EAC - Voluntary Voting System Guidelines

Name : | Alfie Charles
Organization : | Sequoia Voting Systems
Post Date : | 9/30/2005
Section Comments
Section : | 1.6.1
Page no. : | 1-9
Line no.: | 20-25
Comment : | This section states that the Certification Number applies to the system as a whole and not to individual components. It is important to require the end-to-end system testing discussed here, but it would also be useful to have separate qualification numbers for individual components so that components already in use can be combined with newer components as long as a comprehensive end-to-end functional test is conducted of the proposed configuration. As written, the standards appear to contemplate only systems that are certified with each individual component tested to the same version of standards. This approach has already proven problematic for election administrators during the transition from the 1990 to the 2002 voting system standards. During this transition, certification testing of changes to 1990-qualified technology was phased out by NASED, effectively requiring local government to purchase new equipment to accommodate necessary features. We strongly encourage the EAC to accommodate system qualification for systems that are comprised of components that have been tested to differing levels of the voting system standards. This approach will prevent unnecessary delays in the upgrading of voting technology and can avoid the unanticipated local government expense of a comprehensive system or component replacement when the 2005 VVSG are implemented as well as when they are modified in the future. This approach might also have the added benefit of ensuring that states continue to participate in the national standards process rather than opting out of the federal standards for fear of losing federal qualification or the ability to implement modifications as new federal standards are deployed in the future.