The Center for Election Confidence (CEC) submitted comments to the North Carolina State Board of Elections (NCSBE) concerning proposed statewide procedures for absentee-ballot deficiencies and irregularities.

CEC supports the proposed framework, which distinguishes among curable deficiencies, non-curable deficiencies, irregularities requiring no additional voter action, and irregularities requiring further action. “Absentee voting depends on both voter access and strict adherence to statutory safeguards,” CEC explained. Uniform classifications and prompt staff screening can help eligible voters cure correctable problems while reducing inconsistent treatment across counties.

CEC urged NCSBE to clarify how the proposed terms “ballot envelope” and “outer return envelope” correspond to the statutory “container-return envelope,” distinguish a third party’s lawful transmission of cure materials from the voter’s own substantive attestation, and specify the information that must be included in a written deficiency or irregularity record. Staff may perform administrative screening, but final classifications and determinations should remain with the county board where the statute or rule requires board action.

The comments also recommend that cure notices state the actual calendar deadline, that electronic submissions be preserved in their original form, and that a missing ZIP code alone not invalidate an absentee application and certificate. Spoil-and-reissue actions should be documented, and NCSBE should provide objective guidance for distinguishing ordinary mailing wear from evidence that an envelope was opened and resealed.

For serious chain-of-custody, ballot-secrecy, or ballot-identity irregularities, CEC opposes automatic staff-only resolution. Voter attestations should be formal, preserved statements, and the affected materials should be presented to the county board for a documented decision. The final rule should also explain what happens when a voter does not respond and require preservation of the materials’ condition and handling history.

CEC urged NCSBE to adopt the framework with these safeguards so absentee ballots are processed consistently, transparently, and in accordance with North Carolina law.