We write to you on behalf of those individuals listed below from the California Secretary of State’s Top-To-Bottom Review (TTBR) in 2007. The TTBR was an unprecedented, in-depth evaluation of California’s voting systems, which allowed investigators to gain a better understanding of their vulnerabilities. As you know, the EAC recently certified Premier’s Assure 1.2 voting system as conforming to the 2002 Voting System Standards (VSS). This system was tested by iBeta Laboratories (iBeta), one of the accredited Voting System Test Labs (VSTLs). According to the posted test plan—the roadmap for a VSTL’s evaluation of a voting system during certification testing—for Premier Assure 1.2, iBeta interpreted the TTBR studies of the Premier system’s predecessor to have “concluded that the vulnerabilities within the system depend almost entirely on the effectiveness of the election procedures.” On the basis of this interpretation, iBeta developed a test plan that called for “no additional testing” of the Premier system’s security properties. The EAC approved this plan. Taken together, iBeta’s misunderstanding of the significance of the TTBR findings and the EAC’s approval of a test plan that was designed around this misunderstanding, represent a missed opportunity to use the testing and certification process to improve voting system integrity and reliability.
