EAC Decision on Request for Interpretation 2008-06 

(Battery Back Up for Central Count) 

2002 VVSS Volume I, Sections 3.2.2.4c, 3.2.2.5 

2005 VVSG Volume I, Version 1.0, Sections 4.1.2.4c (Electrical 

Supply), 4.1.2.5 (Electrical Power Disturbance) 

Date: 

August 29, 2008 

Question: 

Given the size and power needs of a central count voting system and in light of the 

EAC’s recent Request for Interpretation 2008-02 regarding a battery back up 

requirement, is a central count voting system required to have a battery back up? 

Facts: 

Both sections of the VSS and VVSG as well as the EAC interpretation imply that all 

voting systems require backup power, whether they are central count or precinct level 

systems. Prior to the EAC Decision on Request for Interpretation 2008-02, the 

requirement of 3.2.2.4c was being met by the jurisdiction ability to provide backup power 

and the voting systems being capable of operating for at least 2 hours on that backup 

power. The interpretation added the requirement to the manufactured voting systems that 

the backup power be battery backup. Central counts systems tend to be very large and 

can have very large power requirements, which could not be easily handled by a standard 

UPS unit. 

Section of Standards or Guidelines: 

3.2.2.4c/4.1.2.4c Electrical Supply 

All voting machines shall also be capable of operating for a period of at least 2 hours on 

backup power, such that no voting data is lost or corrupted nor normal operations 

interrupted. When backup power is exhausted the voting machine shall retain the 

contents of all memories intact. 
3.2.2.5/4.1.2.5 (Electrical Power Disturbance) 

Vote scanning and counting equipment for paper-based systems, and all DRE equipment, 

shall be able to withstand, without disruption of normal operation or loss of data: 

a. Surges of 30% dip @10 ms; 

b. Surges of 60% dip @100 ms & 1 sec 

c. Surges of >95% interrupt @5 sec; 

d. Surges of +15% line variations of nominal line voltage; and 

e. Electric power increases of 7.5% and reductions of 12.5% of nominal specified power 

supply for a period of up to four hours at each power level. 

EAC Request for Interpretation 2008-02 

Conclusion: 

This conclusion is intended to amend the EAC’s Request for Interpretation 2008-02 with 

regard to the battery backup requirement for central count optical scan systems. 

Central count systems must meet the requirements of the electrical power disturbance 

standard whether or not that power source is the facilities main power source or backup 

power source. 

However, a central count system cannot assume an uninterrupted transition to facility 

backup power or the availability of facility backup power at all. Central count systems 

are not required to have a 2 hour battery backup. A central count system shall provide for 

a graceful shutdown to allow switching to an alternate power source. The graceful 

shutdown shall meet the following requirements: 

1. All ballots shall reside in either the input or output hopper with no ballots in process at 

the end of the shutdown process. 

2. All ballots in the output hopper shall be fully read and saved. 

3. A report, including the final state of all ballots, timestamps and of the final state of the 

unit, shall be printed or saved in a file. The report shall be part of the permanent election 

record and shall be available when power is restored to the system. 

4. The system shall be capable of resuming operation from the point it stopped once 

power is restored. 

Testing for the graceful shutdown shall maintain ballots in the input hopper through the 

shutdown process. The purpose of this requirement is to confirm that the system will 

stop processing further ballots, complete ballots in process and save a report that 

accurately identifies the final state of the ballots and the system. The second part of the 

test shall restore power to the system and confirm that the system restarts properly and 

that the status report reflects accurately the state of the ballots and the system. 

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