Today ACCURATE submitted a public comment to the U.S. Election Assistance Commission (EAC) on the draft Voting System Testing & Certification Program (VSTCP) Manual. The Brennan Center for Justice at NYU School of Law, the Electronic Frontier Foundation, and the Verified Voting Foundation endorsed the comment.
The VSTCP Manual is an important document. When finalized, it will essentially be the rulebook that the EAC, vendors, and test labs will follow throughout the testing and certification process. The Manual also outlines the EAC’s approach to publishing testing- and certification-related information, as well as how and when the EAC will solicit information from the public. The Manual also acknowledges some of the critical purposes of the federal process: to support state and local election officials and to increase voter confidence.
Although, as ACCURATE’s comments acknowledge, the Manual takes some important steps toward serving these purposes—for example, the EAC will publish test reports (albeit after redacting trade secret and confidential information)—it doesn’t go far enough. In many places, it is unclear about whether the EAC will publish certain information at all. In others, the Manual seems to say that the EAC will give information only to certain individuals or groups, or that it will accept information about testing and certification issues from
a narrowly defined group.
In other areas of the testing and certification process, including specifying testing methods and increasing test lab accountability, the Manual doesn’t do all that it could to increase voter confidence and support state and local election officials.