IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on BALLOT #6 - 2022

Jurisdiction Position Comments

ALABAMA		 Undecided

ALBERTA		 Support

BRITISH COLUMBIA		 Support

IDAHO		 Undecided

INDIANA		 Undecided More discussion required.

KANSAS		 Support

KENTUCKY		 Support

MAINE		 Undecided Maine is not sure if it is a good idea to codify the clearinghouse data quality plan as any changes in data parameters would need to go through the ballot process before changes to the plan could be made.

MANITOBA		 Support

MICHIGAN		 Support

MINNESOTA		 Support

NEBRASKA		 Undecided Nebraska welcomes discussion of this ballot in conjuction with the Data Quality Plan discussion both scheduled at the ABM. 

NEW BRUNSWICK		 Support

NORTH CAROLINA		 Support North Carolina recommends that references to "penalties" be removed. North Carolina, and many other States, make a distinction between penalties and interest.  Further, the Agreement also makes this distinction. See for example R1210.300 separating the categories between penalties and interest.
 
Further, it is not required (or best drafting practices) to place the identical proposed language in three places. Once in the Agreement or other document will suffice.
 
Finally, and structurally, it does not belong within R2120. Although it is related to timely upload transmittal data, the assessment of interest is a distinct concept. Therefore, it merits its own section.
 
As amended (with a few tweaks):
 
"R2130 INTEREST ASSESSED FOR UNTIMELY SUBMITTED TRANSMITTAL DATA
 
Participating Members failing to timely upload any Transmittal Data per the Funds Netting Calendar will be assessed interest at the prevailing IFTA, Inc. interest rate in accordance with Articles of Agreement Agreement Section R1230.
 
The participating members shall be required to pay interest to each jurisdiction . . . ."

ONTARIO		 Undecided Ontario understands and supports the concept of quality data and the necessity for consistency across all IFTA jurisdictions. However, as written the intent and workings are unclear in some instances. We recommend editing the ballot for clarity and consistency. Some suggested edits are as follows:
  • Ensure all groups mentioned are named correctly, e.g., committee names and IFTA Team – does this refer to IFTA, Inc.?
  • Clarify what is meant by “advisories”.
  • Modify language in the addition to R2120.200 for clarity:
    • .100 – how will the data quality/validation checks be demonstrated to IFTA, Inc.?
    • .200 – the IFTA Clearinghouse “can” reject the file or “must” reject the file. If a decision is being made, how will it be made?
    • .300 – how/when will these corrections occur?
  • Ensure all related provision in the Agreement & Procedures Manual are aligned.

OREGON		 Support

PENNSYLVANIA		 Support

PRINCE EDWARD ISLAND		 Undecided

QUEBEC		 Support

SASKATCHEWAN		 Support

SOUTH CAROLINA		 Support

SOUTH DAKOTA		 Support

TENNESSEE		 Support

VIRGINIA		 Support

WASHINGTON		 Undecided Warrants further discussion with member jurisdictions.

WEST VIRGINIA		 Oppose If this could happen automatically for us within our systems we would possibly consider it. It would be a task to get it set up for automation if it was required.   There is no way that we could manually test the data.  We do not have enough staff in IT take on this task.  Additionally, it would be a large undertaking for our IT to get an automatic testing program or connect created given the reduced work force. 

WYOMING		 Undecided We would like to hear discussion on this ballot before making a decision.  
Support: 17
Oppose: 1
Undecided: 9

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