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 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 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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