VVSG 2.0: VotingWorks’s Written Feedback to the EAC

June 23, 2020 — Ben Adida

The Election Assistance Commission is the federal agency responsible for the Voluntary Voting Systems Guidelines (VVSG), which define the certification process for election equipment in the United States. A few weeks ago, we were invited to comment at a live hearing of the EAC on the VVSG 2.0, the latest version of these requirements currently under consideration. This week, we’ve submitted our full written comments (regulations.gov, direct PDF) about these specifications.

Our introduction is quoted here:

June 22nd, 2020

Dear EAC Commissioners & Staff,

Please find, attached, our comments on the VVSG 2.0 Requirements.

As we all know, each certification requirement raises the bar to produce a compliant voting system. Most of the time, that’s exactly right: there should be a high bar for the systems that safeguard our democracy. Sometimes, though, a requirement imposes a burden without a corresponding benefit. Especially where requirements with no clear benefit impact the usability, affordability, or security of the system, we argue that the requirement should be changed or removed. Affordability of voting equipment should be a major goal of the VVSG, as it is a major consideration for election officials. Each requirement’s burden should be weighed against its benefit.

To that end, we’ve provided feedback in three categories:

  1. Promoting innovation and competition – the VVSG should promote competition and innovation, producing a dynamic market of vendors working to produce the best possible system at the best possible price. This benefits jurisdictions and voters.

  2. Goal-driven requirements – the VVSG requirements should be driven by goals, not by specific implementation choices that meet those goals in a particular way. This is important for flexibility, innovation, and future-proofing of the requirements.

  3. Modern requirements – the VVSG requirements should be pruned of carry-over requirements from prior versions of the VVSG that are outdated. Software development methods have evolved significantly in the last 15 years, and some requirements are carried over from that long ago.

We hope this feedback is helpful, and we welcome any further discussion, of course.

Sincerely,

Ben Adida, PhD
Executive Director
VotingWorks