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TGDC discussion sharpens on banning wireless hardware and accessibility trade‑offs; vendors, NIST warn of costs and implementation impacts
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Summary
Committee members called for an explicit ban on wireless hardware in VVSG 2.1; industry and NIST warned the change could be a major shift with supply‑chain and cost impacts, while accessibility advocates urged solutions for automatic paper handling and independence for voters with disabilities.
Members of the Technical Guidelines Development Committee debated whether VVSG 2.1 should include an explicit requirement that voting systems "must not contain wireless communication hardware," with proponents arguing a hardware ban is necessary to increase trust and make it provable that systems cannot establish wireless connections.
"You can't prove a negative," said Kevin Skoglund, arguing that disabling wireless by software is inadequate and that a device incapable of establishing a wireless connection would better support voter trust. Several members supported moving the proposed language from the discussion text into the requirement body to make it explicit.
Industry representatives and NIST urged caution. Chris Woloshen, speaking for vendors, said many manufacturers have already removed wireless from the devices they fully control, but vendors relying on commercial off‑the‑shelf (COTS) components would face additional cost and supply‑chain constraints to source non‑wireless variants. He said some manufacturers might exit portions of the market rather than reengineer products. Benjamin Long (NIST) described a hardware prohibition as a potential "major change" that requires study of ecosystem impacts and lifecycle costs.
Accessibility advocates focused on a related tradeoff: automatic paper handling and "all‑in‑one" devices that support verification without requiring voters to manipulate ballots. Diane Golden and other accessibility stakeholders warned that multi‑page ballots and separate devices can create burdens for voters with disabilities and stressed that at least one fully accessible device per polling place is required to preserve privacy and independence under HAVA.
Committee members noted examples of state action—Ohio and some other states have banned wireless hardware—and discussed procurement implications. A standards‑board participant recalled an earlier figure suggesting potential cost increases in the 20–50 percent range for some configurations, though EAC staff and vendors said exact numbers depend on device type and sourcing and that no definitive, system‑wide estimates were available.
No formal vote on a wireless hardware ban was taken; members requested further analysis and additional documentation on cost, supply‑chain, and testing implications before adopting major hardware prohibitions.

