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Proposed Ballot 2007-05 Comments
| Jurisdiction/Company |
Position |
Comments |
| Alabama |
Opposed |
Oppose as written. We agree with adding the proposed requirements to the audit report (vii – xii), however, we don’t believe the requirement for the detail is necessary. The bond suggestion should not be a provision of the Plan. |
| Washington |
Opposed |
Do not support the proposed ballot. The proposed ballot has the effect of changing the meaning of the word “adequate” for audit purposes to “perfect” for audit purposes (all requirements of Article 4 of APM have been met). Perfect is a much higher standard than adequate. The purpose of an IRP audit is to provide a reasonable degree of assurance, not absolute assurance, that the registrant reported distance and vehicle information is properly reported to the base jurisdiction in accordance with the IRP. If the records are “adequate” for audit purposes, the audit report should be able to form or base a conclusion on those records. Defects in the mileage accounting system, that need correcting, should be minor. If the records are “marginal” for audit purposes, there are more serious defects in the mileage system that need correcting or the jurisdiction would be forced to estimate operations. The proposed ballot suggests that jurisdictional credit could be denied in situations where all requirements of APM 4 have not been met. |
| Idaho |
Undecided |
In Subsection C, Idaho is concerned that the clause headings of “Adequate,” “Marginal” and “Inadequate” are too vague, thus opening the door for a wide range of interpretations between the member jurisdictions. We recommend: (i) Complies with Requirements; (ii) Qualified; and (iii) Does not Comply with Requirements. |
| ATA |
Opposed |
The Summary of the ballot states: “adequate does NOT mean adequate….” And this sort of approach is intended to give guidance to jurisdiction auditors and registrants? As with several of the other ballots in this series, the intent of this one seems to be punitive. The drafting of this ballot is again very bad. Strongly opposed. |
| Oregon |
Opposed |
Do not support. Adequate records should mean that the jurisdiction is reasonably able to complete an audit - not that the registrant has perfect records. |
| Total supporting: |
0 |
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| Total opposing: |
4 |
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| Total undecided: |
1 |
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