EAC - Voluntary Voting System Guidelines

Name : | Stanley A. Klein
Organization : | N/A
Post Date : | 9/30/2005
General Comments
Comment : | VOTING MACHINE INSECURITY Above and beyond the basic unreliability of voting machines and the likelihood of undetectable, unrecoverable modification or loss of votes, there is the issue of malicious tampering with voting machines and vote tabulation. Lack of Mandatory Vulnerability Testing Negates Provisions The draft VVSG continues numerous requirements from the FEC standards and provides additional requirements for security. However, all of the security requirements of the VVSG are nothing but untested and unenforced platitudes about security. This includes those added to address the serious problem of wireless use in voting systems and those that provide detailed requirements purporting to ensure that the distributed and installed software in the voting machine is the same as the software certified. In particular, none of the security requirements in the draft VVSG is tested seriously enough to ensure that their implementation can not be defeated or bypassed. To properly test for security there are two key activities that security standards have identified: (1) a systematic search for vulnerabilities with mandatory correction of each vulnerability, and (2) mandatory penetration testing by a team of at least specified size and qualifications for at least a specified duration. In the Department of Defense Trusted Computer System Evaluation Criteria, the almost 30yearold “Orange Book”, the more serious B and A divisions of evaluation require penetration testing of 2 to 6 months in duration. By contrast in the VVSG, Volume II, Section 6.4 makes the penetration testing “discretionary”, which means it will likely not happen. This effectively neutralizes and negates all the requirements of Volume I Sections 2.2.1, 2.2.4 (c through j), 2.2.5, 2.6, 6.2, 6.3, 6.4, 6.5, 6.6, and 6.7. Unless these requirements are seriously and intensively tested, they are nothing but window dressing.