[Cccnfbw] Fwd: EAC 120-Day Public Comment Period for VVSG 1.1 Begins Today

Beth Manning b-bmanning at comcast.net
Tue Jun 9 20:47:56 CDT 2009

United States 
Election Assistance Commission 
1225 New York Avenue N.W. - Suite 1100 
Washington, DC 20005         
For Immediate Release         Contact: 
Jeannie Layson, Sarah Litton 
(202) 566-3100 

120-Day Public Comment Period for VVSG 1.1 Begins Today 

WASHINGTON- The U.S. Election Assistance Commission (EAC) will hold a 
120-day public comment period for the Voluntary Voting System Guidelines 
y-voting-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 
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 <http://www.eac.gov/News/about/committees/tgdc> , 
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 

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 
es-vvsg-v-1-1>  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 at eac.gov 
<mailto:votingsystemguidelines at 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 
gins-today/portal_factory/PressRelease/portal_factory/PressRelease/> . 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 
<http://www.eac.gov/News/program-areas/voting-systems/>  at www.eac.gov 
gins-today/portal_factory/PressRelease/portal_factory/PressRelease/> . 

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. 


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