Voting System Standards
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This document is part of Agenda Document Number 01-62 on the agenda for consideration at the December 13, 2001, meeting of the Federal Election Commission.
FEDERAL ELECTION COMMISSION
[Notice 2001
- ]
AGENCY:
Federal Election Commission
ACTION:
Notice with request for comments
SUMMARY:
The Federal Election Commission (the “FEC”) requests comments on the
second draft of the revisions to the 1990 national voluntary performance standards for
computerized voting systems and the first draft of the revisions to the 1990 national test
standards. Please note that these drafts do
not represent a final decision by the Commission. The
FEC will publish a notice when both volumes of the final revised standards are issued. Note also that the text of the final documents
will not become part of the Code of the Federal Regulations because they are intended only
as guidelines for states and voting system vendors. States
may mandate the specifications and procedures through their own statutes, regulations, or
administrative rules. Voting system vendors
may voluntarily adhere to the standards to ensure the reliability, accuracy, and integrity
of their products. Further information is
provided in the supplementary information that follows.
DATE:
Comments must be received on or before February 1, 2002.
ADDRESSES:
Copies of the draft revised performance and test standards may be found on the
Federal Election Commission’s web site at www.fec.gov/elections.html, or may be
requested by contacting the Office of Election Administration, Federal Election
Commission, 999 E. Street, N.W., Washington, D.C. 20463.
They may also be requested in person at the Office of Election Administration, 800
N. Capital St., N.W., Washington, D.C., Suite 600.
All comments should be addressed to Ms.
Penelope Bonsall, Director, Office of Election Administration, and must be submitted in
either written or electronic form. Because no anonymous submissions will be considered,
all submissions must include the commenters full name, postal mail address, and electronic
mail address if submitted by e-mail. Written
comments should be sent to the Office of Election Administration, Federal Election
Commission, 999 E. Street, N.W., Washington, D.C., 20463.
Faxed comments should be sent to (202) 219-8500, although it is advisable to send a
printed copy to ensure legibility. . Comments
can be submitted electronically to vss@fec.gov. It
is suggested that electronic comments submitted as attachments use Microsoft Word and that
all comments avoid the use of special characters or encryption. Comments can be submitted through the close of
business on February 1, 2001
FOR FURTHER
INFORMATION
CONTACT:
Ms. Penelope Bonsall, Director, Office of Election Administration, 999 E. Street,
N.W., Washington, DC 20463; Telephone: (202) 694-1095; Toll free (800) 424-9530, extension
1095.
SUPPLEMENTARY
INFORMATION:
In 1990, the FEC and its Office
of Election Administration promulgated standards for computerized election equipment
pursuant to its responsibilities under 2 U.S.C 438(a)(10), which requires the FEC to
“serve as a national clearinghouse for the compilation and review of procedures with
respect to the administration of Federal elections.”
The resulting product is the Voting System Standards (the “Standards”). Although voluntary, the Standards have been
adopted in 37 states in whole or in part and are used to design systems and procure
equipment to meet the needs of diverse jurisdictions serving a wide variety of voting
populations and election formats.
The Standards are designed to provide technical specifications and documentation
requirements to vendors that intend to sell systems in the states that require compliance
with the Standards. In order to show
compliance, a vendor must submit its system for qualification testing. The qualification testing is done through an
Independent Testing Authority (“ITA”) that has been certified by the National
Association of State Election Directors (“NASED”). Once a system has completed the ITA process, it
receives a NASED Qualified identification number. In
order to maintain its status as a NASED qualified system, the hardware and software must
be identical to the hardware and software tested by the ITA.
The Standards are designed to guide development of computerized voting systems. To this extent, the only voting systems that are
addressed in the Standards are electronic DRE systems and paper-based systems that utilize
electronic technology to count ballots. The
Standards do not address lever machines systems, as there are currently no manufactures
that design systems using such machines.
Periodic revisions to the Standards are
necessary to reflect the development of emerging technology in voting systems and design
innovations. Increasingly, voting system
vendors are designing systems that use electronic and telecommunications components not
addressed in the original standards. As a
result, proposed revisions have been developed by the FEC that reflect the technologies
contemplated by the voting system industry. Also,
the Standards acknowledge the impact of the Americans with Disabilities Act and provides
specifications so that voting system vendors can design systems that allow a voter with a
disability to exercise his or her democratically protected right to vote.
Additionally, the revised Standards incorporate a broadened understanding of what
constitutes a voting system by including not just the machine used by voters to cast
ballots, but also certain components of the Election Management System (EMS), the
telecommunications system (where applicable), and the ballot counting system. The revised Standards augment the requirements for
the EMS, addressing preparation of the ballot, election-specific coding of software, and
vote consolidation and reporting processes. The
Standards does not provide guidance to computerized election database systems that are not
part of the voting system itself. Such
systems include voter registration databases and other consolidated databases used by
election officials. The FEC’s Office of
Election Administration has produced other documents, available upon request, that can
assist election officials and other interested party in developing and maintaining such
systems.
The FEC recognizes that human interface considerations are an integral part of
developing an accurate, reliable voting system. The
FEC has allocated funds to investigate human factors issues and is developing
specifications that can be used in conjunction with both the Standards and other FEC
operational and management guidelines to ensure that human factors considerations are
given an important place in the development and procurement of voting systems.
The 1990 Standards were released as a single volume.
However, the new Standards are divided into two volumes, both included for this
release. Volume I provides functional and
technical requirements for a number of system types and configurations. Volume II provides testing specifications for the
requirements of Volume I.
On July 21, 2001, the Commission published a notice requesting comments on the
first draft of Volume I of the revised Standards (66 FR 35978). Public comment was significant in both volume and
content. Over 350 comments from over 40
commentators provided ideas and approaches to the Standards that greatly enhance their use
by vendors, election officials, and voters. Because
of this feedback, substantive changes were made to Volume I and a second draft of this
document is being released for additional public comment.
Although many of the comments on Volume I were helpful in devising the content of
Volume II, this will be the first opportunity for the public to comment on its specific
content.
The documents released with this notice include an Overview document, Volume I of
the Standards (containing nine sections and three appendices), and Volume II of the
Standards (containing seven sections and four appendices).
The overview document explains in detail the history of the Standards project,
provides a description of how the Standards fit into election vending process, and gives
an explanation of the reasoning behind the inclusions and exclusions of various systems,
requirements, and test methods. Volume I of
the Standards contains functional requirements (Section 2) that outline system benchmarks. The Standards also anticipate an increased demand
for equipment that meets the needs of people with disabilities. In order to address and facilitate these needs,
the FEC, in consultation with the Access Board, has provided specific requirements for
systems (Section 2.6) allowing vendors to develop systems that increase accessibility to
voters with disabilities.
The Standards provide specific requirements for system software (Section 3) and
hardware (Section 4). Additionally, the
Standards anticipate that voting systems will move increasingly towards the use of
telecommunications to cast ballots, consolidate vote data, and report results. As such, two sections of Volume I of the Standards
outline requirements to guide selection of proper telecommunications equipment (Section 5)
and ensure that the introduction of telecommunications equipment does not compromise the
security and secrecy demanded by the election process (Section 6). Section 6 also addresses security and secrecy
requirements for a voting system’s software, hardware, and administrative procedures
(as specified by the vendor).
Volume I of the Standards also provides information on quality assurance (Section
7) and configuration management issues (Section 8). These
sections are tailored towards the unique needs of the election system industry, and are
designed to provide guidance in sound management practices without posing an undue burden
on small companies that have traditionally formed the backbone of the election system
industry.
Section 9 of Volume I of the Standards provides an introduction and overview to the
testing process necessary for a system to be qualified.
The testing processes and specifications themselves are found in the body of Volume
II.
Ultimately, the Standards are only a component of the necessary steps to ensure
reliable, accurate, and secure elections. A
qualified system has passed certain benchmarks for accuracy and reliability, but this is
not sufficient to ensure overall system reliability unless jurisdictions who purchase the
system use sound procurement and management practices to ensure that the system’s
security, accuracy, and reliability are protected during the election cycle itself. Because such practices are related to the actions
of voting officials rather than vendors, they are clearly outside the scope of the
Standards. However, the Standards mandate a
significant number of disclosure from vendors in order to provide a clear understanding to
election officials of how the system can be optimally operated.
The FEC invites all interested parties to submit comments. It is requested that each commenter indicate is he
or she is willing to appear before the Commission. The
FEC asks that, where appropriate, submitted comments reference specific sections of the
Standards that are germane to the submitted comment.
Additionally, the FEC requests that comments regarding specific content be
accompanied by specific suggestions for alterations to language or technical
specifications, so that the Commission may consider alterations that best reflect the
intent of the commenter. Comments suggesting the use of alternate industry standards
should provide the standard industry reference.
______________________
Danny L. McDonald
Chairman
Federal Election Commission
DATED: ________
BILLING CODE: 6715-01-P