Further, the statute says, "A verification shall be considered for all purposes certification that the vital event did occur and that the facts of the event are as stated by the applicant." If there are "facts" stated by the applicant in a request for a letter of verification that the DOH does NOT verify, then those facts are not and cannot be certified.
First, Bennett sent to the DOH its own standard birth-record request form. That form contains information including the date of birth, names of the parents and place of birth. Onaka did not verify any of the information on this form with the possible exception of place of birth, but there are problems with the wording on item No. 1. First, it refers to a "birth certificate." At the bottom of the letter, Onaka uses the terms "additionally" and "Certificate of Live Birth," which would indicate that the former document is not the same as the latter document. The last statement, if it were comprehensive to Bennett's request, should actually be sufficient as a verification of ALL the facts. IOW, the comment about the COLB at the end is redundant UNLESS it is referring to a separate document with no known legal value. Again, Onaka says he is verifying "pursuant" to the statutes.
Second, Bennett asked if the attached PDF was a true and accurate copy of the original birth record on file. Onaka does NOT verify this information. Instead, he says that the information in the PDF "matches" the "original record" in the files, which has no specific legal meaning. Part of Onaka's job (and/or his predecessors) is to certify birth records as "true" or "correct" or "accurate." He did not do this. Likewise, several months later, KS SOS Kobach recognized that this verification was inconclusive, so he requested his own letter of verification asking specifically if the Obama PDF was "identical" to original record on file. Again, "pursuant" to the statutes, Onaka must verify this information. But, in his reply to Kobach, he did NOT say the record was identical. His failure to do so means that the PDF is NOT identical and is NOT a true, correct or accurate copy of the birth record.
Something else that's important to note is that the DOH website on Obama points to specific departmental rules that include rules regarding foreign-born children who are adopted in Hawaii. IOW, they seem to be indicating that Obama was foreign-born and that he was adopted, which starts to explain why his PDF cannot be completely verified, and is therefore is legally invalid.