U.S. Election Assistance Commission

WASHINGTON- The U.S. Election Assistance Commission (EAC) will hold a 120-day public comment period for the Voluntary Voting System Guidelines (VVSG) version 1.1 beginning June 1, 2009. The purpose of the comment period is to provide an opportunity for the public to offer input on proposed revisions to the 2005 VVSG.

The VVSG are a set of federal specifications and requirements that are used to test voting systems for basic functionality, accessibility and security capabilities. EAC certifies voting systems according to this standard and requires testing to determine compliance with it. EAC certification is entirely voluntary – states are not required to use EAC-certified voting systems and voting system manufacturers are not required to obtain federal certification.
 
Why the revision is needed
The guidelines are being revised to improve the quality and efficiency of testing performed under the EAC testing and certification program by including new software development and testing protocols and practices. This includes the development of uniform test suites by the National Institute of Standards and Technology (NIST). This revision will also clarify several ambiguities in the standard, providing test labs and voting system manufacturers with a clearer sense of performance and test requirements for EAC certification.

The revision process
In partnership with NIST, EAC routinely examines the VVSG to make sure they reflect the best and most recent software development and testing standards and protocols. This involves informal observation and information gathering as well as formal requests for input from a broad group of stakeholders, including computer scientists, usability and accessibility experts, election officials, voter advocates, voting machine vendors and federally accredited test labs.

The proposed revisions are largely informed by the EAC Technical Guidelines Development Committee, which issued recommendations for the next iteration of the VVSG, and the thousands of public comments on the recommendations that the EAC solicited. The EAC also held seven roundtable discussions with groups of stakeholders to gather additional information on the recommendations.

By revising the guidelines now, the EAC expects to improve the test process over the short term while allowing additional time to develop more complex revisions to be included in the second complete iteration of the guidelines, the VVSG version 2.0.

Areas to be revised
The EAC and NIST selected the revisions based on their ability to yield immediate and marked improvements to the test process and be implemented with relative ease. Moreover, the revisions do not require any hardware changes or significant software changes, and can be adopted without extended research.

The revisions replace outdated practices with modern, proven methods that improve the development, analysis and testing of voting system logic. For example, by adding block structured exception handling to the list of acceptable control constructs, vendors will be able to use modern error handling techniques to better guard against undetected errors and improve system robustness.

The proposed revisions are limited to usability and accessibility, security, and core areas such as software workmanship. Following is a complete list of areas to be revised:
 
1) Hardware and software performance benchmarks and test method
2) Software workmanship
3) Test plan and test report
4) TDP and voting equipment user documentation
5) Non-EMC environmental hardware
6) Human factors requirements
7) System security documentation requirements
8) Election records
9) Voter verified paper audit trails (VVPAT)
10) Cryptography
11) External interface requirement
12) EAC requests for interpretation (RFI) decisions
13) General edits

A draft of the proposed revisions along with frequently asked questions about the process are posted on the EAC Web site.

Timeline for adopting the revisions
At the conclusion of the 120-day public comment period, the EAC and NIST will review the comments received on the proposed revisions, and will issue the revised guidelines, VVSG version 1.1, in late 2009.

Methods for submitting comments
Comments may be e-mailed to votingsystemguidelines@eac.gov or mailed to Voluntary Voting System Guidelines Comments, U.S. Election Assistance Commission, 1225 New York Avenue, NW, Suite 1100, Washington, DC  20005.  In addition, an online comment tool will be available this summer at www.eac.gov. The  are posted on the EAC Web site.

Background information
For more information about the VVSG and the Voting System Testing and Certification program, visit the Voting Systems Center at www.eac.gov.

The EAC is an independent commission created by the Help America Vote Act.  The EAC serves as a national clearinghouse and resource of information regarding election administration.  It is charged with administering payments to states and developing guidance to meet HAVA requirements, adopting voluntary voting system guidelines, and accrediting voting system test laboratories and certifying voting equipment.  It is also charged with developing and maintaining a national mail voter registration form. The three EAC commissioners are Gineen Bresso Beach, chair; Gracia Hillman, vice chair and Donetta Davidson. There is one vacancy on the Commission.