IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on BALLOT #2 - 2022

Jurisdiction Position Comments

ALABAMA		 Support

ALBERTA		 Support Alberta is supportive of the intent of this ballot. The suggested wording however makes it somewhat unclear. Alberta recommends using phrasing that is more consistent with P540.100 such as:

Distance records produced by a vehicle tracking system utilizing latitudes and longitudes which creates and maintains, at a minimum of every 15 minutes when the vehicle’s engine is on, a record that contains the following elements shall be accepted by the base jurisdiction as adequate under this article:

.005  the date and time of each system reading,
.010  the latitude and longitude calculated to four decimal places of each system reading,
.015  the engine control module (ECM) reading of each system reading or, if an vehicle is not equipped with an ECM, the beginning and ending dashboard odometer or hubodometer readings, and
.020  the vehicle identification number or vehicle unit number.

ARKANSAS		 Support

BRITISH COLUMBIA		 Support

IDAHO		 Support

ILLINOIS		 Oppose While the Intent of the Ballot Proposal includes the statement, “The intent is not to exclude future or current technologies that would sufficiently capture distance accrued and allow for the verification of distance,”  the actual crossed out wording in the Procedures appears to be narrowing the scope of electronic systems which are acceptable. 
 
The ballot shows the removal of “other location data” (.005), “other system reading”(.010), and “the location of each GPS or other system reading” (.015)  from the Procedures manual.  Eliminating the possibility of using other system readings from vehicle tracking devices such as city, state, and zip code to only using longitude/latitude readings unfairly assumes that all the  jurisdictions’ audit systems are capable of reading longitude and latitude readings. Jurisdictions that accept and use data such as city, state, and zip code readings would be non-compliant.
 
Also, the ballot appears to be eliminating other forms of data captures like “the route of the vehicle’s travel” (.030), “the total distance traveled by the vehicle” (.035),and such. Removing data that can be used to verify raw data seems counterproductive.
 
Furthermore, eliminating “other location data” or “other system reading” creates a burden on taxpayers whose GPS providers do not provide longitude/latitude data to their customers without additional fees. 
 
 

INDIANA		 Support IN supports the ballot, and the changes to the language. Ballot provides uniformity to carriers and for all jurisdictions.

KANSAS		 Support

KENTUCKY		 Support

MAINE		 Undecided Maine has concerns with the 15-minute interval and how this would be interpreted by system providers and suggest the following:
 
.200 Distance records produced by a vehicle tracking system that utilizes latitudes and longitudes, a record must be created and maintained at a minimum every 10 minutes when the vehicle’s engine is on, including when the engine is started and turned off, and contain the following data elements:
 
.005 the date and time of each system reading,
.010 the latitude and longitude to include a minimum of 4 decimal places (0.0001) of each system reading
.015 the odometer reading from the engine control module (ECM) of each system reading. If no ECM odometer is available a beginning and ending dashboard odometer or hubodometer for the trip will be acceptable.  
.020 the vehicle identification number or vehicle unit number
 
This data must be accessible in an electronic spreadsheet format such as XLS, XLSX, CSV or delimited text file. Formats from a vehicle tracking system that provides a static image such as PDF, JPEG, PNG, or Word are not accessible.
 
One of our other concerns is there appears to be a gap in record keeping requirements.  P540.100 provides record keeping requirements for “other than vehicle-tracking systems” and the proposed change to P540.200 provides record keeping requirements for “vehicle tracking systems that utilizes latitudes and longitudes”.  What about vehicle tracking systems that do not use latitudes and longitudes?  Should we have a section that is a catch-all?  Or should it refer back to P540.100?  Or should P540.100 be restated such as “For all records produced by a system that does not utilizes latitudes and longitudes”?

MANITOBA		 Undecided Manitoba does not want to force carriers to have specific systems due to the potential cost if the system they are currently using is compliant with what is currently required.

MICHIGAN		 Support

MINNESOTA		 Support Minnesota is favorable to this ballot proposal. We would like to consider lowering the record to every ten minutes for alignment with IRP. We would like to understand the prohibition against static images as the proposal is not clear as to the reasoning for their removal

NEW BRUNSWICK		 Support

NEW HAMPSHIRE		 Undecided New Hampshire aggrees with Maine we would like to see 10 minutes instead of 15 minutes.

NORTH CAROLINA		 Undecided First, the ballot states that as it applies to "[d]istance records produced by a vehicle tracking system that utilizes latitudes and longitudes."  In reference to Maine’s comment and Illinois’ comment, where P540 provides what records must be maintained, North Carolina reads the language to exclude vehicle-tracking systems not using latitudes and longitudes. There does not appear to be a clear ‘third option’ based on how this is written.
 
If this is the intent, it may be more clear to state that the "Distance records produced by a vehicle tracking system must use latitudes and longitudes . . ."
 
However, this is contrary to the intent of the ballot as noted by Illinois. Because the stated intent of the ballot is inconsistent with the language as drafted, North Carolina is undecided. North Carolina is open to working with the sponsor to ensure the intent of the ballot matches the language of the ballot.
 
Second, the requirements that data be in an accessible format is 'hanging' on its own. It would be better to incorporate it into the leading paragraph. Incorporating a few other tweaks and the fix above, it may be better for it to read as follows:
 
"Distance records produced by a vehicle tracking system must use latitudes and longitudes coordiantes. This data must be accessible in an electronic spreadsheet format such as XLS, XLSX, CSV, or delimited text file. Formats from a vehicle tracking system that provides a static image such as PDF, JPEG, PNG, or Word are not accessible formats. A record must be created and maintained at a minimum every 15 minutes when the vehicle’s engine is on and contain all of the following data elements: . . . . "
 
Third, GPS coordinates can be noted by either by DD (decimal degrees) or DMS (degrees, minutes, seconds). It appears the ballot is referring to DD. Therefore, the following changes may make it more clear:
 
".010     the latitude and longitude in decimal degrees with a minimum of 4 decimal places (e.g., 0.0001) of for each system reading"
 
Finally, it appears that requirements for total distance traveled and distance traveled by jurisdiction were removed. It may be helpful in reviewing a motor carrier's records to quickly see the summary data. Therefore, the sponsor should consider re-including those requirements, specifically .035 and .040. 

NORTH DAKOTA		 Support

ONTARIO		 Oppose We support the data format requirements and where the latitude and longitude are provided the requirements listed are sufficient but we feel the requirements are too restrictive. Listing the data elements that must be created takes away a jurisdiction’s discretion to accept alternate data elements that it considers adequate. 

OREGON		 Support

PENNSYLVANIA		 Undecided

PRINCE EDWARD ISLAND		 Support

QUEBEC		 Support

SASKATCHEWAN		 Undecided Agree with the importance of removing the ability to provide static images versus formats that are compatible with Excel.
Concerns with removing the requirement to include route of travel, total distance traveled by vehicle, and distance traveled in each jurisdiction since this information is important to allow jurisdictions to validate the raw data.
A daily summary that reflects the distance per jurisdiction for each vehicle is now missing from the proposal which would be an important piece for audit purposes.
The proposed amendment states that if no ECM odometer is available, a beginning and ending dashboard odometer or hubodometer for the trip will be acceptable. This would not be sufficient for IFTA audit purposes since the trip could cross multiple jurisdictions and would hinder the auditor’s ability to verify jurisdictional distance.
Lastly, if the carrier has the ability to provide electronic records, they should be required to provide records electronically for audit purposes.

SOUTH CAROLINA		 Support

SOUTH DAKOTA		 Support South Dakota supports this ballot. I applaud the work of both audit committees in IFTA and IRP and the time and effort they took to look at this subject. This ballot will give industry and jurisdictions a source to be able to audit effectively for all jurisdictions. 

TENNESSEE		 Support

VIRGINIA		 Undecided Agree with Manitoba. Also question if there is really a problem here that needs to be fixed.

WASHINGTON		 Undecided Reviewing to determine if restricting data formats to an electronic spreadsheet format, therefore excluding data that may be available by other means, would be problematic.  

WEST VIRGINIA		 Support

WYOMING		 Support
Support: 20
Oppose: 2
Undecided: 8

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