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Proposed Ballot 2007-10 Comments
| Jurisdiction/Company |
Position |
Comments |
| Alabama |
Support |
Support. An audit procedure addressing this issue has been needed for some time. This proposed procedure will help promote uniformity. |
| Washington |
Undecided |
Once you assess full fees for a vehicle(s) because the vehicle did not travel interstate for 18 months (Registration year plus 6 months), you should refund for those jurisdictions where no travel occurred in the registration year unless the jurisdictions’ laws say otherwise. By this ballot and Plan rewrite, these are not apportionable vehicles and not subject to the IRP, yet the ballot requires you to keep the fees for those jurisdictions where no travel occurred. Suggest last sentence of proposed 706 be deleted and alternative wording that states “Fees will be adjusted in accordance with the laws of the member jurisdictions effected.”
It is unclear which “distance the Vehicle(s) traveled will be subtracted from the reported Fleet distance” during the Reporting Period. Assuming that the vehicle(s) in question was licensed with the Fleet during the Reporting Period, is the distance to be subtracted:
· the vehicle distance traveled “for the entirety of a registration Year and for six additional months” in one specific Member Jurisdiction or
· the vehicle distance traveled “for the entirety of a registration Year” in one specific Member Jurisdiction or
· the vehicle distance traveled during the Reporting Period in that one specific Member Jurisdiction or
· the vehicle distance traveled during the Reporting Period in any Member Jurisdiction the vehicle may have operated since the vehicle may have operated inter-jurisdictionally until the audited registration period? If the vehicle(s) in question was not licensed with the Fleet during the Reporting Period, why should any distance be subtracted from the Reporting Period? |
| ATA |
Opposed |
This proposal contradicts both the specific language and intent of the Plan. See the final paragraph of the commentary to the definition of Apportionable Vehicle. That provides the necessary flexibility for industry and states, and was several times discussed as the rewrite went forward. This solution would be far too rigid in practice. Strongly opposed. |
| Oregon |
Opposed |
Do not support as written. Propose alternative language, "If, through Audit, it is determined that an Apportioned Vehicle(s) did not operate in two or more Member Jurisdictions for the entirety of a Registration Year and for six additional months and whose apportioned registration has been renewed in the subsequent Registration Year, it is presumed that the Registrant did not intend to operate the Vehice(s) in two or more Member Jurisdictions..." This would give registrants the opportunity to self-monitor their operations and give them operational flexibility. |
| Total supporting: |
1 |
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| Total opposed: |
2 |
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| Total undecided: |
1 |
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