National: Verified Voting Comments On VVSG 2.0 v3
June 22, 2020
TO: The United States Election Assistance Commission (EAC)
Thank you for the opportunity to comment on the proposed Voluntary Voting Systems Guidelines (VVSG) 2.0. Verified Voting’s mission is to strengthen democracy for all voters by promoting the responsible use of technology in elections.
Verified Voting applauds the diligent work that has occurred over the past several years to get to the final stages of VVSG 2.0 and agrees with Chairman Hovland that this is an important step toward improving election security.
Verified Voting has contributed to the development of prior versions of the VVSG since its inception in 2004. We appreciate the EAC’s invitation for public comments and that the EAC has incorporated a number of our suggestions throughout the years. Several of Verified Voting’s Board and Advisory Board members have participated in the development of earlier versions of the VVSG 2.0 as well as on several NIST-EAC Working Groups that helped develop the Requirements for the latest proposed VVSG 2.0.
The EAC should adopt the VVSG 2.0 as soon as possible and enforce the expiration of VVSG 1.0 and 1.1 in order to ensure that systems fulfill the most recent standards, rather than grandfathering election systems that continue to evolve.
