IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #2 - 2025

Jurisdiction Position Comments

ALBERTA		 Alberta is supportive of the new streamlined review procedures and understands the need for this change but is concerned that “appropriate share” is very vague.

Attorney Advisory Committee		 Undecided
  • History/Digest paragraph 2 should be changed as follows:

The IFTA Board of Trustees issued a Board Charge (Charge) to the Program Compliance Review Committee (PCRC) in March 2024 to develop new review procedures that include an annual Administrative review of all member jurisdictions. The Charge directs the PCRC to streamline the review process with more of a focus on items that are of monetary importance to all member jurisdictions.

  • The ballot should explain how the current participation limit in program compliance reviews is counter to an annual admin review. It also does not explain how the limit is counter to multiple reviewers working together on portions of reviews for multiple jurisdictions. That is, it is not clear whether the annual admin review is intended to replace one or more compliance reviews such that there is only ever going to be one annual review in which jurisdictions must participate, or whether there may still be other reviews in addition to the annual admin review as needed.
  • By continuing to state that jurisdictions will be required to participate in their appropriate share of program compliance reviews each year, the implication is that there will be more than one. This does not make sense if there will only be one annual review of each member jurisdiction.
  • The term “appropriate share” is ambiguous and subjective. Without being defined or otherwise constrained, the term is effectively unenforceable and open to dispute.
    • Without better defining this term it could lead to future issues.
  • If the intention is that jurisdictions will only participate in one annual admin review, then perhaps P1230 should be revised to state:
    “Each jurisdiction will be required to participate in one annual administrative review of their program compliance.”
  • If the intention is that jurisdictions will be required to participate in an annual admin review as well as other compliance reviews as necessary, then it is suggested that the maximum number of reviews in which a member jurisdiction must participate should reasonably be specified or otherwise limited.
  • A jurisdiction should be aware of the amount of work this ballot passing would entail.
  • It is also not clear as to the expectation of the reviews. Is it just the annual administrative review, or will there be more?

BRITISH COLUMBIA		 Undecided British Columbia agrees with other jurisdictions that more information is required on the new review process before supporting this ballot.

ILLINOIS		 Oppose Removing a limitation that protects each jurisdiction from abuse of time/resources is concerning.
The ballot does not appear fully fleshed out.  Are we replacing current PCRs with this new “annual Admin reviews” or augmenting current PCRs with this annual Admin review?  If the participation cap is removed, required participation is ambiguous because the remaining language says only that jurisdictions must participate in their “appropriate share” of reviews.  According to whom?  For clarity, maybe the proposal should be to keep the existing 2 reviews cap but qualify Sec. 1230 by adding language that says something more like, “, except that, in addition, each jurisdiction shall participate in one [more than one?] annual administrative review” and then provide a description of what an “annual Administrative review” consists of as compared to a standard “program compliance review” – whatever these differences might be (not stated anywhere).

INDIANA		 Undecided Indiana is undecided on this ballot and would like to request more information to completely understand the intent of the proposed change.

Industry Advisory Committee		 The Industry Advisory Committee (IAC) does not oppose the general intent of Ballot #2-2025. However, when considered alongside the broader set of 2025 ballots, we feel it is important to offer a word of caution.

IOWA		 Support Iowa is in favor of this ballot.

KANSAS		 Undecided

KENTUCKY		 Support

MANITOBA		 Oppose

MARYLAND		 Oppose Maryland does not support as written.

MICHIGAN		 Support Michigan supports this ballot. 

NEVADA		 Undecided Agree with NC. Language is not clear. What is "appropriate share". How much time will be consumed with these?  Need more information. 

NEW BRUNSWICK		 Oppose

NEWFOUNDLAND		 Oppose

NORTH CAROLINA		 Undecided North Carolina generally supports the ballot's intent but has concerns with its language. Therefore, it has noted its position as undecided. If the appropriate changes are made to this ballot, North Carolina would support the ballot.

First, because the ballot removes the cap on the number of program compliance reviews each year, the "appropriate share" language becomes more important but is vague in the number of reviews in which the jurisdiction must participate.

Second, it is important to note that the procedures used to direct the program compliance reviews are not voted upon by all the member jurisdictions as occurs with an amendment to the Procedures Manual. Therefore, the time commitment may change and with no cap, the burdens placed on jurisdictions may shift significantly over time.
 
Third, it may be beneficial to differentiate between and audit type review and an administrative review.

If the purpose of the ballot is to allow annual reviews, which are less time intensive, then it may be best to re-write the ballot as follows:

"Jurisdictions will be required to participate in their appropriate share of program compliance reviews each year. No member jurisdiction will be required to participate in more than three program compliance reviews per year."

In the alternative, if the sponsor differentiates between types of review, the ballot could read as follows:
 
"Jurisdictions will be required to participate in their appropriate share of program compliance reviews each year. No member jurisdiction will be required to participate in more than: (1) two audit program compliance reviews per year. year; and (2) one administrative program compliance review per year."

Either of the above solutions would address North Carolina concerns and would likely secure a "Yes" vote from North Carolina.
 
North Carolina will assist the sponsors in drafting an amended ballot upon request.
 

OKLAHOMA		 Undecided Oklahoma needs more clarity on the intended purpose of this ballot. 

ONTARIO		 Undecided Ontario would like the committee to provide more details about the new review process and the time commitment jurisdictions can expect.
The phrase “appropriate share” in P1230 should be defined if there is no maximum to the number of reviews a jurisdiction is required to participate in. The phrase should be defined so jurisdictions will have a clear understanding of what constitutes compliance and non-compliance.

PENNSYLVANIA		 Undecided

QUEBEC		 Oppose Quebec do not support the current wording associated with the ballot and the effects it can have on jurisdictions participating in an uncapped amount of compliance reviews each year.

SASKATCHEWAN		 Undecided Saskatchewan interpreted the proposed ballot to only impact the designated reviewers (and PCRC committee members) that are completing the compliance reviews, to increase the number of reviews they could be involved with in a year.  However, confirmation on what impact this would have to the jursidictions that are the subject of the reviews is required before we can fully support this ballot.

SOUTH DAKOTA		 Support

VIRGINIA		 Undecided Virginia shares the concerns raised by other member jurisdictions regarding removal of the cap.
Support: 4
Oppose: 6
Undecided: 11

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