IFTA / IRP 2010 Annual Audit Workshop
Breakout Session # 1 – Part 2




Distance – It’s a Long, Long Road;
Auditing That Newfangled GPS .
Gene Hall
(VA)
Derrick Rumph (AR)
Drake Israel
(IL)
1
The carrier has the option of using
onboard recording devices. These
devices are not required by either IRP
or IFTA.
If the carrier chooses to use one of
these devices, the recording system
would have to meet the record keeping
requirements of both IFTA and IRP.
2
On board recording devices
Global positioning systems (GPS)
3
When you run into an electronic system there are
several things you need to know about it.
a) What does the driver do to activate it?
b) Are there any reviews or checks by office staff?
c) How does the information get into the system? At
what point? Reviews or checks before entry?
d) Does their system do any automated checks?
e) If odometers are entered, does the system check
odometer total distance to jurisdiction total
distance?
4
Would you accept records if kept
electronically by registrant/licensee?
The main thing to remember is what
information do you need to test
distance?
You should ask as many questions
about the software and procedures
in order to fully understand them.
5
Have you conducted a GPS
audit?
What questions do you ask
about the carriers system?
6
*P600 ELECTRONIC DATA RECORDING SYSTEMS
*P610 OPTIONAL USE FOR FUEL TAX REPORTING
On-board recording devices, vehicle tracking systems, or other
electronic data recording systems may be used (at the option of
the carrier) in lieu of or in addition to handwritten trip reports for
tax reporting. Other equipment monitoring devices that transmit
data or may be interrogated as to vehicle location or travel may
be used to supplement or verify handwritten or electronicallygenerated trip reports. Any device or electronic system used in
conjunction with a device shall meet the requirements stated in
this Section. On-board recording or vehicle tracking devices
may be used in conjunction with manual systems or in
conjunction with computer systems.
7
P620 DEVICES USED WITH
MANUAL SYSTEMS
All recording devices must meet the requirements
stated in IFTA Procedures Manual Section P640 and
P660. When the device is to be used alone, printed
reports must be produced which replace handwritten
trip reports. The printed trip reports shall be retained for
audit. Vehicle and fleet summaries which show miles
and kilometers by jurisdiction must then be prepared
manually.
8
P630 DEVICES USED WITH
COMPUTER SYSTEMS
The entire system must meet the requirements stated in IFTA
Procedures Manual Sections P640, P650, and P660.
If the printed trip reports will not be retained for audit, the system
must have the capability of producing, upon request, the reports
indicated in IFTA Procedures Manual Section P640.
When the computer system is designed to produce printed trip
reports, vehicle and fleet summaries which show miles and
kilometers by jurisdiction must also be prepared.
9
*P640 DATA COLLECTION
REQUIREMENTS
To obtain the information needed to verify fleet distance and to
prepare the "Individual Vehicle Distance Record”, the device must
collect the following data on each trip.
.100 Required Trip Data
.005 Date of Trip (starting and ending);
.010 Trip origin and destination (location code is acceptable);
.015 Routes of travel or latitude/longitude positions used in lieu
thereof (may be waived by base jurisdiction). If latitude/longitude
positions are used, they must be accompanied by the name of
the nearest town, intersection or cross street. If
attitude/longitude positions are used, jurisdiction crossing
points must be calculated or identified;
10
P640 Continued
.020 Beginning and ending odometer or hubodometer reading of
the trip (may be waived by base jurisdiction);
.025 Total trip distance;
.030 Distance by jurisdiction;
.035 Power unit number or vehicle identification number;
.040 Vehicle fleet number; and
.045 Registrant's name.
11
What is an “Exception report”?
650..400 Exception Reports
Exceptions that identify all edited data,
omissions of required data (see IFTA
Procedures Manual Section P640), system
failures, noncontiguous life-to-date
odometer readings, travel to noncontiguous
jurisdictions, and trips where the location of
the beginning trip is not the location of the
previous trip must be identified.
12
IRP/APM ARTICLE 500 ON-BOARD
RECORDING DEVICES



501. On-Board Recording Devices
(a) On-board recording devices may, at the option of the Registrant,
be used in lieu of or in addition to handwritten trip reports for
purposes of apportioned registration record-keeping. If a Registrant
exercises this option, any device or electronic system used in
conjunction with a device shall meet the requirements identified in
this Manual. Other equipment monitoring devices, such as those
which transmit or may be interrogated as to Power Unit location or
travel, may (at the option of the Registrant) be used to supplement or
verify handwritten or electronically-generated trip reports.
(b) All recording devices used to generate trip reports or used in
conjunction with manual systems must meet the requirements shown
in Sections 504 and 505. When the on-board recording device is used
in conjunction with an electronic computer system and reports are
prepared on the basis of data downloaded from the recording device,
the overall system must meet the requirements of Sections 504, 505,
and 506.
13
502. Use of On-Board Recording Device
Only

When the device is to be used alone,
printed reports must be produced
which replace handwritten trip
reports. The printed trip reports shall
be retained for Audit. Power Unit and
Fleet summaries which show InJurisdiction Distance must then be
prepared.
14
503. Use of On-Board Recording
Device in Conjunction with an
Electronic Computer System


(a) When the computer system is designed to
produce printed trip reports, Power Unit and
Fleet summaries which show In-Jurisdiction
Distance must also be prepared.
(b) When the printed trip reports will not be
retained for Audit, the system must have the
capability of producing, upon request, the
reports indicated in Section 506.
15
504. Minimum Device Requirements




(a) The Registrant must obtain a certificate from the
manufacturer certifying that the design of the on-board
recording device has been sufficiently tested to meet the
requirements of this provision.
(b) The on-board recording device and associated support
systems must be, to the maximum extent, practicable and
tamperproof and must not permit altering of the information
collected. Editing of copies of the original information
collected will be allowed, but all editing must be identified,
and both the edited and original data must be recorded and
retained.
(c) The on-board recording device shall warn the driver
visually and/or audibly that the device has ceased to function.
(d) The device must time and date stamp all data recorded.
16
504 Continued



(e) The device must not allow data to be overwritten
before the data has been extracted. The device shall
warn the driver visually and/or audibly that the device’s
memory is full and can no longer record data.
(f) The device must automatically update a life-to-date
odometer when the Power Unit is placed in motion, or
the operator must enter the current Power Unit
odometer reading when the on-board recording device
is connected to the Power Unit.
(g) The device must provide a method for the driver to
confirm that driver-entered data is correct (e.g. a visual
display of the entered data that can be reviewed and
edited by the driver before the data is finally stored).
17
IRP 505. Data Collection
(a) To obtain the information needed to verify fleet distance
and to prepare the Individual Vehicle Distance Record
(IVDR), the device must collect the following data on each
trip:
1. Date of trip (starting and ending);
2. Trip origin and destination (location code is acceptable);
3. Route of travel (may be waived by base jurisdiction);
4. Beginning and ending odometer or hubodometer reading
of the trip (may be waived by base jurisdiction);
5. Total trip distance traveled;
6. Distance traveled by jurisdiction;
7. Power unit number or vehicle identification number.
18
(b) The Base Jurisdiction may waive either item
(3) or (4) above, but may not waive
both items (3) and (4).






Also, the device may include, at the discretion
of the Base Jurisdiction, the following
additional information:
(i) Fleet number;
(ii) Registrant’s name;
(iii) Vehicle identification numbers;
(iv) Driver ID or name; and
(v) Intermediate trip stops.
19
506. Capability of System to Produce Reports



Generally speaking, the reports referred to in this
section are not prepared by the on-board recording
device. Instead, these reports are prepared using an
electronic computer system which accepts data from the
on-board recording device. The system shall be able to
produce the following reports:
(i) For each trip, an Individual Vehicle Distance Record
(IVDR) report that includes the information required in
Section 505 (Note: This report may be more than one
page.);
(ii) A report that indicates when the on-board recording
device was last calibrated and the calibration method
used;
20
506 Continued



(iii) An exception report(s) that identifies all
edited data, omissions of required data (see
Section 505), system failures, non-continuous
life-to-date odometer readings, travel to
noncontiguous states, and trips where the
location of the beginning trip is not the
location of the previous trip;
(iv) A monthly, quarterly, and annual summary
of trips by unit number showing total InJurisdiction Distance; and
(v) Monthly, quarterly, and annual trip
summaries by Fleet showing the number of
total In-Jurisdiction Distance.
21
507. Registrant Responsibility


(a) It is the Registrant’s responsibility to recalibrate the
on-board recording device when tire size changes, the
Power Unit drive-train is modified, or any modifications
are made to the Power Unit which affect the accuracy of
the on-board recording device. The device must be
maintained and recalibrated in accordance with the
manufacturer’s specifications. A record of recalibrations
must be retained for the record retention period.
(b) It is the Registrant’s responsibility to ensure their
drivers are trained in the use of the computer system.
Drivers shall be required to note any failure of the onboard recording device and prepare manual trip reports
of all subsequent trip information until the device is
again operational.
22
507 Continued



(c) It is the Registrant’s responsibility to maintain a
second copy (back-up copy) of the electronic files, either
electronically or in paper form, for the Audit retention
period.
(d) At the discretion of the Base Jurisdiction, Registrants
may submit Operational Records for Audit to the Base
Jurisdiction through electronic data transfer.
(e) It is the Registrant’s responsibility to ensure the
entire record-keeping system meets the requirements of
the Plan. It is suggested that the Registrant contact the
Base Jurisdiction for verification of Audit compliance
prior to implementation.
23
Questions to ask.
1. What type of GPS system do you have?
2. How often does the GPS send a signal? (transmits a ping)
Are all pings recorded? If not, why not?
3. What information is the GPS recording? (i.e. date, location points,
odometer reading, fuel stops, when the engine is turned off,
some sort of “event”, etc.)
4. If your GPS system records odometer readings, at what points are
the odometer readings being captured?
5. How does your GPS system calculate miles?
24
6. Do you use other computer software in addition to your GPS that
calculates miles and or fuel? If so, what type of software do
you use and what is its function?
7. Can the following reports be generated?
_____
_____
_____
_____
Fleet mileage summaries listing total miles and juris.
miles per unit and for the entire fleet?
Unit mileage summaries listing total miles and juris.
miles.
Total and jurisdictional miles per trip.
Routes of travel (detail of GPS location points) by trip.
List any other reports generated by the GPS system that would be
useful for a mileage and fuel audit.
25
8.
What reports do you use to prepare your IFTA returns?
9.
What reports do you use to prepare your IRP renewals?
10. How long are you retaining your printed GPS reports?
11. How long are you able to retrieve printed and non-printed
reports?
12. Are you able to generate and print exception reports? (See
Section P650.400 IFTA Procedures Manual)
13. Is the GPS information being edited? Why would someone edit
the GPS information? What specifically is being edited?
14. Can the driver defeat or tamper with the GPS system?
26
15. Does your GPS system rely on the truck’s battery for power?
16. How would you know if the truck was being towed (moving but
not accruing miles)?
17. Are you alerted when the GPS system is not receiving a signal
from a unit or if there is a problem with the signal?
18. What is your procedure or policy of recording mileage
information if the GPS system were to malfunction?
19. Do you have units that are not equipped with the GPS? Please
provide a listing of units, (by unit number) without GPS.
20. If you operate units without GPS, what records are being kept for
these units?
27
Has the technology of G.P.S matured to the point where its
fully dependable to accurately capture all vehicle activity?
Has the technology and computer software able to
capture a trucks signal and produce the reports that the
IFTA and IRP require?
Are we moving from the old geological Lat, Long “ping”
every 30 minute systems, to real time monitoring via a road
map system?
Will makers like Tom-Tom, Garmin, and Magellan take the
place of the traditional “hand prepared” driver source
documents on-board the trucks we audit?
Is G.P.S systems more accurate than driver recorded
odometer readings and routes of travel?
More accurate than PC-Miler or Promiles mapping software?
28
Do you trust it?
How do you test a G.P.S system?
The carrier your about to audit does not have driver
prepared source documents. No unit odometers, routes
of travel or beginning and ending destinations. They did
however, maintain their bills of laden for the audit scope
and their last 6 months of D.O.T. logs which have
odometer readings recorded on them.
The owner, states he uses his G.P.S. computer printouts
which records routes of travel, captured by their 5
minute “ping” G.P.S. They use their G.P.S.reports with
ProMiles to report his IFTA returns, and IRP renewal.
How would you handle this type of situation?
29
A)
Tell the carrier that since he did not have his G.P.S. checked
and given a wavier from using driver source documents, that
you will be back in 1 year to check for compliance.
(Get a pencil and paper and start recording the requirements of
the IFTA and IRP).
B) Trust the G.P.S and accept the reports?
C) Apply a reduction in MPG’s to cover what you don’t know for
sure?
D) Apply a 4.0-MPG adjustment and 100% fees to cover what you
don’t know for sure?
E) Use the last 6 months of D.O.T. logs and bill of laden to
check against the G.P.S. system.
F) Roll your eyes and laugh hysterically as you mumble to the
owner that “You’ll send a bill”…………………. Then leave………..
30
Has your jurisdiction granted a GPS wavier?
31