(following text was approved at the June 1998 TACDFIPSFKMI meeting)


Dear Mr. Secretary:

We respectfully submit the attached technical input from the “Technical Advisory 
Committee to Develop a Federal Information Processing Standard for the Federal 
Key Management Infrastructure” (TAC) for Requirements for Key Recovery Products.  
The TAC is cognizant of the steps you are obligated to take under various 
statutes and policies to seek public comment in making your determination about 
implementing a Federal Information Processing Standard.  However, the TAC 
believes significant, substantive additional work is necessary before this 
document will be ready for the next step in the process. Specifically, we 
believe that this document is not ready to be released for public comment, to be 
used as a basis for generation of answers to policy questions relevant to a 
FIPS, or to begin planning for development of implementation guidance.

With regard to this latter topic, we suggest initiating work on detailed 
implementation guidance, once this document is completed. Such guidance will be 
essential to the successful deployment of any key recovery system (KRS), since 
many aspects of KRS security are outside the scope of the work we have 
undertaken.  We also urge pursuit of conformance testing based on the NVLAP 
model, e.g., as employed for FIPS 140-1.  Because of the complexity and security 
sensitivity of KRS technology, we do not support vendor self-declaration of 
conformance.

The TAC has made substantial progress and a completed version of the work begun 
here could provide a basis for the development of a FIPS.  However, the TAC 
encountered some significant technical problems that, without resolution, 
prevent the development of a useful FIPS. There are unresolved conflicts among 
some requirements. In addition, the model that underlies the product evaluation 
process is not yet complete.

In retrospect, the time and effort devoted to this task were not sufficient to 
develop an adequate set of technical requirements for a FIPS.  Because the focus 
of this work is security, we feel that it is critically important that we 
produce a document that is complete, coherent, and comprehensive in addressing 
the many facets of this complex security technology.  The attached document does 
not satisfy these criteria.

The TAC understands that its charter expires in July of 1998.  However, the TAC 
has gained much experience during this process, and is willing to continue to 
work towards the completion of its initial charge.

As you know, TAC members were appointed for their individual expertise.  The 
actions of the TAC do not have the explicit or implicit endorsement of the 
corporations or organizations with which its members are affiliated.

On behalf of the TAC, we hope that you find our efforts have been useful, and we 
thank you for the opportunity to work on your behalf.