The Election Assistance Commission has sent this response to Aaron Burstein and Joseph Lorenzo Hall’s comments on the EAC’s Voting System Test Lab and the California Top to Bottom Review of Voting Systems.
Thank you for your letter dated October 13, 2009, concerning the federally accredited Voting System Test Lab’s (VSTL) consideration of the California Secretary of State’s Top-To-Bottom Review (TTBR) in developing the test plan for the Premier Assure 1.2 voting system. The VSTL that tested the Premier Assure 1.2, iBeta Laboratories, closely reviewed the findings of the TTBR during the development of its test plan in accordance with the requirements of EAC’s Testing and Certification program and the “Evolution of Testing” requirement contained in Section 1.5 of the 2002 Voting System Standards (VSS). In addition, the VSTL reviewed the results of the Kentucky, Ohio, and Connecticut Reports which resulted in an update of the Security Test Case to verify that Connecticut’s recommended tamper-resistant seals were incorporated into the Premier Technical Data Package (TDP). The review of the 3 March 2009 California Secretary of State report. was also reviewed as well as the Premier Product Advisory Notices. Finally, please note that the software and firmware versions of each component of the system reviewed by California were an earlier version than that tested by the EAC VSTL. A comparison is listed below for your information.