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as of June 18, 2018:

$1 USD = $1.3229 CAD
$1 CAD = $0.7559 USD

Comments on Proposed Ballot: Audit Procedures Manual Sections 504 and 505

The following comments were submitted for the proposed ballot - Audit Procedures Manual Sections 504 and 505.






Garry Hinkley
Maine BMV
Based on section 1000 of the Plan, Retention and Availability of Records, audits can be conducted on any registration were estimated distance was used to calculate fees until November of 2018. Removing estimated distance audit procedures at this time is premature. Suggest that current sections 504 and 505 of the audit manual be renamed "Distance Adjustments for Pre-Full Reciprocity Registrations” and a new section added entitled "Distance Adjustments for Full Reciprocity Registrations” to cover the word change of section 320 of the Plan from Estimated Distance to Average per-Vehicle Distance. As a point of clarification, the term and idea of Average per-Vehicle Distance was used in the pre-full reciprocity section 320. The removal of the word estimate from the plan has not changed the way in which these numbers are calculated, just that carriers cannot estimate distance.

Joe Sculley

Truck Renting and Leasing Association (TRALA)The Truck Renting and Leasing Association (TRALA) appreciates the opportunity to submit comments in response to ballot proposal 2015.01 – audit procedures manual sections 504 and 505. TRALA understands the need to amend the audit procedures manual to reflect implementation of the FRP. TRALA supported and advocated for passage of the Full Reciprocity Plan (FRP), and the biggest reason for this was because the FRP solves the problems of TRALA members not knowing what jurisdictions to put on their cab cards because of the fact that they often don’t know where their customers will need to operate the vehicles in the coming year. With that situation in mind, TRALA would like to suggest that two additional revisions be made to the audit procedures manual. TRALA members feel that some clarity could be added regarding adjustments upon the discovery of actual distance. A provision could be added to the new section 504 which states that "credit” can be given when comparing what was actually remitted at the time of registration, versus what will be due after recalculation. TRALA also suggests that the proposed new paragraph (e) – relating to vehicles that may be deemed to not qualify as an apportionable vehicle – should be removed. TRALA members need to be able to provide the ability for their customers to operate interstate, and just because a vehicle might not have crossed state lines due to customer activity, that does not necessarily mean the same thing will happen in the future. Since this ballot states that actual distance accrued will be used (if found), TRALA members believe this paragraph is not necessary. You may contact TRALA’s Joe Sculley directly at or by calling (703) 299-9120. Thank you for your consideration.

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