I am confused by the proposed changes to 1VAC20-70-20.  I cannot determine if the intent is 1) to allow the voter to enclose the marked ballot in an envelope other than the supplied Envelope B as long as the required Statement of Voter is included, or 2) to allow the marked ballot not to to be enclosed in any envelope at all as long as it is accompanied by the required Statement of Voter, or 3) to eliminate the requirement that the Envelope B must be sealed.  Further, I do not understand the meaning of "substantial compliance" in Section C.10.   I have the following comments:

• §24.2-706 states that upon the acceptance of an AB application the general registrar will send the voter a packet of material which includes "An envelope, with printing only on the flap side, for resealing the marked ballot...."  This is not called Envelope B in the Code but we know it as Envelope B.  Will this no longer be required?  Can the voter use any envelope or none if they so choose?
• It is important that marked ballot be sealed in something when it is returned.  In §24.2-711, the procedure for processing the marked ballots states that the ballot envelope shall be opened after it has been determined that the voter is entitled to vote AB (on the AB list and in compliance with the requirements of the Statement of Voter).  The order of this process is important to ensure that the decision to accept or reject the AB is based only upon the acceptability of the ballot.  If the ballot is openly available (unsealed envelope or no envelope) and can seen by the Election Officers prior to the determination of acceptability, the opportunity exists for the Officers to be influenced by how the ballot was marked.  Regardless of the low probability of this occurring, it is senseless to open up the process to potential fraud.
• "Substantial compliance" is an imprecise phrase open to wide interpretation.  Since the intent of 1VAC20-70-20 is to provide a precise interpretation of  §24.2-706 and specifically the requirements of the Statement of Voter, to introduce an imprecise phrase would have a deleterious effect on the entire regulation.  If the intent of these changes is to eliminate the requirement that the Envelope B must be used, then C.10 should say that "the substitute Statement of Voter must include all the required voter information, as interpreted by this Regulation."