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Frequently Asked Questions About Voting System Standards
Who establishes voting system standards? The development, promulgation, and revision of the national voluntary voting system standards is a joint effort headed by the U.S. Federal Election Commission (FEC) but also involving:
The original standards, published in 1990, and subsequent revisions also reflect contributions from other election officials, from designers and manufacturers of voting systems, from concerned interest groups, and from interested members of the general public, whose input is received during public comment periods. Each version of the standards must be approved by a majority vote of the FECs six Commissioners, prior to final release. What are voting system standards? Voting system standards are documented agreements containing technical specifications to be used consistently as guidelines to ensure that automated voting systems (both those that use a paper ballot and all electronic systems) are accurate, reliable, and secure. The standards include functional criteria (things that any voting equipment must do) along with technical requirements for: hardware, software, security, quality assurance, and documentation. The standards also include testing procedures to ensure that voting systems meet these requirements. Note that the standards address only what a voting system should do, not how the system should do it. The standards are not intended to impede the design and development of new, innovative voting equipment. Nor are they intended to drive the prices of voting equipment out of the range of local jurisdictions.
Why do we need voting system standards? The short answer is that we need voting system standards to help State and local election officials ensure that the voting systems they buy, and that the public vote on, work accurately and reliably. The long answer requires a stroll down memory lane. During the 1970s, nearly anybody could cobble together a "voting machine" in their garage (and some of them looked like they had been), then go out and sell it to unwary local election officials. Few States had any guidelines for testing or evaluating these devices. So local officials either had to take the salesmans word for it or else depend on the opinion of colleagues who had already bought it. Voting equipment horror stories -- some of them funny, some of them downright chilling -- soon began circulating through the election community. They triggered concerns about the integrity of the voting process. In 1975, the National Bureau of Standards prepared a report entitled Effective Use of Computing Technology in Vote-Tallying. The report concluded that one of the basic causes for computer-related election problems was the lack of appropriate technical skills at the State and local level for developing or implementing sophisticated and complex written standards against which voting system hardware and software could be tested. This report, along with comments from State and local election officials, led the U.S. Congress to designate the FEC to work with the National Bureau of Standards (now known as the National Institute of Standards and Technology) to conduct a study of the feasibility of developing national standards for voting systems. Following the release of the feasibility study in 1982, Congress appropriated funds for the FEC to develop national standards for computer-based voting systems which the States might voluntarily adopt. In the course of that effort, the FEC sponsored thirteen meetings involving more than 130 State and local election officials, independent technical experts, voting system vendors, Congressional staff, and computer security advocates. On January 25, 1990, the FEC approved for publication the first voluntary national performance and test standards for punchcard, marksense, and direct recording electronic voting systems. Today, 37 States have adopted these national standards or require testing against the standards before a system can be marketed within their boundaries. As a result, the voting systems now reaching those markets are (even according to their designers) greatly improved; State and local officials are better assured that the devices they buy will work accurately and reliably; horror stories are on the decline (and now tend to involve pre-standards equipment, untested equipment configurations, or the mismanagement of tested equipment); and one of the greatest concerns about the integrity of the voting process has been largely put to rest.
Which States require voting systems to meet the FEC As of April 2001, the following States have adopted the FECs voting system standards or require the testing of systems against the standards by independent testing authorities (ITAs) designated by the National Association of State Election Directors:
Who decides if voting equipment meets the voting system standards? The standards call for three levels of tests to be performed on voting systems to ensure that the end product works accurately, reliably, and appropriately:
Qualification tests, conducted by an independent testing authority, encompass:
The scope of qualification testing should not be confused with the vendors developmental testing. Qualification testing is the process whereby a voting system is shown to comply with the requirements of its own design specifications and with the requirements of the standards. The ITA is expected to evaluate the completeness of the vendors developmental test program including the sufficiency of vendor tests conducted to demonstrate compliance with performance specifications. The ITA also performs sample testing of the vendors test modules and designs independent system-level tests to supplement and check those designed by the vendor. Certification tests should be conducted by individual States in order to ensure that the voting system complies with State laws and election practices and is appropriate to the intended environment. Accordingly, certification criteria are not included in the standards since they must be defined by each State. We recommend, however, that they not duplicate the qualification tests but rather include functional tests and qualitative assessments to ensure that the system functions in accordance with State law and practice. Acceptance tests should be performed by the jurisdiction (State or local) procuring the voting system. The purpose of acceptance tests is to ensure that the units delivered to the user conform to the system characteristics specified in the procurement documentation as well as those demonstrated in the in the qualification and certification tests. Some of the operational tests conducted during qualification should be repeated on each unit during the acceptance test. Only through these three testing procedures can local election officials ensure that the voting equipment delivered will function accurately and reliably. How can I determine if voting equipment has met the voting system standards? First, it is important to recognize that the independent testing authorities are not in the business of approving whole companies. Instead, they test and qualify only specific voting systems. Any given vendor may offer both systems that have been tested and systems that have not been qualified. It is essential, then, that you get a description of the configuration, the model number, and the software version of any equipment that you want check up on. There are then three avenues you can take. You can:
Are the current national voting system standards up-to-date? Not entirely. Standards are not permanent. They must evolve alongside technological advancements. Indeed, it is common practice to review and update technical standards every five years or so. The voting system standards, issued in 1990, are no exception to this rule. Vendors are now using new technology and expanding system functions that are not sufficiently covered by the existing standards. Therefore, the FEC is drafting the next version of the standards to cover the newer technology as well as to change standards that currently unduly restrict design. Still in all, the current standards remain for the most part adequate and useful for the purpose of ensuring the accuracy and reliability of voting systems.
Who will update the national voting system standards? The FECs Office of Election Administration (OEA) is drafting the next version of the voting system standards, in conjunction with the National Association of State Election Directors (NASED), the independent test authorities designated by NASED, and technical experts. The FEC plans to offer drafts of the new version for public comment during 2001, incorporate appropriate recommendations, and publish the next version of the standards early in 2002.
During this update process, we anticipate no delays in equipment testing.
May 18, 2001
NASED VOTING SYSTEMS/INDEPENDENT TEST AUTHORITY ACCREDITATION BOARD
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