Comments on FTPBP #5 - 2017
Jurisdiction Position Comments

ALABAMA
Support

ALBERTA
Undecided We understand that electronic services is the way of the future.  However, we would like to hear how some of the concerns as noted through the pilot project are to be dealt with first.  Alberta also agrees with the concerns as noted by Ontario.

BRITISH COLUMBIA
Support

CONNECTICUT
Support Connecticut is in support of this ballot. Since electronic credentialing is where IFTA is moving as a membership, this ballot is a critical step toward that goal.

ILLINOIS
Undecided

INDIANA
Support Indiana supports this ballot as it moves away from requiring paper when we exist in an electronic world.  However,  the presentation of a paper or electronic image of a license does not verify the status of a credential as additional acts must be taken by roadside enforcement. 

Imagine roadside enforcement already knowing the status of an IFTA license prior to pulling a truck over.  It is possible and it is time.           

KANSAS
Undecided Without the full endorsement from LE, Kansas cannot support the ballot as this time.  We have similar concerns as Alabama, Ontario and Washington.
 
This section of the ballot may need more clarification.
As noted in the History/Digest of the ballot:  The response of licensees and LE has been highly positiveIn my opinion, this is misleading, LE from Kansas has vocalized concerns that were not acknowledged.  It is my understanding that very few carriers participated and only 1 carrier of relevant fleet size participated in the study and no inspection reports were “turned in”.

We too would like the Law Enforcement Committee to voice their concerns.

MAINE
Support The IFTA license, whether paper or on a device, is merely a convenience to provide basic information.  In order to truly verify a licensee's status, a check must be made against a database such as SAFER (via a CVIEW) or the CH. 

MICHIGAN
Undecided Michigan is not opposed to electronic credentials and recognizes it will inevitably be accepted.  Even as a participant of the pilot program, we recognize the potential.  Our concern is that the language of the ballot states jurisdictions must accept electronic images of the IFTA license if that is the format provided by the licensee.  This language has no regard to the jurisdictional statutes or the jurisdictions law enforcement policy.  Since the effective date is allowing time for statutory and regulation changes, what are the consequences of jurisdictions who do not implement a change of accepting an electronic image of an IFTA license?     

MINNESOTA
Support Minnesota is very supportive of the ballot proposal and the January 2020 effective date but would prefer to have a definition included that the electronic image shall be in unalterable format.

MISSISSIPPI
Support

MONTANA
Oppose

NEVADA
Support Nevada fully supports the use of electronic credentials.  Whether in paper format or electronic, the only real way to know if a vehicle is on the road legally is to confirm the company information through another means such as NLETS, ASPEN, SAFER, CVIEW, etc.  Reliance on a decal and paper cab card, or an electronic image of a cab card, does not ensure the company operating the vehicle is properly registered and licensed at the time of the stop.

NEW BRUNSWICK
Support

NEW HAMPSHIRE
Support

NORTH CAROLINA
Undecided If this ballot passes, we may have to make statutory changes.

NOVA SCOTIA
Undecided We agree with Ontario's comments.

ONTARIO
Undecided While there may be value in allowing either format in licensing, it seems fundamentally skewed for that decision to be controlled by an individual licensee. By all means introduce the flexibility at the discretion of each jurisdiction but continue with the requirement to also carry a paper copy of the license. Despite the best of intentions there may be situations where electronic information is simply not accessible (e.g. service provider limitations, dropped signal, defective device, etc.) Jurisdictions must be permitted to continue with roadside inspection activities and enforcement by demanding proof of an IFTA license in these circumstances.
 
It would be beneficial to add language and establish a process for an evidence trail that may be necessary in the event that fraudulent electronic documents are discovered. Additionally the ballot does not speak to the control, handling or potential jurisdictional liability of any device presented by the licensee.

PENNSYLVANIA
Support

PRINCE EDWARD ISLAND
Undecided We agree with Ontario's comments.

QUEBEC
Undecided As per our Law Enforcement agents, it is always the responsability of the carrier to prove he has a valid license. If electronic information is not accessible then the driver needs to carry a paper copy of the licence.

RHODE ISLAND
Support

SASKATCHEWAN
Support

SOUTH CAROLINA
Undecided

Stakeholders
Support 6-2-2017 ATA Robert Pitcher
We support the concept very strongly, but the effective date should be moved up at least a year, to no later than January 2019!

TENNESSEE
Support

UTAH
Support

VERMONT
Support

VIRGINIA
Support

WASHINGTON
Undecided Washington would like to have the Law Enforcement Committee to review and explain their enforcement concerns (if any).  We are concerned with a "picture" or other electronic documents.  We are interested in hearing from other jurisdictions regarding any concerns that this is at the taxpayer's discretion and not more defined by the ballot language. 

WISCONSIN
Support
Support: 19
Oppose: 1
Undecided: 11
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