Association of Assistive Technology Act Programs (ATAP)

Vote-PAD Accessibility Summary

The Help America Vote Act (HAVA) requires one accessible voting machine per polling place. To make voting accessible for a reasonable range of individuals with disabilities (vision, motor, hearing, combination of vision and hearing, and learning/cognitive) augmented and alternative options must be available to enable voters with disabilities to ---

 receive ballot information     mark the ballot     review the marked ballot     and cast the official ballot

The term “augmented” means that the media/form is enhanced to enable access, for example standard print is enlarged or regular volume is amplified. The term “alternative” means the media/form is converted from something inaccessible for individuals with certain types of disabilities to something accessible. Examples would be converting print to speech for individuals who are blind and converting manual markings (by pencil/pen) to markings generated using switch input, software, and electronic marking for individuals with motor disabilities.

The following specific standards ensure a reasonable range of augmented and alternative access is available to voters with disabilities. The Federal Election Commission (FEC) Guidelines of 2002 and the Election Assistance Commission (EAC) Voluntary Voting System Guidelines (VVSG) of 2005 requirements are referenced. Specific conformance of the Vote-PAD to these access standards is described in detail.

BALLOT OUTPUT All ballot information, initial interaction with the ballot and any ballot review of a marked ballot, must make available:

	Disabilities Addressed	Standards References	Vote-PAD Conformance
Standard print and large print with good contrast (figure/ground) and spacing	Vision Learning Cognitive	FEC 2.2.7.2 (e) VVSG 3.2.2.1 (b-d) VVSG 3.1.5 (d-i) VVSG 3.1.7 VVSG 3.1.5. (e)	No large print ballot for reading and marking is available. A separate large print version of the ballot content can be produced, but is not available for marking/casting a ballot. (Election officials could provide electronic enlarging devices to meet this requirement.)
Speech (audio output) that is synchronized with both the visual display (large print/regular) and the tactile input.	Vision Learning Cognitive	FEC 2.2.7.2 (b-d) VVSG 3.2.2.1 (f) VVSG 3.2.2.2 (b-c)	Speech output is not synchronized with the regular print ballot or the tactile input mechanism. Voters must align the speech output with their finger placement on the overlay for ballot marking. To review, voters must manually operate and listen to audiotape, identify and process tactile hand cues for ballot orientation, and position/manipulate a vibrating wand in conjunction with hand cues all manually coordinated with no built-in synchrony. If the ballot review for non-disabled voters includes automatic notification of over/under vote (e.g. via precinct counter), Vote-PAD provides no audio notification.
Speech (audio output) that allows the voter to repeat, pause/resume, skip to next or return to previous contests, skip reading of referendum, and adjust rate of speech from 75% to 200% of normal.	Vision Learning Cognitive	FEC 2.2.7.2 (b) VVSG 3.2.2.2 (b-c)	A commercially available analog tape player is used to deliver audio output. Digital content markers are not available to skip to next or return to previous contests or to skip referendum text reading. Rate of speech adjustment is available on the tape player but delivered adjustment rate is unknown for the source tape. For standard National Library System format tapes, speech adjustment available is –10% to 100%. These features are critical to voter efficiency in navigating through the ballot.
Speech (audio output) that has good intelligibility, with set initial and maximum volume, automatic volume reset to initial level, and prescribed frequency response to ensure speech intelligibility.	Vision Vision & hearing Learning Cognitive	FEC 2.2.7.2 (b) VVSG 3.2.2.2 (b-c) VVSG 3.1.5 (b-c)	Use of a commercially available analog tape player does not allow for verification that output conforms to required volume standards. Unknown frequency response of tape player with tone control that is voter manipulated makes it difficult to verify intelligibility of speech and impossible to ensure consistency of output. Volume control is manually operated by voter and does not automatically default to initial level (can only be done through software controls.)

BALLOT INPUT - All ballot manipulation, navigation/control, and marking must be available through:

	Disabilities Addressed	Standards References	Vote-PAD Conformance
Standard tactile controls and large buttons and controls identifiable by shape and color available for use with visual display output and audio output	Vision Mobility	FEC 2.2.7.2 (f) VVSG 3.2.2.1 (e) VVSG 3.2.2.2 (b-g) VVSG 3.2.3 b	Ballot manipulation, navigation of ballot contents, and ballot marking must all be done using voter dexterity skills, no large button/control mechanism is available. The ballot overlay provides limited “augmentation” for voters with somewhat reduced dexterity skills for ballot marking. It does not deliver alternative access in the form of tactilely discernable controls identifiable by shape and color.
Switch input used to control/navigate ballot information and mark ballot available for use with visual display output	Mobility	VVSG 3.2.3 (d)	No switch input is available to control and navigate through the ballot and to mark the ballot. Without switch input, a decreased range of voters with motor disabilities will be able to navigate and mark the ballot.
Controls are operable by an individual who is in a fixed seated position and one who has one hand (visual output)	Mobility	FEC 2.2.7.1 FEC 2.2.7.2 (f) VVSG 3.2.3 (b) VVSG 3.2.4	No controls are available for ballot navigation and marking. Without such controls a decreased range of voters with motor disabilities will be able to navigate and mark the ballot.
Mechanism for write in of text using tactile controls/buttons and review of write in available	Vision Mobility	FEC 2.2.7.2 (b) 3.2.2.2 (b)	No controls are available to write in text. Hand dexterity is needed to use the overlay and to tactilely recognize Braille or raised lettering (both are used by a limited portion of the visually impaired population). No review of write-in is available in audio or large print for visually impaired voters.

BALLOT CASTING - Ballot casting must be available through:

	Disabilities Addressed	Standards References	Vote-PAD Conformance
Some form of automatic or “hands-free” mechanism	Vision Mobility	VVSG 3.2.3 (e) VVSG 3.2.2.2 (e)	No automatic paper handling is available. Voters must have vision, dexterity and motor skills to cast paper ballot independently.

Summary

To meet the HAVA requirement of one accessible voting machine per polling place, the Department of Justice opined several times (e.g. letter to Texas, 5/20/03, letter to Mississippi, 3/4/05) that the FEC and VVSG standards “can be used to determine the accessibility of voting machines”. As a result, purchasing and deploying voting systems that conform to FEC 2002 or VVSG 2005 access standards would be one defendable way to meet HAVA requirements. At this time, the Vote-PAD has not been certified as meeting any set of accepted access standards and is unknown if it would withstand a legal challenge to meeting HAVA requirements for an accessible voting machine.

In general, the accessibility limitations of the Vote-PAD can be summarized as follows:

For individuals who are visually impaired and need large print output, those who need synchronized large print and audio output, and those who need navigation and marking via large print, the Vote-PAD offers no accessibility.

For individuals who have learning/cognitive disabilities and need large or regular print output, with an option of synchronized audio output, and ballot marking via large print, the Vote-PAD offers no accessibility.

For individuals who are blind and need audio output with integrated tactile ballot navigation and ballot marking capacity, the Vote-PAD requires exceedingly complex skills to operate a stand-alone tape recorder that is not integrated with the manual tactile overlay. Add to that a third vibrating wand element that must be coordinated with both the audio tape and the tactile overlay to review a marked ballot and the required skill set becomes even more demanding. Most individuals who have lost vision later in life, especially older individuals, will not be able to use this complicated arrangement. The Vote-PAD offers no accessibility features to enable individuals who are blind to independently cast their ballot when such casting involves depositing the ballot in a box at the polling place.

For individuals who are blind and have a hearing loss, the Vote-PAD provides limited standardization of audio output (volume and frequency response) necessary to ensure speech intelligibility and to protect against voters “inheriting” the volume of previous voters, which can cause hearing damage and create a significant liability risk for local jurisdictions.

For individuals with motor disabilities who need alternatives to manual manipulation, navigation, and marking of ballots, the Vote-PAD offers only an augmented mechanism of ballot marking (an overlay to keep the marks in a contained space.) No alternative access option such as switch input or other tactile control of a scanned ballot is available with the Vote-PAD providing no accessibility for many individuals with motor disabilities. The Vote-PAD offers no accessibility features to enable individuals who have significant motor disabilities to independently cast their ballot when such casting involves depositing the ballot in a box at the polling place.

Summary based on observation and demonstration of Vote-PAD system - June 14, 2006

Diane Cordry Golden, Ph.D.

Association of Assistive Technology Act Programs

dianegolden@sbcglobal.net

Under contract with:

National Disability Rights Network