Comments on FTPBP #2 - 2017
Jurisdiction Position Comments

ALABAMA
Support

ALBERTA
Undecided Alberta generally supports the ballot but has concerns.  We have agents requesting decals to be distributed to their various client licensees as listed by the agents.  While Alberta keeps track of serialized decals and can update the serialized decal information for those decals Alberta issued directly to licensees, we do not have information on which specific serialized decals are distributed by the agents to the specific licensees.  Since Alberta cannot update the serialized decal information for decals distributed through these agents, there continues to be a need to call Alberta for verification of decal information for those cases.  We are, therefore, wondering about the value of the proposed ballot. 

BRITISH COLUMBIA
Support Already doing.

CONNECTICUT
Support Connecticut is in support of this ballot. While IFTA is expressly not vehicle specific, nothing prevents jurisdictions from maintaining information on what serial numbers have been issued to specific carriers.  By providing this information as part of the Clearinghouse demographics, law enforcement can readily identify what decal numbers a carrier has in their possession.  This will make things easier for law enforcement to identify the misuse of decals.  Once IFTA goes to full electronic credentialing we will in fact be vehicle specific; until such time this is a good measure to undertake to assist law enforcement. 

ILLINOIS
Oppose Oppose as written.  One very important component that must be required with this ballot language is the decal year must be identified with the serial number.  It is possible that decal number IL123456 is valid for two different companies at the same time: carrier ABC could have decal IL123456 issued for 2017, while carrier DEF could have decal IL123456 issued to them for 2018:  both decals (could be) valid from December through the end of the grace period.  A roadside search of "serial number" could provide a false hit if that decal serial number is not tied to a specific year.

INDIANA
Oppose Indiana does not support this ballot as it does not provide a complete solution.  If passed this ballot would require programming changes, continual updates, and still would not verify that the credential is valid through this change alone.   

To expend resources to comply with this ballot when we are on the doorstep of a very different future verification process that would also require allocation of scarce resources is inefficient.

As an alternative, Indiana supports the concept of electronic records as a safe, accurate, inclusive, economical, and effective validation of credentials.   

 

KANSAS
Support

MAINE
Undecided While Maine currently seializes its decals, we see limited value in requiring jurisdictions to send their serial numbers to the CH.  This option exists today fo rany jurisdiction wishing to avail themselves of the service.  Making this a requirement at this late date would seem superfluous.

MANITOBA
Support

MICHIGAN
Support

MINNESOTA
Support Minnesota is supportive of the ballot proposal and the effective date.

MISSISSIPPI
Support

MONTANA
Support

NEVADA
Support Nevada supports this ballot as we already serialize our decals.  That said, what does this ballot really accomplish?  It will require costly changes for system programming and a new field in the clearinghouse.

Decals and copies of licenses in the cab are little more than a false sense of security for law enforcement and have been for years.  A decal (serialized or not) on the cab of the truck does not ensure that vehicle is being reported for IFTA.  The license is only a piece of paper that states the "company" the vehicle belongs to licensed for IFTA.  It doesn't mean the returns were received, all the vehicles were reported on the return, or the information on the return is even accurate.  Only real time information which may also be available through ASPEN, NLETS, SAFER, PRISM, CVIEW, etc., will tell you if the company is still active and in good standing with IFTA. 

Perhaps rather than trying to fit the electronic credentials into a box that is rapidly becoming obsolete, it is time to think outside the box and find long term solutions that will fit the changing transportation industry, i.e. in 2035 when driversless vehicles are the norm.  It's time to consider  piloting a few states to go totally electronic, no paper license and no decals, or perhaps build an app through IFTA that will provide realtime status of the company for roadside enforcement to view if it provides greater value to the officer coming directly from IFTA. 

NEW BRUNSWICK
Undecided We support the idea of including the decal numbers, however we will need to investigate the capability of our IT system to provide this information.
 

NEW HAMPSHIRE
Undecided

NORTH CAROLINA
Undecided There is concern with the system changes needed and costs associated with those changes.

NOVA SCOTIA
Undecided We are unclear about  operational and IT implications.  

ONTARIO
Support

PENNSYLVANIA
Support

PRINCE EDWARD ISLAND
Undecided We would need to confirm with our IT department that the information we already have in our system could easily be reported on.

QUEBEC
Oppose Even if Quebec is not part of the clearinghouse, we think this proposal will require a significant system development and it will be costly.

RHODE ISLAND
Support RI currenty already does this

SASKATCHEWAN
Support

SOUTH CAROLINA
Support

Stakeholders
Oppose 6-2-2017 ATA Robert Pitcher
Although more thorough and timely sharing of IFTA licensees’ demographic data by the states and provinces is necessary, the sharing of serialized decal numbers is not, and would be bound to cause problems for compliant carriers.

TENNESSEE
Support

UTAH
Oppose We feel it's not worth the effort to have our system changed, and decals serialized, if decals are going to be obsolete in the next few years. .  

VERMONT
Support

VIRGINIA
Undecided Virginia already does this voluntarily, but to require it of all jurisdictions seems at odds with the long-term goal of moving to electronic credentials.  We look forward to the discussion of this ballot.

WASHINGTON
Oppose This proposal would require a significant system development.  We have IFTA accounts without IRP and IRP accounts with foreign jurisdiction IFTA.  An IFTA account without vehicle information would be difficult to track decals by vehicle. 

WEST VIRGINIA
Support

WISCONSIN
Oppose Wisconsin does not support.  We currently maintain serial numbers internally but do not feel the juice is worth the squeeze.  Reprogramming our system to upload serialized decal numbers to the clearinghouse would require funding and energy that we feel would be better spent elsewhere (electronic records).
If decals were going to be around for another decade or longer, I would fully support vehicle specific decals.  That being said, I believe the decal's days are numbered.
Wisconsin is supportive of allocating resources to electronic records concept and level 8 (moving) roadside inspections.
Support: 18
Oppose: 7
Undecided: 8
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