IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #4 - 2021

Jurisdiction Position Comments



Undecided CA is undecided at this time; we generally support the idea/concept and efforts behind the ballot.  Strongly support any language that will clarify the reporting requirement to have the data logs in an CVS (XLS), or Delimited text file format.   We find having to work with static images like a PDF data file to be very time consuming for audit staff. 


Undecided Indiana is undecided on ballot 4-2021.  While we agree with the premise of the ballot, some items need revision.
For example, we find the sentence on lines 37-38  to be an overreach. Requiring the licensee’s system be capable of generating daily summaries for each truck in the fleet is an unnecessary burden to place on the licensee. We realize the language does not require that the licensee generate the daily summaries, but must have the capability to. This is essentially a requirement that they  generate them at the time of reporting, in the event the licensee happens to change GPS providers in the future. Should the licensee discontinue its relationship with the provider, they lose the capability of generating the daily summaries in the event of an audit at a later date.

Industry Advisory Committee
Oppose The IFTA IAC cannot support the ballot as written. The purpose of the working was to define what is needed to be in compliance with all electronic reporting and to make the process more clear. The current language does not make it clearer and adds additional burden to the carrier: 1. Daily odometers- if odometers are not pulled from ECM; monthly odometers, or any time frame, would work equally as well. 2. Nowhere in the Article of Agreement does it call for daily summaries, so why would they be needed for GPS reporting The current ballot language only covers vehicles that utilize latitudes and longitudes that interface with a distance program. There are other types of systems that utilizes GPS Data that does not interface with a distance program and equally effective, i.e. GEO FENCING. This ballot greatly narrows the use of GPS systems that work differently.



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.

Oppose Manitoba agrees with Missouri's comments.


Support Michigan supports this ballot with one change to the current ballot purposed language - on page 3, line 37, it currently states -  The system should be capable of generating a daily summary that reflects the distance per 38 jurisdiction, for each vehicle, when requested for audit purposes. 

Michigan would like the change to the following statment -  The system must be capable of generating a daily summary that reflects the distance per 38 jurisdiction, for each vehicle, when requested for audit purposes

Oppose Minnesota has concerns with this ballot pertaining to the information that has been removed in P540 .200. Instead of removing the items in this section Minnesota would like the authors to consider Section .200 be left as currently written.

Minnesota proposes that everything written in red in .200 be moved to its own sub-section. In addition, Minnesota suggests that .035 and .040 be included in the new sub-section under “GPS” so it can be located in both sections.

Line 37- Daily Summary. Minnesota would like the authors to consider it to read as follows: “The system must be capable of generating a summary per trip or day, whichever is greater. That reflects the distance per jurisdiction, for each vehicle, when requested for audit purposes.”

Oppose With the advancements in technology coming so rapidly, to “tightly define” what is acceptable seems to be a burden to the carriers.   We get PDF documents, which would not be acceptable, from carriers and can convert them to Excel.  So to exclude PDF documents from being acceptable doesn’t seem right to us.  A new and better format may come along that wouldn’t be considered acceptable because of the tightly defined parameters. 

Support The research and work the Working Group did supports the changes.  Nebraska would support the change of Monthly manual odometer readings instead of daily odometer readings when the ECM odometer readings are not captured in the pings. 

Undecided Two areas of concern. 
First, will the 15 minutes per lat/long provide enough information for an accurate route?  Were there any studies comparing various timing of the pings?  Should we have more information on Route of Travel?

Second, don't have a warm fuzzy feeling on "the system should be capable of generating a daily summary...".  This is very gray and could lead to a higher rate of non-compliance audits being issued.  I'm also concerned about summaries being daily which then might not allow an auditor to match up to trips when a trip is in progress at the end of the day, especially when that day is the last day of a tax return period. 

We need to have records that will mirror that period that was reported on the return.  At this point I am not sure if this will happen.  Might need to add additional language that if running on these electronic records, there shall not be any deviation from calendar date and time of a tax return reporting period.



Support (1) Line 37 -- The language currently uses "should." If it is a requirement, use mandatory language such as shall or must. If it is not a requirement, it should be removed.

(2) Lines 37-43 -- These need to be denoted within a subsection or subsections.

(3) The commentary should not be placed as commentary inside the ballot. This content needs to move into the ballot language itself.

(4) Word is neither a static image nor a format. Consider revising to be consistent with the other items listed (e.g. PDF and JPEG).



Undecided Unsure about all carriers system capabilities and if/how to transition industry and the burden/education for the client for requiring a system that will produce electronic documentation.  We agree that electronic records should be required upon a carrier having the capability to do so. 

ATA opposes this proposed ballot in its current form. While ATA believes this ballot is well-intended, there are potential unintended and unforeseen consequences that necessitate a deeper review. The proposed language overly narrows the scope of technologies- both current and future- that would be applicable and acceptable under current language. Additionally, it may be worth exploring, before proposing an actual amendment, what the rationale is for some of these changes. New phrases in the proposed language lack underpinning definitions, which may lead to confusion as currently drafted. For example, providing examples of "acceptable" formats, as well as examples of "unacceptable" formats, does not define the term for another format not specified. Examples, in and of themselves, are not definitions and should not be treated as such. It is also unclear how these changes would mesh with other related sections on adequacy of records. In looking to "tightly define", the committee should be careful to not forestall the ability of the language to adapt to the needs of both carriers and states.

Undecided Washington is undecided at this time; we generally support the premise and efforts but need mroe time to dig into the language and assess impacts.
Support: 8
Oppose: 5
Undecided: 10