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RE: COTS scope

As I stated on the conference call, it seems to me that there are a
relatively small set of issues in which it may make sense to have two
requirements, one stringent and one relaxed.  If all the stringent
requirements are met, the auditability and recoverability provided by
AVVPAT would remain optional.  If any of the relaxed requirements are
selected, the auditability and recoverability provided by AVVPAT would
become mandatory.

The issues I have identified thus far are:

1.  Reliability - I have been highly critical of the 163 hour MTBF.  I
have concluded that the "stringent" spec should be 15000 hours (allowing
a 0.001 failure probability on election day).  The relaxed spec can be
something between 163 and 15000.  (BTW, my comment was to increase to
1500, but I now believe that is inadequate.)

2.  COTS - The stringent spec would be to inspect all COTS exactly the
same as non-COTS (IIRC, this would fully apply all resolutions of the
COTS STG).  The relaxed spec would be to allow some COTS to be accepted
without inspection.

3.  Security - Although the state of the Common Criteria Protection
Profile is uncertain at this point, I will state the specs in terms of
Common Criteria Evaluation Assurance Levels.  The stringent spec would
be something roughly equivalent to EAL-5 or 6 (although I advocate
stepping away from the prescribed EAL's that are mandatory only if
automatic international recognition of certification is important).  The
relaxed spec could be EAL-2, which represents basic commercial practice.

There may be a few additional areas to which this approach would apply,
but I leave it to others to suggest them.

Stan Klein

On Tue, 2004-11-30 at 15:34, Deutsch, Herb wrote:
> If this is on central count equipment or any central site software or
> equipment, it is not covered in our scope.  It would have to be part
> of the polling place unit to be considered.  In that case, since I
> believe you take an image of the entire system including the OS, how
> would you treat that today?
> -----Original Message-----
> From: Merle King [mailto:mking@kennesaw.edu]
> Sent: Tuesday, November 30, 2004 12:45 PM
> To: sklein@cpcug.org; hdeutsch@ESSvote.com; stds-1583-disc@IEEE.ORG;
> stephen.berger@IEEE.ORG
> Cc: ren@EFF.ORG; s.tatiner@IEEE.ORG; cots@lipsio.com;
> vince@lipsio.com;
> notable@mindspring.com; rivest@mit.edu; s.morganstein@Populex.com
> Subject: Re: COTS scope
> Stan, Vince, et al -
> The question that I intended to ask during the teleconference of Nov.
> 30... Under this proposed scope, how will warranty work on the
> equipment
> be addressed?  If each time a defective driver or other COTS component
> is identified and a warranty recall is issued (example: recent recall
> by
> Dell for a defective driver for their RAID configuration used on
> central
> tabulation machines), how will this impact requalification of a
> system? 
> The owners of the systems (jurisdictions) will want to take advantage
> of
> warranty work while still covered by the warranty.   If the warranty
> work requires the entire system to be requalified...that could be
> impractical, given the time and expense involved, as well as the
> potential quantity of warranty claims over the life of the unit.
> - Merle
> Merle S. King
> http://science.kennesaw.edu/csis
> Chair, CSIS Department
> Kennesaw State University
> 1000 Chastain Road, MB #1101
> Kennesaw, GA  30144-5591
> voice: 770-423-6354; fax: 770-423-6731
> >>> "Stanley A. Klein" <sklein@CPCUG.ORG> 11/22/2004 10:37:40 AM >>>
> When P1583 was last balloted, there were numerous comments to the
> effect
> that COTS should not be exempt from inspection.  An STG was set up to
> resolve those and other comments regarding COTS.
> The resolution generally was that COTS should undergo the exact same
> testing as any other parts of a voting system, unless it had been
> previously tested and certified as satisfying the requirements of the
> specification.
> It seems to me that the proper procedure is to incorporate the
> resolutions into the P1583 draft and move forward with the document.
> We are working to replace an FEC standard that is widely agreed to be
> inadequate.  The recent election resulted in numerous reports of
> problems with voting systems that can easily be attributed to the
> inadequacy of both the FEC standards and the ITA certification
> process.
> The COTS exemption is a major, glaring loophole in the FEC standard.
> Given the technical alternatives for vendors and the procedures used
> in
> other mission critical systems, there is absolutely no reason for
> allowing the COTS exemption to remain.  Of course it will be initially
> inconvenient for vendors, but any meaningful upgrade of the FEC
> standard
> will involve some initial inconvenience for vendors.
> >From my perspective, I see the leadership of P1583 slipping back into
> the kinds of process games that just a month or two ago they agreed to
> stop playing.  Their credibility is now on the line, and by
> implication
> the credibility of IEEE Standards as it relates to an issue with major
> national attention.
> Stan Klein
> On Mon, 2004-11-22 at 08:31, R. Mercuri wrote:
> > Herb --
> >
> > I would like to add my voice to Vince's with regard to the
> > attempted replacement of our sub-group's work by material submitted
> > by Sandy, who isn't even a member of P1583. We were offended
> > at the meeting when it was suggested that Sandy replace us
> > as the co-chairs of the working group, and that materials be
> > fed to him, rather than us.  We had asked NUMEROUS TIMES for
> > input, so if that is going to be provided, it should be to
> > Vince and myself, not Sandy. Sandy is welcome to make suggestions,
> > of course, but not as a co-chair of the COTS-STG. We had also
> > provided material from our sub-committee for the draft document
> > that was not included, despite REPEATED requests to do so, and
> > this situation continues to be remiss.
> >
> > Now it seems that the entire standard will be compromised through
> > COTS exemptions.  Sandy's comment "code review of COTS software
> > cannot ensure that the COTS firmware/software is failsafe"
> > could be equally applied to the entire voting product --
> > why bother to have code review at all???  BECAUSE white box
> > AND black box testing are NECESSARY to reveal different
> > sorts of problems, such as VULNERABILITIES.  Additionally,
> > the code MUST be available in order to provide assurances
> > and evidence if later problems arise. There are certainly
> > ways in which vendors can contract with suppliers to provide
> > their code -- the choices they make can/should include products
> > that already are open to review (such as Linux or BSD-based).
> >
> > The bottom line is that there's no point in having a voting
> > system standard if parts of the ballot casting and tabulation
> > system are going to be exempt. It is bad enough that the standard
> > does not require any auditability feature to provide independent
> > recounts -- but to further allow non-inspected components, just
> > makes the whole thing a joke.
> >
> > I seriously hope that this issue can be resolved appropriately,
> > Rebecca Mercuri.
> --
> Stanley A. Klein <sklein@cpcug.org>
Stanley A. Klein <sklein@cpcug.org>