Name

Organization/

Jurisdiction

Comment

Oklahoma

The term "electronic device" as used in the ballot needs a clear definition. The ballot is unclear if "electronic device" is referring to something like a smart phone that contains an electronic image of the credential, or a transponder that electronically transmits data to a receiver. If "electronic device" refers to the later, the standards for how the base jurisdiction will "verify" the registration information need to be more thoroughly explained.

Support.  It is time that jurisdictions – and registrants – had the flexibility under the Plan to experiment with electronic credentials.

We spent 30+ minutes in an in-house meeting discussing what this ballot is trying to say. The summary section talks about roadside readers which are used today primarily for screening purposes, not to substitute for credentials. OR is this ballot simply saying you can issue an electronic credential (displayed on a smart phone for example). Which appears to already be permissable under the Plan. Nebraska supports the effort to have open discussions on what the future of vehicle registrations should look like, but cannot support this ballot as it is written today.

Support concept of electronic credentialing, but only as an alternative to the paper cab card, and only if it is supported by the jurisdictions in which the vehicle operates.

Oppose as written. While generally supportive of emerging technologies as they relate to this issue Oregon is keenly aware of the downstream implications of a less than precise initial understanding of fundamental implementation, operational interoperability considerations and administration of such technology borne innovations. This ballot as written appears to simply invite competing discordant offerings from vendors prepared to jump into the arena with whatever technology they are poised to offer to the marketplace. A more ordered approach at the outset would pay dividends down the road. At the least, USDOT has authored language which sets forth its basic understanding of requirements as they relate to current installations of technology for prescreening to include, "the system is technology platform neutral, does not require new hardware, and can operate on a variety of mobile devices as well as onboard fleet management systems. The system is designed to meet FMCSA mobile device and texting requirements and complements existing DSRC-based screening systems." The ballot should incorporate some of these tenets as well as plainly state that such technology shall be open architecture, and universally operable without specter of fee to jurisdiction or end user. All that said, I think a better approach would be to establish an IRP work group to conduct additional review and bring forth a more robust ballot in the near term future.