSG. We include with our comments the letter [1] we sent to the then-Chairman of the TGDC, Dr. William Jeffrey, expressing our support for Software Independence and other recommendations made to the TGDC. Given the shortfalls of security testing, it is our long-standing belief that voting systems should also enable each voter to inspect a physical (e.g., paper) record to verify that his or her vote has been accurately cast and to serve as an independent check on the result produced and stored by the system. We are pleased that the TGDC recommends that voting systems must have an independent way of verifying a voter’s selections. An important part of ensuring a software independent system is developing both an effective test and definition for determining software independence. We find both lacking in this version of the VVSG. We recommend that you define software independence as meaning that an error or fault in the voting system’s software is not capable of causing an undetectable change in election results. This will help provides state and local elections officials, as well as vendors, with the knowledge they need to help ensure that their systems are software independent. Without a specific test or a more specific definition, other groups will object to the principle on the grounds that the concept is too vague and indistinct to be effectively implemented. Given that many states currently do not conduct effective post-election audits, there is a need for software independence, together with clear guidance as to what makes a voting system software independent.. We recommend you include in the VVSG a process akin to the hypothetical example we outline in Appendix B — a process that demonstrates both the production of Independent Voter Verifiable Records and Software Independence. [1] http://usacm.acm.org/usacm/PDF/USACMCommentsSTSPaper.pdf