A New Voting System Certification Regime

Voting systems are certified at the national level to a set of standards–the VVSG–by the U.S. Election Assistance Commission (EAC). The EAC recently adopted a second avenue for certifying voting systems for use in pilot programs, called the Voting System Pilot Program Testing and Certification (VSPPTC) program. A critical piece of the VSPPTC program is the adoption of the VSPPTC manual, a manual and set of policies that will govern how, when and what voting system manufacturers can submit for pilot voting system testing and certification.

The EAC made this manual available for a 15-day public comment period that ended today and we submitted comments (In 2006, ACCURATE submitted public comments on the original manual for the larger testing and certification program).

From our comment submitted today:

The Draft Manual does an admirable job of incorporating some of the features of a feedback-rich pilot testing process, but we believe that it can and should go further. Our recommendations fall into four categories. First, the EAC should amend the Draft Manual to provide more details about what separates pilot certification from certification under the current, VVSG-based certification program. Specifically, the EAC should clarify what qualifies as a voting system pilot program, how it will decide whether to allow a manufacturer to pursue pilot certification for a given system, and what conditions are attached to pilot certification. Second, the pilot certification program should accept feedback from, and establish a systematic process for responding to, voters. Third, the EAC should strengthen the Draft Manual’s provisions for engaging with manufacturers at the system design stage and feeding data from pilot elections back to the design stage. Finally, the EAC should address the question of balance between piloting relatively mature systems and permitting pilots to force potentially major changes in pilot system design. This involves questions of the time and expense involved in pilot certification.

Our comment goes into detail about what we think could be improved in the VSPPTC Manual and how the unique nature of pilot voting systems provide opportunities and pose risks different from more mature voting technology.

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