IFTA Ballot Proposals Comments

IFTA Ballot Comments

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2nd Period Comments on FTPBP #3 - 2025

Jurisdiction Position Comments
Support: 8
Oppose: 3
Undecided: 3

ALBERTA		 Support

BRITISH COLUMBIA		 Support Support using an “average fuel consumption factor” as an all encompassing measurement to represent fuel consumption.

CONNECTICUT		 Support

ILLINOIS		 Oppose Position: Oppose as drafted.
This ballot confuses terminology.  Fuel consumption and fuel economy are two terms of art that have different meanings. 
Fuel economy:
  • Measures how much distance a motor vehicle can travel on certain amount of fuel.
  • Is expressed in miles per gallon (mpg) or kilometers per liter (kpl).
Fuel consumption:
  • Measures to how much fuel a motor vehicle uses to go a certain distance.
  • Is expressed in gallons per mile (gpm) or liters per kilometer (lpk).  See e.g. 49 CFR 535.59(c).
Fuel consumption and fuel economy are inversely related, which means as one increases, the other one decreases.  “Fuel efficiency means the amount of work performed for each gallon of fuel consumed.”  49 CFR 535.4 (emphasis added).
1.)  The “average fuel consumption factor” should be replaced with “average fuel economy value” in A350, A460, P570, and P720.350 for the following reasons. 
To use phraseology of “average fuel consumption factor” while the concepts of fuel economy (MPG, MPGe and KPL) are already present in the current language, not only makes A350, A460 and P570 internally inconsistent but also contrary to generally accepted principles.  The general public, US Dept. of Energy, the US National Highway Traffic Safety Administration, and US Environmental Protection Agency utilize generally accepted principles of fuel economy, fuel consumption and fuel efficiency.  The “Intent” makes a claim that “Miles per gallon equivalent (MPGe) is recognized as a valid fuel consumption measurement for the electricity fuel type, consistent with its use by the U.S. federal government and recognized in the industry.” (emphasis added).  However, that statement is contradicted by federal law.  According to the Code of Federal Regulation, MPGe or “Equivalent petroleum-based fuel economy value means a number representing the average number of miles traveled by an electric vehicle per gallon of gasoline.”  40 CFR 600.502(c) (emphasis added).  Other claims made in the “Intent” section are not supported by specific citations to authoritative sources, studies, federal or state laws. 
Further, definitions of MPG, KPL and MPGe should be added to ensure clarity.  For instance, the following definition already exists in the Code of Federal Regulation and could be utilized for consistency with the federal government: MPGe or “Equivalent petroleum-based fuel economy value means a number representing the average number of miles traveled by an electric vehicle per gallon of gasoline.”  40 CFR 600.502(c). 
2) Further, the proposed .015 in P570.100 should be removed from .100 and should become .150 to allow for greater clarity on how this item applies.  Also, the proposed .015 in A350.300 should be removed from .300 and should become .350 to allow for greater clarity on how this item applies. 
3)  In .200 “suspend, revoke, or cancel the license issued to a licensee” should be changed to “suspension, revocation, or cancellation of the license issued to a licensee”.
 

KENTUCKY		 Support

MANITOBA		 Support

MICHIGAN		 Undecided Michigan is undecided on this ballot because of the same concern we had in the first comment period.

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		 Oppose Nevada opposes this ballot as drafted and agrees with Illinois' comments. 

NEW BRUNSWICK		 Support

NORTH CAROLINA		 Undecided North Carolina agrees with Illinois that the use of terms remain problematic.
 
As described in detail in North Carolina's first comment, fuel economy is the most clear, consistent, and understood term for the function it is serving in this ballot. Injecting terms that are inconsistent with understood industry and federal standards poses issues that can be easily avoided.
 
North Carolina supports the intent of this ballot but has reservations based on the terms used.

ONTARIO		 Support

PRINCE EDWARD ISLAND		 Oppose

VIRGINIA		 Support

WEST VIRGINIA		 Undecided
Support: 8
Oppose: 3
Undecided: 3

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