IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #3 - 2025

Jurisdiction Position Comments

ALBERTA		 Undecided Alberta is supportive of the intent of this ballot but has concerns with the language used. This ballot requires significant revision and we support North Carolina's comments and offer to assist in redrafting the ballot.

Attorney Advisory Committee
  • The ballot recommends updating A350.300 of the Audit Manual.
    • It is noted that A350.300.005 refers to “…or any factor used to compute motor fuels consumption…”, whereas A350.300.010 refers to “…or other industry recognized factor used to compute motor fuel consumption…”
  • It is recommended that the wording referred to above be made more consistent.
    • For example, both sections .005 and .010 might refer to “…or any other industry-recognized factor used to compute motor fuel consumption…”
  • In any event, it is noted that .005 refers to “motor fuels” (plural), whereas .010 refers to “motor fuel” (singular).
    • Either plural or singular should work, but it should be consistent in both sections.
  • The ballot also recommends comparable changes to P570 of the Procedures Manual.
    • Depending on what is decided in respect of the above comments, P570.100.005 and .010 should be updated consistently.
  • Minor grammatical point: For both A350 and P570, consider whether “industry recognized” should be hyphenated.
    • Suggest that “industry-recognized” would be the correct form, as it is a (hyphenated) adjective modifying the noun “factor”.

BRITISH COLUMBIA		 Undecided

ILLINOIS		 Undecided Support only if revisions made.  While we understand the need to add detail about auditing alternative fuels, this ballot still needs work.  There is no definition for “MPGe” and “KPLe”.  In addition, a definition should also be added for “MPG,” “KPL,” and “kWh.”  Also, the amendments must explain how the third sub-item in both A350.300 and P570.100 relates to each the first two (4 mpg/20% mileage reduction).  Is it an “or” or an “and” or something else.  Specifically, is sub-item 3 (i.e. “.015”) an alternative option or a sub-option or an additional option to the first 2 items (i.e., “.010” and “.015”)?  It appears not to be related to the first 2 items, but instead to be separate, additional instructions about alternative fuel jurisdictions.  More needs to be done to synthesize this option.

INDIANA		 Support Indiana is in favor of this ballot. It provides instruction on how to handle adjusting in the audit for a carrier who operates alternative fuel vehicles, when the records are determined to be inadequate. We do recommend, however, that the definition of MPGe and KPLe be added. 
 

Industry Advisory Committee		 The IAC supports the intent of Ballot #03-2025 and agrees with the comments submitted by North Carolina.  As alternative fuels continue to evolve, it remains critical that updates to the IFTA Audit and Procedures Manuals are carefully developed to ensure accuracy and consistency.  We recommend the IFTA Audit Committee collaborate with the Attorney Advisory Committee to draft a comprehensive ballot that includes clearly defined terms, appropriate abbreviations, and standardized options for calculating consumption.  Any proposed changes should also address the full scope of documentation requirements to support effective and uniform audits across jurisdictions.

IOWA		 Support Iowa is in favor of this ballot. 

KANSAS		 Undecided

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Undecided Maryland, at this time, does not tax consumption of the alternative fuels proposed in this ballot.

MICHIGAN		 Support Michigan supports this ballot however has a few concerns. based on A350.300.015 - 'increase only jurisdictional distance by 20% for jurisdictions that impose a consumption of fuel by applying a tax rate by distance.' Michigan will need to consult with our IFTA system vendor on the change to apply 20% change to specific jurisdictions since this would be a significant change from our the system currently works. We do not support the current effective date of this ballot

NEVADA		 Undecided Currently, NV does not tax on alternative fuels. We also don't know if NV is working on any laws pertaining to this issue, that may impact this ballot.  NV agrees with NC comments. 

NEW BRUNSWICK		 Support

NEWFOUNDLAND		 Undecided

NORTH CAROLINA		 Undecided North Carolina has multiple concerns regarding this ballot. Some of these concerns are fundamental errors effecting the validity of the ballot if it passes. Therefore, North Carolina recommends that the sponsor reach out to the AAC (Attorney Advisory Committee) for ballots. Based on North Carolina’s understanding, this is something the AAC encourages.

This Ballot May Not Be a Ballot 
 
North Carolina is concerned that the ballot is so improperly formatted that the ballot may not meet the requirements of R1615, which requires that all ballots “contain . . . [t]he precise language to be considered.”
 
The ballot materially misrepresents the changes to be made to all the following sections: (1) A350.100; (2) A350.300.005; (3) A460.500.015; (4) P570.100.005; and (5) P570.200. North Carolina is not stating that the sponsor intentionally misrepresented the language to be considered, but the extent of the errors raises an issue under R1615 whether the ballot contains the “precise language to be considered.”

Because R1610.100 requires that “[a] proposed amendment is to be submitted to the repository at least 60 calendar days before an open meeting of the commissioners[,]” the sponsors cannot cure this error in 2025.

It must be noted that when a ballot makes changes to the Articles of Agreement that are not in compliance with the Agreement, the validity of the ballot will remain in question. In other words, the existence of this comment (which North Carolina felt compelled to advise membership) can be used to overturn the ballot because persons subject to the changes are now aware that the ballot could be procedurally defective.

To provide certainty to jurisdictions and licensees, North Carolina recommends that the sponsors amend the ballot and move forward with it in 2026.
 
The Ballot Poses Issues with Terminology

Given that jurisdictions and industry are trying to adjust this ever-changing landscape, it is important to be consistent and clear with terminology. The ballot makes the following errors or incorrect assumptions regarding critical terms of art: 
  1. kWh is not a report “of volume consumption . . . .” kWh is also not a measure of fuel economy (efficiency) – it is a measure of volume. To be equivalent to MPG or KPL, a jurisdiction would need to measure the miles per kWh (mpkWh). Reducing the volume of fuel (kWh) is covered by A360 and should not be in A350.100.
  2. Fuel economy is preferred term (in the US) over fuel efficiency based on its use by the US Department of Energy and the US Department of Transportation. Based on North Carolina’s understanding, fuel economy is the measure of distance per unit of fuel. Fuel efficiency is represented by a percentage of work per unit of energy. Therefore, the wrong term is being used.
  3. Fuel consumption is incorrectly used in the ballot – it should be replaced with fuel economy. Fuel consumption is the units of fuel used per unit of distance (e.g., liters per 100 kilometers (L/100 km)). Fuel economy is the unit of distance per unit of fuel consumed (e.g., miles per gallon (MPG)).
  4. As noted in North Carolina’s 2024 comment, it disfavors imprecise language such as “other industry recognized factor.” It places unnecessary ambiguity in the IFTA governing documents with no discernable benefit.
General Drafting Concerns
 
The ballot uses terms inconsistently and unclear language. For example: 
  1. The repeated use of acronyms is not a best practice and makes it difficult to read.
  2. MPG and KPL are referenced as fuel consumption factors but then later collectively referred to as an efficiency metric.
  3. The ballot breaks out the equivalency standards (e.g., MPGe) from MPG and KPL and treats equivalency standards calculations differently (one is subject to a 4.0/1.7 reduction while the other subject only to the 20% reduction.) Why would MPG be treated differently than MPGe? That would be defeat the purpose of calculating MPGe.
  4. The ballot treats fuel economy and fuel volume interchangeably under A350.300.005 and P570.100. North Carolina is concerned about the that apparent unintentional melding of A350 and A360. Consistency can only be achieved by using miles per kWh (mpkWh) or the metric unit equivalent.
Drafting Assistance
 
North Carolina will assist the sponsors in drafting an amended ballot upon request. As an example of a potential starting point to address these concerns, North Carolina would remove all references to MPG, KPL, fuel consumption, efficiency, and similar terms and replace all references with a newly defined term: fuel economy. It would be defined something like the following:
 
"R222     Fuel economy means the ratio of distance traveled per unit of fuel consumed. Fuel economy can be expressed as miles per gallon (MPG), kilometers per liter (KPL), miles per kWh (mpkWh), and kilometers per kWh (kpkWh). Energy equivalency such as MPGe or KPLe is determined by the base jurisdiction’s laws."
 
This would clear up the language significantly, make it easier to read, and ensure consistency.

 

OKLAHOMA		 Oppose Oklahoma has concerns over the ambiguity of the ballot language and the authority over the taxation of distance versus fuel consumption. 

ONTARIO		 Undecided Ontario would like to see North Carolina’s comments addressed before deciding whether to support ballot #03.

PENNSYLVANIA		 Support As a partial sponsor of Ballot 08-2022 and the primary sponsor of Ballot 05-2023, we appreciate the AC drafting this ballot to clarify the necessary changes to the governing documents.
With all due respect to North Carolina's comments, we agree that it appears there is a reference to "kWh" as an example of a fuel economy factor and maybe that can be removed as a non-substantial change, but we disagree with North Carolina's following assessment: 
"Fuel economy can be expressed as miles per gallon (MPG), kilometers per liter (KPL), miles per kWh (mpkWh), and kilometers per kWh (kpkWh). Energy equivalency such as MPGe or KPLe is determined by the base jurisdiction’s laws."
Although it sounds logical to measure the fuel economy factors for Electricity as MPkWh or KPkWh, we have yet to see these in practical use. We have to take our cues from the industry here and they utilize the MPGe (essentially equivalent to MPkWh); to our knowledge, this did not come from any base jur’s laws; its to match what the industry uses and reduce confusion.
Also, the AC included the catch-all of "other industry recognized factor(s) used to compute motor fuel consumption,” to cover other terminology examples. When PA presented on these issues at the 2024 ABM, we suggested that you could essentially put any term you want in the box that usually says “MPG” (ex.: MPGe, FECF (meaning: fuel economy compliance factor), or even “Distance/Fuel” or “Distance/Volume.”
Lastly, to Maryland’s point, this ballot is intended to assist jurisdictions using mileage-based-solution, like Indiana, fit into the existing framework of our conventional-based fuels. You do not have to employ this method in order to support it.
 

SASKATCHEWAN		 Support

VIRGINIA		 Undecided
Support: 8
Oppose: 1
Undecided: 10

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