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as of June 19, 2017:

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Comments on Proposed Ballot: 2017.03 Inadequate Records; Unreported Jurisdictions' Assessment

The following comments were submitted for the proposed ballot - 2017.03 Inadequate Records; Unreported Jurisdictions' Assessment.

 Date  Name

 Organization/

Jurisdiction

 Comment
6/6/17

Renée
Kyser

Alabama and Audit Committee Vice Chair The AC appreciates the comments and discussion here and at the Annual Meeting - both positive and negative. As discussed in Tempe, while we saw this rarely in AL prior to FRP implementation, approximately 25% of the inadequate records assessments we've issued this year have reflected unreported jurisdictions discovered either during the audit prelim process (when reviewing our systems and SAFER), or when scanning minimal records provided by a carrier, that are inadequate for validating total and jurisdictional distance, yet reflect such travel. The AC voted last week to change the language minimally and proceed. We are hopeful we answered your questions satisfactorily, the reward of which will be your support. For those that suggested reverting from the reported back to the APVD chart and then adding the customary percentage, we did not opt for that approach for 2 reasons. First, it would necessarily create unwarranted credits in numerous jurisdictions; second, the programming would be more intense. Our goal in this was similar to the current assessment - get such a carrier's attention and get something that is reasonable for the impacted jurisdiction and manageable for the registrant. After all, in most cases, our large carriers are not guilty of this. Thanks again for all your comments!
 5/18/17 Craig Johnson Pennsylvania Oppose. The audit is to seek compliance, not to impose an arbitrary $50 assessment.
5/9/17 Thomas Henderson Minnesota Driver and Vehicle Services

Minnesota is generally in agreement with the ballot proposal. However, Minnesota believes one of the guiding purpose of the agreement is to audit on behalf of all member jurisdictions and we would like to suggest for consideration an alternative method to compensate for unreported distance.

In this alternative, the base jurisdiction shall impose registration fees for the unreported jurisdiction(s) based on Article 320 Average Per-Vehicle Distance. The apportionment percentage for a jurisdiction(s) unreported distance shall be determined by the sum of the average per-vehicle distance plus the total actual distance reported according to Article 315; then divide the unreported jurisdictional average per-vehicle distance by the sum of actual distance plus average per-vehicle distance.

An example of this alternative for illustration purposes would be: --- Actual distance for Jurisdiction A, B, C, and D equals distance of 70,000 miles. --- Unreported jurisdiction E average per-vehicle distance 1,000 miles. --- Total distance for determining jurisdictional unreported distance is 71,000 miles. Then 1,000 divided by 71,000 results in .014084 apportioned percentage and rounded to 5 decimal places. The .01408 is multiplied by the jurisdictional fee plus the appropriate 20%, 50% or 100% Apportionable Fees. For our example the registration fees are assumed to be $1,700.00 multiplied .01408 which results in assessment of $23.94, rather than a flat $50 assessment, plus the applicable 20%, 50% or 100% Apportionable Fees that the ballot proposes.  

5/5/17 Dawn Lietz  Nevada Support. However, we are open to other suggestions on ways to address this issue. With full reciprocity, law enforcement has no way to determine whether fees have been paid for a jurisdiction as they did in the past. Without a mechanism to address unreported jurisdictions through audit, there is nothing in the Plan to prevent a registrant from omitting distance in a high fee jurisdiction. If a registrant is not reporting all of their distance, they are going to be more likely to fail to provide adequate records for audit as well.
 5/4/17 Stacey Hammond Utah Undecided.  We tend to support the theory of this ballot as it proposes some compensation for a jurisdiction that has never been recognized in the past. There is currently no remedy for this situation. Why not recognize travel when there is evidence discovered in the normal process of an audit and the jurisdiction is completely unreported? What other remedy for this situation exists?
4/21/17 Robert Pitcher American Trucking Association Oppose. This would impose a new kind of penalty in IRP. There is no need for it, and the amendment seems poorly conceived.
(1) The current language of Sec. 1005 was designed to make plain to a registrant that it needed to keep records for audit. It was NOT designed to make ANY jurisdiction whole – in the absence of decent records, how could it?
(2) The newly proposed $50 penalty looks just like a minimum fee, which IRP specifically forbids – and for good reason. That’s not a road IRP wants to venture down, even with much better reason than there is here.
(3) The current language is supposed to keep auditors from wasting time on a set of records that are inadequate. The proposal would encourage them to look through what little they have to find $50 discrepancies.
(4) Finally, there are problems with the language of the proposal. It’s just a bad idea.
4/10/17 Paul Johnson Washington Department of Licensing We are concerned the $50.00 is clearly a penalty. We understand the other percentages are based on registration fees. This is clearly not based on registration fees and we would oppose this ballot.
4/6/17 Rena Hussey Virginia Department of Motor Vehicles Virginia looks forward to further discussion of the ballot; however, our initial inclination is to not support the proposal. We have some basic philosophical concerns about making such adjustments when it has been determined that the carrier’s records are not auditable. The additional fee appears to be punitive in nature. We also believe the proposal poses fairness and equity concerns as audit practices will vary by jurisdiction, resulting in carriers based in some jurisdictions being held to a higher standard. Over time those equity concerns could result in a push for additional audit requirements being imposed on jurisdictions to proactively seek out violation, inspection and other information.
 3/31/17 James Starling Alabama Support
 3/22/17 Renée Kyser Alabama & Audit Committee Vice Chair For clarification to MB's question. The current language requires the percentage assessment be based on the fees originally paid, and the distribution of that assessment is only to those jurisdictions where fees were paid; therefore, unreported jurisdictions would not be included because no fees were paid. The remedy for any unreported jurisdiction would be an additional $50 assessment, which would be assessed for, and distributed to, each unreported jurisdiction.
 3/21/17 Marguerite Monchamp  Manitoba Public Insurance The ballot states that we are to levy 20 percent from the original invoiced amount then allocate it proportionately to all affected jurisdictions (reported and unreported). Then we are to levy a $50 fee for every jurisdiction where distance was not reported. How is that fee to be distributed?? 
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