This notice is being amended to provide for a one hundred thirty (130) day comment period. The original ninety (90) day public comment period provided for in the initial notice is amended in order to allow the election community additional time to comment after the November 2012 Presidential election. As required by Section 222 (d) of HAVA, the U.S. Election Assistance Commission (EAC) is publishing for public comment a set of proposed requirements, the Voluntary Voting System Guidelines, Version 1.1. The VVSG provides specifications and standards against which voting systems can be tested to determine if they provide basic functionality, accessibility, and security capabilities.
Background: The EAC made the decision to update and revise the 2005 VVSG (also known as VVSG 1.0) as a result of feedback received through its Voting System Testing and 2 Certification Program. As the EAC has worked to test and certify voting systems it observed and received feedback from various sources that the standards being tested to were at times ambiguous and difficult to apply in testing. This ambiguity led to challenges in making testing consistent both within a test laboratory and across test campaigns at different laboratories. The EAC also received feedback from the National Institute of Standards and Technology (NIST) that the creation of formalized test suites for the 2005 VVSG would be aided by a clarification of certain portions of document. This information, combined with the EAC’s issuance of thirty five interpretations of the VVSG to clarify various standards, led the EAC to propose improvements to the 2005 VVSG. In addition, the EAC determined to implement a number of recommendations submitted by the EAC’s Technical Guidelines Development Committee (TGDC).
The TGDC held numerous public meetings and subcommittee conference calls to create a set of draft guidelines for recommendation to the EAC (all TGDC meeting materials can be found at http://www.nist.gov/itl/vote/). On August 17, 2007, the TGDC voted to complete final edits of their recommendations and submitted them to the Executive Director of the EAC. The EAC received the draft guidelines from the TGDC on August 31, 2007.
After receipt of the TGDC’s recommendations for the next iteration (VVSG 2.0) of the VVSG the EAC opened a one hundred and eighty day public comment period. During this comment period, which ran from September 2007 to May 2008, the EAC received comments praising many of the proposed standards as being more testable and less ambiguous than previous versions of the standard. This public comment period produced over 3000 comments on the recommendations. In addition, during the comment period the EAC conducted a series of seven roundtable discussions regarding the TGDC’s recommendations. After the close of the public comment period for the TGDC’s VVSG 2.0 recommendations and considering a variety of relevant factors, the 3 EAC made the decision to first update and revise the 2005 VVSG with portions of the TGDC’s recommendations. This serves as the basis for the creation of VVSG 1.1.
As noted during the previous public comment period for version VVSG 1.1, by revising the guidelines now, the EAC expects to improve the test process over the short term for existing voting systems while allowing additional time to develop more complex revisions for the requirements in VVSG 2.0 written for the next generation of voting systems. Topics currently undergoing continued research at NIST include open ended vulnerability testing/penetration testing, volume testing, further development of the concept of software independence and the development (with IEEE Working Group P1622 of a common data format for voting systems.