This notice of clarification is to clarify the information needed to describe changes to a system accepted in to the testing and certification program as a modification. In addition to the general description currently given as part of the system overview for modifications, each Test Plan and Test Report must include a detailed listing of all the changes made to the modified system. This can be included in the body of the Test Plan and Test Report (if it is a small number of changes); or referred to in the system overview and included as an Appendix (if it is a large number of changes). The detailed description shall include: name of component and/or module, version number and brief description of the change.

This notice of clarification is to clarify the way discrepancies are listed in the Test Report. Discrepancies noted during testing shall be entered in the test report as individual occurrences, not batched based on test case or component. The only discrepancies that may be batched or grouped are source code discrepancies and TDP discrepancies. In addition, even though source code TDP discrepancies may be batched or grouped, the number of occurrences of each identified discrepancy must be tallied and the total number noted in the section for that batch (i.e. source code or TDP).

System validation is an extremely important pre-election and post-election activity. The system identification tools required by the manual are intended for Federal, State, and local officials to identify and verify that the equipment used in elections is unmodified from its EAC certified version.

The replacement of certain obsolete or end-of-life COTS components in an EAC certified voting system with equivalent components is permitted. Using the process outlined above, the equivalence of the replacement components can be demonstrated and be considered for a de minimis classification provided the change meets the requirements of section 3.5 of the EAC’s Program Manual and this clarification. The EAC will continue to monitor the use of COTS products in voting systems and make appropriate changes to its procedures in instances in which it sees minimal risk to voting system integrity and potential cost savings.

In order for a data change to be found de minimis, the change must not materially alter the system’s reliability, functionality, capability, or operation (i.e. meeting the requirements of section 3.5 of the Cerification Manual).  Under no circumstance shall a change to the system’s data be considered de minimis if it has a reasonable and identifiable potential to impact the system’s performance and compliance with applicable voting system standards.

Test Plans submitted for modifications to previously EAC certified voting systems should be brief and structured to minimize test plan development and review, while enabling the EAC to maintain solid control of the certification process. The test plan shall concisely document the strategy and plan for testing those sections of the VVVSG applicable to the modification or modifications submitted. The test plan shall be written with clarity that will allow all constituents to understand what testing will be conducted, to verify compliance to VVSG requirements, and to assure that the test plan will remain a living document throughout the life of the test campaign for the modification.

The goal of this NOC is to guide the production of test reports that are clearer and more comprehensive by documenting:- All the components, and necessary information that comprise the version and configuration of hardware, software and COTS needed for the evaluation of the voting system;- The completeness and comprehensiveness of the testing performed; - The adequacy of the testing performed; and- The results of all the testing performed.All such information needs to be provided with clarity, completeness and without ambiguity, so that a wide range of readers and users of the document will be able to understand the evaluation that supports a system’s certification

 A change to a voting system’s TDP can be considered de minimis provided the change meets the requirements of section 3.5 of the EAC’s Program Manual. Changes to the TDP that have the potential to effect the reliability, functionality, capability, and operability of a system will not be considered de minimis and must pass modification testing before being approved.

The EAC’s Program Manual states in part, “Participation [in testing] includes but is not limited to the observation of testing by the Manufacturer.” The purpose of this statement is to reiterate that under no circumstances can a voting system manufacturer be present in the testing room while certification testing is being conducted. This prohibition is in place to ensure that the conformance testing being conducted is an independent evaluation of the system to the standards without influence or interference by the manufacturer. The EAC does recognize that in some cases there is value in allowing manufacturers to witness a particular test or a re-creation of a test in order to allow them to comment on the proper system set up or operation. However, any such participation must be (1) at the discretion of the VSTL, (2) supervised by the VSTL and (3) clearly documented in order to maintain laboratory independence.- halting an active certification test and bringing the manufacturer into the testing room for a re-creation of the test being performed- creating for the manufacturer either a closed circuit video feed or a web cam feed to allow for real-time correspondence during testing- supervised access prior and during the testing to perform unscheduled and non-routine maintenance

Clarification appears necessary to further describe the expected depth and completeness of the test plan that is necessary to help ensure that a comprehensive test campaign is carried out and to help ensure that test campaigns are consistent among different VSTLs. The test plan shall document the strategy and plan for testing each section of the applicable voluntary voting system guidelines and is to be used as a key tool to manage the test campaign and to verify that a voting system or component meets all VVSG and program defined requirements. The test plan shall be written with completeness and clarity that will allow all constituents to understand what testing will be conducted, to assess each group of VVSG requirements, and to assure that the test plan will remain a living document throughout the life of the test campaign. The objective is to address each section (in both Volume I and Volume II of the 2005 VVSG) in detail, and to clearly and succinctly describe the strategy and/or approach for testing each section