IFTA, Inc. International Fuel Tax Association

IFTA Ballot Proposals Comments

IFTA Ballot Comments

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2nd Period Comments on FTPBP #2 - 2025

Jurisdiction	Position	Comments
Support: 6 Oppose: 9 Undecided: 2
ALBERTA	Support	Alberta supports this change as it is necessary for the new compliance review process, which has been adopted and should result in less resource burden for jurisdictions.
BRITISH COLUMBIA	Support	BC supports this ballot as it is necessary for the new streamlined review process.
CONNECTICUT	Support	Connecticut supports this change as it is necessary for the new compliance review process, which has been adopted and should result in less resource burden for jurisdictions. When P1230 Required Participation was set stating that no member jurisdiction will be required to participate in more than two program compliance reviews per year, in person reviews were conducted at the location of the jurisdiction being reviewed. Since the reviewers were required to travel to the jurisdictions being reviewed, it made sense to limit the number of in-person reviews to 2 per year so it would not put an undue burden on the reviewer and the reviewer's jurisdiction. This ballot will allow the reviewers to more efficiently conduct multiple reviews in a group setting during one travel week which is no more burdensome than what the current language requires.
ILLINOIS	Oppose	Position: Oppose as drafted. The proposed language in this ballot is ambiguous and not fully developed. For instance, the following questions must be addressed in the body of P1230: What does “assistance with these program reviews” entail? What is the “bulk review process”? How is the schedule to be established? What are the parameters for establishing a schedule? How frequently will a reviewer have to serve the “two-year term”? How will the reviewer jurisdictions be selected for the two-year terms? What are the “review responsibilities”? If they are outlined in another section of the manual, a cross reference should be inserted. Also, it should be noted that, although a reviewer “may be asked” to participate in entrance meetings or discussion, this ballot does not actually require a reviewer to participate.
KENTUCKY	Support	Should streamline the process and make it easier on jurisdictions.
MANITOBA	Oppose	Manitoba agrees with Ontario's comment about the travel week. It most likely will be difficult to get approval to travel.
MICHIGAN	Undecided
NEVADA	Oppose	Nevada opposes the ballot as written. Differentiating between Admin and Audit reviews would be beneficial. Nevada agrees with Illinois on adding details of the process and agrees with Ontario on travel week.
NEW BRUNSWICK	Support
NEWFOUNDLAND	Oppose
NORTH CAROLINA	Undecided	North Carolina applauds the sponsor's changes after the ABM to attempt to resolve the concerns raised by membership. As stated in the first round of comments, North Carolina is in favor of modernizing the review process and amending the Procedures Manual to effectuate those changes. However, concerns remain with the new language. Did the Sponsor Intend for this to Apply to All Reviews? First, North Carolina needs to emphasize to membership that the ballot, as written, applies to all periodic program compliance reviews. The requirement for jurisdictions to make available jurisdiction reviewers is exclusively found within P1230. Therefore, did the sponsor intend to have the designated week apply to both the annual compliance review and the 5-year audit review? If this ballot passes, regardless of what type of compliance review is being conducted, the majority of duties placed on jurisdictional reviewers is limited to that one designated week. If this is not the intent of the sponsor, the ballot must be re-written to distinguish between annual compliance reviews and the 5-year audit reviews. Note, that because making this type of change would be substantive, there are significant questions on ballot procedure for how R1620.300.15 works in conjunction with R1625. The remaining comments assume that it is the intent of the sponsor to have this ballot apply to all compliance reviews. Vague Language and Time Commitments of Reviewers As noted in the first round of comments, North Carolina is concerned about the time commitment asked of jurisdictions and its jurisdictional reviewers. This manifests through "squishy" ballot language. Specifically, the following phrases and terms are undefined or vague: "bulk review process" "majority of review responsibilities will be concentrated" "limited follow-up discussions" "no additional extensive review obligations" These phrases need to be further developed to provide certainty for the future of these reviews. Concerns with a Travel Week North Carolina is also concerned about the reference to a "travel week" in the ballot. The ballot can be reasonably interpreted to require all jurisdictional reviewers to commit to one week of travel per year. There are multiple concerns here. First, this goes further than the recently amended IFTA Program Compliance Review Guide. This guide provides, in part (underlined is North Carolina's emphasis): "By prioritizing in-person engagement, organizations can ensure that program compliance reviews are not only thorough but also aligned with best practices and IFTA standards." "Ballot #2 proposes removing the current restriction that limits member jurisdictions to participation in no more than two program compliance reviews per year. This change is intended to facilitate collaborative, on-site reviews by enabling jurisdictional reviewers to travel . . . ." The emphasized words above prefers and encourages in-person work. It does not require it. The ballot, however, may indeed require travel. This is problematic in many ways, including whether a jurisdiction would allow its person to travel and the potential of a jurisdiction to require direct payment of travel expenses. Specifically, P1210 provides that "the expenses of such reviews may be paid through the International Fuel Tax Association if funds are available." Proposed Ballot Language The sponsors were gracious enough to ask for proposed language from North Carolina. It proposes the following re-write of P1230: P1230 REQUIRED PARTICIPATION IN PERFORMING PROGRAM COMPLIANCE REVIEWS .100 Member jurisdictions shall make available jurisdictional reviewers to conduct periodic program compliance reviews as scheduled by IFTA, Inc. The jurisdiction reviewers designated by the jurisdiction must serve a two-year term but may be substituted at the discretion of the jurisdiction. .200 IFTA, Inc. shall assign periodic program compliance review responsibilities equally among the member jurisdictions. .300 Periodic program compliance reviews must be conducted during one week of the calendar year. The Program Compliance Review Committee shall determine the applicable week. .400 Unless consented to by the member jurisdiction, its jurisdictional reviewer may not perform more than 24 work hours associated with conducting periodic program compliance reviews outside of the designated week. As noted above, if the sponsor intended this language only to apply to annual reviews, this language is moot.
ONTARIO	Oppose	Ontario supports the new program compliance review process, and we recognize this process has been adopted apart from ballot #02-2025. However, Ontario does not support including the concept of a “travel week” in the Articles of Agreement under Required Participation. Ontario cannot commit to funding travel and accommodations for a week and does not support making travel for IFTA events required for member jurisdictions. Ontario could support this ballot if it was updated to say travel was preferred but not required.
PRINCE EDWARD ISLAND	Oppose
QUEBEC	Oppose	The jurisdiction of Quebec opposes the current ballot for the following reasons: 1) Fundamental structure of the proposed review process: while the jurisdiction of Quebec acknowledge the intent to speed up the review process, we also feel that in 2025, a true hybrid process of remote work and in-person meetings should be prioritized. Regarding the travel week, an hybrid system should give each jurisdiction the choice to send its reviewers on site. This is especially important in the context of labour shortage experienced by many jurisdictions. A true hybrid process would also allow for more pre-planning meetings, thefore avoiding stumbling blocks during the "travel week". 2) Language used: terms like "appropriate share" and "bulk" are a broad language and creates uncertainty to determine if a jurisdiction is in compliance with the proposed section P1230. 3) Unexpected / unintended result: given the intent to concentrate the reviews in a travel week, the ballot should allow jurisdictions to change reviewers under predetermined and exceptional circumstances (ex: illness, traveling problems, etc), in order to remain in compliance with section P1230. 4) Bearing of the costs: section P1210 of the agreement mentions that the expenses of the reviews might be paid through IFTA if funds are available. Given that it's IFTA's intention to change the current process, the jurisdiction of Quebec would propose the following section P1210, which would allow more certainty to grant travel approvals for the reviewers: Member jurisdictions shall permit periodic program compliance reviews to be performed to assure they are in compliance with the provisions of the Agreement. At the expense of the member jurisdictions conducting such reviews, they will be performed after the first year of implementation of the Agreement. The expenses of such reviews must be paid through the International Fuel Tax Association if funds are available. Beginning January 1, 1997, the program compliance reviews will be conducted according to a schedule developed by IFTA, Inc. The jurisdiction of Quebec also feels that if known at the time, such intention to change the process should have been clearly presented within the context of the dues increase vote at the 2024 ABM.
VIRGINIA	Oppose	Virginia supports the new compliance review process. However, the scope of this ballot goes beyond the changes needed to align the language of the Articles of Agreement with that process, introducing vague and potentially onerous requirements, as other commenters have noted.
WEST VIRGINIA	Oppose	Language needs clarified
WYOMING	Support	Wyoming supports this ballot. The current limitation, restricting jurisdictions to no more than two reviews per year, conflicts with the new process. In the old process, if you reviewed 2 jurisdictions each year, it would take many days for each review. In the old process, the reviewer would be spending 2 weeks or more to review 2 jurisdictions. In the new process, you will be able to review 10-15 jurisdicions in a few days. The new process has dramatically changed so that you are looking at reports to determine compliance vs going line by line through taxpayer returns.
Support: 6 Oppose: 9 Undecided: 2

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