TRALA Comments on IRP Ballot Proposal
TRALA has submitted comments on an International Registration Plan (IRP) ballot proposal which suggest that some clarifications could be made to the Plan's audit procedures manual. IRP Ballot 2015.1 - Audit Procedures Manual Sections 504 and 505, was prompted by the adoption of a previous ballot known as the Full Reciprocity Plan (FRP), something which was supported by TRALA. One of the things the FRP accomplished was that it eliminated any references to estimated distance; so accordingly, this ballot would eliminate any references to estimated distance from the audit procedures manual. TRALA understands why this is necessary and supports the move, especially in light of TRALA's previous advocacy in support of the FRP.
TRALA's comments also suggest that additional amendments could be made to the audit procedures manual, in the section of the manual that will already be amended if this ballot is adopted. The first surrounds the discovery of actual distance during an audit. The ballot understandably calls for a recalculation of fees based upon the discovery of actual distance, though it does not specify that "credit" should be given for the amounts initially paid when comparing that amount against the recalculated amount. TRALA believes that should be the case and that language could be added which makes that clear.
TRALA's other point suggests that the paragraph regarding recalculation of fees for vehicles determined not to be an apportionable vehicle should be eliminated. TRALA supported the FRP because it solved a problem of renting and leasing companies not knowing for sure what jurisdictions they needed to put on their cab cards because they often cannot predict customer needs. For those same reasons, TRALA believes the paragraph dealing with non-apportionable vehicles should be eliminated. The TRALA comments state "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."