Analysis and Prioritization of Mileage Reporting Methods (12)

Description:

This building block involves the analysis and prioritization of potential mileage reporting methods in either a pilot or operational program in a jurisdiction. Mileage reporting methods are not generally specified in legislation, but the law must enable various reporting methods, such as odometer readings and/or location-based methods. Importantly, noncommercial vehicles and medium-duty commercial vehicles may use similar mileage reporting technologies, while heavy-duty commercial vehicles will likely use methods similar to those already in place for meeting existing federal and international regulatory requirements.

For noncommercial vehicles, currently available RUC mileage reporting methods include the following:

Automated methods (location optional):

  • On-board diagnostic-II (OBD-II) device that plugs into the vehicle and collects data directly from the vehicle. These devices include both location-based and non-location-based options.
  • Native automaker telematics that use a vehicle’s built-in computer and communications equipment to determine mileage data. Currently, startups provide third-party application programming interface services to vehicles from automakers with whom they have agreements.
  • Smartphone app with the option to measure location and compute miles traveled by state.

Manual methods (no location):

  • Safety inspection reporting that uses odometer values already recorded at safety inspections.
  • Self-reporting in which the user reports odometer readings using a computer, app, or mail-in option. This method must be accompanied by auditing for a significant percentage of vehicles, and it can use methods like odometer image captures or coordination with a vehicle history provider like CARFAX.
  • Odometer image capture that uses a smart device, like a phone or table, to capture odometer readings. Security measures are required to prevent fraud, and may include detection of image manipulation, the use of live images from the device, and comparisons with the dashboard layout to ensure the vehicle matches the make, model, and year encoded in the vehicle identification number.
  • High flat fee or time permit that is charged for unlimited travel. The fee must be set sufficiently high so that only a few of the highest mileage drivers end up paying less than the average per-mile RUC rate.

For light-, medium-, and heavy-duty commercial vehicles, currently available RUC mileage reporting methods include the following:

  • Fleet management system devices and software provide a suite of vehicle services that are more sophisticated than electronic logging device functionality. These services may include higher security and higher frequency location information. This system is ideal for RUC collection for vehicles equipped with them.
  • Electronic logging device, which is used by interstate heavy-duty vehicles to report hours of service. This device is mandated by the Federal Motor Carrier Safety Administration and is required on most interstate heavy-duty vehicles without exemptions.
  • International Fuel Tax Agreement and International Registration Plan reporting. These are manual reporting requirements for most interstate trucks (e.g., the International Fuel Tax Agreement does not apply to electric trucks because they do not use liquid fuel, but the International Registration Plan does). Registration is not required of intrastate trucks.

Mileage reporting technology is constantly evolving, and research should be done on a recurring basis to keep mileage reporting methods current.

 

Details:

The state determines the highest-level organizational structure necessary for the mileage reporting methods under consideration. Account managers generally will be required for automated options, while manual options can be provided either by the state directly or by account managers. Based on stakeholder needs gathered during the task force and public opinion research exercises (see Creation and Convening of Task Force and Public Opinion Research building blocks), as well as financial models and the business case, the state can prioritize viable mileage reporting methods.

Primary Use:

Select mileage reporting methods for pilot or operational program.

Best Practices/Lessons Learned:

  • During the selection of mileage reporting methods, develop a report comparing each of the available options. Given the rapid evolution of this segment of the industry, this task will need to be done at the time of execution. As part of this effort, reach out to other deployment managers and projects to collect lessons learned from peer agencies.
  • To address public concerns about privacy, do not mandate use of location-based technology; include at least one mileage reporting method that does not require location.
  • Consider providing various mileage reporting and technology options (e.g., no tech, low-tech, high-tech, automated, and manual) in the RUC-enabling law to better meet the needs of various vehicle owners.
  • Safety inspection–based reporting is a good option for states that have this type of reporting. However, this method requires a supplementary option for cross-state travelers.
  • Manual methods are generally less expensive to implement and are often recommended for inclusion in larger RUC systems to drive down costs.
  • All reporting methods should be accompanied by an audit for a specified percentage of users to reduce fraud. Unintentional noncompliance will occur, so mistakes in reporting should not lead to the vehicle owner being considered an intentional offender. Note that odometer image capture can support manual self-reporting and reduce the need for audits.
  • If using the high flat fee, use truly high fees (95th or more percentile of driving) to avoid losses by high-mileage drivers choosing this option to save money.
  • Provide mostly credits for gas tax paid; offer refunds only when necessary because they involve more expensive processing costs.
  • Consider heavy-duty vehicles and passenger vehicles in separate discussions. Involve the trucking community in any discussion of heavy-duty vehicle charges. Heavy-duty vehicles traveling interstate are subject to International Fuel Tax Agreement and International Registration Plan mileage reporting requirements. Heavy-duty vehicles traveling intrastate and all medium-duty vehicles can use mileage reporting methods appropriate for passenger vehicles or those used for International Fuel Tax Agreement and International Registration Plan reporting. The state should determine how and to which agencies RUC for those vehicles should be reported.

State Government Context and Assumptions:

The task force, if one exists, in conjunction with the lead RUC agency work on this task as soon as the policy vision is completed. This task will inform the choice of mileage reporting methods for the pilot and/or potential RUC-enabling legislation.