August 6, 2020
The EAC is committed to moving the process of adopting the Voluntary Voting System Guidelines Version 2.0 (VVSG 2.0) forward. During 2019 and 2020, tremendous progress was made toward the adoption of VVSG 2.0. The VVSG 2.0 represents a significant advance forward in defining standards that will serve as the template for the next generation of secure, accessible, and accurate voting systems.
The EAC hosted VVSG 2.0 virtual hearings on March 27th, May 6th, and May 20th and continues with reviewing the comments received, developing and updating Testing and Certification Program Manuals, reviewing the glossary, and working on testing assertions where required, making the changes needed to support VVSG 2.0 resulting in a successful deployment of the new testing standards.
Following extensive work by EAC Commissioners and staff, the Technical Guidelines Development Committee (TGDC), and the National Institute of Standards and Technology (NIST), the EAC submitted the proposed VVSG 2.0 Requirements to the Standards Board and Board of Advisors executive committees for review on March 11th. On March 24th, the EAC initiated a 90-day public comment period on the VVSG 2.0 Requirements which concluded on June 22nd.
On July 17th, we conducted our annual Board of Advisors meeting virtually which was predominately focused on VVSG 2.0. Additionally, on July 31st we conducted our Standards Board meeting virtually which was also focused on VVSG 2.0. The Standards Board passed a resolution recommending adoption of the VVSG 2.0 Requirements.
The EAC received 77 sets of comments and a total of 1,660 comments. The comments we received predominately focused on accessibility, ambiguity and vagueness of requirements, inconsistent terminology, additions and changes to the glossary, and some requirements were viewed as being difficult to qualify or test in their current form. These would require testing assertions associated with them.
After the May 20th hearing that included Voting System Test Laboratories (VSTL) and EAC-registered manufacturers, the EAC in partnership with NIST had discussions with the VSTLs and manufacturers to better understand issues raised at the May 20th hearing. The VSTLs and manufacturers raised concerns regarding a lack of clarity, feasibility, and a substantially increased cost to build and test the new voting machines to the requirements. The EAC and NIST obtained technical clarification on some of the major issues during these discussions. The EAC will continue to reach out to the VSTLs, manufacturers, and other stakeholders as needed to clarify technical comments throughout the process to ensure the success of the VVSG 2.0.
Also, the EAC's Testing and Certification and Cyber Programs meet twice per week with the NIST Voting Systems Program to evaluate and resolve public comments on the requirements. To date, all of the comments related to the Introduction section and Principles 1 and 2 have been evaluated.
The EAC is working on numerous parallel paths in order to submit the VVSG 2.0 Requirements, Test Assertions, EAC Testing and Certification Program Manual, and EAC Voting System Test Laboratory Program Manual to the Commissioners for adoption by the end of the calendar year.