The NY State Board of Elections has put out draft standards for testing voting machines, developing security procedures, and interpreting the votes on paper ballots.
http://www.elections.state.ny.us/NYSBOE/hava/6210DRAFTRegs.pdf

The draft, with my written comments embedded, is posted at
http://www.wheresthepaper.org/6210cmt.htm

It is time for everyone to send an email, fax, or paper letter to the State Board to recommend changes.

Peter S. Kosinski, Co-Executive Director
Stanley L. Zalen, Co-Executive Director
Commissioner Evelyn J. Aquila
Commissioner Helena Moses Donohue
Commissioner Neil W. Kelleher, Co-Chair
Commissioner Douglas A. Kellner, Co-Chair
New York State Board of Elections
40 Steuben Street
Albany, New York 12207

Dear Members of the State Board of Elections:

I urge you to make the following changes in the draft regulations for Part 6210, "Routine Maintenance and Testing of Voting Systems and Operational Procedures."

1. Visual illustrations should accompany the verbal descriptions of how paper ballots can be marked and how to interpret the marks.

2. Procedures for security and other purposes should not be delegated to county boards, but should be developed by experts under contract to the State Board.

3. Any models or diagrams used in pollsites to show voters how to use new equipment must be required to show how to locate and verify the voter-verifiable paper audit record of DREs, and how to locate and use the override button of Optical Scanners that voters can use to cause their ballot to be accepted even though it has overvotes or undervotes.

4.The regulations should require the choice "None of the above" in all contests, so that paper ballots need not contain undervotes if voters do not wish to vote for a candidate in a contest.

5. The use of system logs for pre- and post-election testing should be specified, as well as the use of system logs in investigation of discrepancies found during audits.

6. The regulations should require the use of cameras to record the keyboard, mouse, and display screen when the EMS (Election Management System) and all other equipment is used or subject to maintenance in the county board or its storage facility.

7. County boards must be accountable to the public, so the role of the public should be specified in the regulations, including the right of citizens to:
**participate by observing all procedures;
**easily obtain information about audits including when and where the random selection of machines and the audit itself will take place and all reports created.

8. Even simple security breaches, such as the compromising of a single password, can result in tampering that changes the outcome of all contests in an election within the county. When security breaches occur, the regulations should require county boards of elections to request assistance of law enforcement authorities to investigate.

Sincerely yours,