This week the Elections Assistance Commission (EAC) released public comments submitted on their draft UOCAVA Pilot Program Testing Requirements. The EAC document spell outs testing and certification requirements for Internet voting pilot programs for military and overseas voters, partly in response to the requirements of the Military and Overseas Voter Empowerment (MOVE) Act passed in 2009. The MOVE Act required many excellent improvements that increase opportunities for voters overseas to be able to cast their ballots in time to be counted. These changes include the electronic delivery of blank ballots and information, but not the electronic return of voted ballots. The Act also included a provision for experimental programs involving voting via the Internet. At least three states (AZ, CO, WV, and possibly GA and FL) are planning to carry out voluntary pilot programs this year. Despite the short time available for comment, many substantive comments were submitted, including from Verified Voting. While we do not mention them all here, there were many insightful comments and we urge you to read through them. Many of the comments expressed recurring themes:
Audits, Security Standards and Procedures: Verified Voting noted that an equipment manufacturing standard alone is insufficient to provide anything resembling “reasonable assurance that the pilot systems will operate correctly and securely”, as stated in Section 1.1.3 of the EAC Draft. We assert that a comprehensive security plan is required, not merely an equipment testing plan. Robust post-election audits are essential to demonstrating correct and secure operation of any voting system, be it remote or local.