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Election Assistance Commision

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The
VVSG contains considerable new material and material expanded
from previous versions of the voting standards. This section
provides an introduction to and overview of major features of
the VVSG, those being
- organization
of the VVSG, requirements structure, and classes;
-
usability performance benchmarks;
-
expanded human factors coverage;
- Software
Independence, Independent Voter Verified Records voting
systems, and the Innovation Class;
-
open-ended vulnerability testing and expanded security coverage;
-
treatment of COTS
in voting system testing;
-
end-end testing for accuracy and reliability;
-
new metric for voting system reliability;
-
expanded core requirements coverage.
The
VVSG structure is markedly different from the structure of previous
versions. First and foremost, the VVSG should be considered as
a foundation for requirements for voting systems; it is a foundation
that provides precision, that reduces ambiguity and multiple repeated
requirements, and that provides for change, i.e., the addition
of new requirements for new types of voting devices or voting
variations.
It was necessary to focus on providing this robust foundation
for several reasons. First, previous versions suffered from ambiguity,
which resulted in a less-robust testing effort. In essence, it
has been more difficult to test voting systems when the requirements
themselves are subject to multiple interpretations. This new
version should go a long way towards reducing that ambiguity.
Secondly, there are simply more different types of voting devices
than anticipated by previous versions, and new devices will continue
to be marketed as time goes by. This proliferation of new devices
required a strong organizational foundation so that existing devices
could be unambiguously described and so that the development of
new devices can proceed in an orderly, structured fashion.
The
VVSG has been reorganized to bring it in line with applicable
standards practices of ISO, W3C and other standards-creating organizations.
It contains 3 volumes or "Parts" for different types
of requirements:
- Part
1, Equipment Requirements, provides guidelines for
manufacturers to produce voting systems that are secure, accurate,
reliable, usable, accessible, and fit for their intended use.
Part 1 sets a precedent where requirements in VVSG 2005 that
were ambiguous have been clarified. In those cases where no
precise replacement could be determined and no testing value
could be ascribed, requirements have been deleted.
- Part
2, Documentation Requirements, is a new section containing
documentation requirements separate from functional and performance
requirements applying to the voting equipment itself. It contains
requirements applying to the Technical Data Package, the Voting
Equipment User Documentation, the Test Plan, the Test Report,
the Public Information Package, and the data for voting software
repositories.
- Part
3, Testing, contains requirements that apply to the
national certification testing to be conducted by non-governmental
certified testing laboratories. It has been reorganized to focus
on test
methods and avoid repetition of requirements from the
product standard. Although different testing specialties are
likely to be subcontracted to different laboratories, the prime
contractor must report to the certifying authority on the conformity
of the system as a whole.
The
requirements in these Parts rely on definitition and strict usage
of certain terms, included in Appendix
A, Definition of Words with Special Meaning in the VVSG.
This covers terminology for standardization purposes that must
be sufficiently precise and formal to avoid ambiguity in the interpretation
and testing of the standard. Terms are defined to mean exactly
what is intended in the requirements of the standard, no more
and no less. Note: Readers may already be familiar
with definitions for many of the words in this section, but the
definitions here often may differ in small or big ways from locality
usage because they are used in special ways in the VVSG.
The
VVSG also contains a table of requirement summaries, to be used
as a quick reference for locating specific requirements within
sections/subsections. Appendix B contains references and end
notes.
Voting
system and device classes are new to the VVSG. Classes in essence
form profiles of voting systems and devices. They are used as
fields in requirements and they connote what the requirement applies
to. For example, Figure 1 shows the high-level device class called
vote-capture
device. There are various requirements that apply to
vote-capture
device; this means that all vote-capture
devices must satisfy these requirements (e.g., for security,
usability, etc.).
There
are also requirements that apply more specifically to, say, IVVR
vote-capture device and those explicit devices underneath
it, such as VVPAT.
These devices inherit the requirements that apply to Vote-capture
device, that is, they must satisfy all the general Vote-capture
device requirements as well as the more specific requirements
that apply. In this way, new types of specific Vote-capture
devices can be added in the future; they must satisfy
the general requirements that all Vote-capture
devices are expected to satisfy, but at the same time
they can satisfy specific requirements that only apply to the
new device. This structure assists in unambiguously making it
clear to vendors and test labs which requirements apply to ALL
Vote-capture
devices, for example, as opposed to which requirements
apply specifically to just VVPAT
systems. This structure also allows for the addition or modification
of new or existing device requirements without impacting the rest
of the standard.
Figure
1: Voting device class hierarchy

Requirements
are now very specific to either a type of voting
variation or a type of voting device (as stated in the
previous section, the voting device can be a general profile of
voting devices or a more specific voting device). They contain
expanded text and more precise language to make explicit what
exactly is required and what type of testing is to be used by
the test lab to determine whether the requirement is satisfied.
If possible, the requirement also contains a reference to versions
of the requirement in previous standards (e.g., VVSG 2005 or the
2002 VSS) so as to show its genesis and to better convey its purpose.
The
terminology used in the VVSG has been considered carefully and
is used strictly and consistently. In this way, requirements
language can be made even more clear and unambiguous. Hypertext
links are used throughout the VVSG for definitions of terminology
so as to reinforce the importance of understanding and using the
terminology in the same way.
However, it is important to understand the terminology used in
the VVSG is specific to the VVSG. An effort has been made to
make sure than the terms used in the VVSG mean essentially the
same thing as used in other contexts, however at times the definitions
in the VVSG may vary in big or small ways.
Figure
2 illustrates the relationships and interaction between requirements,
device classes, types of testing from Part 3, all in the framework
of strictly used terminology.
Figure
2: Interaction between requirements, definitions, and parts of
the VVSG

Usability
Performance Requirements
Usability
is conventionally defined as: "the extent to which a product
can be used by specified users to achieve specified goals with
effectiveness, efficiency and satisfaction in a specified context
of use" ([ISO98a]
ISO 9241-11: 1998 Ergonomic requirements for office work with
visual display terminals (VDTs) -- Part 11: Guidance on usability).
In VVSG'05, the usability guidelines basically relied on three
assessment methods:
- checking
for the presence of certain design features which are believed
to support usability, and for the absence of harmful design
features,
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checking for the presence of certain functional capabilities
which are believed to support usability, and
-
requiring vendors to perform summative
usability testing with certain classes of subjects and
to report the results. However, these reporting requirements
do not specify the details of how the test is designed and conducted.
While
all these help to promote usability, they are all somewhat indirect
methods. The actual "effectiveness, efficiency and satisfaction"
of voting systems are never evaluated directly.
This version of the VVSG uses a new method based on summative
usability testing that directly addresses usability itself:
how well do users achieve their goals? The features of this new
method include:
- the
definition of a standard testing protocol, including a test
ballot, set of tasks to be performed, and demographic characteristics
of the test participants. The protocol supports the test procedure
as a repeatable controlled experiment,
-
the use of a substantial number of human subjects attempting
to perform those typical voting tasks on the systems being tested,
in order to achieve statistically significant results,
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the gathering of detailed data on the subjects' task performance,
including data on accuracy, speed, and confidence,
-
the precise definition of the usability metrics to be derived
from the experimental data,
-
the definition of effectiveness benchmarks
against which systems will be evaluated.
Obviously,
the implementation of such complex tests is more difficult than
simply checking design features. However, performance-based testing
using human subjects yields the most meaningful measurement of
usability because it is based on their interaction with the system's
voter interface, whereas design guidelines, while useful, cannot
be relied upon to discover all the potential problems that may
arise. The inclusion of requirements for performance testing
in these guidelines advances the goal of providing the voter with
a voting system that is accurate, efficient, and easy to use.
Table
1 shows all five benchmarks;
the actual values are included in Part 1 Section 3.2.1. Please
see this section for full details.
Tabe
1: Usability performance benchmarks
| Benchmark
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Used
to Pass/Fail
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Description
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Total
Completion Score
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Yes
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The
proportion of users who successfully cast a ballot.
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Voter
Inclusion Index
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Yes
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A
measure of voting accuracy and variance, based on the
mean accuracy per voter and the associated standard deviation.
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Perfect
Ballot Index
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Yes
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The
ratio of the number of cast ballots containing no erroneous
votes to the number containing one or more errors.
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Average
Voting Session Time
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No
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The
mean time taken per voter to complete the process of activating,
filling out, and casting the ballot.
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Average
Voter Confidence
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No
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The
mean confidence level expressed by the voters that the
system successfully recorded their votes.
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Expanded
Usability and Accessibility Coverage
In
addition to usability performance benchmarks
, the treatment of human factors, i.e., usability, accessibility,
and privacy, has been expanded considerably. Table 2 summarizes
the new and expanded material.
Table
2: Expanded human factors coverage
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Human
Factors Topic
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Description
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Voter-Editable
Ballot Device
|
The
VVSG defines a new class of voting station: Voter-Editable
Ballot Device (VEBD). These are voting systems such as
DREs and EBMs that present voters with an editable ballot
(as opposed to manually-marked paper ballots), allowing
them easily to change their choices prior to final casting
of the ballot.
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Ballot
Checking and Correction
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Requirements
for both interactive and optical-scan based ballot checking
and correction (so-called "voter's choice" issues).
There is a new requirement for detection and reporting
of marginal marks.
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Notification
of Ballot Casting
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Requirements
to notify the voter whether the ballot has been cast successfully.
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Plain
Language
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Requirements
for the use of plain language when the voting system communicates
with the voter. The goal is to make the instructions
for use of the system easier to understand and thus improve
usability.
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Icons
and Language
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New
requirement that instructions cannot rely on icons alone;
they must also include linguistic labels.
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Choice
of Font and Contrast
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Requirements
for the availability of the choice of font size and contrast
on VEBDs.
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Legibility
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Legibility
for voters with poor reading vision has been strengthened
from a recommendation to a requirement.
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Timing
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Requirements
on the timing for interactive systems. Addresses the response
time of system to the user (no undue delay) and mandates
that systems issue a warning if there is lengthy user
inactivity.
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Alternative
Languages
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This
entire section has been expanded and clarified.
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Poll
Workers
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Addresses
usability for poll workers as well as for voters. Vendors
are required to perform usability testing of system setup,
operation, and shutdown. System safety is addressed
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End-to-end
Accessibility
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New
requirement to ensure accessibility throughout the entire
voting session.
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Accessibility
of Paper Records
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Requirements
address the need for accessibility when the system uses
paper records as the ballot or for verification. In particular,
an audio readback mechanism is required to ensure accessibility
for those with vision problems.
|
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Color
Adjustment
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Consolidated
and clarified material on color adjustment of voting station.
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Synchronized
Audio and Video
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Mandates
the availability of synchronized audio and video for the
accessible voting station. The voter can choose any of
three modes: audio-only, visual-only, or synchronized
audio/video.
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Adjustability
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Clarified
that when the voter can control or adjust some aspect
of voting station, the adjustment can be done throughout
the voting session.
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Software
independence [Rivest06]
means that an undetected error or fault
in the voting system's software is not capable of causing an undetectable
change in election results. All voting systems must be software
independent in order to conform to the VVSG.
There are essentially two issues behind the concept of software
independence, one being that it must be possible to audit
voting systems to verify that ballots are being recorded correctly,
and the second being that testing software is so difficult that
audits of voting system correctness cannot rely on the software
itself being correct. Therefore, voting systems must be "software
independent"so that the audits do not have to trust that
the software is correct; the voting system must provide other
proof that the ballots have been recorded correctly, e.g., voting
records produced in ways in which their accuracy does not rely
on the correctness of the voting system's software.
This is a major change from previous versions of the VVSG, because
previous versions permitted voting systems that are software dependent,
that is, voting systems whose audits must rely on the correctness
of the software, to be conformant. One example of a software
dependent voting system is the DRE,
which is non-conformant to the VVSG.
There
are several general types of voting systems that can satisfy the
definition of software
independence, but the VVSG currently contains requirements
for only one: those types of voting systems that use voter-verifiable
paper records (VVPR),
such as with
The
relevant requirements, though, have been abstracted to apply to
a higher-level type of voter-verifiable records called independent
voter-verifiable records (IVVR),
which can be audited independently of the voting system software
much the same as with VVPR but do not necessarily have to be paper-based.
IVVR
relies on voter-verification, that is, the voter must verify that
the electronic record is being captured correctly by examining
a copy that is maintained independently of the voting system's
software, i.e., the independent voter-verifiable record.
NOTE:
If different types of IVVR
are developed that do not use paper, systems that use them can
also be conformant to the VVSG "as is.". In other words,
new types of IVVR
that do not use paper are already "covered"by the IVVR
requirements in the VVSG; new requirements do not necessarily
need to be added.
Figure 3 illustrates this in a tree-like structure. At the top
of the tree is software
independence; as stated previously all voting systems
that are conformant to the VVSG must be software independent.
One route to achieving software
independence is to use IVVR.
The VVSG contains requirements for IVVR,
of which VVPR
is one (ccurently the only) type. New types of IVVR
voting systems, as long as they meet the current requirements
in the VVSG, will also be conformant to the VVSG without needing
to add additional requirements.
Figure
3: Voting systems that can conform to current requirements in
the VVSG

Use
of IVVR
is currently the only method specified by requirements in the
VVSG for achieving software
independence. Vendors that produce systems that do NOT
use IVVR
must use the Innovation Class as a way of proving and
testing conformance to the VVSG. The innovation class is for
the purpose of ensuring a path to conformance for new and innovative
voting systems that meet the requirement of software
independence but for which there may not be requirements
in the VVSG. Technologies in the innovation class must be different
enough to other technologies permitted by the VVSG so as to justify
their submission. Technologies in the innovation class must
meet the relevant requirements of the VVSG as well as further
the general goals of holding fair, accurate, transparent, secure,
accessible, timely, and verifiable elections.
A review panel process, separate from the VVSG conformance process,
will review innovation
class submissions and make recommendations as to their
eventual conformance to the VVSG.
The
goal of open-ended vulnerability testing (OEVT) is to discover
architecture, design and implementation flaws in the system which
may not be detected using systematic functional, reliability,
and security testing and which may be exploited to change the
outcome of an election, interfere with voters' ability to cast
ballots or have their votes counted during an election,
or compromise the secrecy of vote. The goal of OEVT also includes
attempts to discover logic bombs, time bombs or other Trojan Horses
that may have been introduced in the system hardware, firmware
or software for said purposes. Open-ended vulnerability testing
(OEVT) relies heavily on the experience and expertise of OEVT
team members, their knowledge of the system, its component devices
and associated vulnerabilities, and their ability to exploit those
vulnerabilities.
In
addition to software
independence and OEVT, the treatment of security in voting
systems has been expanded considerably. There are now detailed
sets of requirements for eight aspects of voting system functionality
and features, as shown in Table 3.
Table
3: Expanded security coverage
|
Security
Topic
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Description
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Cryptography
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Requirements
relating to use of cryptography in voting systems, e.g.,
use of U.S. Government FIPS standards
|
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Setup
Inspection
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Requirements
that support the inspection of a voting device to determine
that: (a) software installed on the voting device can
be identified and verified; (b) the contents of the voting
device's registers and variables can be determined; and
(c) components of the voting device (such as touch screens,
batteries, power supplies, etc.) are within proper tolerances,
functioning properly, and ready for use.
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Software
Installation
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Requirements
that support the authentication and integrity of voting
system software using digital signatures provided by test
labs, National Software Reference Library (NSRL), and
notary repositories.
|
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Access
Control
|
Requirements
that address voting system capabilities to limit and detect
access to critical voting system components in order to
guard against loss of system and data integrity, availability,
confidentiality, and accountability in voting systems.
|
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System
Integrity Management
|
Requirements
that address operating system security, secure boot loading,
system hardening, etc.
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Communications
Security
|
Requirements
that address both the integrity of transmitted information
and protect the voting system from communications based
threats.
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System
Event Logging
|
Requirements
to address system event logging to assist in voting device
troubleshooting, recording a history of voting device
activity, and detecting unauthorized or malicious activity.
|
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Physical
Security
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Requirements
that address the physical aspects of voting system security:
locks, tamper-evident seals, etc.
|
To
clarify the treatment of components that are neither manufacturer-developed
nor unmodified COTS
(commercial off-the-shelf software/hardware) and to allow different
levels of scrutiny to be applied depending on the sensitivity
of the components being reviewed, new terminology has been introduced:
application
logic, border
logic, configuration
data, core
logic, COTS,
hardwired
logic, and third-party
logic. Using this terminology, requirements have been
scoped more precisely than they were in previous iterations of
the VVSG.
The way in which COTS
is tested has also changed; the manufacturer must deliver the
system to test without the COTS
installed, and the test lab must procure the COTS
separately and integrate it.
End-to-End
Testing for Accuracy and Reliability
The
testing specified in previous versions of the VVSG for accuracy
and reliability is not required to be end-to-end
but may bypass significant portions of the system that would be
exercised during an actual election, such as the touch-screen
or keyboard interface. A volume
test is now included that is analogous to the California
Volume Reliability Testing Protocol.
The
metric for reliability has been changed from Mean Time Between
Failure
(MTBF) to a failure
rate based on volume that varies by device class and severity
of failure.
Reliability, accuracy, and probability of misfeed are now assessed
using data collected through the course of the entire test campaign,
including the volume testing. This increases the amount of data
available for assessment of conformity to these performance requirements
without necessarily increasing the duration of testing.
The
general core requirements for voting systems has been expanded
greatly. In addition to the already noted improvements in COTS
coverage, end-to-end
testing for accuracy and reliability, and the new reliability
metric, the following topics in Table 4 have been added or expanded.
Table
4: Expanded core coverage in the VVSG
|
Core
Topic
|
Description
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EBMs
|
Updates
to handle EBMs and early voting.
|
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Early
voting
|
Updates
to handle EBMs and early voting.
|
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Coding
conventions
|
Major
revisions to coding conventions.
|
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EMC
|
Major
revisions to EMC requirements.
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QA
and CM
|
Major
revisions to quality assurance and configuration management
requirements.
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Humidity
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New
operating tests for humidity.
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Logic
verification
|
Added
logic verification for core logic.
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