VotingWorks

Thank you, as always, to @EACgov for the opportunity to comment on the certification process.

Bottom line – we urge the EAC to consider that current policies are entrenching manufacturers created prior to 2015 and making it harder for newer manufacturers to get certified. But it's the newer manufacturers who are more interested in moving the market to VVSG 2.0.

In addition, the only reasonable implementation path for this requirement happens to be patented by a major vendor. It's a highly questionable patent, but still: this is likely going to make this requirement even more expensive.

On cost: we focus on Commercial Off The Shelf (COTS) hardware to reduce costs. One of the accessibility requirements in particular, given how it is worded, makes a COTS implementation impossible. That will significantly increase cost.

On modularity: we would *love* to submit components of our system for VVSG 2.0 certification. Unfortunately, as we are a manufacturer born after 2015, there is no path for us to do this. We hope the EAC will provide us a path to certify components under VVSG 2.0.

If the EAC doesn't act on this, VVSG 2.0 is likely in danger. There's little motivation for manufacturers to upgrade to 2.0 if they can continue to sell, update, and market systems under the much lower bar of 1.0.

The lifecycle policy, how we move from VVSG 1.0 to VVSG 2.0, is critical. In 2021, long-established manufacturers are still submitting new systems, for example a brand new central scanner with a brand new product name and brand new features, under the 16yo VVSG 1.0 standard!

EAC staff have been very helpful, answering every question we've sent promptly and effectively.

We're working as fast as we can on VVSG 2.0 certification and planning on submitting our system for certification in mid 2022.

Job alert: VotingWorks will soon open two positions for experienced software engineer. Work anywhere in the United States. Help build the only publicly accountable voting system. Watch this Twitter account or our web site for more information by mid next week.

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