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May 18, 2021

Joint Committee on Election Laws
Massachusetts Legislature
24 Beacon Street
Boston, MA 02133
via email

RE: Verified Voting Urges Rejection of Senate Bill 469

Dear Committee Members,

On behalf of Verified Voting, I write in opposition to Senate Bill 469 regarding the creation of an internet voting pilot project. Verified Voting is a nonpartisan nonprofit organization with a mission to strengthen democracy for all voters by promoting the responsible use of technology in elections. Since our founding in 2004 by computer scientists, we have acted on the belief that the integrity and strength of our democracy rely on citizens’ trust that each vote is counted as cast. With this in mind we oppose allowing voted ballots to be returned electronically through insecure means.

Multiple cybersecurity experts have concluded that internet voting is insecure. The National Academies of Sciences, Engineering and Medicine released a report in 2018 stating that the technology to return marked ballots securely and anonymously over the internet does not exist.1 Additionally, in the lead up to the 2020 General Election, the Department of Homeland Security, the Election Assistance Commission, the Federal Bureau of Investigation, and the National Institute of Standards and Technology told states and election officials that electronic ballot return “creates significant security risks to the confidentiality of ballot and voter data (e.g., voter privacy and ballot secrecy), integrity of the voted ballot, and availability of the system. We view electronic ballot return as high risk. Securing the return of voted ballots via the internet while ensuring ballot integrity and maintaining voter privacy is difficult, if not impossible, at this time [emphasis added].”2 Nothing has changed; no new internet technology has been created to mitigate this risk.

This bill would establish an internet voting pilot project for municipalities to “establish the viability, efficacy, and security of mobile voting…” and in addition it also establishes a commission to study such voting for UOCAVA and voters with disabilities generally. It is exceptionally unclear just how electronic ballot return could be deemed secure by a commission when NIST told states and local governments just last year that they “recommend paper ballot return as electronic ballot return technologies are high-risk even with controls in place.”2

Some argue that blockchain technology can increase the security of internet voting. Let me be clear: Blockchain does not solve the security issues inherent to internet voting. The National Academies report states that “blockchain technology does little to solve the fundamental security issues of elections, and indeed, blockchains introduce additional security vulnerabilities.” Blockchain technology is designed to keep information secure once it is received. It cannot defend against the multitude of threats to that information before it is entered in the blockchain, and voters cannot verify their votes are entered into the blockchain correctly without compromising ballot secrecy. Recording ballots on a blockchain also risks ballot secrecy if encryption keys are not properly protected or software errors allow decryption of individual ballots.

We know that there are vendors of online election systems that make bold statements about how safe and secure their systems are. Unfortunately, these vendors do not reliably assess the security risks of the products they sell. Their public relations, marketing, and lobbying efforts consistently downplay the inherent risks of internet voting. Multiple studies have been performed on these types of systems and the conclusion is always the same: the risks are significant and no good solution yet exists to mitigate those risks.

We understand the profound challenges you face to assure every voter’s ability to vote. Verified Voting strongly supports interventions to assure voters’ equal opportunity and access to cast their ballot — securely and verifiably. However, electronic return fails to confer this equality, and it threatens the trustworthiness of the election itself. Recognizing that no current solution is ideal for all voters, we support thoughtful consideration of other secure innovations. We would be happy to participate in further discussions of how to meet the standard of equal access and uncompromised security. One such solution could be providing on-demand services for voters who require them, such as election officials bringing portable accessible voting equipment directly to individual voters.

At a time when election security and public confidence are under attack, electronic return of voted ballots presents a slippery slope to vulnerable and untrustworthy elections. We therefore urge that SB 469 be rejected.

Respectfully submitted,

Mark Lindeman
Acting Co-Director

  1. National Academies of Science, Engineering, and Medicine, 2018. “Securing the Vote: Protecting American Democracy.” Washington, DC: The National Academies Press. []
  2. DHS Memo.
    Joint Committee on Election Laws [] []