Comments on new Federal Voting Systems Guidelines

Last week I submitted comments for the State Audit Working Group on the proposed (Voluntary Voting Systems Guidelines) VVSG 2.0 standards which will define future voting system standards. Looking over all the submissions, ours were likely the most extensive detailed comments submitted. In total our submission was about three hundred and fifty pages!  You might consider reading the cover letter and then the Glossary Comments which have their own cover letter. In all, we spent over 200 hours developing and agreeing upon our comments. We were pleased to have thirteen signers and endorsements in comments from others groups : <SAWG Comments>

In all there were seventy-seven comments from various voting integrity, vendor, disability rights groups, and individuals <All Comments>

By far the largest number of comments were from disability rights groups and individuals supporting their positions, many redundant. Access for the disabled is one of the most controversial and critical issues. Many argue that everyone should vote on exactly the same voting machines so that all have equal access. There are several problems with this argument which would have us all vote on BMDs (Ballot Marking Devices): BMDs are not fully developed to meet the needs of the disabled, they need lots of work; Despite voting on identical machines, BMDs provide multiple interfaces for those with various disabilities , leaving voters not actually voting the same way anyway; BMDs cost about four times what a combination of a single BMD per polling place with VMPB (Voter Marked Paper Ballots) for most voters; BMDs do not serve some voters with disabilities  who cannot use them but can use paper ballots; BMDs are often the cause of the long lines we see in Georgia, Pennsylvania and elsewhere – almost non-existent in CT which has the single BMD and VMPB model; those long lines hurt the vast majority of those with disabilities who have issues with walking and standing in line for hours. I would favor investing the savings in BMD research and preparing to replace that one BMD per polling place as better solutions are developed. For some interesting comments on the challenges of the disabled that do not take the standard advocacy line, read the comments from <Marybeth Kuznik>, <Noel Runyan>, and <Harvie Branscomb>.

There are other issues with the proposed guidelines: They spend too little on vote-by-mail equipment; fail to fully recognize early voting; are too detailed in some areas and sketchy in others; provide for unsafe Recallable Ballots; and as vendors point out are often too prescriptive and expensive to implement. The proposal is a far from a finished product, with wide-ranging comments. It will be a huge task to complete them, far more challenging to complete well.

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