The following comments were submitted for proposed Ballot - Electronic Credentialing.
See the Open Ballots page for more information.
"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.
|5/20/2013||N/A||American Trucking Associations||
Support. It is
time that jurisdictions – and registrants – had the flexibility under the Plan
to experiment with electronic credentials.
|5/23/2013||Cathy Beedle||Nebraska DVM||
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
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.
|5/28/2013||Gregg Dal Ponte|
Transportation Division, Oregon Department of Transportation
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.