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Re: COTS scope

I quite agree, Stan, with your compromise distinction between stringent specification (no AVVPAT reqd to meet standards) and relaxed specification. That seems fair.

(1) But you don't really look carefully enough at the differences between hardware and software concepts of MTBF; software traditional requires far more specific testing in order to reliably estimate MTBF in advance of extensive use. Thus, reliability in software depends on context (configuration, integration, installation, and myriad other issues) and test automation (with repeatable context and repeatable tests) becomes crucial in assessing system reliability.

(2) To inspect COTS software, as you suggest, would require vast resources. Consider the existing DREs running on Microsoft's operating system and using Microsoft's Access database. These two Microsoft programs are not likely to be inspected line by line in the way Open Source code might be. In addition, the diverse means by which states tabulate and transfer counts to central state voting authorities involve highly complex and diverse systems, few of which have ever been or ever will be tested as total systems with either proprietary or open voting systems. To be real about this, we have to treat specialized voting software (and hardware) separately from COTS items. Still, it is Open Test using automated testware that would allow us to propose total system testing where total system inspection is simply not feasible. Then, a total system can be characterized meaningfully as to its estimated MTBF.

(3) Security should not so easily be dismissed. All vendors of systems meeting the standard should provide the security equivalent of Environmental Impact Statements: what are the risks of (1) failure and (2) corruption in a given system and how does the system meet them? No system lacking a testable, behavioral risk analysis should be considered to meet the standard. Certification, especially if proprietary and hidden as to its substance, is a very thin bulwark against error and corruption. Again, Open Test seems a reasonable approach to this problem.

Of course, if we need to inspect Microsoft's XP and Access, well, let me know and I am sure I can find some time to volunteer. I assume that the exceptions found though inspection would be fixed before the stuff is used in an election, right?

This is my personal and professional opinion, and it does not necessarily reflect the opinions of my employer.

-- Dick

Richard C. Johnson, Ph.D.
Applications Architect
Oracle Corporation

Stanley A. Klein wrote:

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
be addressed? If each time a defective driver or other COTS component
is identified and a warranty recall is issued (example: recent recall
Dell for a defective driver for their RAID configuration used on
tabulation machines), how will this impact requalification of a
system? The owners of the systems (jurisdictions) will want to take advantage
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
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
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

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

The COTS exemption is a major, glaring loophole in the FEC standard.
Given the technical alternatives for vendors and the procedures used
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
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
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>