IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #4 - 2021

Jurisdiction Position Comments



Oppose We understand amendments are needed to vehicle tracking systems record keeping requirements and applaud the working group’s efforts. 
A reference to proposed section P540.200 covering the format of the data should be made in section P530 third paragraph.
The current language provides guidance for multiple types of vehicle tracking systems and the proposed language only provides guidance for vehicle tracking systems using latitudes and longitudes that interface with a distance program.  Perhaps a section should be used for the proposed language P540.300 and the current language amended to cover other vehicle tracking systems P540.200.
We have concerns that a 15-minute interval in created records is not sufficient for the northeast.  Suggest adding the requirement of a jurisdictional distance between readings to the four required data elements.  We believe that with this added as a data set the requirement of daily summaries would not be needed as the auditing jurisdiction could create any time frame summary to test towards.  In general, we would create a pivot table for the month and check that to the current requirement of a monthly summary by vehicle.  Summaries under sections P560 should be a requirement.  Current wording makes it a requirement that an auditing jurisdiction give “due notice” to receive summaries.
Should there be a preamble as to the reason the information is required.  “The information required for vehicle tracking systems is to be both sufficient and appropriate to allow an auditing jurisdiction to determine the completeness and accuracy of distance calculated per jurisdiction as reported by the licensee.”
As a side note, most carriers using a vehicle tracking system have no idea how they work and would not know what information is required.
Support: 1
Oppose: 1
Undecided: 1