Voluntary Voting System Guidelines

The Voluntary Voting System Guidelines (VVSG) are guidelines adopted by the United States Election Assistance Commission (EAC) for the certification of voting systems. The National Institute of Standards and Technology's Technical Guidelines Development Committee drafts the VVSG and gives them to the EAC in draft form for their adoption.

History

The Help America Vote Act instructed Election Assistance Commission (EAC) to develop voluntary voting system guidelines—a set of specifications and requirements against which voting systems can be tested to determine if the systems provide all of the basic functionality, accessibility and security capabilities required of these systems.

On December 13, 2005, the Election Assistance Commission unanimously adopted the 2005 Voluntary Voting System Guidelines (VVSG), which significantly increase security requirements for voting systems and expand access, including opportunities to vote privately and independently, for individuals with disabilities.

The guidelines update and augment the 2002 Voting System Standards, as required by HAVA, to address advancements in election practices and computer technologies. These guidelines are voluntary. States may decide to adopt them entirely or in part prior to the effective date.

A proposed revision to these guidelines, known as the VVSG 1.1, was offered during a 120-day public comment period in the summer of 2009. There are also efforts in parallel to develop a rewrite of these guidelines, known as the VVSG 2.0 or the VVSG Next Iteration, though these efforts are still underway.

2002 Voting System Standards

Three iterations of federal voting system standards have been issued by the federal government. The first set of standards was created in 1990 by the Federal Election Commission (FEC.) In 2002, the FEC updated the standards by adopting a second iteration, known as the 2002 Voting System Standards (VSS). The VSS consists of two volumes: Volume 1 and Volume 2.

The Help America Vote Act of 2002 (HAVA) created the U.S. Election Assistance Commission and transferred the responsibility of developing voting system standards from the FEC to the EAC. HAVA also tasked the EAC with establishing the federal government’s first voting system certification program.

2005 Voluntary Voting System Guidelines

The EAC adopted the VVSG on December 13, 2005, after a thorough and transparent public comment process. The EAC conducted an initial review and then released the proposed guidelines for a 90-day public comment period. Each of the more than 6,000 comments was reviewed and considered before the document was finalized and adopted, and all comments are made available 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 (Volume 1 and Volume 2) was adopted at an EAC public meeting on December 13, 2005.[1]

EAC-accredited test laboratories[2] currently test voting systems to both the 2002 voting system standards and the 2005 VVSG. Voting systems submitted for testing after December 13, 2007, will be tested only to the 2005 VVSG.

Voluntary Voting System Guidelines 1.1

The VVSG 1.1 Volume 1 and Volume 2 were delivered to the Election Assistance Commission in the summer of 2009. They are an incremental revision to the 2005 VVSG. They were unanimously approved by the Election Assistance Commission on March 31, 2015.[3]

Voluntary Voting System Guidelines 2.0

The VVSG 2.0, also known as the VVSG Next Iteration, is an effort to completely re-write the 2005 VVSG, intended to address the next generation of voting systems. The TGDC prepared a draft of the VVSG 2.0, and the TGDC's draft was delivered to the Election Assistance Commission in August 2007, but have not yet been adopted by the Election Assistance Commission and work remains in progress to refine these guidelines. The guidelines contain new and expanded material in the areas of reliability and quality, usability and accessibility, security, and testing. The TGDC draft prohibits radio frequency (RF) wireless, address software independence and include improved requirements for the overall reliability of voter verifiable paper audit trail voting systems.

The TGDC draft guidelines require software independence for all voting systems, in order to allow the correct outcome of an election to be determined even in the face of software bugs or vulnerabilities. According to the TGDC draft, 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.

Structure of the TGDC's Draft of the VVSG 2.0

The TGDC draft is divided into three main parts. It also includes an introduction and a glossary. The glossary can be found at the end of the document as "Appendix A" (Definition of Words with Special Meanings), and it indicates that the definitions provided there are special to the VVSG and may not conform to local or traditional usage.

Introduction - provides background information about voting system standards and guidelines; the purpose and scope; and an overview of new and expanded material.
Part I: Equipment Requirements – includes general core requirements for voting systems and voting devices. It includes security and audit architecture, usability, accessibility and privacy requirements, security requirements, and general core requirements.
Part II: Documentation Requirements – contains requirements that apply to the technical data package, voting equipment user documentation, the test plan, the test report, the public information package, and data for repositories.
Part III: Testing Requirements – this section describes the way voting system test laboratories are to determine if voting systems, voting devices and software meet the requirements of the VVSG.

VVSG Timeline
  • FEC adopts the federal government’s first set of voting system standards in 1990. Federal government does not test voting equipment against these standards
  • The National Association of State Election Directors (NASED) begins testing voting equipment against the 1990 standards; NASED, a non-governmental entity, voluntarily offers the service to the states
  • In 2002, FEC updates 1990 standards
  • NASED begins testing voting systems against the 2002 standards
  • The Help America Vote Act of 2002 (HAVA) creates the EAC
  • HAVA transfers the responsibility of developing voting system standards from the FEC to the EAC
  • HAVA requires EAC to set up the federal government’s first program to test voting equipment against the federal standards
  • HAVA renames the voting system standards, listing them as the voluntary voting system guidelines (VVSG)
  • NASED terminates its voting system testing program in July 2006
  • EAC launches full testing and certification program in January 2007
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References
  1. "2005 Voluntary Voting System Guidelines". Archived from the original on 2013-06-24. Retrieved 2013-06-24.
  2. Accredited Test Laboratories by EAC
  3. "Voluntary Voting System Guidelines - Voting Equipment - US Election Assistance Commission". www.eac.gov. Retrieved March 28, 2018.
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