If this is like past VVSG comments, they'll have a on-line section by
section commenting tool but will also allow narrative submissions.
FYI: We've submitted narrative and section-by-section comments for our
NSF ACCURATE center twice in the past:
http://josephhall.org/papers/2005_vvsg_comment.pdf
http://josephhall.org/papers/accurate_vvsg2_comment_final.pdf
best, Joe
On Tue, Jun 2, 2009 at 6:55 AM, David RR Webber (XML) <> wrote:
> John,
> Great idea. I guess for format - just note Page # and paragraph - and then
> put comment below each item?
>
> Thanks, DW
>
> -------- Original Message --------
> Subject: [election-services] Fw: [Fwd: VVSG v.1.1 documents]
> From: John Borras <>
> Date: Tue, June 02, 2009 4:38 am
> To: EML TC <>
>
> Colleagues
>
> For information and review please. Can I suggest we put in a single
> response from the TC so if you would let me have your comments, say by the
> end of June, I'll co-ordinate them and send in our response.
>
> Regards
> John
>
> M. +44 (0)7976 157745
> Skype: gov3john
>
> ----- Forwarded Message ----
> From: P.Gannon <>
> To: "Borras, John" <>
> Sent: Tuesday, 2 June, 2009 2:39:21
> Subject: [Fwd: VVSG v.1.1 documents]
>
> John,
>
> You may want to forward this notice and attached documents to the OASIS E&VS
> TC for the 120 public comment period on the US Voluntary Voting System
> Guidelines (VVSG) version 1.1.
>
> Best regards,
>
> -- Patrick Gannon +1 978 458 7478 (office) +1 408 242
> 1018 (mobile)
>
>
> -------- Original Message --------
> Subject: VVSG v.1.1 documents
> Date: Mon, 1 Jun 2009 15:15:09 -0400
> From:
> To: , ,
> , , ,
> , , ,
> , , ,
> , , ,
> ,
>
>
> June 1, 2009
>
>
> Technical Guidelines Development Committee Members,
>
>
> I wanted to write and notify you of the Election Assistance Commission’s
> (EAC) official submission of Voluntary Voting System Guidelines (VVSG)
> version 1.1 for review and comment by the Standards Board and Board of
> Advisors per section 222 of the Help America Vote Act (HAVA). The attached
> document represents the EAC’s purposed revision to the 2005 VVSG (v1.0.).
> The submission of the EAC’s purposed amendments to the VVSG to the Executive
> Board of the Standards Board and to the EAC’s Board of Advisors marks the
> opening of the official public comment period for VVSG v. 1.1. This comment
> period will run for 120 days and will conclude on September 28th, 2009. At
> the conclusion of the 120-day public comment period, the EAC and NIST will
> review the comments received on VVSG v.1.1, and will issue the revised
> guidelines in late 2009.
>
> Why the revision is needed
> The guidelines are being revised to improve the quality and efficiency of
> testing performed under the EAC testing and certification program by
> including new software development and testing protocols and practices. This
> includes the development of uniform test suites by the National Institute of
> Standards and Technology (NIST). This revision will also clarify several
> ambiguities in the standard, providing test labs and voting system
> manufacturers with a clearer sense of performance and test requirements for
> EAC certification.
>
> The proposed revisions are largely informed by the work done by you the
> TGDC, when you issued your recommendations for the next iteration of the
> VVSG, and the thousands of public comments on the recommendations that the
> EAC received. The EAC also held seven roundtable discussions with groups of
> stakeholders to gather additional information on the recommendations.
>
> By revising the guidelines now, the EAC expects to improve the test process
> over the short term while allowing additional time to develop more complex
> revisions to be included in the second complete iteration of the guidelines,
> the VVSG version 2.0 (TGDC Recommendations, August 31st, 2007).
>
> Areas to be revised
> The EAC and NIST selected the revisions based on their ability to yield
> immediate and marked improvements to the test process and be implemented
> with relative ease. Moreover, the revisions do not require any hardware
> changes or significant software changes to existing systems, and can be
> adopted without extended research.
>
> The proposed revisions are to usability and accessibility, security, and
> core areas such as software workmanship. Following is a complete list of the
> areas to be revised:
>
> Hardware and software performance benchmarks and test method
> Software workmanship
> Test plan and test report
> TDP and voting equipment user documentation
> Non-EMC environmental hardware
> Human factors requirements
> System security documentation requirements
> Election records
> Voter verified paper audit trails (VVPAT)
> Cryptography
> External interface requirement
> EAC requests for interpretation (RFI) decisions
> General edits
>
> I want to encourage you to please review and comment on the purposed
> revisions. As I mentioned above, many of the revisions come as a result of
> your effort in creating the TGDC recommendations for the Next Iteration and
> your comments will prove invaluable as the EAC works to complete this work
> prior to the end of 2009. If you have any questions please do not hesitate
> to contact me at any time. Thank you.
>
>
> Donetta L. Davidson
> Commissioner
> United States Election Assistance Commission
> 1225 New York Avenue, NW
> Suite 1100
> Washington, DC 20005
> (202) 566-3100
> (202) 566-1392 (fax)
>
>
> (202)566-2365
>
> ________________________________
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--
Joseph Lorenzo Hall
ACCURATE Postdoctoral Research Associate
UC Berkeley School of Information
Princeton Center for Information Technology Policy
http://josephhall.org/