IFTA Ballot Proposals Comments

IFTA Ballot Comments

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Support: 3
Oppose: 2
Undecided: 2

2nd Period Comments on BALLOT #2 - 2022

Jurisdiction Position Comments

KENTUCKY
Support

NEW JERSEY
Support New Jersey is supportive of Ballot 2-2022 based on the accuracy of longitude/latitude as being a superior form of assessing exact location for measuring distance.  This form of measurement narrows the often-gray area of location versus zip codes or cities.  The United State Census Bureau abandoned the use of zip codes in the year 2000 and reverted to the use of longitude/latitude to have a more reliable source of identifying location.

We would like to lower the ping time to every ten minutes for alignment with IRP. 

PENNSYLVANIA
Undecided Pensylvania is undecided, as we are confused as to why static formats, such as PDF, are completely excluded. This is the PA IFTA Commissioner writing this and I am not an auditor, but I was an enforcement agent and records compliance inspector, and I can think of instances where PDF records should be acceptable, if not preferable (in specific instances). Our Bureau of Audits is also unsure as to why these formats are not acceptable either. Any further discussion is welcome.
Thank you.

RHODE ISLAND
Oppose I still have issues with this ballot for the following reasons, and I think some of these rewrites may actually hurt the small companies because of the expense involved:
  1. The time frame should be every 3-5 minutes.  For the smaller jurisdictions, this can make a difference.
  2. Although ECMs have been used for audits in some jurisdictions for a long time, there is an expense to getting them.  It used to be a jurisdiction requiring the carrier to go to a mechanic to have it read and was really only used if necessary.  I don’t know if jurisdictions have the capability to do this themselves, but for a small trucking company, this can be expensive.  I don’t know how often the odometer readings are saved by the ECM and if it connects to all electronic tracking systems.  However, the section does give the opportunity to continue to use manual recordings, which I think will usually be the case.  I don’t understand why ECMs are taking precedence.
  3. Having the electronic tracking systems accessible in the formats listed is fine if the carrier and the jurisdiction has the ability to do this.  If a carrier does not, then the “static” images should still be able to be utilized as “best information available”.  This information can and must still be tested for reliability. 
  4. Is IFTA, Inc. close to “certifying” some electronic tracking systems?  It seems like this is trying to get all size carriers over to electronic (which I know is the ultimate aim but still years away).  If so, then they need to have companies/systems that are good for all budgets.

SASKATCHEWAN
Oppose

TENNESSEE
Support

WASHINGTON
Undecided Washington is generally supportive of this ballot that, when able, a carrier should be required to produce records containing certain elements and in certain formats.  However, unlike the similar IRP ballot, this one does not appear to allow for jurisdictional discretion in accepting records that are otherwise sufficient to support an audit and tax returns.  Allowing jurisdictional discretion in acceptance of non-standard records, and providing a reasonable opportunity by the carrier to demonstrate their travel and fuel consumption (as opposed to a blanket determination that records must be not acceptable) would resolve most of our concerns with this ballot as written.  Additional comments provided directly to the ballot sponsors.