Thank you for the opportunity to comment on the State Board of Elections' regulations requiring logic and accuracy testing of electronic poll books. Verified Voting is a national non-partisan, nonprofit organization whose mission is to strengthen democracy for all voters by promoting the responsible use of technology in elections. As part of our mission, we maintain an extensive database of voting technology used in jurisdictions throughout the country, including electronic poll books, and make this database available as a public resource on our website.

Logic and accuracy testing of any technology used in elections is a key component in maintaining election integrity. One recommendation we have is to include more detailed guidance on how the testing process should be conducted, especially to verify the correct ballot style. It is our understanding that such a process may exist in practice, be we encourage the State Board of Elections ton include this in the regulations.  

We recognize, however, that no matter how thorough the testing, no technology is foolproof, and errors can still occur. A jurisdiction in Virginia using electronic poll books in the June 2020 primary elections had to rely on provisional ballots for voters when a glitch with the electronic poll books caused problems with checking in voters. It is vital, therefore , to have paper poll books at each polling place as a back-up, even when logic and accuracy testing of the poll books is performed beforehand. It is our understanding that effective July 1, 2020 per the passage of HB1421, every precinct using electronic poll books will be required to also have a paper pollbook produced by the general registrar. We emphasize the importance of these paper backups even as Virginia adds steps to improve the pre-election testing of electronic poll books.

Verified Voting commends Virginia's leadership in election security in recent years through its actions of moving to voter-marked ballots and piloting risk-limiting audits to verify the accuracy of the machines tabulating the votes. These processes go hand-in-hand with the logic and accuracy testing of tabulation machines that happens before the election, completing the cycle so that voters can be confident their votes were counted as cast. As Virginia moves to the utilization of electronic poll books as a component of its voting technology, logic and accuracy testing, together with the paper poll book backups, will help ensure all eligible voters can cast their votes. Verified Voting supports these regulations.