EAC Seeks Public Comment on TGDC’s Recommended Voluntary Voting System Guidelines
Posted on October 31, 2007
WASHINGTON – The United States Election Assistance Commission (EAC) has launched the first of two public comment periods on the draft voluntary voting system guidelines (VVSG) prepared by EAC’s Technical Guidelines Development Committee (TGDC). The public is now able to submit comments about the draft guidelines by accessing the comment tool available at www.eac.gov. The public will also be able to view the comments submitted. Comments will be accepted through the online comment tool or by mailing them to EAC at 1225 New York Avenue NW, Suite 1100, Washington DC, 20005.
"The initial public comment phase is only the first step in EAC’s inclusive and thorough approach as we move toward the adoption of the next iteration of voluntary voting system guidelines," said EAC Chair Donetta Davidson. "Throughout the process, public input and involvement will be extremely important to the EAC, and we will review each and every comment that is submitted. We strongly encourage everyone to participate in this important review process."
The draft guidelines were prepared by the TGDC and delivered to EAC in August and posted on the EAC’s Web site. The introduction of the public comment tool launches the first of four phases leading to the adoption of a final version.
Phase I – The EAC submits the TGDC’s draft document to the Federal Register and launches the first public comment phase with an online comment tool available at www.eac.gov. The public comment period will last for 120 days and all comments will be made public. Also during this phase the EAC will hold public meetings with stakeholders to discuss the proposed guidelines.
Phase II – The EAC will collect and review all public comments submitted on the TGDC draft. After consideration of all public comments, the EAC will perform an internal review.
Phase III – Based upon public comment and internal review of the TGDC document, the EAC will develop and publish its draft version in the Federal Register. The public will have another 120 days to comment on the EAC draft version. The EAC will conduct public hearings about its draft version.
Phase IV – The EAC will collect and review all comments submitted and make final modifications. The final version of the VVSG will be adopted by vote of the Commission at a public meeting and then published in the Federal Register.
One of EAC’s most important mandates under the Help America Vote Act (HAVA) is the testing, certification, decertification, and recertification of voting system hardware and software. The VVSG provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality, accessibility, and security capabilities required of voting systems. According to HAVA, adoption of the VVSG at the state level is voluntary. However, states may formally adopt the VVSG, making these guidelines mandatory in their jurisdictions.
The draft guidelines, which were prepared by the TGDC, are a complete re-write of the 2005 guidelines, intended to address the next generation of voting systems. These guidelines contain new and expanded material in the areas of reliability and quality, usability and accessibility, security, and testing. The draft guidelines require software independence, a concept created for purposes of the TGDC draft as a high level security requirement for all voting systems. According to the TGDC draft guidelines, software independence can be achieved through the use of independent voter verifiable records (IVVR) or through the innovation class. Additionally, the TGDC draft recommends open-ended vulnerability testing (OEVT), a testing method designed to bring greater security to voting systems in the polling place.
History of Voting System Standards and Guidelines
The first set of national voting system standards was created in 1990 by the Federal Election Commission (FEC). In 2002, the FEC updated the standards (2002 VSS). With the passage of the Help America Vote Act of 2002 (HAVA), EAC was assigned the responsibility of updating these standards, which would be known as the Voluntary Voting System Guidelines. HAVA also instructed the EAC, along with its Federal advisory committee, the Technical Guidelines Development Committee (TGDC), and the National Institute of Standards and Technology (NIST), to work collaboratively to develop the VVSG.
On December 13, 2005, the EAC adopted the VVSG. Before the adoption of the VVSG, the EAC conducted a thorough and transparent public comment process. After conducting an initial review of the draft VVSG, the EAC released the two-volume proposed guidelines for 90-day public comment period; during this period, the EAC received more than 6,000 comments. Each comment was reviewed and considered before the document was finalized and adopted, and all comments were posted on the EAC Web site. The EAC held public hearings about the VVSG in New York City, NY; Pasadena, CA; and Denver, CO. The final version was adopted at the public meeting in December 13, 2005.