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The Technical Guidelines Development Committee (TGDC) may not be well-known, but it plays a crucial role in the process of standards-setting in the field of voting technology testing and certification. About a year ago, the TGDC announced that it was going to convene a series of public working groups as part of a new approach to updating the federal Voluntary Voting System Guidelines (VVSG).
Late last month, the TGDC issued a draft project charter for VVSG version 2.0 that attempts to define both the scope of the project and lay out a way forward. The first key piece of the draft charter is the statement of objectives:
In order to align with the goals articulated by both the National Association of State Election Directors (NASED) and the EAC Future VVSG Working Group, this Committee agrees that the primary objectives of Version 2.0 of the VVSG shall be:
- To assess the ability of the election systems to correctly execute secure, usable and accessible elections in order to provide assurance to voters that the election is an accurate reflection of the voters’ will.
- To enable, not obstruct or impede, innovation and needed response to changing statutes, rules, jurisdictional and voters’ needs.
- To create a set of implementable guidelines that allows deployment of systems by jurisdictions constrained by election calendars, schedules and budgetary restrictions.
- To facilitate the interoperability of election systems.
- To facilitate an open and transparent process that allows voters and election jurisdictions to assess the performance and capability of the election systems.
- To provide a set of testable requirements that jurisdictions can understand and use to evaluate the performance of election systems and to procure new systems.
To meet these objectives, the draft charter proposes a scope for testing and certification – and includes a revision in the approach to applying the standards in practice:
The overall scope of VVSG 2.0 remains similar to versions 1.0 and 1.1 of the VVSG. The document is intended to provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality, accessibility, usability and security capabilities required. The requirements are intended to apply to all systems and/or system components used to:
- Prepare the voting system for use in an election
- Produce the appropriate ballot formats
- Test that the voting system and ballot materials have been properly prepared and are ready for use
- Record and count votes
- Consolidate and report election results
- Display results on-site or remotely
- Produce and maintain comprehensive audit trail data
The proposed structure of VVSG 2.0 would differ significantly from previous VVSG versions in that it will be divided into higher level principles and guidelines and be accompanied by detailed requirements and test assertions documents. The complete new structure would be:
- Principles: High level system design goals;
- Guidelines: Broad system design details focused primarily on election official use;
- Requirements: Contain the technical details necessary for manufacturers to design their voting system;
- Test Assertions: Contain the technical specifications required for laboratories to test voting systems to the guidelines and requirements of the document.
The EAC, NIST and the TGDC believe that the revised structure of the VVSG would better serve the objectives of this project and, ultimately, better serve the needs of election officials.
The draft charter also proposes a timeline for completion and adoption that, if successful, would have the new standards in place and ready for use by Election Day 2018:
- [Now] – January 2017 TGDC Meeting = Detail final scope & Format of VVSG 2.0 and begin to draft High Level Goals document & some level of requirements.
- January 2017 – December 2017 = Final development of High Level Goals and Requirements. (Includes 2 TGDC Meetings and at least 1 [EAC] Standards Board and Board of Advisors Meeting.)
- January 2018 – March 2018 = 90 Day Public Comment period.
- March 2018 – May 2018 = EAC-NIST staff response & changes from Public Comment.
- June 2018 = Final formatting.
- July 2018 – August 2018 = EAC vote on VVSG 2.0.
This story won’t draw the same interest in a presidential election year as the latest voting lawsuit or enactment of new state laws, but it’s incredibly important for the future of elections in the United States. Once VVSG 2.0 is in place, it will serve as the foundation for a host of key decisions – not just about what technology states and localities use, but also what that technology costs and how it supports the ever-changing picture of voting in America.
The vast majority of you won’t likely want to pay much more attention to this than being aware it’s out there – but if you are interested in being more involved, you can use the same page where the draft charter is located to subscribe to one or more working group lists and get involved.
Either way, it’s a big deal. Kudos to the TGDC for this document and good luck to everyone involved in taking VVSG 2.0 from concept to reality. Stay tuned …