Public comment period for voting system guidelines extended to June 7, 2019

The Election Assistance Commission is responsible for setting the Voluntary Voting System Guidelines that determine many factors in how we vote. They are currently approving the new guidelines called the VVSG 2.0. Although these guidelines are an improvement, they have serious shortcomings that will undermine the ability to guarantee that all votes are counted as cast.

We ask that you send this letter, or your own version of it to the EAC by 5pm EST on 6/7/19. (Note that the EAC has not updated the deadline everywhere on their website, but it is confirmed to be June 7.)

How to make a comment to the Election Assistance Commission

1) Use this form – the link is case sensitive.

https://www.eac.gov/vvsg-form/

2) Copy and paste the letter below into the form. Make changes if you’d like, and then send it.

3) Send a copy to AUDIT USA by pasting the letter into the form at http://auditelectionsusa.org/contact/

——- copy below ——-

Dear Commissioners McCormick, Hovland, Palmer, and Hicks:

I am pleased to see that the new proposed Voluntary Voting System Guidelines address some of my concerns about election security. Unfortunately, plugging only some of the security holes in electronic voting equipment is not enough.

VVSG 2.0 must provide adequate security to provide public confidence that votes are counted as cast and that election results are correct.

I request the following changes to the Guidelines:

1) All approved voting systems must enable voting via hand-marked paper ballots, except in the case of necessary accommodations for voters with disabilities.

2) All approved voting systems must preserve the sanctity of the secret ballot. No “recallable ballot” provisions can be allowed in any voting system that enable the identification of a specific voter’s ballot after it is cast. Once a ballot is recorded it must never be recallable.

3) Digital ballot images, cast vote records (CVRs), and the spreadsheets containing CVRs that are generated by digital scan voting systems must all be designated as “archival” public records that must be preserved for 22 months following a federal election. None of these items should be designated as “transient” materials.

4) No voting systems may encode votes using barcodes, QR codes, or any other format that is not visually verifiable by the sighted voter, or otherwise verifiable by the vision-impaired voter using assistive technology.

5) A paper ballot produced by ballot marking device must be indistinguishable from the ballots hand-marked by voters.

6) No voting system may be approved that has the capacity to change voter selections on a ballot after the voter has cast it.

7) No voting system may have a modem or allow remote or internet access.

8) No voting system may record votes directly to a computer memory without the voter reviewing a paper ballot.

9) Where ballot marking devices are used (to provide access for voters with disabilities), no voting system may record votes directly to a computer memory without the voter reviewing the paper ballot.

10) All electronic voting systems must create a digital ballot image that is identical to the paper ballot, for use in auditing, adjudication and forensic analysis.

11) All digital scan voting systems must mark paper ballots and their associated ballot images with corresponding numbers necessary for audit. These numbers must not identify the voter. All election jurisdictions must adopt and adhere to practices and procedures to ensure that paper ballots are stored in a manner that permits matching of ballot images with their corresponding ballots for the purposes of audit and adjudication.

12) No voting system may be configurable to allow weighted elections. All votes must be recorded as whole numbers.

Please take my comments into consideration before the new VVSG is finalized. Thank you for your consideration.