IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #2 - 2026

Jurisdiction Position Comments
Support: 14
Oppose: 1
Undecided: 3

BRITISH COLUMBIA		 Support

CALIFORNIA		 Support The Jurisdiction of California supports this ballot. California agrees that there should be consistency with the requirements for the effective dates for implementing amendments.

CONNECTICUT		 Support

FLORIDA		 Undecided Florida is concerned if the effective date is advanced and programming is required, we may not have the changes implemented prior to the effective date.

ILLINOIS		 Support

INDIANA		 Support

Industry Advisory Committee		 No comment.

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Support Approval of this ballot would establish a uniform and consistent process for implementing amendments to the Audit Manual as well as all other IFTA manuals.

MICHIGAN		 Undecided Michigan supports the goal of aligning the language to allow effective dates to be advanced with a three‑quarters vote, ensuring consistency with the rest of the Agreement.

However, the proposal does not specify any minimum lead time before a change is effective.  This could create challenges, particularly if the changes are significant. 

NEBRASKA		 Support

NEVADA		 Support

NORTH CAROLINA		 Undecided North Carolina is undecided about this ballot.

Original Intent and Framing the Change

The sponsors posit that the original drafters of this section "did not intend for different requirements to exist for effective dates" and that the "original intent was not to limit flexibility in setting effective dates for amendments." The "inconsistency" was thus the primary impetus for the change.

North Carolina respectfully disagrees with the sponsors regarding its analysis and views this change under a different lens, which it invites other jurisdictions to do as well. Specifically, North Carolina does not agree that sections R1340.200 and R1340.300 are "redundant" or "inconsistent." Both provisions serve in conjunction showing the drafters knew the mechanics of how to change the governing documents (R1340.200) and showed an intentional deviation from those mechanics (R1340.300).

As with any document establishing rights and duties, reasons may exist to deviate from general requirements. Therefore, the question is not how to correct an inconsistency, but to evaluate whether there are reasons to justify removing the 'higher bar' (unanimous approval as opposed to three-fourths approval) placed on when changes to audit requirements may be effective.

To this point, North Carolina is undecided and welcomes discussing further whether to remove the higher bar.

Other Notes and Concerns

North Carolina notes two additional issues with the ballot.

First, the amended language is more restrictive than the existing language. R1340.100 provides that the Audit Committee reviews "audit requirements" as part of its duties. The revised language limits the review to the "IFTA Audit Manual." North Carolina notes this discrepancy may be significant and thus should be re-reviewed by the sponsors to ensure that was the sponsors' intent.

Second, the language provides that the Audit Committee "may propose any amendments considered necessary in accordance with Article XVI." This is unnecessarily ambiguous. Is it the Audit Committee that determines whether a proposal is necessary or is it the language in Article XVI that determines whether language is necessary? It is much clearer to simply state that the committee "may propose any amendments in accordance with Article XVI."

ONTARIO		 Support

PENNSYLVANIA		 Support

QUEBEC		 Oppose The jurisdiction of Quebec agrees with the intent to harmonize the language that allows for the advancement of an effective date by means of a three-quarters vote, which is consistent with the rest of the agreement.

However, the current proposal doesn't include a minimum delay related to the effective date. Thefore, we raise the possible operational issues, especially if the changes are substantial:

- Not having enough time to implement changes and provide training to the audit team;

- From a PCRC standpoint, an potential implementation of a new practice in the middle of the year;

- The possibily to propose retroactive changes, which isn't consistent with audit procedures.


Our suggestion would be to propose a language which includes a minimal effective date at the start of the following calendar year. For example, a change proposed in 2026 could have been proposed with a minimal effective date of January 1st, 2027.

SASKATCHEWAN		 Support Saskatchewan supports this ballot as it allows section R1635 of the Articles of Agreement to dictate the effective date of proposed changes, in alignment with changes to other IFTA manuals.

WASHINGTON		 Support
Support: 14
Oppose: 1
Undecided: 3

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