Today, the Republican National Lawyers Association (RNLA) submitted a public comment to the United States Election Assistance Commission (EAC) regarding the proposed Voluntary Voting Systems Guidelines (VVSG) 2.0 Principles and Guidelines.

As the EAC commissioners noted in an article earlier this year:

Under HAVA [Help America Vote Act of 2002], the EAC develops and maintains Voluntary Voting System Guidelines (VVSG), requirements against which voting systems can be tested to determine if the system meets federal certification standards.

Systems are tested by EAC-certified laboratories and those that meet the federal standards are certified by the EAC. Some factors examined under these tests include voting system functionality, accessibility, accuracy, auditability and security capabilities. Earlier this year, we unanimously voted to publish the proposed VVSG 2.0 Principles and Guidelines in the Federal Register for a 90-day public comment period that concludes next month. At this week’s meeting, we will examine the VVSG 2.0’s proposed testing requirements and how these standards will shape the next generation of voting systems in the United States....

The comment period for VVSG 2.0 Principles and Guidelines just came to a close this afternoon, but before the RNLA submitted its comment for consideration.

The RNLA continues to lead efforts on the national stage as an advocate for open, fair, and honest elections. Read below for some key excerpts from our submitted comments:

The United States has the finest election system in the world and enjoys a proud position as the leading, longest lasting representative democracy in the world. Yet, there is always work to be done to improve the election system, and updating the VVSG is an important step to bring the certification standards for many voting systems used in America up to date with modern technological standards.

The RNLA emphasized the importance of maintaining a bipartisan representation of the Commission and recognizing the primary role that state’s play in elections:

While updating the VVSG is an important goal, it is vital that the EAC not abandon these two foundational principles in the process: bipartisan control of election standards and the primary role of the states in election administration.

The EAC’s respect for these two principles are what gives the agency its legitimacy and what have made it a successful, trusted federal partner for election officials around the country.

First, the RNLA recommends more clearly defined terms within the VVSG:

The proposed high-level Principles and Guidelines provides worthy goals for guidelines on voting system, but the terms used throughout the document need to be defined. The terms as currently written are vague and ambiguous and subject to differing interpretations. This may cause confusion for election officials and vendors who are seeking to create systems that meet the requirements of VVSG 2.0.

It is important for manufacturers of voting systems to have clear Principles and Guidelines and specific corresponding Requirements together in order to be able to design systems that comply with the VVSG and obtain certification.

Furthermore, the RNLA does not advise taking oversight away from the commissioners and entrusting it to unaccountable staff:

Removing oversight and approval of the VVSG from the commissioners—who are suggested by congressional leaders, nominated by the President, confirmed by the Senate, and must act in a bipartisan manner—and placing it with unaccountable staff, threatens the legitimacy of the VVSG itself.

Bipartisan approval of the standards governing our elections is vital to ensuring that our election systems are open, fair, and honest both in appearance and actuality. Removing bipartisan oversight would decrease public confidence in the VVSG and reduce buy-in by the community of election officials.

The RNLA supports all efforts to update the VVSG in an open, transparent, and bipartisan process. This is an opportunity for the EAC to improve the public’s confidence in the reliability of the voting systems, the voting process, and the outcomes of elections across America. 

To view the entire comment submitted to the EAC, please click here.