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Subject: FW: EAC Seeks Public Comment on Recommended Voting System Guidelines
John Borras, Please let me know if the
OASIS E&VS TC plans to submit further comments on the US EAC VVSG documents
during this public comment period. -- Patrick
Gannon +1.978.761.3546
- mobile From: Bryan Whitener [mailto:bwhitener@eac.gov]
Contact: EAC Seeks Public Comment
on TGDC's Recommended Voluntary Voting System Guidelines Online Comment Tool Now
Available WASHINGTON -
The U.S. 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
here. 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. EAC is an independent bipartisan
commission created by the HAVA. 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 four EAC commissioners are Donetta Davidson, chair; Rosemary
Rodriguez, vice chair; Caroline Hunter; and Gracia Hillman. ### |
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