US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Alfie Charles
Organization :   Sequoia Voting Systems
Post Date :   9/30/2005

Section Comments
Section :  .20.1.8
Page no. :  1-15
Line no.:  
Comment :  We reiterate our suggestion that this section and other language regarding the full system testing be modified to permit components of various systems to be tested against different versions of standards.  Under our recommended approach, a system would only receive a 2005 VVSG qualification number when all components are deemed compliant with the 2005 VVSG, but it would not prohibit federal testing of components and systems to earlier versions of standards.  Under that scenario, the system would retain a qualification number linked to the latest version of standards against which all components have been tested.

It would be fiscally irresponsible for state and local government to embrace the federal standards if they are then unable to make state-specific modifications to a system because one particular component is unable to be upgraded from the 1990 to 2002 standards or from the 2002 standards to the 2005 VVSG or from the 2005 VVSG to the next version of standards.  The notion that an entire well-functioning voting system may have to be replaced because a single component may not have been tested against the latest standards would place unreasonable fiscal burdens on local government well after one-time HAVA funds have been expended.