CEC submitted a comment to the U.S. Election Assistance Commission today urging it to adopt “broad interoperability requirements” in the upcoming release of version 2.1 of the Voluntary Voting System Guidelines (“VVSG”), arguing that “interoperability requirements will benefit all areas of [election] administration, including list maintenance” across state lines. The EAC is considering updates to the VVSG in response to Executive Order no. 14248 (“Preserving and Protecting the Integrity of American Elections”).
While the VVSG has previously called for common data formats, a good first step toward interoperability of election equipment from different vendors, no interoperability requirement has been adopted.
Principle 3.3-B in the latest draft of the Voluntary Voting System Guidelines VVSG 2.1 manual notes that “[c]onformance to a common data format does not guarantee data interoperability.” While this statement, standing alone, is an aphorism, CEC encourages the EAC to ensure state and local election officials may realize the full promise of common data formats (“CDFs”) by requiring in VVSG 2.1 interoperability between vendors for all referenced CDFs on a forward-looking basis. While any CDF is an improvement for the reuse of data across systems in a multi-vendor environment, a CDF that requires interoperability between systems (at least those certified to the same standard) would greatly reduce administrative labor hours involved with translating data between various vendors’ compliant-but-not-interoperable implementations of the CDF.
As CEC notes, “it’s no secret that inter-state list maintenance continues to be a significant challenge for state and local election officials across the country”, with a national electorate consistently on the move.
[W]ith 56 federal voting jurisdictions and 211 million registered voters—and a population on the move2—inter-state list maintenance becomes ever more important. The reference of CDFs for important election transactions, such as cast vote records, and for voter records interchange (VRI) represents important opportunities for the EAC to ease the frustration of inter-state list maintenance by requiring the data represented by at least these CDFs to be interoperable.
Current election equipment is not required to interchange with equipment from other manufacturers, making inter-state list maintenance a difficult, time-consuming, and manual process. An interoperability requirement would resolve much of this difficulty.
Interoperability between vendor systems will allow election officials in different states, who may use equipment from different vendors, to use data supplied by officials in other states for list maintenance purposes without re-importing, translation, or conversion.
CEC urges the EAC and its advisory committee, the Technical Guidelines Development Committee, to adopt an interoperability requirement in the upcoming update to the VVSG, which would help to ensure that regular inter-state list maintenance becomes a practical reality.