Verified Voting Public Commentary

Comments and responses to documents and proposals from the EAC, NIST and other organizations and agencies.

Verified Voting Blog: Verified Voting Comment on Los Angeles County VSAP 2.0 Certification

The following is a comment on the certification process for Los Angeles County’s VSAP 2.0 system. To view a pdf, click here.

Los Angeles County Voting Systems for All People (VSAP) 2.0 Certification
Comment of Pamela Smith, Senior Advisor, Verified Voting

January 20, 2020 Verified Voting commends Los Angeles County for the decade-long process of reimagining a voting system that must effectively serve the nation’s most populous and most diverse voting jurisdiction, as that system approaches certification and use in California’s upcoming elections. We have appreciated the opportunity to participate on the County’s Technical Advisory Committee since it was established and provide vigorous comment through the development process. We also appreciate the changes brought about by California’s lawmakers and Secretary of State Padilla to establish a more rigorous set of requirements for testing and examination of voting systems prior to approval for use. We believe, however, that there is a gap in the certification process that must be addressed for it to be fully transparent and to enable the public to more fully understand voting system compliance with California’s requirements.

The California Voting System Standards (CVSS)1 framework is supported by a set of regulations1 which govern a sequence of events for certification of a system, from application and provision of documentation and system/s for test, to a series of tests by qualified testing entities on security, software, functionality and more, to a set of reports to be published prior to a public hearing and comment period, and to eventual approval or denial of certification.

The required publications include test reports from the involved testing authorities, and a staff report from the Office of Voting Systems Technology Assessment (OVSTA). Reviewing these reports show test results that are characterized as failing or not complying with requirements in some instances, while the subsequent Staff report indicates that the system is in compliance, which seems contradictory at best, and it is not clear to the public how to reconcile those reports. Read More

Verified Voting Blog: Verified Voting Comments on proposed amendments to Georgia State Election Board rules

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Verified Voting welcomes the opportunity to comment on the proposed amendments to Georgia’s State Election Board rules published on December 19, 2019. These amendments are wide-ranging, and we recognize that substantial work has gone into drafting them. Our comments focus on certain aspects especially relevant to cybersecurity and election verification. We substantially endorse the comments jointly submitted by the Brennan Center and Common Cause, but we have prepared these comments separately and more briefly.

Georgia’s new statewide voting system combines ballot marking devices, printers, and scanners on an unprecedented scale. The new system raises questions about voter verification and resilient election procedures about which little direct evidence exists. Accordingly, our recommendations our based on our review of this preliminary research recognizing that more research needs to occur.

Rule 183-1-12-.10 Before the Opening of the Polls

Voters will be instructed to verify their ballots, but it is unclear where or how. Providing a “station” for voters to verify their ballots – ideally, with good lighting and a magnifying glass available for any who need it – will help some voters to do so, and will encourage others even if they prefer not to use the station.

  • We recommend that election superintendents provide a verification station and/or otherwise accommodate voter verification in every polling place (and advance voting location).
  • We recommend that election superintendents provide a combination of interventions, some of which are described below, to encourage voters to check the accuracy of the printed ballots.

Read More

Verified Voting Blog: Letter to North Carolina Board of Elections Regarding Certification Waiver for ES&S EVS 5.2.4.0

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Dear Members of the North Carolina Board of Elections,

I am writing to you in my capacity as President of Verified Voting. Please forgive the lateness of the communication as I only recently learned of your meeting today. I am writing to urge the State Board of Elections to proceed with caution and decline to waive certification requirements for the ES&S EVS 5.2.4.0 to allow Mecklenburg County to purchase uncertified ExpressVote HW2.1 ballot marking devices (“BMDs”) for all voters. Not only would such a decision run contrary to North Carolina statutory law, but the failure to carefully examine the differences between this system and the certified system could needlessly expose Mecklenburg County to increased security risks in the upcoming election. Because Mecklenburg County insists on buying computerized ballot marking devices for all voters, the increased risk to North Carolina voters is grave indeed.

As we discuss more fully below, the differences between the two systems in both software and hardware are substantial. We believe elevating the security risk is needless because Mecklenburg County has other options in two certified systems by two other vendors. Additionally, in our view, there is time for Mecklenburg to institute a more secure system in which voters primarily mark paper ballots with a pen and the county also supplies sufficient operable ballot marking devices for voters who need or wish to use them. According to the Board, a prerequisite to use of the certified ES&S system in Mecklenburg County is the use of the system in at least one precinct in the November 2019 election. That has apparently already occurred with ExpressVote HW1.0 ballot marking device. To avoid waiving any legislative requirements, Mecklenburg could institute hand-marked paper ballots that are scanned by the DS 200 and BMDs with the vendor’s existing supply of BMDs. If the vendor represents that it does not have enough systems to even supply a small number of BMDs for each precinct, the State Board of Elections should consider the vendor’s presentation of the system for certification as offered in bad faith, especially if the vendor knew it would no longer manufacture that version of its equipment and would be unable to adequately supply counties that chose it. Read More

Verified Voting Blog: Statement to House Committee on Science, Space, and Technology Joint Investigations & Oversight and Research & Technology Subcommittee

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Chairwoman Sherrill, Ranking Member Norman, Chairwoman Stevens, Ranking Member Baird and committee members, thank you for the invitation to submit a written statement in connection with the Joint Investigations & Oversight and Research & Technology Subcommittee Hearing on “Election Security: Voting Technology Vulnerabilities.” Our statement will focus on 1) a brief overview of technologies in use for election administration; 2) describe some of the risks associated with those technologies as well as solutions for mitigating those risks; 3) review the role that NIST and other agencies have played in developing technologies for secure elections; and 4) suggest regulatory changes necessary to address advances in voting technology and the changing threat model facing our elections.

The scale and scope of threats to U.S. elections go far beyond what the current federal policy framework can address. Since the Help America Vote Act was passed, technology has advanced and the security threat landscape has also evolved. It’s time to re-think the regulatory framework to align it with the current environment. Your committee plays a crucial role in shaping our collective response. We urge the committee to take the steps necessary to enact mandatory security measures for all technology that touches election administration, to ensure that the foundation of our democracy is protected from ongoing threats. Read More

Verified Voting Blog: Verified Voting Public Comments on VVSG 2.0 Principles and Guidelines

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Verified Voting is pleased to see the VVSG 2.0 principles and guidelines finally moving forward. We are enthusiastic about the VVSG 2.0 structure and, with some reservations, about the content of the principles and guidelines. Full implementation of the VVSG 2.0 will, in time, help bring about voting systems that set new standards for universal usability, security, and verifiability. All these properties – backed by sound procedures – are essential to enable officials to run resilient elections, and to reassure voters that their votes have been cast as intended and counted as cast.

We urge the EAC to allow the technical requirements and test assertions to be approved and revised without a vote of the commissioners. We agree with the TGDC, the NASED executive council, and others that for several reasons, these documents are best managed by technical staff, adhering to a well-defined process with broad consultation and opportunity for public comment.

Verification and the VVSG

Verified Voting especially welcomes Principle 9, which stipulates that a voting system “is auditable and enables evidence-based elections,” and the associated guidelines. No matter how otherwise usable and reliable a voting system may be, it is unacceptably dangerous if it cannot provide trustworthy, software-independent evidence that people’s votes have been accurately recorded and counted.

A voting system alone can “enable” evidence-based elections but cannot provide them. As Philip Stark and David Wagner wrote in their seminal paper, the basic equation is that “evidence = auditability + auditing.” A voting system with a voter-verifiable audit trail, such as a voter-marked paper ballot, provides auditability. Compliance audits to ensure that the audit trail is substantially complete and accurate, and risk-limiting tabulation audits of the audit trail, provide actual evidence that outcomes are correct. Read More

Verified Voting Blog: Verified Voting Testimony before the Allegheny County Pennsylvania Board of Elections

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Thank you, Chairman Baker and members of the Board, for allowing Verified Voting to submit written testimony in connection with the Public Meeting on the Purchase of Voting Systems. We hope to provide background on the security needs that counsel for the adoption of a new voting system with a verifiable and auditable paper ballot, and provide some high-level recommendations for consideration by the Board as it deliberates the purchase of new voting equipment for Allegheny County.

The Scope of the Problems with Election Security and Current Election Infrastructure

Election administration depends on computers at multiple points in the election process. Equipment for voting is but one part of a broad array of election technology infrastructure that supports the conduct of elections today. Some of that technology infrastructure includes voter registration databases, internet facing applications such as online voter registration and polling place lookup, network connections between state government and local jurisdictions, the computers that program the voting devices that record and count votes in addition to the voting devices themselves. Some jurisdictions also use electronic poll books to check voters in at polling sites and most states and localities report election night returns via a website.

To the extent that any of these can be compromised or manipulated, can contain errors, or can fail to operate correctly—or at all—this can potentially affect the vote. Election system security requires not only efforts to prevent breaches and malfunctions, but also fail-safes that address breaches or malfunctions that do occur and procedures to confirm the correctness of election outcomes. Read More

Verified Voting Blog: Verified Voting Testimony Before the House Administration Committee hearing on “Election Security”

Download the Written Testimony (pdf)

Chair Lofgren, Ranking Member Davis and members of the Committee, thank you for the invitation to submit testimony to the Committee on House Administration hearing on “Election Security.” We urge the Committee to move expeditiously to support state and local jurisdictions in strengthening their election systems and provide upfront and sustained investment in election infrastructure and security. Since 2016, it is clear that the threat to our democratic institution of voting is not theoretical, but real and persistent. We must, as a nation, adopt the clear solutions that will allow us to defuse the destructive narrative of election hacking that undermines the very fabric of our democracy.

The Scope of the Problems with Election Security and Current Election Infrastructure

Election administration depends on computers at multiple points in the election process. Equipment for voting is but one part of a broad array of election technology infrastructure that supports the conduct of elections today. Some of that technology infrastructure includes voter registration databases, internet facing applications such as online voter registration and polling place lookup, network connections between state government and local jurisdictions, the computers that program the voting devices that record and count votes in addition to the voting devices themselves. Some jurisdictions also use electronic poll books to check voters in at polling sites and most states and localities report election night returns via a website.

To the extent that any of these can be compromised or manipulated, can contain errors, or can fail to operate correctly—or at all—this can potentially affect the vote. Election system security requires not only efforts to prevent breaches and malfunctions, but also fail-safes that address breaches and malfunctions that do occur. Read More

Verified Voting Blog: Verified Voting Testimony before the Pennsylvania Senate State Government Committee

Written Testimony of Verified Voting President Marian K. Schneider before the Pennsylvania Senate State Government Committee Public Hearing on Senate Bill 1249 and Voting Machine Demonstration, September 25, 2018. Download as PDF.

Thank you Chairman Folmer, Minority Chair Williams, and members of the Committee for allowing Verified Voting to submit written testimony in connection with the Senate State Government Committee hearing. We write to address the security risks presented for Pennsylvania’s counties and the need to expeditiously replace aging and vulnerable electronic voting systems. We urge the Committee to recommend that the Commonwealth appropriate adequate funding to permit counties to replace their aging electronic voting systems as soon as possible.

Verified Voting is a national non-partisan, non-profit research and advocacy organization committed to safeguarding elections in the digital age. Founded by computer scientists, Verified Voting’s mission is to advocate for the responsible use of emerging technologies to ensure that Americans can be confident their votes will be cast as intended and counted as cast. We promote auditable, accessible and resilient voting for all eligible citizens. Our board of directors and board of advisors include some of the top computer scientists, cyber security experts and statisticians working in the election administration arena as well as former and current elections officials. Verified Voting has no financial interest in the type of equipment used. Our goal is for every jurisdiction in the United States to have secure and verifiable elections.

There are two basic kinds of electronic voting systems in use in Pennsylvania: Direct recording electronic (DRE) or optical scan systems. Both types of systems are computers, and both are prepared in similar ways. The primary difference is that an optical scan system incorporates a voter-marked paper ballot, marked either with a pen or pencil or with a ballot marking device and that ballot is retained for recounts or audits. Optical scan systems leverage the speed of the computer to report unofficial results quickly. The presence and availability of that paper ballot provides a trustworthy record of voter intent and allows jurisdictions to monitor their system for problems, detect any problems, (either hacking or error), respond to them and recover by, if necessary, hand counting the paper ballots. Seventeen counties in Pennsylvania already benefit from the security protection of paper ballots. Read More

Verified Voting Blog: Pamela Smith: Testimony Submitted to the Little Hoover Commission

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Honorable Members of the Commission: I serve as Senior Advisor to Verified Voting, a national non-partisan non-profit educational and advocacy organization committed to safeguarding elections in the digital age. Verified Voting advocates for the responsible use of emerging technologies to ensure that Americans can be confident their votes will be cast as intended and counted as cast. We promote auditable, accessible and resilient voting for all eligible citizens. I previously served as President of Verified Voting for more than a decade. I have provided information and testimony on voting technology and policy issues at federal and state levels, including to the US House of Representatives Committee on House Administration, and earlier this year at the Joint Hearing of Assembly Elections and Redistricting and Senate Elections and Constitutional Amendments Committees, on Cybersecurity and California’s Elections.1

I have curated an extensive information resource on election equipment and regulations nationwide, and co-authored several key works on election security policy, including Principles & Best Practices for Post Election Audits2 and the introductory chapter of Confirming Elections: Creating Confidence and Integrity through Election Auditing.3 I participate in the Future of California Elections, a collaboration between election officials, civil rights organizations and election reform advocates to examine and address the unique challenges facing the State of California’s election system.[4.  Futureofcaelections.org] I also serve on the Los Angeles County Voting Systems for All People (VSAP) Technical Advisory Committee.4

In my capacity at Verified Voting I have worked with advocates, election officials and lawmakers from all across the country. In my view, the states that do the best on metrics relating to voting system security are often the ones that continue to look for and embrace opportunities to improve. As security threats do not stand still, neither can those whose work it is to safeguard our elections and consequently our democracy. I applaud the Little Hoover Commission for taking up this crucial topic of investigation, and am pleased to participate in and contribute to that effort.

Election security is not an on-off switch, where a thing either is secure or it is not. Rather it involves incrementing layers of effort, analysis, systems and procedures, all created or conducted by people, all while balancing costs and priorities. Such incremental measures harden a system, making it more secure than before and solving for problems when they occur. Perfect security is not attainable, but diligence in the pursuit of secure elections is. Read More

Verified Voting Public Commentary: Verified Voting Testimony before the Pennsylvania State Senate Senate State Government Committee: Voting System Technology and Security

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The security of election infrastructure has taken on increased significance in the aftermath of the 2016 election cycle. During the 2016 election cycle, a nation-state conducted systematic, coordinated attacks on America’s election infrastructure, with the apparent aim of disrupting the election and undermining faith in America’s democratic institutions. Intelligence reports that have been published in 2017 demonstrate that state databases and third-party vendors not only were targeted for attack, but were breached.1 Regardless of the success of hacking attempts in 2016, the consensus among the intelligence community is that future attacks on American elections are inevitable.2 The inevitability of attacks is a key concept in cyber security, that is, it’s not whether a system will be attacked, but when.

The existence and national significance of this threat have escalated the priority of securing Pennsylvania’s elections infrastructure. Two primary areas that require immediate and sustained attention are 1) securing both the state and county networks, databases and data transmission infrastructure that touch elections; and 2) instilling confidence in election outcomes by replacing legacy voting systems with new systems that permit reliable recounts and audits.

During the time that I served the Commonwealth as Deputy Secretary for Elections and Administration and Special Advisor to the Governor on Election Policy, I worked with the Office of Administration-Office of Information Technology to protect the Commonwealth’s networks that touch elections and to implement procedures to recover from any potential attacks. These efforts complied with cyber security best practices to monitor, detect, respond and recover. OA-OIT’s experienced staff is continuing this effort, and along with the Department of State, they have engaged county CIOs and technology staff to coordinate similar efforts at the counties working through the Commonwealth’s relationship with the County Commissioners Association of Pennsylvania (CCAP). Assuming the administration receives support from the General Assembly, the Commonwealth is on the right track to taking the necessary steps to monitor, detect, respond and recover from cyber attacks. Read More

Verified Voting Blog: Testimony of Verified Voting to the Georgia House of Representatives House Science and Technology Committee

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Georgia’s voting machines need an update. The lifespan of voting machines has been estimated at 10-15 years.1 Purchased in 2002 Georgia’s voting machines are at the outside of that estimate. As voting systems age they are more susceptible to error, malfunction or security threats potentially losing or miscounting votes.

Georgia is one of only a handful of States that is still casting votes on entirely electronic voting systems, known as Direct Record Electronics (DREs). These machines record votes only in digital form; if the digital records are corrupted, either by benign error or malicious attack, there are no backup records and no way to know whether votes have been corrupted. When Georgia purchased these machines in 2002, the national trend was toward paperless touchscreen voting machines. Since then, however, most states moved away from paperless voting systems, driven by mounting research establishing these machines’ security flaws and some high profile and costly machine failures.2 Most of the nation has adopted voting systems that rely on a voter-marked paper ballot, an election safeguard recognized as essential by election officials and computer security experts alike.

A paper ballot provides a durable, physical record that is out of reach of a cyber attack and cannot be lost by a digital malfunction or programming error. Paper ballots can be used in a recount or to perform a post-election audit or check on the election results to help ensure the election outcome is correct. Today roughly 70% of voters in our nation mark a paper ballot which is counted by an electronic scanner. Read More

Verified Voting Blog: Testimony of Verified Voting to the New York State Assembly Standing Committee on Election Law

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In 2016 the threat of cyber attacks on our elections from foreign entities became an alarming reality. We learned that an adversarial nation was targeting our election systems with the intent to disrupt and undermine the legitimacy of our free, democratic government. In the declassified report “Assessing Russian Activities and Intentions in Recent U.S. Elections” the U.S. Intelligence Community warned that “Russian intelligence obtained and maintained access to elements of multiple US state or local electoral boards.”1 Several months ago we learned that the U.S. Department of Homeland Security (DHS) contacted officials in twenty-one states to notify them that their election systems had been targeted by Russian hackers. When asked at a June hearing of the Senate Select Committee of Intelligence if we should expect continued cyber attacks on our election infrastructure, then FBI director James Comey stated emphatically, “[t]hey will be back.”2 The gravity of this threat cannot be overstated. It is critical that we take every precaution to protect our election systems.

The stealth, skill and sophistication of today’s state-level cyber attackers should not be underestimated. Cyber security experts have warned that attacks today continue to outpace our ability to defend against them. The unending list of high profile and well-defended enterprises that have fallen victim to cyber attacks3 demonstrates the impracticality of trying to defend any computer system absolutely. Further complicating the problem, our election offices are typically under-resourced and understaffed. Though the New York State Board of Elections currently has in place some of the more advanced cyber security and cyber hygiene requirements for election systems, we cannot expect our county election offices to defend against cyber attacks from a state-level attacker. Read More

Verified Voting Blog: Verified Voting Testimony for the New Jersey State Assembly Judiciary Committee

Verified Voting is a national non-partisan, not for profit research and advocacy organization founded by computer scientists and committed to safeguarding democracy in the digital age. We promote technology and policies that ensure auditable, accessible and resilient voting for all eligible citizens. We urge you to adopt the proposed amendments and vote “YES” on A-4619.

New Jersey is one of only a handful of states whose voters are still casting votes on entirely electronic voting systems, direct recording electronic (DREs). Because these systems record votes directly onto computer memory without any independent paper record of the vote, they are especially vulnerable to undetectable and uncorrectable errors in the vote count.

Numerous studies and security evaluations of DRE systems over the years have found that the DREs in use in New Jersey have insecurities making them vulnerable to undetectable manipulation and tampering.1 Because DRE systems prevent anyone from verifying that the electronic tally accurately reflects voter intent, many States have discontinued the use of electronic DRE voting systems in favor of paper ballots. In 2006 only 25% of voters nationwide cast their ballots on paper but in 2017 more than 70% of U.S. voters marked a paper ballot.2 Read More

Verified Voting Blog: Verified Voting Letter to the US Senate Select Committee on Intelligence

This letter was sent to the US Senate Select Committee on Intelligence following a hearing on June 21, 2017. (Download PDF)

Verified Voting vigorously applauds the Senate Select Committee on Intelligence for its leadership and commitment to securing our elections. With clear evidence that foreign attackers sought to attack our 2016 elections through various means, our intelligence agencies warn that hostile attackers will be back to attack future elections. Congress and the most vulnerable states should act with urgency to fund and implement protective reforms that will make our election systems resilient against cyber attack: funding the adoption of paper ballots and accessible ballot marking systems, and implementing robust, manual post-election audits of the votes.

The June 21 hearing is an important first step toward those reforms, providing valuable information through witness testimony and questions of the Senators. We wish to expand on several key points that were raised in the hearing to ensure a clear understanding of the challenges we face in securing our elections.

It is crucial to understand that further reforms are urgently needed to bolster the mitigations currently in place so that it is possible to detect and correct a cyber attack on the vote count.

Some testimony asserted that pre-election testing and post-election audits currently in place would catch errors in vote tallies caused by a malicious attacker or software failure. Unfortunately, pre-election testing, though helpful for ensuring the completeness of ballot programming, can be defeated by malicious software designed to detect when the system is in test mode. This is what happened with Volkswagen diesels cars: the software caused the cars’ emissions systems to behave correctly during testing, but then allowed them to pollute under non-testing conditions.

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Verified Voting Blog: Alex Halderman: Expert Testimony before the US Senate Select Committee on Intelligence

This testimony was delivered at a hearing on June 21, 2017. (Download PDF)

Chairman Burr, Vice Chairman Warner, and members of the Committee, thank you for inviting me to speak today about the security of U.S. elections. I’m here to tell you not just what I think, but about concerns shared by hundreds of experts from across cybersecurity research and industry. Such expertise is relevant because elections—the bedrock of our democracy—are now on the front lines of cybersecurity, and they face increasingly serious threats. Our interest in this matter is decidedly non-partisan; our focus is on the integrity of the democratic process, and the ability of the voting system to record, tabulate, and report the results of elections accurately.

My research in computer science and cybersecurity tackles a broad range of security challenges.1 I study attacks and defenses for the Internet protocols we all rely on every day to keep our personal and financial information safe. I also study the capabilities and limitations of the world’s most powerful attackers, including sophisticated criminal gangs and hostile nation states. A large part of my work over the last ten years has been studying the computer technology that our election system relies on.2 In this work, I often lead the “red team,” playing the role of a potential attacker to find where systems and practices are vulnerable and learn how to make them stronger.

I know firsthand how easy it can be to manipulate computerized voting machines. As part of security testing, I’ve performed attacks on widely used voting machines, and I’ve had students successfully attack machines under my supervision. Read More

Verified Voting Public Commentary: Statement to the Pennsylvania Senate State Government Committee Re: SB 1052

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Verified Voting is writing today to express our opposition to Senate Bill 1052, a bill which would permit the return of ballots by electronic transmission over insecure Internet means for military voters in Pennsylvania, and to urge you to vote NO on SB 1052. Ballots sent by email are vulnerable to undetectable manipulation or tampering while in transit over the Internet. 1Ballots sent by fax are also vulnerable to attackers. Today most facsimiles are sent via Internet over facsimile mail programs which have the same threat profile as emailed ballots. By permitting the electronic return of voted ballots, SB 1052 will significantly damage the integrity of Pennsylvania’s elections and put the ballots of military voters at grave risk.

Department of Defense and National Institute of Standards and Technology oppose online voting.

At the start of the 21st century the promise of secure Internet voting seemed attainable; Congress directed the Department of Defense (DOD) in the 2002 National Defense Authorization Act (NDAA) to develop an online voting system for military and overseas voters.  The Federal Voting Assistance Program (FVAP), an agency administered by the DOD, developed a system for deployment in 2004. After a security review the DOD cancelled the project because it could not ensure the legitimacy of votes cast over the Internet.  In 2005 Congress directed the National Institute of Standards and Technology (NIST) to study the online return of voted ballots for the purpose of setting security standards so DoD and FVAP could develop a secure online voting system for military voters. NIST published numerous reports on its research, and documented several security issues that cannot be mitigated or solved with the cyber security safeguards and voting system protocols currently available. NIST concluded that until these challenges are overcome, secure Internet voting is not yet feasible. 2

For these reasons the Department of Defense has warned that it cannot ensure the legitimacy of ballots sent over the Internet and has stated “[the Department of Defense] does not advocate for the electronic transmission of any voted ballot, whether it be by fax, email or via the Internet.” 3 In addition, the Federal Voting Assistance Program, in a report to Congress in 2013, stated clearly that the postal mail return of a voted ballot, coupled with the electronic transmission of a blank ballot is the “most responsible”4 method of absentee voting for UOCAVA voters. The overwhelming evidence that secure Internet voting is not within our grasp led Congress to repeal, in the 2015 National Defense Authorization Act, the earlier directive that DoD pursue online voting for military and overseas voters.

It is not reasonable to expect the Pennsylvania Department of State should be able to develop a secure online ballot return system when the Department of Defense and the National Institute of Standards and Technology have determined secure online voting is not presently achievable. Read More

Verified Voting Public Commentary: Comments on Colorado Rules Concerning Internet Voting

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We are pleased to provide testimony and remarks regarding proposed rule changes to Colorado’s Rules Concerning Elections 8 CCR 1501-5. We appreciate the effort of your office to solicit preliminary comments from the public to inform the draft of the proposed rule changes and were happy to participate in the process. We remain in opposition to Rule 16.2.1(c). However, before addressing Rule 16.2.1(c), we would first like to address proposed new Rule 16.2.8 prohibiting Internet voting because it is inextricably linked to proposed Rule 16.2.1(c).

Public comments voiced significant objection to Internet voting. The Secretary has proposed Rule 16.2.8 which states:

New Rule 16.2.8:
16.2.8 NOTHING IN THIS RULE 16.2 PERMITS INTERNET VOTING. INTERNET VOTING MEANS A SYSTEM THAT INCLUDES REMOTE ACCESS, A VOTE THAT IS CAST DIRECTLY INTO A CENTRAL VOTE SERVER THAT TALLIES THE VOTES, AND DOES NOT REQUIRE THE SUPERVISION OF ELECTION OFFICIALS

Proposed new Rule 16.2.8 unfortunately fails to recognize that email and fax return of voted ballots (permitted and expanded in Rule 16.2.1(c)) is Internet voting and includes all of the inherent security risk of Internet voting. In fact, email (and digital fax) are considered by voting system experts at both the National Institute of Standards and Technology and the U.S. Election Assistance Commission to be even less secure, 1, 2 than the type of Internet voting system described in proposed Rule 16.2.8. Read More

Verified Voting Public Commentary: Developing a Framework to Improve Critical Infrastructure Cybersecurity

Under Executive Order 13636 [2] (“Executive Order”), the Secretary of Commerce is tasked to direct the Director of NIST to develop a framework for reducing cyber risks to critical infrastructure (the “Cybersecurity Framework” or “Framework”). The Framework will consist of standards, methodologies, procedures and processes that align policy, business, and technological approaches to address cyber risks. The Department of Homeland Security, in coordination with sector-specific agencies, will then establish a voluntary program to support the adoption of the Cybersecurity Framework by owners and operators of critical infrastructure and any other interested entities.

NIST has issued a Request for Information (RFI) in the Federal Register. It is to this RFI that our response pertains. The undersigned persons and organizations include experts on matters relating to election technology, election practices, encryption, Internet security, and/or privacy. We appreciate the opportunity to provide input on this RFI entitled “Developing a Framework to Improve Critical Infrastructure Cybersecurity”.

Our response focuses on the discussion of specific practices as they pertain to elections practices and systems as part of the nation’s critical infrastructure. (Download the Full Response as a PDF) Read More

Verified Voting Public Commentary: Verified Voting Lauds Successful Test Hack of Internet Voting Pilot

Verified Voting applauds the decision of the District of Columbia Board of Elections and Ethics to suspend their plan to offer overseas voters the dangerous option of returning their voted ballots by a “digital vote by mail” Internet voting system. The District’s plans to continue other Internet-based ballot return methods (including email and fax) for the District’s military and civilian overseas voters still raise concerns among voting security experts. DC election officials made the decision after inviting technology experts to hack the Board’s prototype voting system during a trial period. The test pilot was apparently attacked successfully shortly after it began by a team of academic experts led by Prof. J. Alex Halderman at the University of Michigan.

The attack caused the University of Michigan fight song to be played for test voters when they completed the balloting process. Full details of the hack and its impact on submitted test ballots are expected to become available in the coming days. In addition to the Michigan team’s breach of the voting system, Verified Voting’s Board Chair Dr.David Jefferson documented a very serious vote loss problem that caused voters to inadvertently return blank ballots while believing that they had submitted complete ballots. The disenfranchising bug was noted in at least two widely used computer/browser configurations. It is possible that the same problem would affect voters trying to use email or some fax systems to return voted ballots.

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