ACCURATE Comments on the VVSG

A Center for Correct, Usable, Reliable, Auditable and Transparent Elections (ACCURATE) submitted public comment today to the U.S. Election Assistance Commission on their draft Voluntary Voting System Guidelines (VVSG), urging the Commission to adopt certain key features fo the draft. The VVSG provides a national certification framework for U.S. voting systems against which 40 states require their voting systems to be certified.

ACCURATE’s comments laud the new draft as a groundbreaking and badly needed overhaul of our national voting system standards while making constructive suggestions for further development.

The most significant element of the draft VVSG is the requirement for software independence, which would require voting systems to be designed so that undetected flaws in the voting system software cannot cause changes in the vote count. ACCURATE fully supports requiring software independence as the backbone of a robust and comprehensive next-generation voting system certification regime.

The commentary goes on to emphasize the importance of welcome features of the draft: adversarial vulnerability testing, volume testing, the new framework for usability and accessibility testing and comprehensive voting system documentation requirements. The comment closes by pointing out areas of the VVSG that will require increased institutional support outside of the VVSG process, including the crucial innovation class and a closed loop for incident reporting and feedback.

ACCURATE plans to participate further as the draft VVSG is modified and extended.