Comments to Election Assistance Commission on the Voluntary Voting System Guidelines (VVSG)
Submitted September 30, 2005.
Please cite this document as follows:
Vanderheiden, G. (2005). Comments to Election Assistance Commission on the Voluntary Voting System Guidelines (VVSG). (Available at http://guidelines.kennesaw.edu/vvsg (p/intro.asp.)
BACKGROUND
These comments are submitted on the behalf of the Trace Research and Development Center at the University of Wisconsin in Madison. The Trace Center is the rehabilitation and engineering research center funded by the National Institute on Disability and Rehabilitation Research, US Department of Education, to carry out research in the area of accessible information technologies. The Trace Center has participated directly in the Access Board's Electronic and Information Technology Advisory Committee and the IEEE Voting Standards activities, as well as providing input to the Federal Election Commission in its past efforts up to date. Features developed at the Trace Center are incorporated into both the Windows and Macintosh operating systems as well as accessible voting systems in the field today.
COMMENTS
We would like to applaud the Commission in moving the standards forward. We would also like to commend the inclusion of many features in all voting stations which would maximize their use by individuals who have functional limitations. With an aging America it is increasingly important that the mainstream voting stations (where most older voters cast their vote) be easily usable by individuals with limitations that come with aging. The inclusion of larger fonts, straight forward layouts, and such features as a part of all voting systems is an important step toward accurate and reliable voting which in fact captures the voter's intent. To these we would like to add one additional and that would be a new provision for audio confirmation of the vote. This would require that all electronic voting systems provide the option of donning a pair of headsets and having votes confirmed as they are pressed. This measure would greatly reduce the number of mis-selections that would go undetected. This would also be useful to individuals who for any reason confused by the ballot layout, options, pronunciation of names, etc.
Specific comments on provision are as follows.
Regarding (2.2.7.1) 2.1.4 –
An Acc-VS and any voting station with a black-and- white-only electronic image display shall be capable of showing all information in high contrast either by default or under the control of the voter or poll worker. High contrast is a figure-to-ground ambient contrast ratio for text and informational graphics of at least 6:1.
RECOMMENDATION:
Use the term "monochrome" instead of "black and white only."
Regarding (2.2.7.1) 2.1.8 -
Buttons and controls on Acc-VS should be distinguishable by both shape and color.
COMMENT:
This guideline is confusing as to intent. It sounds like users should be able to figure out what the meanings are by shape or color or it means that the shape should be unique for each key. If the device includes a keyboard, does that mean that each key has to be a different shape? Even for a smaller button raise trying to have a different button shape for each key may be somewhat confusing. Position is often as salient as shape. It is good to use shape and color, but to require that they all have different shape and color.
RECOMMENDATION:
Change to (2.2.7.1.) 2.1.8 to: "Shape, color, and position should be used to make it easy for voters to find, remember, and re-find buttons and controls."
Regarding (2.2.7.1) 2.1.9 –
Any voting station using an electronic image display shall provide synchronized audio output to convey the same information as that which would be displayed on the screen.
COMMENT:
This is a good guideline.
RECOMMENDATION:
The discussion is to be extended somewhat to read: "The redundant cues are helpful to those with low vision. They are also helpful to individuals who may have difficulty reading the text on the screen for any other reason as well as individuals who may not be able to realize ethnic names when printed if they have only heard them pronounced in the past. The ability to have any text selected by the user read individually while the voter is on a page would constitute synchronized presentation if the page title/contents were announced when it appeared and the method for reading text was described to the voter."
Regarding (2.2.7.1) 2.2.3.4 –
A sanitized headphone or handset should be made to each voter.
COMMENT:
It is not clear from this guideline whether the intention is that should relates to providing a sanitized headset or whether it refers to providing any headset at all. There is no other guideline requiring that a headset or handset be available. If it is the intent that the headset should be available, then one of the provisions (or a new provision) should state that a headset or handset should be provided to each voter as part of each accessible voting station.
RECOMMENDATION:
Clarify intention and add guideline if appropriate.
Regarding (2.2.7.1) 3.4 –
The Acc-VS should provide a mechanism to enable non-manual input that is functionally equivalent to tactile input
COMMENT:
The discussion adds a requirement that is not reflected in any requirement.
RECOMMENDATION:
Suggest that a new guideline be added:
"If alternate voting mechanisms are provided, they shall provide full access to the voting process including all voting functions and options available in the primary mode."
Regarding (2.2.7.1) 2.2.2 –
The Acc-VS shall provide an audio-tactile interface (ATI) that supports the full functionality of a normal ballot interface, as specified in Section 2.4.
RECOMMENDATION:
In the list, the following bullets should be added:
- "Any status or warnings provided to voters"
Regarding (2.2.7.1) 2.2.3.9 –
The audio system should allow voters to control, within reasonable limits, the rate of speech.
COMMENT:
It might useful to get some idea for the range of reading speeds that people who are blind read at.
Regarding (2.2.7.1) 2.2.3 –
All voting stations that provide audio presentation of the ballot shall conform to the following sub-requirements.
COMMENT:
In this provision you have a shall with should underneath it, making it slightly ambiguous.
RECOMMENDATION:
You can use the strategy you used on 4.2.2 and word 2.2.3 to say: "For all voting stations that provide audio presentation of the ballot, the following sub requirements apply."
Regarding (2.2.7.1) 2.2.2.3 –
The ATI shall allow the voter to pause and resume the audio presentation.
COMMENT:
Occasionally audio cues are given. Providing controls on the these short messages would be confusing. Being able to stop them or replay them should be sufficient.
RECOMMENDATION:
Add to discussion: "Stop and replay would be sufficient for audio presentations that are less than 15 seconds."
New Guideline with "discussion" note (2.2.7.1) 2.1.10
RECOMMENDATION:
Add a new guideline at position (2.2.7.1) 2.1.10: "Any voting stations that electronically determine the users vote shall provide audio confirmation of the ballot choices."
New Note: Many individuals can use the standard voting systems, but their operation or font sizes are at the edge of their vision. Particularly, older individuals would benefit from this feature which provides an option of having the choice they have just made read back to them in their headphones, thus avoiding wrong ballot choices of which they are unaware.
Respectfully submitted,
Gregg C. Vanderheiden Ph.D.
Professor, Director
Trace R&D Center
University of Wisconsin- Madison