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as of April 16, 2018:

$1 USD = $1.2580 CAD
$1 CAD = $0.7949 USD

Comments on Proposed Ballot: 2018.01 Reciprocity for Non-Apportioned Commercial Vehicles

The following comments were submitted for the proposed ballot - 2018.01 Reciprocity for Non-Apportioned Commercial Vehicles.

 Date  Name

 Organization/

Jurisdiction

 Comment
 5/15/18 Jay Sween Wisconsin Wisconsin supports the concept of putting all reciprocity agreements in one place as this ballot proposes. This ballot does not create or require reciprocity that does not currently exist within each individual jurisdiction and should probably be renamed so it does not give that impression (Jurisdiction Non-Apportion Reciprocity Repository). Two suggestions. First, ensure the format is consistent for all reciprocity agreement submissions and second, extend the initial date to January 1, 2020. It will take significant time for each jurisdiction to gather this information and report to IRP. 
 3/8/18 James Starling Alabama Support. The International Non-Apportioned Commercial Vehicle Agreement (INCVA) working group did a lot of good work on this project. Jurisdictions were generally supportive of the INCVA proposal; however, the biggest concern was the creation of another registration reciprocity agreement. This ballot proposal is a first step at amending the Plan to create ONE registration reciprocity agreement for all commercial vehicles. 
3/9/18 Cathy Beedle Nebraska While generally supportive of granting reciprocity for non-apportioned commercial vehicles I have a few questions: 1) was there any discussion of amending the definition of apportionable vehicle to remove the option offered to the registrant of obtaining an IRP plate on a vehicle less than 26,000lbs. 2)in addition to identifying reciprocity type conditions, was there any discussion of how to treat "restricted" plated vehicles which may or may not be covered under reciprocity agreements ? Would all possible types of restricted plates offered by each jurisdiction be included in this annual filing ? That may make for quite a cumbersome appendix!  
 3/16/18 Lynne Jones Oklahoma The state entity that is the IRP member may/may not be the entity that signs state-to-state reciprocity agreements, nor may the IRP member be aware of any agreements. Therefore the IRP member could not perform requirements as set forth in this ballot. Additionally, IRP devoted a considerable amount of time and money to INCVA. Not a single jurisdiction signed the agreement. The jurisdictions have been down this path and there just doesn’t appear to be demand necessary to support his measure.
3/30/18  Elaine Speller, MSgt Washington, DC The Intermodal Surface Transportation Efficiency Act (Pronounced IS-TEA) of 1991 essentially requires all states to become members of IRP with the following: After September 30, 1996, a State that is not participating in the International Registration Plan may not establish, maintain, or enforce a commercial motor vehicle registration law, regulation, or agreement that limits the operation in that State of a commercial motor vehicle that is not registered under the laws of the State, if the vehicle is registered under the laws of a State participating in the Plan. Channeling, Thor: Ragnarock – why should we [IRP] care and why do we need Reciprocity Agreements for Non-Apportioned Commercial Vehicles in the IRP Plan? 
4/4/18 Bob Pitcher American Trucking Association STRONGLY OPPOSE. If the intent of these changes is to provide reciprocity for smaller vehicles, there are far better, more straightforward ways of accomplishing it. There are all sorts of things wrong with this proposal. This is just a sample: The amendment to the Official Commentary for the amended definition of Apportionable Vehicle would actually allow into IRP all kinds of new restrictions on reciprocity, including the reciprocity currently accorded to trailing equipment under Section 515. In new Section 535, the new category “non-Apportionable Vehicle” includes trailing equipment, and could well include apportioned vehicles other than Apportionable Vehicles, that is, those at 26,000 pounds and below that are registered under the Plan. The Official Commentary for proposed Sec. 535 makes things worse, since it focuses on restrictions to reciprocity which, under this language, could distinguish between the inter- and intrajurisdictional movements even of Properly Registered Vehicles. INCVA has a good definition of Non-Apportioned Vehicle – why wasn’t it used here? The reciprocity appendix proposed for the Plan under the amendment to Sec. 1220 would have to be updated only annually, but a jurisdiction could alter its reciprocity arrangements on 30 days notice. Work on INCVA demonstrated how lengthy, detailed, confusing – and, often, just plain wrong, such an appendix would turn out to be. In short, this proposal messes with the basic reciprocity structure of the Plan in ways that would be very damaging. 
 4/27/18 Carolyn Evanston Ohio Though reciprocity of CMV inter-jurisdictional registration is an encourageable goal, the ballot at hand as well as the concept/comments of severally modifying The Plans apportionable vehicle definition beyond the “may” statement would cause considerable negative consequences to the apportionable percentage calculations for all FJ’s as well as take away the imbedded-foundation of IRP Audit selection differences between IRP actual mileage and IFTA taxable miles by Jurisdiction. We all are familiar with studies that indicate heavier weighted vehicles damage roadways at an exponentially higher level than lower weighted/passenger vehicles. State weight registration fees represent this difference as increased weight equals increased fees. When a vehicle that is not traditionally defined as apportionable, because they are more regional in nature, it skews mileage to BJ as well as its border FJ’s for the whole Fleet it is added to. This mileage skew reduces APR of FJ’s where the Fleet’s heavier apportionable vehicles travel. So less is paid to the FJ simply by adding these vehicles to a mixed weight fleet. AVD and forced registrations in non-travel jurisdictions of traditionally non-apportioned vehicles do not make up the difference in lower APR. Both issues could be mitigated if all non-definition apportionable vehicles were combined into a separate fleet than the traditional apportionable vehicles. With that addition the ballot might produce greater support.
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