IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #8 - 2025

Jurisdiction Position Comments

Attorney Advisory Committee
  • The ballot proposes to update certain section references in R2120 of the Agreement for consistency with past changes to the Procedures Manual.


  • The reference in R2120.200.200 to “P1040.800.001 through .005” also needs to be revised to state, “P1045.100 through .500”. These are the new section references in respect of errors for which the entire transmittal can be rejected until they are corrected.


  • The proposed amendment to R2120.200.400, to replace “P1040.800.006 through .008” with “P1045” is not specific enough. That is, only sections P1045.600 and .700 are in respect of data validation warnings that will be accepted by the clearinghouse with the possibility of further steps (P1045.100 through .500 are in respect of errors that can be rejected until corrected). Accordingly, the proposed amendment to R2120.200.400 should be revised to strike out “P1040.800.006 through .008” and substitute “P1045.600 and .700”.


  • It is noted that references to the clearinghouse are inconsistent throughout R2120. For example, R2120.100 refers to “clearinghouse”; R2120.200.100 through R2120.200.400 all refer to “IFTA Clearinghouse”; and R2120.200.500 refers to “Clearinghouse” in one sentence and “IFTA Clearinghouse” in the next. However, the term is defined in R2110 and “hereafter” as “clearinghouse” (with a lower case “c”). It is suggested that, for consistency, all references within R2120 be updated to “clearinghouse”.

  • It is also noted that there are various inconsistencies between the wording of R2120 of the Agreement and P1045 of the Procedures Manual. It is understood that the Agreement Procedures Committee has agreed to form a subcommittee to review the inconsistencies and may propose a future ballot in respect of P1045, if considered appropriate. For example (assuming that the wording of the Agreement generally takes precedence):

    • R2120.200 states, “Where the monthly transmittal data from a jurisdiction contains data that produces data validation errors under [P1045.100 through .500], the clearinghouse ‘can reject’ the entire transmittal file” until the validation errors are corrected. However, P1045.100 through .500 each set out a requirement and states that the entire transmittal file “will be rejected” by the clearinghouse if the requirement is not met. Accordingly, the authority to reject a transmittal is discretionary in the Agreement, but mandatory in the Procedures Manual.
    • R2120.200.500 permits a jurisdiction to request that the clearinghouse accept a transmittal file notwithstanding a data validation error. Therefore, the authority of the clearinghouse to reject a transmittal must necessarily be discretionary. The mandatory rejection set out in P1045.100 through .500 is inconsistent with the process anticipated by the Agreement.
    • R2120.400 refers to “data validation warnings” under [P1045.600 and .700]. However, those sections of the Procedures Manual state that “…the jurisdiction will receive an advisory email from the IFTA Clearinghouse alerting the jurisdiction” to the particular data error, and do not refer to any particular “warning”.

BRITISH COLUMBIA		 Support

IOWA		 Support

KANSAS		 Support

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Support

MICHIGAN		 Support

NEVADA		 Support Changes references from P1040 to P1045

NEW BRUNSWICK		 Support

NEWFOUNDLAND		 Support

NORTH CAROLINA		 Support North Carolina generally supports the ballot.
 
North Carlina notes the following: 
  1. R2120.200.200 needs updated references.
  2. The third level numbering schema with .005 (not .100). Therefore, everything under .200 should be updated with that numbering structure.

OKLAHOMA		 Support

ONTARIO		 Support

PENNSYLVANIA		 Support

QUEBEC		 Support Quebec supports the ballot while noting that the cross references to other sections such as R2120.200.200 needs a review (refers to P1040.800). Numbering in the section should also follow the sequence as .005, .010, .015 etc.

SASKATCHEWAN		 Support

SOUTH DAKOTA		 Support
Support: 18
Oppose: 0
Undecided: 0

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