IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #5 - 2024

Jurisdiction Position Comments

Undecided Alberta supports the purpose of the ballot but recognizes that the changes to the Articles of Agreement, Procedures Manual & Audit Manual needed to accomodate fuel volumes that are not measured in gallons or liters are tricky. We agree with the comment made by Saskatchewan and the technical concerns raised by North Carolina.




Undecided Much like the comment by Saskatchewan,  we find language on Lines 37,43, 92, and 99 in the sections that give the authority to adjust the average fuel consumption factor confusing as written. Average Fuel Consumption Factor is calculated using Distance/Volume (i.e., Miles/gallon or Kilometers/liter).  Having “kWh” as a volume that stands alone on these lines does not appear to communicate the same intent. It would need a distance paired with it. Maybe miles per kilowatt hour (M/kWh) or kilometers per kilowatt hour (K/kWh)?



Undecided The definition of Volume as proposed is problematic – historically IFTA has been concerned with the gallons/liters place in the supply tank, this definition confuses this by adding “or used by a qualified motor vehicle”.  Suggest removing this section from the definition of volume.

We are not sure it is appropriate to remove the most common means of measurement throughout the manuals.  A measurement still used by the mass majority (98%) of carriers operating under IFTA.  We suggest that with a corrected definition of volume and the addition of volume to the various sections would make the documents easier to understand and clearer for industry.
As an example of what we are proposing – P710.200 “Total number of gallons/liters, or volume of motor fuel used by the licensee in operation of qualified motor vehicles;”





Undecided North Carolina supports the purpose of the ballot. Based on the use of electricity as a fuel source, volume more accurately captures the fuels subject to fuel use taxation.
However, North Carolina's technical concerns with the ballot is why it is currently undecided. The concerns are as follows:
  1. P550.300.015 should be added to the ballot and amended as follows: "the total volume of fuel purchased."
  2. P550.300.025 should be amended as follows: "the price of the fuel per unit of volume or the total price of fuel purchased."
  3. North Carolina is unclear why the definition of volume needs the following phrase: "and/or any unit of measurement used as an industry standard for a specific fuel type." There are gallons (or equivalent), liters (or equivalent), or kWh. North Carolina is unaware of a fourth method of measuring volume.
  4. The definition of kilowatt is problematic.
    1. It should not be defined. It is not helpful to understand kWh and is only used in the definition of kWh.
    2. Kilowatt is not a unit of energy: it is a unit of power. Kilowatt-hour is a unit of energy.
    3. If the ballot is defining kWh as the volume of electricity used in or disbursed into a qualified motor vehicle, why is it necessary to include a reference to an internal combustion "engine" in the definition?
  5. The use of the following phrase needs to be removed: "or any other factor used to compute motor fuels consumed [consumption]."
    1. It is inconsistent with P720.350, which uses the term "fuel consumption factor."
    2. It is unclear why the phrase is not consistently used. In one instance it uses the term "consumed." In others, it uses the term "consumption."
    3. Licensees will report MPG, KPL, or kWh (miles or kilometers per kWh?). North Carolina is unaware of a fourth method to determine motor fuel consumption. Therefore, even if was not inconsistent with P720.350, it is not clear why this is needed. If a fourth method emerges, the member jursiodcitiosn can amend the ballot when and if that occurs.




Support As the sponsor, PA obviously supports this ballot and we plan to speak to and clarify any concerns or comments at the ABM. We understand that the vast majority of activity is still centered around diesel fuel, but this ballot was created not only to create a catchall term that would still encompass units of measurement like "gallons and liters," but also include real/actual units of measurement like "kilowatt hours (kWh)" now being used that conflict with those terms.
Jurisdictions that currently tax per kWh are to simply put those units of measurement where the traditional gallon figures would go (Taxable Gallons/Volume, Tax Paid Gallons/Volume, and Net Taxable Gallons/Volume), but there is at least one jurisdiction that is taking the incorrect step of converting their kilowatt hours to gallons, because they think that is what the IFTA returns and schedules are asking them to do. We feel this ballot will also help clarify that unnecessary conversion issue.



Undecided IFTA requires a method of calculating tax payable on the volume of fuel consumed in each jurisdiction based on the distance travelled within a specified jurisdiction. This is accomplished by establishing an average consumption rate and applying it to the reported distance to calculate what volume of fuel would be required to travel that distance.

Where the fuel is electricity, kWh is the volume of fuel and not a consumption rate, unlike KPLs or MPGs which use volume and another measurement (distance) to calculate the required volume of consumption over a travelled distance. Using an allocation like km per kWh or miles per kWh would be similar to km per litre (KPL) or miles per gallon (MPG).  These terms are therefore not similar and would be an inaccurate reference in articles P570 and A350.
This method of determining a consumption rate for EV’s is further demonstrated in the EV Policy Memorandum issued by IFTA where a consumption rate is specified as dividing the total distance by the total fuel consumed and rounding to two decimal places with the example xx.yy per kWh where xx.yy represents a distance.


Undecided I don't completely understand this ballot.  Ideally I feel like IFTA should define the standard rate of measure for all of the fuel types.  ie:  CNG, hydrogen, electricity, etc.  The tax matrix should specify both the fuel type and the measurement.  ie:  Gas = gallon / liter, Diesel = gallon / liter, Electricity = kWh, CNG = whatever it is...    If this is what the ballot is trying to do, then I'm all for it.  
Support: 11
Oppose: 0
Undecided: 10