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We appreciate the opportunity to comment on the most recent iteration of the Voluntary Voting System Guidelines (1.1). We understand that the goal is to move forward on specific elements from the prior draft which were widely supported. The exclusion of some key principles warrant great concern and if left out of any approved version going forward, will delay progress toward greater reliability of voting systems. We support the comments made by A Center for Correct, Usable, Reliable, Auditable and Transparent Elections (ACCURATE), and add our comments on three main points below.
1. SOFTWARE INDEPENDENCE
Software independence (SI), or the “quality of a voting system or voting device such that a previously undetected change or fault in software cannot cause an undetectable change or error in election outcome,” is the foundation of an auditable voting system. Verified Voting strongly supports software independence. Leaving out this core element from the prior draft in the current VVSG 1.1 will delay essential progress in voting system reliability and security. We strongly recommend the reinstatement of the principle of software independence into the VVSG to be enacted as quickly as possible. For security, nothing is as crucial as auditing an auditable voting system. Without the ability to detect changes or problems in the voting system confidence in the integrity of electoral outcomes is unfounded.