IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #9 - 2025

Jurisdiction Position Comments

ALBERTA		 Undecided Alberta supports the intent of this ballot but has concerns about determining what is “unusual”.

Attorney Advisory Committee
  • Edits are not in red, like other ballot proposals.


  • The ballot proposes to clarify that, when preparing an audit file, only “unusual” trends or variances must be noted.


  • With respect to the proposed amendment to A460.100.060, it is suggested that the verb “Note” is not required, as A460.100 contains a list of general information to be included in the audit report, as opposed to actions. Therefore, it is recommended that the proposed amendment to A460.100.060 be updated to state, “Unusual trends or variances” or, alternatively, “Unusual trends or variances noted in the audit file”, as opposed to inserting an action item at the end of a list.

BRITISH COLUMBIA		 Oppose British Columbia is not convinced this change is necessary. The current language does not restrict auditors from noting unusual trends. Limiting the focus to only “unusual” trends implies an assumption of non-compliance. There may be trends that are not unusual—such as seasonal variations in distance travelled—that are still worth noting and may, in fact, support a finding of compliance.

INDIANA		 Support Indiana supports the ballot.  The additional language improves clarity regarding the circumstances under which the auditor has a duty to document trends or variances in the audit file and audit report.

Industry Advisory Committee		 The IAC supports Ballot #09-2025 and appreciates the continued efforts to improve clarity and consistency within the IFTA framework.

IOWA		 Support Iowa is in favor but recommends the definition of unusual trends or variances be added to A310.300.

KANSAS		 Support

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Undecided Maryland agrees auditors should only address and concentrate on unusual trends and variances instead of normal activities that are in compliance.  However, without some sort of list or something similar of what defines "unusual trends and variances" we think we would still run into issues and would still be subject to the preference of the reviewer.  Maryland theoretically agrees with the premise of this ballot, but we believe it needs to be more detailed as written in order to have a positive impact.

NEVADA		 Undecided What actually constitutes an "unusual" trend? Is this phrase "unusual trends and variances" referring to unusual trends only, or is it for both? Maybe should be worded "unusual trends and/or variances" or "unusual trends or unusual variances". These "unusual" items should be defined. What one juris finds unusual, another juris may not. When audited, the reviewers may also disagree on what is "unusual".   Need to define unusual trend and variances. 

NEW BRUNSWICK		 Support

NEWFOUNDLAND		 Support

NORTH CAROLINA		 Support North Carolina has no comments for this ballot and supports it as currently written.

OKLAHOMA		 Support Noting unusual trends, with sufficient detail to be articulated to other jurisdictions, if needed, could be very useful in identifying inter-jurisdictional compliance issues by motor carriers. This ballot ensures that auditors focus on trends that are relevant for audit purposes only, rather than all notable trends. 

ONTARIO		 Support

PENNSYLVANIA		 Undecided

QUEBEC		 Undecided Quebec supports the intend of the ballot while noticing the need for a definition of unusual trends and variances, as stated by Maryland.

SASKATCHEWAN		 Support

SOUTH DAKOTA		 Support
Support: 12
Oppose: 1
Undecided: 5

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