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Proposed Ballot 2007-01 Comments
| Jurisdiction/Company |
Position |
Comments |
| Alabama |
Opposed |
Oppose as written. The term “source document" should be defined, or another defined term should be used (i.e. IVMR or operational records). Delete “and is evidence of non compliance”. Change “created” to “determined”. Change “event” to “trip”. |
| Washington |
Undecided |
Proposed ballot 2007.01 states that IRP defines route of travel. Proposed ballot 2007.09 states that IRP does not define route of travel. Suggest combining both ballots after suggested changes are made.
Suggested wording change by deleting the sentence in proposed Section 405 “Fleet distance and routes created before the event occurred are not acceptable and is evidence of non-compliance unless the Registrant can substantiate the information with original source documents from either the driver or the on-board recording device.” Insert new sentence in proposed Section 405: “Fleet distance and routes created by mileage software programs are acceptable provided they are reconciled to the source documents reflecting actual travel.” |
| ATA |
Opposed |
The drafting of this ballot is very poor, so poor that it’s difficult to say what it means. This is true of many of the others in this year’s crop of proposals. Ironic, when IRP has just spent several years and many thousands of dollars in a successful effort to clean up the Plan’s language. It does seem probable, however, that this ballot would bar registrants’ use of GPS technology to track their miles. Clearly, there are no solutions here for IRP today, let alone for tomorrow. Strongly opposed. |
| Oregon |
Opposed |
Do not support. "Distance and routes created before the event is evidence of non-compliance..." Article 405 already has language about recording actual distance traveled. What is the consequence of the evidence of non-compliance? This doesn't add clarity to language already in place. |
| Total supporting: |
0 |
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| Total opposed: |
3 |
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| Total undecided: |
1 |
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