EAC - Voluntary Voting System Guidelines

Name : | James C. Johnson III
Organization : | N/A
Post Date : | 9/9/2005
General Comments
Comment : | Simple measures such as: ensuring that after certification testing systems are closed and cannot be manipulated; disallowing the use of wireless (optical and RF) communications on Election Day; use of encryption and strong authentication between all communicating components was not required; and a written prohibition against allowing software on voting system equipment that it did not undergo certification testing with. These are examples of some of the precautions that were presented to IEEE and the TGDC and rejected by both without justification. I hope that the EAC will have the VVSG specification reviewed by security experts and the language within the specification strengthened in a manner that compliance can be easily determined and enforced. It is also a concern that this morning the EAC adopted certification procedures based on a model used by the FCC. The FCC procedures are inappropriate for certifying voting systems where the threat model is considerably different. A more appropriate starting point would have been standards used in the gaming and banking industries where there are similar threats of fraud by making changes to the data being collected and managed by the system. Mr. Berger’s colleague from TEM Consulting even pointed out that FCC does not conduct performance testing only for RF emissions. It is interesting that the security measures required by these standards are much more stringent than the ones used for voting. Without access to the vendor’s source code, software escrow at NIST will be extremely limited in value. Counting votes is not rocket science and does not require complex proprietary procedures that require independent discovery by different vendors. Also submitting source to NIST does not constitute public disclosure if this is a concern of manufacturers. By submitting binaries the possibility of an outside check on the logic is all but eliminated.