IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #9 - 2026

Jurisdiction Position Comments
Support: 9
Oppose: 4
Undecided: 5

CALIFORNIA		 Undecided The Jurisdiction of California is Undecided with this ballot as it is written for the submission of the proposal. California supports the intent of the ballot and supports the PCRC travel expenses to be funded by IFTA, Inc. as well as the ballot intent to streamline the review process. However, we agree with the other jurisdictions who voiced that the language in the ballot should be revised for additional clarity. California is concerned with the time commitment for these reviews.  In addition, this ballot conflicts with the Program Compliance Review Guide, does not address international travel concerns, and does not address training concerns.

ILLINOIS		 Oppose Illinois supports the intent of the ballot but opposes the ballot as drafted. The Program Compliance Review Guide has not been amended to show the proposed changes as a result of the Board Charge Proposal dated August 2025.  Currently, they are separately standing documents.  Consequently, Board Charge Proposal dated August 2025 is not incorporated in either the Program Compliance Review Guide, IFTA Articles of Agreement, Audit Manual, or the Procedures Manual.  It is impossible to know what the extent of this new review program truly is unless Program Compliance Review Guide is properly redlined to show the proposed changes.  If the current Program Compliance Review Guide is becoming obsolete then repeal the current guide in its entirety.  Otherwise, one cohesive Program Compliance Review Guide with proposed revisions should be presented to the membership for consideration. 

Remote participation in the scheduled review week should be allowed for due cause. 

Also, the following questions must be addressed in the body of P1230:
“Assistance in the program compliance review process” is too ambiguous and should be replaced with more specific language.
What are the parameters for establishing a schedule by IFTA, Inc./Review Facilitator?
How frequently will a reviewer have to serve the “two-year term”?

And, it should be noted that, although a reviewer “may be asked” to participate in entrance meetings or discussion, this ballot does not actually require a reviewer to participate.

Our proposed changes:
P1200 PROGRAM COMPLIANCE REVIEWS
*P1210 REVIEW REQUIREMENT and funding.
Member jurisdictions shall permit program compliance reviews required under Section R1510.200 of the Articles of Agreement to determine their compliance with the Agreement. IFTA, Inc., shall provide funding for travel expenses for the program compliance reviewers. 
*P1220 PROGRAM COMPLIANCE REVIEW GUIDE
Program compliance reviews shall be conducted in accordance with the procedures and specifications outlined in the IFTA Program Compliance Review Guide, which is published under separate cover.
*P1230 REQUIRED PARTICIPATION
.
.050   Beginning January 1, 1997, the program compliance reviews will be conducted according to a schedule developed by IFTA, Inc. The Program Compliance Review Facilitator shall provide reviewer assignments to member jurisdictions based on the developed schedule.
.100   Each member jurisdiction must designate program compliance reviewers, both audit and administrative, pursuant to the IFTA, Inc.’s schedule.  Reviewers will serve two-year terms.  Subsequently, a reviewer will serve another two-year term after all other reviewers have served their terms. 
.150   Program compliance reviews shall take place during one business week (5 days) within regular business hours 9am -5pm, at a location designated by IFTA, Inc.  Reviewers shall attend in person. Remote participation in the scheduled review week is allowed for due cause with prior approval from IFTA, Inc. 
.200    Prior to the scheduled review week, reviewers shall participate virtually in scheduled opening review conferences and training.  During the scheduled review week reviewers will be responsible for reviewing jurisdictional records pursuant to the IFTA Program Compliance Review Guide.  After the review week closes, reviewers shall complete any pending review work and participate in follow-up discussion as needed.

Please note that suggested language is bold because the underline feature doesn't work in the comment box.

*P1210 REVIEW REQUIREMENT
Member jurisdictions shall permit periodic program compliance reviews to be performed to assure they are in compliance with the provisions of the Agreement. Beginning January 1, 1997, the program compliance reviews will be conducted 8 according to a schedule developed by IFTA, Inc.
IFTA Inc is responsible for funding the designated travel week expenses for reviewers to attend and conduct team-based Program Compliance reviews.

*P1230 REQUIRED PARTICIPATION

Jurisdictions will be required to participate in their appropriate share of program compliance reviews each year through assignment of jurisdictional reviewers to assist  in the program compliance review process. Reviewer assignments are distributed equally among member jurisdictions based on the schedule maintained by the Program Compliance Review Facilitator.

Member jurisdiction reviewers serve a two-year term during which they participate in the team-based review process. The majority of reviewer responsibilities are  concentrated during one designated travel week per year, when administrative and  audit reviews are conducted collaboratively, per the program compliance review guide. Reviewers may be asked to participate in opening review conferences, virtual training, completion of reviews started during the travel week, and limited follow-up discussions, but no additional extensive review obligations should be required.
 

INDIANA		 Undecided Indiana is undecided. It is not mentioned whether jurisdictional reviewers will undergo any sort of training before being involved in a PCR.

Industry Advisory Committee		 No Comment.

KENTUCKY		 Support

MANITOBA		 Undecided Manitoba fully supports modifying the language to remove the limit of two reviews per jurisdiction per year to support the new peer review process.
 
This ballot is not only about the one-week travel requirement.  However, while the ballot clarifies the expense of travel is the responsibility of IFTA Inc., it does not clarify what shall occur if a member jurisdiction cannot travel.  It has been brought forward multiple times that international travel between Canada and the US is not always guaranteed in a jurisdiction and there is no consideration in the ballot for the challenges of travel.  Additionally, concerns have been raised due to situations occurring in the US which may be a safety concern when sending staff to IFTA Inc. events.  It has been noted, but not confirmed, a jurisdiction may be found in non-compliance in these situations and thus subject to the DRC process. 
 
Again, we support the ballot presented by the PCRC.  However, we would like the ballot to include what alternate possibilities may exist to ensure the obligations are met (i.e. virtual participation) and possible consequences if a jurisdiction is unable to meet its obligations.

MARYLAND		 Oppose The proposed ballot does not address the training that jurisdictions should be required to complete prior to participating in Program Compliance Reviews. Observations from previous Peer Reviews indicated clear inconsistencies in reviewer interpretation and judgment. To ensure fair and consistent Peer Reviews, jurisdictions should receive appropriate and standardized training before conducting these reviews.

MICHIGAN		 Undecided Michigan supports the intent of the ballot but cannot support it as written. The Program Compliance Review Guide has not been updated, making it difficult to assess the full impact. Michigan also shares concerns about vague terminology, unclear reviewer expectations, and the removal of the limit on the number of reviews per year. Clarification is needed on time commitments and maximum review workload. Michigan also supports allowing remote participation.

NEBRASKA		 Support We have a reviewer apart of the review team and this years process was significantly less time consuming that prior years.  We support IFTA's efforts in the streamline process.

NEVADA		 Support NV supports the intent of this ballot, we also agree with the comments made by North Carolina, regarding the vague or undefined phrases/terms, and the removal of no more than two per year. Clarification on maximum number of reviews during term, is needed for jurisdictions to plan and accommodate the absence of the staff.

NEW BRUNSWICK		 Support

NORTH CAROLINA		 Undecided North Carolina supports the intent of this ballot and encourages the sponsor to review the comments from North Carolina, Quebec, Virginia, and Illinois from last year. North Carolina appreciates the changes that were made in response to some of the concerns highlighted by these member jurisdictions, but North Carolina seeks additional changes.

As noted in both comment periods, North Carolina is concerned about the time commitment asked of jurisdictions and its jurisdictional reviewers. The current language is grounded by limiting program compliance reviews to no more than two per year. This restraint is removed by the ballot and replaced with unclear or ambiguous language. Specifically, the following phrases and terms are undefined or vague:
  • “appropriate share”
  • "Program Compliance Review Facilitator”
  • "majority of review responsibilities will be concentrated"
  • "limited follow-up discussions"
  • "no additional extensive review obligations"
These phrases need to be further developed or removed to provide certainty for the future of these reviews. A fix for all these phrases and terms was provided by North Carolina in its comments to this ballot last year. North Carolina understands that placing a time limitation on reviewers may be difficult to achieve, but guardrails and clarity placed on time commitments may go a long way in achieving wider support for this ballot.

Finally, North Carolina raises one final concern, which it omitted in its previous comments: R1510 conflicts with the Program Compliance Review Guide. R1510 provides that a compliance review "shall be performed after one year of implementation and once every five years thereafter unless a review is ordered as prescribed by [t]his Agreement . . . ." Because P1210 is silent on the annual review, additional changes to P1210 are required.

North Carolina emphasizes that it understands that this ballot needs to pass to effectively codify what the member jurisdictions seek in a program compliance review. However, the Program Compliance Review Guide can be changed quickly and easily; the Procedures Manual cannot. This is why North Carolina remains undecided and seeks the best possible version of this ballot.

North Carolina remains open to working directly with the sponsor to address the above concerns.

ONTARIO		 Support

PENNSYLVANIA		 Support

QUEBEC		 Oppose The juridiction of Quebec acknowledge the intend of the ballot to speed up both the administrative and audit peer reviews. We also acknowledge changes made to the 2025 ballot related to the bearing of the costs by IFTA inc.

However, our stance remain unchanged on the following matter: it would be desirable to allow this requirement to be fulfilled through the peer review program using a hybrid approach if (and only if) exceptional circumstances warrant it, including:
  • An airline strike or any other major transportation disruption;
  • Overtime restrictions resulting from a strike or other job action within the verification body;
  • The inability of the designated verifier to travel due to administrative, personal, or family-related reasons (e.g., customs restrictions, exceptional family obligations, or other circumstances beyond the reviewer’s control).

RHODE ISLAND		 Oppose

SASKATCHEWAN		 Support The changes remove outdated funding language and outdated participation limits, ensuring that travel costs are centrally funded by IFTA, Inc. and that reviewer assignments can be flexibly managed to support both Administrative and Audit Reviews. Together, these updates are necessary to align with the updated procedures. 

WASHINGTON		 Support

WYOMING		 Support Wyoming supports this ballot. Having served as a member of the PCRC before the process was updated, I believe it is highly beneficial to have all participants in the same room. This ensures alignment and consistency when evaluating errors identified during the peer review process.

A supervisor from Wyoming currently serving on the PCRC attended the meeting in Phoenix and found the training very valuable. She noted that discussing errors in real time allowed for consistent decision-making across all jurisdictions. I believe that a week of training and auditing with all volunteer PCRC team members and required jurisdictional reviewers will lead to more consistent decisions regarding jurisdictional compliance with the IFTA plan.

In addition to improving consistency, the required jurisdictional reviewers will spend less time on reviews than they did under the previous process, as most of the work will be completed during the week of training and auditing.
Support: 9
Oppose: 4
Undecided: 5

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