ALABAMA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
IMPACT
May pose a major problem. We are currently limited to 60
characters horizontal, 56 characters vertical. Font size and realestate are the issues.
1.
60 characters horizontal
1.
Full Legal Name
2.
56 characters vertical
2.
Person’s Date of Birth
3.
none
3.
Person’s Gender
4.
none
4.
Person’s DL or ID Card Number
5.
none
5.
Digital Photograph of Person (and retention)
6.
6.
Person’s Address of Principle Residence
What defines principle residence? How will a homeless
person be licensed?
7.
Person’s Signature
7.
None
8.
Physical Security Features to prevent tampering,
counterfeiting or duplication
8.
None
9.
None
9.
Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
None
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Limited impact – programming effort with associated costs.
Why must it be called a temporary with a different than usual
expiration date? For example, although we call it a foreign
national license the expiration date is shown the same as any
other license. It is simply tied to the expiration date of the
immigration documents.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Verification at Source:
1. None. We are on line.
Enabling your system to electronically verify
documentation with:
2. A work in progress. We have registered and are awaiting the
process to enter into the MOU.
1. SSOLV
2. SAVE
ASSUMPTIONS
3. Who knows? I have not been provided with enough
information to draw a conclusion or make an assumption.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
4.
Limited if any.
5.
Major. Who is going to provide even a list of telephone
numbers? What about US citizens born in foreign
countries?
6.
Who knows? I have not been provided with enough
information to draw a conclusion or make an
assumption.
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Minor. This capability was built into our new system.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Massive. We have equipment available at our six (6) district
offices to accomplish this, however, we do not have the
resources to equip all of our 79 offices.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
We will not retain paper due primarily to security issues and cost
of storage. The hardware and storage space required for this will
be extremely costly.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Unknown. What defines “effective procedure’?
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
Massive. Why should the state be required to resolve the
discrepancy? Why not place this burden on the individual to
Why is there a difference in the time
requirement for storage of paper and
electronic images? What is the logic behind
this requirement?
REAL ID ACT REQUIREMENT
IMPACT
resolve the discrepancy and take appropriate action
resolve with the social security administration?
Check other states if a person already was issued a DL in
another state
None
Ensure physical security of locations where DL/ID cards
are produced
None, other than the cost of travel.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
None
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
In our state, probate judges and license commissioners act as
agents of the state in issuing duplicate driver licenses and we
have no control over these agencies. This would require that
Public Safety take complete control of the licensing process.
A fraudulent document recognition program has been in place
for several years. All Public Safety Driver License Examiners
receive yearly training in fraudulent document recognition.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None. We are on a four (4) year license cycle.
Alternative document design if it does not meet federal
standard
Not enough information provided to respond to this question.
Legal Presence Requirement
None. We already have legislation in place.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Are you talking about just driver license information or are you
including motor vehicle registration data also?
None, if you are just referring to driver license access.
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
None
ASSUMPTIONS
We will conduct a yearly random inspection.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Alabama does not intend to license persons who are in this
country illegally. Therefore there would be no need for such a
certificate.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Although we have many questions we feel it is too early to ask this question when we have not been able to see the
rules that will govern its implementation.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Analysis has not been completed. We are working with the Governors office, our Congressional delegation and our driver license
contractor to determine impact.
ALASKA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System (in Record, on Document)
IMPACT
ASSUMPTIONS
No impact, required by statute for issuance
Have following data elements/features on the document:
10. Full Legal Name
Currently Required
11. Person’s Date of Birth
Currently Required
12. Person’s Gender
Currently Required
13. Person’s DL or ID Card Number
Currently Required
14. Digital Photograph of Person (and retention)
Currently Required
15. Person’s Address of Principle Residence
Currently printing mailing address with
principal residence in database
16. Person’s Signature
17. Physical Security Features to prevent tampering, counterfeiting or duplication
18. Common Machine Readable Technology:
Currently Required
Currently Incorporated
2D Machine readable bar code
Introduce temporary DL/ID cards and tying end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Reprogramming required
Amending card design to show/indicate that it is a temporary document with a “different
than usual” expiration date
Reformatting required
Verification at Source:
Enabling your system to electronically verify documentation with:
1. SSOLV
SSOLV expected by 6/06
2. SAVE
SAVE must be developed
Reprogramming to print principal
residence address
REAL ID ACT REQUIREMENT
IMPACT
3. DEERS (DOD)
Need information on this database
4. Other jurisdiction (DL/ID card)
Must develop
5. Birth certificate
PDPS only check Must develop
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Must develop
Introduce equipment into system to capture digital images of identity source documents
so that images can be retained in electronic storage in a transferable format
Must develop
Retain paper copies of source documents for a minimum of 7 years or images of source
documents presented for a minimum of 10 years
Must develop
Subject each person applying for a driver’s license or identification card to mandatory
facial image capture
Currently required (digital image)
Establish an effective procedure to confirm or verify a renewing applicant’s information
Currently required
In the event that a social security account number is already registered to or associated
with another person to which any state has issued a DL/ID card, the state shall resolve
the discrepancy and take appropriate action
In state can identify duplicate number Must
connect to SSOLV and set up verification of
use between states
Check other states if a person already was issued a DL in another state
Current tool is PDPS which could be expanded
or utilize CDLIS for this purpose
Ensure physical security of locations where DL/ID cards are produced
Current Practice
Subject all person’s authorized to manufacture or produce DL/ID cards to appropriate
security clearance requirements
Needs to be done
Establish fraudulent document recognition training programs for appropriate employees
engaged in the issuance of DL/ID cards
Needs to be implemented
Limit period of validity of DL/ID cards that are not temporary to a period not exceeding
8 years
Current Licenses/ID’s expire in 5 yrs
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Alternative document design if it does not meet federal standard
Need to develop new format
Legal Presence Requirement
Legislation introduced with expected passage
in 2006
Provide electronic access to all other states to information contained in the motor vehicle
database of the state
Needs to be developed
ASSUMPTIONS
Maintain a state motor vehicle database that contains at a minimum:
All data fields printed on DL/ID cards
Current practice
motor vehicle driver’s histories, including motor vehicle violations, suspensions
and points on licenses
Current practice
Optional
Development and issuance of a certificate of driving – not for federal identification
purposes – for those who cannot prove lawful presence.
May consider as option
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Alaska will be introducing the DLA in the next session. If it does not pass in 06’ will be unable to qualify for
grants and federal assistance. This was our comprehension of the REAL ID Act language
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Alaska has not completed an impact analysis but is in the process.
ARIZONA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
IMPACT
ASSUMPTIONS
Change to current process.
Requires database expansion and programming
changes.
Requires legislation.
Requires funding.
Have following data elements/features on the document:
19. Full Legal Name
20. Person’s Date of Birth
21. Person’s Gender
22. Person’s DL or ID Card Number
23. Digital Photograph of Person (and retention)
24. Person’s Address of Principle Residence
25. Person’s Signature
26. Physical Security Features to prevent
tampering, counterfeiting or duplication
27. Common Machine Readable Technology:
Change to current process. Requires system redesign
and changes to forms, web and Customer Service
Guide.
1. Change
2. Currently capture
3. Currently capture
4. Currently capture
5. Currently capture and retain
6. Change
7. Currently capture
8. Security features in place
9. Bar code and magnetic stripe on current DL/ID
Requires additional information on driver
license/identification card.
Credential consumables provided by the industry meet the
new security requirements.
REAL ID ACT REQUIREMENT
IMPACT
Modifications required:
• Database expansion to store 125 characters
• Screen modifications to hold 125 characters
• Programming changes for name expansion
and to always print residence address on the
credential
• Driver license template changes to print 125
characters on the face of the driver license
or ID card
• Online (ServiceArizona) changes
• Bar code changes
• Magnetic stripe changes
• Testing
• Policy change
• Customer service representative training
• Legislation
• Rules
• Funding
Introduce temporary DL/ID cards and tying end of stay
to expiration of DL/ID card (or issuance for no more
than 1 year)
Change to current process. Expiration is currently
tied to end of stay or issuance for no more than 2
years.
Requires new credentials.
Modifications required:
•
•
•
•
•
System programming change
Testing
Policy change
Legislation
Training
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
•
•
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
ASSUMPTIONS
Rules
Funding
Change to current process. Requires new credentials.
New credential templates required for driver license,
instruction permit, identification card & restricted
driver permit (photo & paper credentials).
Modifications required:
Verification at Source:
Enabling your system to electronically verify
documentation with:
•
2. SAVE
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Format changes to indicate “temporary”
on the credential
•
•
•
System programming change
Testing
Funding
Change to current process. Requires significant
system programming change.
1. SSOLV
3. DEERS (DOD)
•
•
•
•
•
•
•
•
•
•
Programming changes to verify SSN’s for
duplicate, photo update and endorsement
applicants via Social Security On-Line
Verification (SSOLV)
E Government Web applications for
duplicate and reinstated driver licenses
Policy memo
Customer service representative training
Capturing photograph of individual who
may be denied a license
Legislation
Rules
Training
Set standards
Funding
New verification transactions will be routed through
AAMVA similar to SSOLV and HAVV.
•
•
•
That national networks are functioning
DRIVerS (National network system currently does
not exist)
Vital Statistics (National network system currently
does not exist). May be others that need to be
established
REAL ID ACT REQUIREMENT
Developing access capability to SAVE system
IMPACT
Change in current process. Requires significant
system programming change.
Modifications required:
• Develop functionality to interface with
Homeland Security’s SAVE program in
both real-time and batch modes.
• Reporting
• New policies
• Training
•
•
•
•
Introduce equipment into system to capture digital
images of identity source documents so that images can
be retained in electronic storage in a transferable format
Programming changes to send all duplicates,
photo updates and endorsements to SSOLV
Legislation
Rules
Funding
Requires the purchase and placement of additional
equipment in each MVD field office.
Requires scanner equipment to be purchased for each
field office.
Software, development, and storage are costs
associated with imaging and storing required
documentation.
Create retention schedule.
Requires policy change.
Requires training.
Requires new office facilities.
Requires office remodel.
ASSUMPTIONS
That Homeland Security’s automated system known as
SAVE (Systematic Alien Verification for Entitlements) will
be functioning.
AAMVA will work with the states to establish a national
standard for legal presence verifications.
INS will make upgrades to their systems to ensure data
integrity.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Requires funding.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Change in current process. Creates significant
impact to record storage capacity and archival
retention.
Requires deployment of technology to capture digital
images of identity source documents so that images
can be retained in electronic storage/transferable
format.
Requires seven-year retention of paper copies of
source documents; ten years of imaged documents.
Requires retention schedule.
Requires training.
Requires policy change.
Requires funding.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Change in current process. Increases customer
wait/visit time.
Requires photo taken of all driver license and
identification card applicants.
Requires increase to Central Image Server capacity
Increases costs for equipment and supplies.
Requires funding.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Change to current process. Modifies screening
process and impedes e-government.
AAMVA will work with the states to establish national
standards
Requires new process to screen applicants.
Social Security Administration will modify their match
criteria to require an exact match.
Requires funding.
In the event that a social security account number is
already registered to or associated with another person to
Change to current process. Increases transaction time
Social Security Administration will strengthen match
REAL ID ACT REQUIREMENT
IMPACT
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
and customer wait/visit time.
Check other states if a person already was issued a DL in
another state
Increased incoming and outgoing data traffic.
ASSUMPTIONS
criteria to require an exact match.
Requires states to resolve discrepancy involving
already registered/associated SSNs and take
appropriate action.
DRIVerS will accommodate the checking of States of
Records; or
CDLIS State to State Status or Driver History
Request transactions will suffice.
Ensure physical security of locations where DL/ID cards
are produced
Process in place. Increases the quantity of secured
areas.
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security clearance
requirements
Change to current process. Increases the number of
security background checks conducted.
Requires all persons authorized to
manufacture/produce DL/ID cards be subjected to
appropriate security clearance requirements.
Criminal history checks would be required on 300
employees including new positions, trainers, records
staff, and Information Technology staff.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Process in place. Established Fraudulent Document
Recognition Training Program in 2004.
Fraudulent Document Recognition Training Program will
need to be expanded as requirements change.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Change to current process. Increases customer traffic
flow and customer wait/visit time in all field offices.
Arizona issues an “extended” driver license that does
not expire until age 65.
Limit the period of a driver license to a period that does not
exceed 8 years.
Modifications required:
• Programming changes to driver license and
ID card initial application program
REAL ID ACT REQUIREMENT
IMPACT
•
•
•
•
•
•
•
•
•
Alternative document design if it does not meet federal
standard
ASSUMPTIONS
Development of a new renewal notification
batch program
Development of a new on-line
(ServiceArizona) application
Modifications to existing on-line
(ServiceArizona) applications
Policy
Training
Legislation
Rule
Public Awareness
Funding
Change to current process. Prohibits access to
certain federal facilities including boarding federally
regulated commercial aircraft.
Prohibits federal agencies from accepting state issued
DL/ID cards for official purposes.
Requires credential to be of unique design/color to
alert federal agency/law enforcement that they may
not be accepted for official purposes.
Legal Presence Requirement
Process in place. Arizona law requires that all
applicants submit proof of authorized presence.
Provide electronic access to all other states to
information contained in the motor vehicle database of
the state
Change to current process.
Maintain a state motor vehicle database that contains at a
minimum:
Process in place.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including
motor vehicle violations, suspensions and
points on licenses
Requires funding.
AAMVA will provide or facilitate electronic access to other
states databases.
Arizona maintains a motor vehicle database that contains all
data field printed on the driver license/identification card
including motor vehicle driver’s histories, motor vehicle
violations, suspensions and point on licenses.
REAL ID ACT REQUIREMENT
Optional
IMPACT
ASSUMPTIONS
Not good public policy.
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Will states have the ability to stagger 8-year credential renewal cycle?
Will states receive the necessary funding from federal sources?
How will the Driver License Agreement (DLA) fit into the scheme of the federal legislation?
What happens if a state does not implement on time?
Will AAMVA provide an implementation guide to the states?
Will AAMVA's DRIVerS system be operational before this provision is implemented?
Will the existing compacts-driver license and nonresident violator compact be repealed?
How soon will states receive rules relevant to the act?
What role will the Department of Homeland Security have in the process?
IF AAMVA is not able to implement DRIVerS by the legislative effective date will congress consider extending the date?
If DRIVerS will not be available and the implementation date is non-negotiable, will AAMVA have a contingency plan to modify existing
CDLIS and PDPS transactions to accommodate the verification requirements?
.
ARKANSAS
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System (in Record, on Document)
Have following data elements/features on the document:
28. Full Legal Name
1. Will have to open field-presently first and middle initial.
29. Person’s Date of Birth
2. Date of Birth is on face of license-would need century.
30. Person’s Gender
3. Already in compliance.
31. Person’s DL or ID Card Number
4. Already in compliance.
32. Digital Photograph of Person (and retention)
5. Already in compliance.
33. Person’s Address of Principle Residence
6. Already on record.
34. Person’s Signature
7. Already in compliance.
35. Physical Security Features to prevent tampering, counterfeiting or
duplication
8. Already in compliance.
9. Yes.
36. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to expiration of DL/ID card
(or issuance for no more than 1 year)
Would have to implement.
Amending card design to show/indicate that it is a temporary document with a
“different than usual” expiration date
Verification at Source:
Enabling your system to electronically verify documentation with:
1. SSOLV
1. Because of state legislation, will implement 1-31-06.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
2. SAVE
2. Because of state legislation, will implement 1-31-06.
3. DEERS (DOD)
3.
4. Other jurisdiction (DL/ID card)
4. Task 8.
5. Birth certificate
5. Have no way to verify birth certificate.
6. Other…i.e. third party vendors
6. Presently not used.
Developing access capability to SAVE system
Would require internet connection to revenue sites over the
state for over-the-counter issuance.
Introduce equipment into system to capture digital images of identity source
documents so that images can be retained in electronic storage in a transferable
format
Will require new driver license system to capture document
and retain to driver license record.
Retain paper copies of source documents for a minimum of 7 years or images of
source documents presented for a minimum of 10 years
Presently don’t have a system that would attach to record,
documents will have to be copied at office site and mailed in
to main office to be scanned and barcoded.
Subject each person applying for a driver’s license or identification card to
mandatory facial image capture
Presently persons because of religious beliefs are not required
to have photo made.
Establish an effective procedure to confirm or verify a renewing applicant’s
information
Would require new process for verification of documents.
In the event that a social security account number is already registered to or
associated with another person to which any state has issued a DL/ID card, the state
shall resolve the discrepancy and take appropriate action
At present we have completed 75 percent of batch process
with SSA. We had a 5 percent error rate. We are still
working through process on how to handle errors.
Check other states if a person already was issued a DL in another state
In the process of migrating off a SNA connection to frame
relay to participate in Task 8 Digital Image Exchange Pilot
Project.
Ensure physical security of locations where DL/ID cards are produced
Issue license over the counter in a secure location.
Subject all person’s authorized to manufacture or produce DL/ID cards to
appropriate security clearance requirements
Presently we have not done background checks on employees
– looking into cost.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Establish fraudulent document recognition training programs for appropriate
employees engaged in the issuance of DL/ID cards
Have conducted an 8-hour training course for some revenue
employees, need an on-going training for new employees.
Limit period of validity of DL/ID cards that are not temporary to a period not
exceeding 8 years
Presently Arkansas license are only valid for a four-year
period.
Alternative document design if it does not meet federal standard
Presently delaying RFP until rule making is completed on
Real ID.
Legal Presence Requirement
Presently have this is a State requirement.
Provide electronic access to all other states to information contained in the motor
vehicle database of the state
Would require system change, which could be a costly price.
Maintain a state motor vehicle database that contains at a minimum:
Current state issued driver license has AAMVA standard – 2D barcode and magstrip.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor vehicle violations,
suspensions and points on licenses
At the present time the state history screen includes MV
violations, suspensions and points on license.
Optional
Development and issuance of a certificate of driving – not for federal identification
purposes – for those who cannot prove lawful presence.
Do not plan on issuing license to anyone who can’t prove
legal presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
One of many concerns is if there is going to be any federal funds available for system changes. How are we
going to verify multi birth records? How can we verify resident’s address? What will the licensee have to
bring with them to be able to verify identity? Our state is not a central issue process; we issue licenses over
the counter. We have a general question, that is, if we go ahead and implement some changes, would that
prevent us from receiving federal funds?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
ASSUMPTIONS
CALIFORNIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document).
IMPACT
California already uses the name on
official documentation (e.g., birth
certificate, court name change,
marriage certificate) as defined in
California Regulations for True Full
Name.
ASSUMPTIONS
The requirements for true full name will match our current regulations,
and the requirements for the length of the name(s) are not specified by
regulation.
Major, if minimum name field
requirements are established. (e.g., 125
character name field as required by the
DLA).
Have following data elements/features on the
document:
37. Full Legal Name
38. Person’s Date of Birth
39. Person’s Gender
40. Person’s DL or ID Card Number
41. Digital Photograph of Person (and
retention)
42. Person’s Address of Principle Residence
43. Person’s Signature
44. Physical Security Features to prevent
tampering, counterfeiting or duplication
Potentially minimal, as DL/ID card
currently contains all items.
If required by regulation to verify
address through presentation of
documents during the application
process (e.g., Utility bill), there will be
a personnel impact.
If the requirement necessitates
verification of the address by a third
party system there will be a need for
California Regulations and increased
costs.
Assumption is that security features and machine-readable
requirements will be similar to existing feature technology.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
45. Common Machine Readable Technology
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for
no more than 1 year).
Costs for personnel and IT
programming changes (for renewal
applicants).
California previously tied the expiration date of the DL/ID card to the expiration
date on the legal presence document for original applications only. Stopped this
process in 1999. Will re-implement for original applicants in August 2005.
Renewals will require changes to California Statute.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date.
Minimal.
Have a process in place that allows us to issue a DL/ID card (“temporary
document”) for a period less than the regular card term. There will be IT costs
associated with applying this process and programming for renewal applicants
(see above).
Verification at Source:
Major Impact (costs, state law) to
electronically verify information with
DEERS, Birth Certificate, and third
party vendors.
Currently verify electronically with SSOLV, SAVE and use CDLIS/PDPS.
Developing access capability to SAVE system.
None for current process and system
design (that now applies to original
applicants), but there are personnel and
IT costs associated with including
renewal applicants.
Assume that there will be no changes to the system currently used.
Introduce equipment into system to capture digital
images of identity source documents so that
images can be retained in electronic storage in a
transferable format.
Major Impact.
We do not capture and store this information today. Requires new equipment,
possible office layout modifications, major programming, and database
development.
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
Assumes that each state will have a centralized database and/or process for birth
document verification, and that DEERS will partner in development with
automated verification. Without such a system, the cost to verify
documentation is substantial.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other, i.e., third party vendors
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Retain paper copies of source documents for a
minimum of 7 years or images of source
documents presented for a minimum of 10 years.
Major Impact.
We do not collect this information today. Requires database storage capabilities
for at least 25 million records.
Subject each person applying for a driver’s license
or identification card to mandatory facial image
capture.
No impact.
Assumes our current process is acceptable.
Establish an effective procedure to confirm or
verify a renewing applicant’s information.
Unable to determine. There will be a
major impact if the regulation for the
verification of identity for renewals
establishes a document-based
requirement.
Currently, the department processes DL renewals by mail or by internet for
customers that have the form we mailed to them. The internet process requires
the use of the last four of the SSN and the use of a “PIN Code” that appears on
the renewal notice mailed to the applicant. Renewals by Mail are mailed to the
address provided to us when the card fee is paid. All other renewals must
appear in person.
Customers requesting ID cards must appear in person to renew.
In the event that a social security account number
is already registered to or associated with another
person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take
appropriate action.
To be determined.
California has already been verifying SSNs with SSA. Entire database
should be cleansed by the end of 2005 for any cardholders that have a
valid DL/ID card. After 2005, if multiples exist on our database for active
cardholders, SSA would have to have verified the duplication of the
number for both parties. California DMV does not issue a card to any
applicant unless the information provided matches SSAs records. SSA
acknowledges that there are a few cases where two applicants may
legally have the same SSN.
Check other states if a person already was issued a
DL in another state.
To be determined.
Assuming AAMVAnet makes programming changes to allow for this
information to be passed through CDLIS/PDPS, then the impact would be
minor. If the States had to do this without a centralized system, costs would be
major.
Ensure physical security of locations where DL/ID
cards are produced.
Probable minimal impact.
This assumes that the current process our vendor uses for physical security of
the manufacturing plant /materials and background checks meets any
regulations promulgated.
Subject all persons’ authorized to manufacture or
produce DL/ID cards to appropriate security
Unable to determine. It is unclear what
“producing cards” or “appropriate
If the goal is to ensure that our vendor employees and the states’ field office
technicians have had fingerprint checks prior to employment, we believe we are
compliant. A full “security clearance” regulation could far exceed fingerprint
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
clearance requirements.
security clearance” mean.
checks and increase costs.
Establish fraudulent document recognition training
programs for appropriate employees engaged in
the issuance of DL/ID cards.
Minimal Impact.
We already have fraud document training. Assume that we would just be
required to update our training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years.
Major impact for identification cards.
This requires that we change state law for the term on our Senior ID cards
(currently 10 years). This would require that these applicants would appear
more often in our field offices.
Alternative document design if it does not meet
federal standard.
Possibly minimal impact.
Requires programming for our database, along with programming and physical
card changes with our card vendor. Assume Feds do not specify document
design.
Legal Presence Requirement.
Possibly minimal impact.
California has required legal presence since 1994. Assume that the documents
we currently accept as proof of legal presence are the documents; we would be
required to accept under regulation.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state.
Unknown.
Maintain a state motor vehicle database that contains at a
minimum:
No impact.
California currently allows other states information as
specified in state law (medical info/addresses are
confidential). Assume that if this is coordinated through
AAMVAnet, overall impact will be less.
Assumes that promulgated regulations contain the same
types of information we retain today.
All data fields printed on DL/ID cards.
Motor vehicle drivers’ histories, including motor
vehicle violations, suspensions and points on
licenses.
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
Major impact.
California currently has pending legislation concerning
this topic. Governor has stated that he would not sign
this into law at this point. Awaiting federal regulations
prove lawful presence.
on HR 1268.
CALIFORNIA
Jurisdiction Impact Analysis Real ID Act
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
•
•
•
•
•
•
If California has already verified all its valid cardholder records with the Social Security Administration and through the use of
SAVE, will we be required to re-verify the birth document? (Poses the question… if we match two different federal databases, why
should we be required to re-verify birth documents unless SSA is required to re-verify?)
Is the requirement day forward? If we issued a card in 2007 that expires in 2011, will the Federal Government still accept it until the
renewal date or will we be required to process all cardholders prior to 5/2008?
What is truly meant by “address verification?”
Will existing cardholders be required to provide an identity/source document to re-verify their identity at the time of every renewal?
How will we verify all identity/source documents when no national system currently exists to support this type of effort?
What will be requirements to allow for a renewal by mail or renewal by internet program?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
COLORADO
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
Have following data elements/features on the
document:
IMPACT
NO IMPACT – Colorado currently
captures, and stores in the database, the
full legal name and any other names
shown on all documents presented for
identification.
1.
NO IMPACT – Currently in
compliance
2.
NO IMPACT – Currently in
compliance
3.
NO IMPACT – Currently in
compliance
4.
NO IMPACT – Currently in
compliance
5.
NO IMPACT – Currently in
compliance
53. Physical Security Features to prevent
tampering, counterfeiting or duplication
6.
NO IMPACT – Currently in
compliance
54. Common Machine Readable Technology:
7.
46. Full Legal Name
47. Person’s Date of Birth
48. Person’s Gender
49. Person’s DL or ID Card Number
50. Digital Photograph of Person (and
retention)
51. Person’s Address of Principle Residence
ASSUMPTIONS
52. Person’s Signature
NO IMPACT – Currently in
compliance
8. NO IMPACT – Currently in
compliance
9.
POTENTIAL IMPACT – The
current 2D-barcode does not
contain
the
photograph
or
9. If the machine-readable technology (barcode) requirement means
to include ALL elements/features from the front of the card, there will
be a fiscal impact for the modification of the barcode and for a redesign
of the back of the cards to create room for the larger barcode.
Clarification required.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
signature of the cardholder. Real
estate on the back of the card is at
a premium.
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for no
more than 1 year)
NO IMPACT – Currently in
compliance
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
POTENTIAL IMPACT –
modification required to ID card
processing map in DLS (IT) and to
the physical ID card to allow
variable text on the back indicating
TEMPORARY ONLY.
Fiscal impact from vendor to modify the back of the ID card and legislative
impact to allow the text TEMPORARY ONLY on the ID card.
Verification at Source:
Enabling your system to electronically verify
documentation with:
1.
NO IMPACT – Currently in
compliance
2. SAVE
2.
Final stages of implementation
3. DEERS (DOD)
3.
Not currently under consideration.
4. Other jurisdiction (DL/ID card)
4.
NO IMPACT – Currently in
compliance
5.
Currently, verification consists of
contacting the issuing agency by
telephone
to
verify
any
questionable documents. Items are
also faxed to the issuing agency
for verification.
6.
N/A
1. SSOLV
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
NO IMPACT – Currently in process.
Introduce equipment into system to capture digital
POTENTIAL IMPACT – cost of
5. Based on new cost-per-query information from NAPHSIS, regarding
the Electronic Verification of Vital Events (EVVE) system, Colorado will
need to revisit participation. Latest estimates are $1.28 per query
(down from $5.00 per query), based on the number of queries and
number of states participating.
To comply with the requirement of this item, the cost of scanners, and
REAL ID ACT REQUIREMENT
IMPACT
images of identity source documents so that images
can be retained in electronic storage in a transferable
format
scanners, office procedure changes,
programming modifications (vendor
and IT). Impact would also be on
customer wait times.
Retain paper copies of source documents for a
minimum of 7 years or images of source documents
presented for a minimum of 10 years
POTENTIAL IMPACT – See above
item. Currently, only documents used
in exception processing are copied and
submitted for microfilming.
Subject each person applying for a driver’s license
or identification card to mandatory facial image
capture
POTENTIAL IMPACT – Only firsttime applicants are subjected to the
facial recognition (FR) process. Impact
would be on IT for programming and,
possibly, modifications by the vendor.
The existing staff of the Investigations
Section is not equipped to handle the
expanded workload presented by this
requirement.
Establish an effective procedure to confirm or verify a renewing
applicant’s information
ASSUMPTIONS
potential vendor programming costs, have been proposed as a decision item
for section funding.
The impact response is based on the assumption that the requirement is
referring to facial recognition processing and not the “valid without photo”
document, currently issued by some states, for religious reasons. Clarification
is required.
POTENTIAL IMPACT – Currently, the image,
fingerprint and SSN are confirmed for renewal
applicants presenting their license/ID card.
However, because customers must renew if they
have lost, had stolen or mutilated their Colorado
license or if they are changing their name, in
addition to the verification of their image,
fingerprint and SSN, they must also present
identification documents to re-establish their
identity. Impact would be on office procedures,
customer wait time and, possibly, cost to inform
Because this would be a drastic change in
established procedures, some type of public service
announcement, to renewal customers particularly,
would be in order.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
the public of the new renewal procedures.
In the event that a social security account number is already
registered to or associated with another person to which any state
has issued a DL/ID card, the state shall resolve the discrepancy
and take appropriate action
NO IMPACT – Currently in compliance
Check other states if a person already was issued a DL in another
state
POTENTIAL IMPACT – A system for this type of
verification is not currently on-line.
If the
customer has a license to surrender, currently only
a state-to-state check is possible. Only restraint
actions and/or commercial driver license
information shows on the existing national system
Ensure physical security of locations where DL/ID cards are
produced
NO IMPACT – Currently in compliance
Subject all person’s authorized to manufacture or produce DL/ID
cards to appropriate security clearance requirements
POTENTIAL IMPACT – Applicants considered
for employment are subjected to a criminal
background check, only. Fiscal impact is involved
with a security clearance.
Establish fraudulent document recognition training programs for
appropriate employees engaged in the issuance of DL/ID cards
NO IMPACT – Currently in compliance. Colorado
uses AAMVA’s FDR (Fraudulent Document
Recognition) training program.
Limit period of validity of DL/ID cards that are not temporary to a
period not exceeding 8 years
NO IMPACT – Currently in compliance
Alternative document design if it does not meet federal standard
N/A
Legal Presence Requirement
NO IMPACT – Currently in compliance
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
POTENTIAL IMPACT – Colorado is in
compliance with the existing requirements of
Should a system go online that would accommodate
this requirement, such as the AAMVA-proposed
DriverS, Colorado would participate.
The assumption is being made that the security
clearance is mandatory not only for driver license
employees but also for vendor employees.
Clarification is required.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
posting restraint actions, per the Compact Law, and
CDL information per the Federal Safety Act,
however, we do not allow direct access, by other
states, to our database. Modifications could have a
fiscal impact and vendor impact if access is to
include photos and signatures.
Maintain a state motor vehicle database that contains at a
minimum:
NO IMPACT – Currently in compliance
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor vehicle
violations, suspensions and points on licenses
Optional
Development and issuance of a certificate of driving – not for
federal identification purposes – for those who cannot prove
lawful presence.
NO IMPACT – State law does not allow issuance
to applicants who cannot prove lawful presence.
COLORADO
Jurisdiction Impact Analysis Real ID Act
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Most of Colorado’s questions center on clarification of the listed requirements:
1. Section 202 (a)(9) Features on the document and in the machine-readable technology – as stated, the requirement seems to indicate that all features on the front
of the card should be in the machine-readable technology. Please clarify whether this includes the signature and the photograph.
2.
Section 202 (d)(3) Mandatory facial image capture – does this requirement refer to the facial recognition process or does this requirement simply mean that there
will no longer be exemptions for a non-photo document?
3. Section 202 (d)(4) Confirm/verify renewal applicant’s information – does this requirement refer to confirming the data elements on the card/database or requiring
presentation of all documents listed in Section 202 (c) (1) prior to issuance?
4. Section 202 (d)(8) Appropriate security clearance for all persons authorised to manufacture or produce DL/ID cards – will this requirement include vendor
employees as well as driver license employees?
5. Section 204 (a) states that grants may be available to assist States in conforming to the minimum standards. Should a State find it necessary to apply, what is the
application process?
6. What will happen to Internet and renew-by-mail processes because of the Act?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
CONNECTICUT
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Yes. (current system limited to 35 characters); Do not
have current “name history” capability.
Regulations should define “name history.” Also, should
clarify “legal” name (Connecticut is a “common law”
state).
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
55. Full Legal Name
56. Person’s Date of Birth
57. Person’s Gender
58. Person’s DL or ID Card Number
59. Digital Photograph of Person (and retention)
60. Person’s Address of Principle Residence
61. Person’s Signature
62. Physical Security Features to prevent tampering,
counterfeiting or duplication
Yes
Yes
Yes (9 digits)
Yes
Yes (must provide residence address)
Yes
7 security features
2-D Bar code
63. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Need enabling legislation
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Need enabling legislation
Verification at Source:
Connecticut now uses FLLQ (NCIC)
Enabling your system to electronically verify
documentation with:
Verification of Birth Certificates must be addressed
somehow in the regulations.
REAL ID ACT REQUIREMENT
IMPACT
1. SSOLV
Yes
2. SAVE
Do not currently use
3. DEERS (DOD)
Do not use
4. Other jurisdiction (DL/ID card)
Acquiring Proofing Workstations for authenticating
DL/ID cards
5. Birth certificate
6. Other…i.e. third party vendors
No
Acxiom Address Verification System
Developing access capability to SAVE system
Will commence work on MOU
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
No. CT DMV currently does not have such a system.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
CTDMV does not currently have optical imaging
capability Yes
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Yes
Establish an effective procedure to confirm or verify a
renewing applicant’s information
May have impact on privatized renewal stations
(AAA)No- No Driver’s system
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
No system available to access duplicate SS# in other
states. CTDMV can only verify duplicate SS# for
Connecticut residents.
Check other states if a person already was issued a DL in
another state
No- No DriverS system
Ensure physical security of locations where DL/ID cards
are produced
Yes
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Do background checks.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Use AAMVA system
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Ok CT CDL = 4 years; Non-CDL= 6 years
Alternative document design if it does not meet federal
standard
Intend to meet federal criteria
Legal Presence Requirement
Yes
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Current information systems limitations
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
ASSUMPTIONS
Regulations must define “security clearance”
Yes, currently resides in flat files
Yes, currently resides in flat files
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Not applicable
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Major issues for Connecticut involve the need for information systems and associated costs. Most legal
requirements are already met or will be met.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
In progress, will forward when completed.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state.
Unknown.
Maintain a state motor vehicle database that contains at a
minimum:
No impact.
California currently allows other states information as
specified in state law (medical info/addresses are
confidential). Assume that if this is coordinated through
AAMVAnet, overall impact will be less.
Assumes that promulgated regulations contain the same
types of information we retain today.
All data fields printed on DL/ID cards.
Motor vehicle drivers’ histories, including motor
vehicle violations, suspensions and points on
licenses.
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Major impact.
California currently has pending legislation concerning
this topic. Governor has stated that he would not sign
this into law at this point. Awaiting federal regulations
on HR 1268.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
•
•
•
If California has already verified all its valid cardholder records with the Social Security Administration and through the use of
SAVE, will we be required to re-verify the birth document? (Poses the question… if we match two different federal databases, why
should we be required to re-verify birth documents unless SSA is required to re-verify?)
Is the requirement day forward? If we issued a card in 2007 that expires in 2011, will the Federal Government still accept it until the
renewal date or will we be required to process all cardholders prior to 5/2008?
What is truly meant by “address verification?”
•
•
•
Will existing cardholders be required to provide an identity/source document to re-verify their identity at the time of every renewal?
How will we verify all identity/source documents when no national system currently exists to support this type of effort?
What will be requirements to allow for a renewal by mail or renewal by internet program?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
DELAWARE
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT
REQUIREMENT
Introduce Full Legal Name into
Driver Licensing System (in
Record, on Document)
IMPACT
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
ID File:
ID File: approximately 4 programs
Modify ID programs to incorporate the new name standards.
Modify to incorporate XML tag for name element
License/ID Card Print:
1 program interface
Application Print:
4 print programs
External communication:
United Network Interface – approximately 100 program,
approximately 40 transaction types
ASSOCIATED
IMPACT COST
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
Associated Cost
2 weeks @ $75.00 = $5,625.00
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Reporting:
Modify approximately 300 programs
Document Imaging:
5 programs indexes to be increased
Website Modifications:
20 modules to identify the name element
Associated Cost:
3 months @$75.00 hr =
$33,750.00
Associated Cost:
3 months @ $30.00 hr =
ASSUMPTIONS
DMV will be responsible for
providing access to Safety and
Homeland Security, Law
Enforcement and Criminal
Justice.
REAL ID ACT
REQUIREMENT
IMPACT
ASSOCIATED
IMPACT COST
ASSUMPTIONS
$13,500.00
Restrictions to Issuance:
Introduce Full Legal Name into
Driver Licensing System (in
Record, on Document) –
CONTINUED
Have following data
elements/features on the
document:
64. Full Legal Name
65. Person’s Date of Birth
66. Person’s Gender
67. Person’s DL or ID
Card Number
68. Digital Photograph of
Person (and retention)
69. Person’s Address of
Principle Residence
70. Person’s Signature
71. Physical Security
Features to prevent
tampering,
counterfeiting or
duplication
72. Common Machine
Readable Technology:
Modify 10 programs to incorporate a restriction to limit the
period of temporary stay
Modify Driver’s License and Identification cards to
incorporate Full Name requirements.
Associated Cost:
1 month @ $30.00 hr =
$4,500.00
Associated Cost:
1 month @ $75.00 = $11,250.00
Total System Modifications:
$217,687.50
Associated Cost:
1 month @ $75.00 hr =
$11,250.00
Associated Cost for AAMVA
Logo (DL Vendor Estimate):
610,406 @ $1.00 per license
= $610,406.00
Delaware will be required to
completely replace driver’s
license and identification card
for all citizens prior to
September 11, 2009. Instead of
having the ability to replace the
DL/ID at the time of renewal.
Delaware will be required to
include the new AAMVA
(Jurisdictional) logo.
o
New Logo – cost
unknown - impact cost
based on limited
information.
REAL ID ACT
REQUIREMENT
Introduce temporary DL/ID
cards and tying end of stay to
expiration of DL/ID card (or
issuance for no more than 1
year)
IMPACT
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
License/ID Card Print:
1 program interface
Modify license/ID programs to establish limits on
expiration date to ensure consistency with
documentation.
Modify inquiry to identify those licenses/ID on a limited
term bases. Modify DELJIS/State Police.
Establish reporting.
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
Associated Cost:
2 weeks @ $75.00 = $5,625.00
Associated cost for issuing new
card:
$6,000.00
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
Associated Cost:
3 months @ $30.00 hr =
$13,500.00
Verification at Source:
Enabling your system to
electronically verify
documentation with:
1. SSOLV
ASSUMPTIONS
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
ID File:
ID File: approximately 4 programs
Modify to incorporate XML tag for name element
Amending card design to
show/indicate that it is a
temporary document with a
“different than usual”
expiration date
ASSOCIATED
IMPACT COST
DEERS Impact:
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
ID File:
ID File: approximately 4 programs
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
Delaware will have to
specifically identify these types
of license, modify legislation to
ensure consistency with
expiration date of
Visa/natural/etc., other than the
DOB (limited license/ID).
Delaware will be required to
create new cart design for
limited term.
SSOLV implemented, but will
have to incorporate mis-matches
within denial system.
Delaware will utilize PROOFS
application to validate
documents being presented as
proof of citizenship.
REAL ID ACT
REQUIREMENT
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID
card)
5. Birth certificate
IMPACT
Modify to incorporate XML tag for name element
License/ID Card Print:
1 program interface
Hire Additional Staff
1 computer tech
6. Other…i.e. third party
vendors
Developing access capability to
SAVE system
ASSOCIATED
IMPACT COST
SAVE Impact:
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
ID File:
ID File: approximately 4 programs
Modify to incorporate XML tag for name element
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
ASSUMPTIONS
No cost impact estimate
provided for DEERS/other
jurisdictions because they have
not been implemented.
Associated Cost
2 weeks @ $75.00 = $5,625.00
Associated Cost:
$68,393.00
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
SAVE – will be incorporated
with Delaware’s license/ID
denial.
Delaware will utilize PROOFS
application to validate
documents being presented as
proof of citizenship.
License/ID Card Print:
1 program interface
Hire Additional Staff
1 computer tech
Introduce equipment into
system to capture digital
images of identity source
documents so that images can
be retained in electronic
storage in a transferable format
Equipment/Training/Installation/Maintenance Agreement
Hire Additional Staff
4 senior techs
Associated Cost
2 weeks @ $75.00 = $5,625.00
Associated Cost:
$68,393.00
Expected Cost
610,406 x $.32 per query =
$195,329.00
Associated Cost:
$450,000.00
Associated Cost:
4 @ $30,000.00 =
$120,000.00
Format stored in AAMVA
standard
REAL ID ACT
REQUIREMENT
IMPACT
ASSOCIATED
IMPACT COST
ASSUMPTIONS
Retain paper copies of source
documents for a minimum of 7
years or images of source
documents presented for a
minimum of 10 years
No impact to Delaware – will
utilize existing document
imaging application to store
documents for a period of 10years.
Subject each person applying
for a driver’s license or
identification card to
mandatory facial image capture
No impact to Delaware – DDL
application utilizing AAMVA
standards and capturing photo
on all transaction.
Establish an effective
procedure to confirm or verify
a renewing applicant’s
information
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
ID File:
ID File: approximately 4 programs
Modify to incorporate XML tag for name element
Associated Cost:
3 months@ $75.00 hr =
$33,750.00
License/ID Card Print:
1 program interface
DMV will be responsible for
providing access to Safety and
Homeland Security, Law
Enforcement and Criminal
Justice.
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
Associated Cost
2 weeks @ $75.00 = $5,625.00
In the event that a social
security account number is
already registered to or
associated with another person
to which any state has issued a
DL/ID card, the state shall
Driver’s License File:
Modify all inquiry – approximately 4 major interfaces,
approximately 30 programs
Modify to incorporate XML tags for name element
ID File:
Associated Cost:
6 months @ $75.00 hr =
$56,250.00
Associated Cost:
DMV will be required to
coordinate with Social
Security office on notification,
identify procedures and
provide the ability to deny
when applicant has been
REAL ID ACT
REQUIREMENT
resolve the discrepancy and
take appropriate action
IMPACT
ID File: approximately 4 programs
Modify to incorporate XML tag for name element
Send Applicant Notification
For all confirmation matches must send notification to
applicant regarding known problem to proceed with
correction
ASSOCIATED
IMPACT COST
3 months@ $75.00 hr =
$33,750.00
determined as non-compliant.
Associated Cost:
37.h hrs @ 75.00 = $2,812.50
Associated Cost
Approximately 20,000 error @
$.37 = $7,400.00
Check other states if a person
already was issued a DL in
another state
Ensure physical security of
locations where DL/ID cards
are produced
ASSUMPTIONS
No Impact – Delaware
presently conduct CDLIS and
PDPS search on all applicants.
Examine management procedures and ensure secure supervision.
Hire additional staff:
Associated Cost:
4 @ $30,000.00 =
$120,000.00
4 Senior Techs (2 bi-lingual)
Subject all person’s authorized
to manufacture or produce
DL/ID cards to appropriate
security clearance requirements
Conduct Background checks on all DMV personnel.
Establish fraudulent document
recognition training programs
for appropriate employees
engaged in the issuance of
DL/ID cards
Re-Certification will occur every two-year or depending on
Federal/State Legislation that would impact document validation.
Limit period of validity of
DL/ID cards that are not
temporary to a period not
Associated Cost:
Approximately 400 employees
@ $50.00 = $20,000.00
Associated Cost:
Certification 400 @ $15.20 hr
for 8 hrs = $48,640.00
Re-Certification 400 @ $15.20
for 4 hrs.= $24,320.00
All DMV employees will be
required to complete a
background check
Delaware will utilize existing
Fraudulent Document Training
program. All staff will be
required to either obtain
certification or re-certification.
No impact to Delaware –
Legislation limits license/ID to
5-years.
REAL ID ACT
REQUIREMENT
IMPACT
ASSOCIATED
IMPACT COST
ASSUMPTIONS
exceeding 8 years
Alternative document design if
it does not meet federal
standard
Legal Presence Requirement
Driver’s License File:
Modify various card designs to conform to AAMVA DL/ID
Design Specifications.
Associated Cost:
One-time Cost - $20,000.00
ID File:
Modify various card designs to conform to AAMVA DL/ID
Design Specifications.
Additional Hearings
Associated cost for issuing new
card:
$6,000.00
Associated Cost
2 @ $35,000.00 =
$70,000.00
Hire additional staff:
Pass legislation requiring Legal
Presence.
2 Driver Improvement Officers (1 bi-lingual)
Provide electronic access to all
other states to information
contained in the motor vehicle
database of the state
No impact to Delaware –
CDLIS/PDPS/SSOLV
communications has been
established.
Maintain a state motor vehicle
database that contains at a
minimum:
No impact to Delaware – DMV
has an established database.
All data fields printed
on DL/ID cards
motor vehicle driver’s
histories, including
motor vehicle
violations,
suspensions and
points on licenses
Optional
Development and issuance of a
certificate of driving – not for
federal identification purposes
N/A
REAL ID ACT
REQUIREMENT
– for those who cannot prove
lawful presence.
IMPACT
ASSOCIATED
IMPACT COST
ASSUMPTIONS
DELAWARE
Jurisdiction Impact Analysis Real ID Act
OVERALL COST TOTAL ESTIMATE: $2,871,568.50
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
1. Will jurisdictions have the ability to replace DL/ID’s at the time of renewal? Or will jurisdictions be required to replace all DL/ID
within the 3-year period (September 11, 2009)?
2. Will each jurisdiction be required to obtain certification?
3. Will each jurisdiction be required to establish a pointer record for each restricted license issued?
4. Will non-electronic document verification be acceptable?
5. Will each jurisdiction be required to complete reporting requirements to ensure all DL/ID have been converted to new format? If so,
where will be reporting be required to be submitted?
6. Will each employee be required to receive re-certification on employee background checks? If so, what is the background length of
time valid for?
7. What kind of development time will be required for the SAVE and DEERS program?
a. Will a structure test be required for both SAVE and DEERS?
b. How can we obtain additional information regarding the DEERS program?
8. What will the minimum requirements be regarding physical security?
9. Will funding be available to the states to help implement the Real ID Act?
Delaware Comment: Strongly recommend that TSA work Real ID implementation unilaterally through AAMVA rather than through
each jurisdiction.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
None; except for this survey.
DISTRICT OF COLUMBIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
ASSUMPTIONS
Already compliant
1.
Already Compliant
73. Full Legal Name
2.
Already Compliant
74. Person’s Date of Birth
3.
Already Compliant
75. Person’s Gender
4.
Already Compliant
76. Person’s DL or ID Card Number
5.
Already Compliant
77. Digital Photograph of Person (and retention)
6.
Already Compliant
78. Person’s Address of Principle Residence
7.
Current on document, but will now require
creation of separate field in data base to store
Ballpark cost for data field medication to system
~$100,000
8.
Will need re-design based on specific
standards which are pending. Level of security
will impact whether license should be
produced centrally or locally.
Costs will be a function of specifications
Have following data elements/features on the document:
79. Person’s Signature
80. Physical Security Features to prevent tampering,
counterfeiting or duplication
81. Common Machine Readable Technology:
9. Again, need specifics on standards to identify
impacts and costs
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Currently done, but will require creation of new data
field to track in system
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Depending on other general specifications, may require
separate card type if so est. $50-100,000 system design
changes
Ballpark cost for data field medication to system
~$100,000
REAL ID ACT REQUIREMENT
IMPACT
Verification at Source:
1. Already Compliant
Enabling your system to electronically verify
documentation with:
2. Need specifics re MOU requirements – requires new
system interface
1. SSOLV
2. SAVE
3. DEERS (DOD)
ASSUMPTIONS
Ballpark cost for any system interface ~$500,000
3. Need specifics on requirements– requires new
system interface
Ballpark cost for any system interface ~$500,000
4. Presumed will happen through AAMVAnet/PDPS
Ballpark cost for interface enhancements/medication
$100-300,000
4. Other jurisdiction (DL/ID card)
5. Birth certificate
5.
6. Other…i.e. third party vendors
6.
No idea what will be required. If
incrementally via 3rd party software like
Viisage, etc. will require one-time system costs
and lesser on-going staff costs. If through
completely manual interaction directly with
each jurisdiction, much higher on-going
staffing costs.
One time system costs ~$1.0 million, with on-going
annual additional system maintenance and staffing costs
of ~$500,000.
Fully manually system could require as much 35
additional staff (+30%) at approximately 1.75
million/year
Unknown what this means
Developing access capability to SAVE system
Need to know specifics of MOU/Requirements
Ballpark cost for any system interface ~$500,000
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Will move to a front-end of process image capture at
each work station
Equipment estimate $500,000
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Will integrate images into Driver data-base, for future
storage and retrieval
Programming estimate $500,000
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Will move to a front-end of process image capture at
each work station
Additional cameras for each workstation ~ $150,000
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Need clearer understanding of requirements. Will
presumably have to apply “new applicant” standard on
first renewal following Real ID effective date, then
image capture and storage with driver record should
allow exception processing thereafter
Will require additional staff, processing time for all firstcycle renewals ~750,000 in additional staffing costs
annually for the first five year cycle
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
Requires expansion of internal “Service Integrity” Unit
Est. minimum 5 additional positions for all
resolution/enforcement matters @ ~$350,000 annually
Check other states if a person already was issued a DL in
another state
Hopefully via AAMVANet/PDPS –
expansion/modification
Costs a function of specifics to be determined
Ensure physical security of locations where DL/ID cards
are produced
Will require enhanced inventory control system, facility
modifications, etc. Will need specifics on license
feature requirements to determine if a centralized versus
decentralized issuance.
With enhanced verification and un-likelihood of overthe-counter service, more likely to go centralized with
mail fulfillment. MAJOR CONCERN re effectiveness
and security of any mailing processes – currently
experiencing sever unreliability of US Mail services.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
Will have to address local legislation/union contracts re
mandatory background checks for all employees. Will
need enhanced contract provisions for some service
providers.
Minimum cost of $30,000 for background checks
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Will required updates and enhancements based on
specifics of regulations and requirements. Key need is
access to specimen documents and fraud samples for
hands-on training. Will need computer-based and
classroom based materials
~ $100,000 for curriculum development and materials
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Already Compliant
Alternative document design if it does not meet federal
standard
Need specifics in order to determine
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Legal Presence Requirement
Already have requirement for Social Security Number
which is de facto legal presence standard. Will need
local policy decision re non-ID driver’s license for local
use.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Hopefully via AAMVANet/PDPS
enhancements/modification
Funding a function of specifics
Maintain a state motor vehicle database that contains at a
minimum:
Addition of new data fields (immigration status,
signature at minimum) as described above.
~$600,000 effort for integration and reprogramming
All data fields printed on DL/ID cards
Requires automated linkage to court system on
violations, and update of driver records, point
assignment system
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
To be determined via local policy process
Est. $150,000 to implement separate “license” type
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Need specific regulations ASAP in order to determine real impacts, follow-on questions.
Biggest questions with respect to type, level and extent of validation required for breeder documents, particularly birth
certificates.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
N/A
FLORIDA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
Already in compliance
Have following data elements/features on the document:
82. Full Legal Name
In compliance per name in DHS documents
83. Person’s Date of Birth
Same as above
84. Person’s Gender
Same as above
85. Person’s DL or ID Card Number
Same as above
86. Digital Photograph of Person (and retention)
In compliance
87. Person’s Address of Principal Residence
Would require statute amendment and programming
changes
88. Person’s Signature
89. Physical Security Features to prevent tampering,
counterfeiting or duplication
90. Common Machine Readable Technology:
In compliance
In compliance
In compliance
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Currently 2 year Maximum
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
In compliance with no design difference
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
Application in use
Application in use
Not in use
Application is in use through NLETS
Not in use
Application in use (Auto Track)
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Already in use
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Currently we scan and retain documents
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
No. Scanned images are retained
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Required by statute
Establish an effective procedure to confirm or verify a
renewing applicant’s information
In Standard Operating Procedure
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
In Standard Operating Procedure
Check other states if a person already was issued a DL in
another state
Automated Standard Operating Procedure
Ensure physical security of locations where DL/ID cards
are produced
Security systems in place
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Background checks and fingerprinting in current
application
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Used programs through DHS, AAMVA, and internal
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Currently 6 years maximum
Alternative document design if it does not meet federal
standard
Not applicable
Legal Presence Requirement
Required by statute
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Available through NLETS and NDR
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
In compliance
In compliance
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove
At this time, we have no plans to implement this
alternative
lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
None at this time.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Already submitted through Col. Billy Dickson.
GEORGIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
91. Full Legal Name
92. Person’s Date of Birth
93. Person’s Gender
94. Person’s DL or ID Card Number
95. Digital Photograph of Person (and retention)
96. Person’s Address of Principle Residence
97. Person’s Signature
98. Physical Security Features to prevent tampering,
counterfeiting or duplication
99. Common Machine Readable Technology:
1. Georgia law was amended 07/01/2005 to require
full legal name. Our current system only has space
for 26 characters. We will be releasing an RFP that
requires the vendor to provide space for 125
characters.
2. Included on current document.
3. Included on current document.
4. Included on current document.
5. Included on current document.
6. Current operation allows for use of mailing
address. Traffic tickets will be written using the
residence address, but the licensee may not
receive mail at that location, so court notices
could be missed.
7. Included on current document.
8. Included on current document, and additional
features will be added via new RFP.
9. This feature was already contemplated as a
requirement for our new RFP.
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Georgia law will contain an identical provision
effective July 1, 2006. Programming has been
completed.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
Some similar messages are already required by
Georgia law. However, technology may not
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
expiration date
allow for the inclusion of multiple messages.
Verification at Source:
1. Georgia already uses SSOLV.
Enabling your system to electronically verify
documentation with:
2. This will require substantial programming.
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
3. This will require substantial programming.
4. Some programming exists for this check (CDLIS,
PDPS, etc.) Additional programming will be
required.
5. This will require substantial programming by
Georgia and by the vital records units in every state.
Unfunded mandate.
6. The verification requirement will reduce the
number of forms of proof of residency states will
accept. Children will be unable to prove their
residency. Senior citizens may be unable to prove
their residency.
Developing access capability to SAVE system
This will require substantial programming.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Georgia plans to include scanning of source
documents in its new RFP. If we are required to scan
the documents and images of individuals who are not
given licenses or ID cards, this will have a
tremendous fiscal impact and affect the amount of
time citizens spend in license facilities.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Significant cost. See supra.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
This is bad customer service for applicants who
are denied a license because they spend extra
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
time in the center. Also, this requirement will
delay customers who are eligible for a license
who are waiting in line behind the customer who
gets nothing.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
If verification is required at each renewal, automated
renewal programs will cease. Delay to verify
documents may leave drivers unable to drive.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve
the discrepancy and take appropriate action
The states have no ability to resolve a problem that
exists at the Social Security Administration.
Check other states if a person already was issued a DL in
another state
Insufficient existing connectivity, and no funding to
create such connectivity. Delay to customers.
Ensure physical security of locations where DL/ID cards
are produced
Some measures already in place; no funding to
expand.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Already in place.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Already in place.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Georgia law allows licensees to get a 5-year or 10year license. Veterans are eligible for a license that
is good to age 65. Limiting licenses to 8 years will
increase the traffic in centers.
Alternative document design if it does not meet federal
standard
Georgia has not reached a conclusion on this item.
Legal Presence Requirement
Already in place.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Requires additional programming for all states with
no additional funding or resources.
Maintain a state motor vehicle database that contains at a
minimum:
Already in place.
ASSUMPTIONS
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
What will be sufficient to satisfy the verification requirement? Could the states accept a certified copy of a document?
Will verification be required at each renewal?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Please see attached.
GEORGIA
Jurisdiction Impact Analysis Real ID Act
CHANGES REQUIRED BY THE REAL ID ACT
I.
Card Features-Each card must contain the following:
REAL ID Act Requirements
Full legal name on driver’s license and ID card
Address of principle residence
Physical security features
Common machine-readable technology
Mandatory facial image capture of all applicants
Expiration date of DL or ID card cannot exceed 8 years
II.
Current Procedure
DMVS uses the full legal name, but the current system only allows 26
characters on the card
DMVS allows licensees to use a mailing address
DMVS currently uses overt and covert security features on licenses and
ID cards
DMVS currently uses an encrypted 2-D barcode
DMVS currently takes digital photographs of each person to whom a
DL or ID is issued
Currently, all DL’s and ID cards expire after 4 years; will expand to 510 years on 07/01/05
Issuance Standards-Applicants must provide the following in order to receive a license or
identification card.
REAL ID Act Requirements
Current Procedure
Photo-ID of applicant or non-photo-ID containing full legal name and
DMVS regulations allows applicants to use original birth certificate,
date of birth required
certificate of birth registration, certified copy of birth certificate,
certified copy of court records (adoption, name change, etc.), certified
naturalization documentation, Immigration ID Card, valid passport, or
military identification card issued by the United States armed forces
Proof of social security number or verification of SSN ineligibility
DMVS conducts electronic verification of SSN’s and receives
ineligibility forms for individuals to whom the Social Security
Documentation of name and principal residence
Prior to issuing a driver’s license or ID card the DMVS will be required
to verify the issuance, validity, and completeness of each document
submitted with a DL or ID application.
No foreign documents may be used except passports.
III.
Administration will not issue an SSN
DMVS regulations allow proof of residence using recent Georgia
utility bill, recent bank statement mailed to Georgia address, currently
valid rental contracts and/or receipts for rent payments, employer
verification, or non-expired Georgia driver’s license, permit or ID card
issued to parent, guardian or spouse.
Document authenticity is not verified unless suspect.
DMVS will accept properly authenticated foreign documents as proof
of identity.
Evidence of Lawful Status-Applicants must prove one of the following in order to be
eligible for a driver’s license or identification card.
REAL ID Act Requirements
Valid documentary evidence of citizenship
Current Procedure
DMVS regulations require proof of citizenship via an original birth
certificate issued by a United States jurisdiction, certified copy of birth
certificate issued by a United States jurisdiction, valid United States
passport, original certificate of citizenship (Form N560), certified copy of
certificate of citizenship (Form N560), original certificate of naturalization
(Form N550), or a certified copy of certificate of naturalization (Form
N550).
Valid documentary evidence of lawful alien status, conditional
DMVS regulations allow applicants to prove lawful status Foreign passport
permanent resident status, approved asylum status, approved
with appropriate immigration documents, Resident Alien Card (Form I-551),
refugee status, valid visa/valid visa status, pending asylum
Temporary Resident Alien Card (Form I-668), or a United States
application, pending application for temporary protected status,
Department of Receptions and Placement Program Assurance Form (for
deferred action status, or pending application for status adjustment
refugees).
IV.
Temporary Driver’s Licenses and ID Cards-If an applicant is not a citizen, lawful resident
alien, conditional permanent resident, asylee or refugee, then he or she is only eligible for a temporary license or ID card.
REAL ID Act Requirements
Current Procedure
Temporary DL or ID is only valid during applicant’s authorized
stay
Card must reflect that it is temporary.
Renewal only permitted upon submission of documentary evidence
that status has been extended
V.
Rather than tying expiration to the authorized stay, Georgia law currently
mandates the revocation of any DL or ID card issued to a non-citizen if
his/her INS status is terminated or revoked.
Non-citizens are issued regular licenses and IDs.
Once a license or ID card is issued, the DMVS does not check INS status
again.
Miscellaneous Requirements
REAL ID Act Requirements
Current Procedure
Requires MOU with Dept. of Homeland Security for SAVE check on
No such connectivity.
immigrants
Requires capture and storage of digital images of all documents
No copies made.
Employee security clearances
Applicants for employment must submit to a thorough background
investigation
Fraudulent document recognition training
Conducted on ad hoc basis
Failure to substantially comply with the requirements of the REAL ID Act will result in Georgia driver’s licenses and identification cards
being unacceptable as proof of identity to any federal agency, including the Social Security Administration, or to board a commercial
aircraft. If a state does not comply with these requirements, the driver’s licenses and identification cards it issues must clearly state on the
face that it cannot be used by any Federal agency for any official purpose, be a unique design or color so that no Federal agency or law
enforcement personnel will accept it.
HAWAII
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System (in Record, on
Document)
Currently being accomplished
Have following data elements/features on the document:
Currently being accomplished
100. Full Legal Name
101. Person’s Date of Birth
102. Person’s Gender
103. Person’s DL or ID Card Number
104. Digital Photograph of Person (and retention)
105. Person’s Address of Principle Residence
106. Person’s Signature
107. Physical Security Features to prevent tampering, counterfeiting or
duplication
108. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to expiration of
DL/ID card (or issuance for no more than 1 year)
Will require additional programming and
change in law. Cost unknown at this time.
Amending card design to show/indicate that it is a temporary document with
a “different than usual” expiration date
See above
Verification at Source:
Hawaii is only using SSOLV. Additional
electronic verification methods would
require additional programming and
unknown cost. All electronic verification
Enabling your system to electronically verify documentation with:
1. SSOLV
ASSUMPTIONS
REAL ID ACT REQUIREMENT
2. SAVE
IMPACT
responses must be “seconds”, NOT minutes.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
See above.
Introduce equipment into system to capture digital images of identity source
documents so that images can be retained in electronic storage in a
transferable format
Hawaii does not have scanners. Additional
unknown costs.
Retain paper copies of source documents for a minimum of 7 years or
images of source documents presented for a minimum of 10 years
Additional unknown cost for filing system.
Subject each person applying for a driver’s license or identification card to
mandatory facial image capture
Presently being accomplished. Need
definition of “facial image” – i.e. does it
include forehead and hair, etc.
Establish an effective procedure to confirm or verify a renewing applicant’s
information
Need new system – facial recognition or
fingerprint comparison to retrieve record of
renewing applicant.
In the event that a social security account number is already registered to or
associated with another person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take appropriate action
Applicants with duplicate SSN are presently
being referred to SSA for resolution. No
DL or ID card should be issued until SSA
RESOLVES duplication issue.
Check other states if a person already was issued a DL in another state
Need access – cost unknown.
Ensure physical security of locations where DL/ID cards are produced
No issue.
Subject all person’s authorized to manufacture or produce DL/ID cards to
appropriate security clearance requirements
Need definition of “appropriate security
clearance”. All employees currently
undergo local background checks.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Establish fraudulent document recognition training programs for appropriate
employees engaged in the issuance of DL/ID cards
Need to bring “train-the-trainer” program to
the State so that an appropriate number of
trainers can be certified. Cost unknown.
Limit period of validity of DL/ID cards that are not temporary to a period
not exceeding 8 years
No issue. Hawaii license valid for six
years, max.
Alternative document design if it does not meet federal standard
Will need to work with DL/ID card vendor.
Cost unkown.
Legal Presence Requirement
Need change in law.
Provide electronic access to all other states to information contained in the
motor vehicle database of the state
Need change in computer programming.
Cost unknown.
Maintain a state motor vehicle database that contains at a minimum:
Violation history is a separate database.
Need computer programming. Cost
unknown.
All data fields printed on DL/ID cards
ASSUMPTIONS
motor vehicle driver’s histories, including motor vehicle violations,
suspensions and points on licenses
Optional
Development and issuance of a certificate of driving – not for federal
identification purposes – for those who cannot prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Access to and timely responses of electronic verification through SAVE, EVVS, DEERS, DRIVERS,
etc. is the key for implementation of the Act by the federally mandated deadline. To minimize the
cost to the States, can AAMVA pursue federal funding to coordinate all such access through
AAMVAnet and initial startup programming costs for the jurisdiction’s connectivity?
AAMVA needs to take an active role as intermediary with the Feds to establish a responsive
electronic verification program between the jurisdictions and the various databases.
As much of the unknown funding and programming costs should be borne by the Feds, including the
jurisdiction programming costs.
I think the Act is unrealistic with the 3 year implementation deadline unless these databases and
communication links are made a funding priority by the Feds.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
IDAHO
IDAHO Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
$30K
Have following data elements/features on the document:
No major impact other than that shown above.
ASSUMPTIONS
Database changes required to accommodate size
109. Full Legal Name
110. Person’s Date of Birth
111. Person’s Gender
112. Person’s DL or ID Card Number
113. Digital Photograph of Person (and retention)
114. Person’s Address of Principle Residence
115. Person’s Signature
116. Physical Security Features to prevent tampering,
counterfeiting or duplication
117. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Legislation and Rule Changes. Development cost
of 70K
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Card development costs $30K
Verification at Source:
Enabling your system to electronically verify
All estimates assume an automated process is available to
verify. Without the automated process, costs will be
significantly higher. For a manual process, will need 6
REAL ID ACT REQUIREMENT
documentation with:
IMPACT
Developed and in place
1. SSOLV
26K programming development (for online access)
2. SAVE
26K programming development
3. DEERS (DOD)
26K programming development
4. Other jurisdiction (DL/ID card)
26K programming development plus 180K per year
cost for the verification
5. Birth certificate
ASSUMPTIONS
additional personnel (a document
verification/correspondence/issue unit) with a set-up cost of
$30K for furniture and hardware, 35K for programming,
$219K ongoing cost per year for personnel and $2500 per
month for office space and equipment lease. Additionally,
postage for ongoing mail verification will be $150K per
year.
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Costs stated above
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
800K initial cost, plus ongoing maintenance and
equipment replacement.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
No impact identified
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
There will be development cost. The amount is
unknown at this time.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
No impact identified
No additional technology required.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
No impact identified
Similar to what is currently done
Check other states if a person already was issued a DL in
another state
26K Programming development More if electronic
verification is not possible
If electronic verification is available
Ensure physical security of locations where DL/ID cards
are produced
No impact identified
If central issue can be negotiated
Images captured at front end.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
No impact identified
If central issue can be negotiated
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
No impact identified
If central issue can be negotiated
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
No impact
Compliant
Alternative document design if it does not meet federal
standard
30K
Vendor charge may vary
Legal Presence Requirement
Legislation to clarify
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
No impact identified
Maintain a state motor vehicle database that contains at a
minimum:
No impact identified
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
60K programming development cost
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
• Is “central issue” for driver’s licenses going to be required?
• Will verification systems be in place for automated verification?
• Will all drivers have to re-verify documentation or only those drivers newly licensing?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
ILLINOIS
REAL I D ACT (P.A. 109-13) IMPACT, ASSUMPTIONS
7-7-05
Provisions
Authority
Specific Requirements
Sec. 205: Authorizes Secretary of
Homeland Security to issue
regulations, set standards and issue
grants, in consultation with the
Secretary of Transportation and the
states.
Sec. 207: Nothing is to affect U.S.
DOT or state authorities under Ch.
303 of Title 49, U.S Code.
Applicability
IL Impact
Assumptions
Illinois is slated to rebid digital
license system in 2007. To the degree
that regulations are not available to
spell out exact requirements, we will
face a much greater challenge in
designing and bidding a system to
fully comply with 2008 provisions.
Time is of the essence for us on rules.
Assume move from DOT to DHS
could mean delays in rule publication
as DHS gears up for this new area.
Sec. 201:
Applies to all U. S states and
territories.
Applies to and defines DLs and IDs.
CDLs?
Can we get any timetable on rule
promulgation?
Assume CDLS are included.
3 years is a very short time, with two
state budget and legislative cycles at
most.
Sec. 202 (a): Effective 3 years after
enactment (enacted May 11, 2005).
Grants
Sec. 204:
Authorizes appropriations for fiscal
years 2005-2009 for the Secretary of
Homeland Security necessary to carry
out this act.
Costs will be huge, esp. for a large
state that may well have to retool
much of its operation, including
eligibility criteria.
Assume no funds in 2005
appropriations. Assume after 2008,
states must bear all on-going costs.
Will extensions if needed also include
funding extensions?
Suggests grants will be permissive.
Assume based on need and
competitive applications rather than
by a formula allocation. Assume state
legislatures will delay making
appropriations until the availability of
federal funds is known—introduce
additional delays.
Secretary of Homeland Security may
make grants to a state to assist in
conforming to the minimum
standards.
Information Required on the Driver’s
License and Identification Card
Sec. 202 (b)
States shall include at
minimum, the following
information and features on
the driver’s license and
identification card:
1. the person’s full legal name,
2. date of birth,
3. gender,
4. driver license or identification
card number,
5. a digital photograph,
6. address of principal
residence,
7. signature,
8. physical security features to
prevent tampering,
counterfeiting, or duplication
of the document for
fraudulent purposes and
9. a common machine-readable
technology, with defined
minimum data elements.
We already have all the text on our
DL/IDs except full legal name. May
need law change for some
requirements. DL/ID records
belonging to same person not linked-need to be located, records linked, and
SOS must require identical
information be used on DL/ID records.
1. Legal name requirement in IL in I
D Security bill effective 1/1/05, but
currently not operationalized as full
legal name.
Once “full legal name” is defined in
federal rule, Illinois will likely need to
change administrative rules. (In law
but generally.) Will need new facility
procedures; change programming on
every screen and databases to store
longer names; change card design to
print full legal name. 18 mo. to 2
years programming estimated. Will
require field changes for likely every
external user who comes into our
systems—law enforcement,
insurance.
5. Without an exception, to
General: Assume DL and ID records
must be linked, and some information
from both shared with any other state
requestor. Should that be assumed?
Who else will have to do major
changes in their systems to
obtain information from
DMVS—law enforcement,
election authorities, insurance
companies, etc.?
6. Assume that standard address
verification methods that verify
legitimacy of mailing address will
suffice as verification of principal
address. If not, we do not know how
we’ll verify that a person actually
lives there esp. if they are not the
named person on documents used to
establish address.
5.Assume no exceptions for
photo/signature requirement,
Illinois will have to eliminate
Valid w/out Photo/signature
cards (religious exemptions,
military, etc.) or re-design them
so they are not valid for federal
purposes. Law change.
9. Illinois DL/IDs have 1-D and 2-bar
codes. MRT to be used is unknown.
Could involve extra cost, legislation.
Minimum
Issuance Standards
inclusion of photo. This would
be important clarification for
Illinois in rules.
9. Assume MRT will be 2-D
bar code with no requirement to
include photo or biometric in it;
need rule on this ASAP.
Sec. 202 (c):
A state shall require, at minimum,
presentation and verification of the
following information before issuing
a driver’s license or ID card to an
individual:
• a photo identity document, except
that a non-photo identity document
is acceptable if it includes both the
person’s full legal name and date of
birth.
• documentation showing the person’s
date of birth.
• proof of the person’s social security
account number or verification that
the person is not eligible for a social
security account number.
• documentation showing the person’s
name and address of principal
residence.
Will need to re-examine I D policies to
ensure that we meet these
requirements for these minimum
documents, and perhaps limit
acceptable documents to those that are
verifiable with issuing source.
Assume all verifications before
issuance means few if any new could
be over the counter unless it involves
a second visit, unless additional
electronic verification methods are
developed.
Must rely on manually prepared letters
from SSA to show ineligibility—
currently they are not verifiable as
validly obtained.
Assume letters of ineligibility from
SSA do not have to be verified with
the issuing source?
Will have definition issues with full
legal name and principal residence.
See immigration requirements.
A state must require evidence of legal
status before issuing a driver’s
license or identification card. (See
Immigration Requirements
Immigration Requirements)
Sec. 202 (c) (2) (B):
A state shall require, before issuing a
driver’s license or identification card
to a person, valid documentary
evidence that an individual is
• a citizen of the United States;
• an alien lawfully admitted for
permanent or temporary
residence;
• has conditional permanent
resident status;
• has a valid, unexpired
nonimmigrant visa or
nonimmigrant visa status for
entry;
• has a pending or approved
application for asylum; has
refugee status;
• has a pending or approved
application for temporary
protected status;
• has approved deferred action
status;
• or has a pending application for
adjustment of status to that of
an alien lawfully admitted for
permanent residence or
conditional permanent resident
status.
Illinois has no legal presence
requirement in Illinois law,
except for TVDL applicants
ineligible for SSNs. Law
change required, major overhaul
in eligibility criteria to add it.
If Illinois needs to redefine regular
DL/ID eligibility to tie it to
citizenship or permanent residency
instead of to SSN, there could
potentially be tens or likely
hundreds of thousands of noncitizens with SSNs who will now
have to get TVDL instead, with DL
tied to authorized length of stay.
Full legal review needed of this,
Sanchez decree which currently
prohibits us from requesting
immigration documents for any
applicant but TVDL.
Need to evaluate potentially
effects on reciprocity
agreements with other
countries.
Big question in a nutshell for Illinois
is will the requirement of SSN suffice
as evidence of legal presence?
Neither holding an SSN nor SSOLV
responses indicates citizenship nor if
the non-citizen is still legally in the
country at time of DL/ID application,
so we assume not. The Question:
Under (c)(2)(B)(ii), a state may
issue a "regular" driver's license to
an alien that is lawfully admitted
for permanent or temporary
residence in the US. Under
(c)(2)(B)(v), a state may issue only a
temporary driver's license to a
person who has a valid, unexpired
nonimmigrant visa or
nonimmigrant visa status for entry
into the US. However, the
definition of alien that is found in 8
USC 1101, Section 101(3) defines
the term alien as "any person not a
citizen or national of the US."
Based on these definitions, it seems
possible that a person could be an
alien (and be eligible for a regular
driver's license), but holds a
nonimmigrant visa (and be eligible
for only a temporary driver's
license). In that case, do we issue a
regular or temporary driver's
license? For example, a man comes
from Germany to work,
temporarily, in the US. He would
be considered an alien. However,
he would not have an immigrant
visa, as he is not planning on
making the US his permanent
home. This person seems to fit into
both categories. In this case, would
the visa status take precedence?
How are the terms alien and
nonimmigrant visa going to be
defined in relation to the
implementation of the Real ID Act?
Potentially affects state’s
reciprocity agreements with
other countries?
Assume move from regular DL
to TVDL would have to be
treated as new, or would
existing ones be
grandfathered?
Temporary Driver’s License and
Identification Cards
Sec. 202 (c ) 2 (C):
States may only issue a temporary
driver’s license or identification card
to applicants who present evidence of
legal status for
• a valid, unexpired
nonimmigrant visa or
nonimmigrant visa status,
• a pending application for
asylum,
• pending or approved
Illinois has TVDL program, but
is issuing regular DLs and IDs to
persons who may have eligibility
restricted to only getting a
TVDL—that is, non-citizens with
SSNs with time-limited legal
authorization to stay in the U.S.
Illinois TVDL program allows
DLs, not IDs. Federal law
Assuming MAJOR operational
impact of shifting many non-citizens
with SSNs into TVDL program, and
then limiting many TVDLs to one
year instead of three years—
More SAVE use--$ and delays
TVDLs at all sites, not just 6
More frequent renewals—
3 yrs. to 1
•
•
application for temporary
protected status,
approved deferred action
status or
has a pending application for
adjustment of status to that of
an alien lawfully admitted for
permanent resident in the
United States or conditional
permanent resident status.
A temporary driver’s license or
identification can only be valid for the
period of time of the applicant’s
authorized stay in the United States or
for a period of one year if there is no
definite end to the period of
authorized stay.
allows temporary IDs.
MAJOR operational impact of shifting
many non-citizens with SSNs into
TVDL program, and then limiting
many TVDLs to one year instead of
three years—
More SAVE use
TVDLs at all sites
More frequent renewals
Must change law and program
For TVDLs to be 1 year instead
of 3 for those with no definite
end of authorized stay.
Current Illinois TVDLs do this AND
A temporary license or ID card
say “Not Valid for Identification” as
must clearly indicate that it is well. Future card design.
temporary and shall state the
date on which it expires.
Currently done in TVDL program.
A temporary license or ID card may
be renewed upon presentation of valid
immigration documents that the status
of stay has been extended by the
Secretary of Homeland Security.
Verification of Documents
Sec. 202 (c ) 3:
Before issuing a driver’s license or ID
card to a person, a state shall verify,
with the issuing agency, the issuance,
validity, and completeness of each
ADDRESS: Will need to find an
address verification method that gets
to principal address, not just valid
mailing address.
Assume Illinois is like every state in
that we are currently unable to
comply with this for every breeder
document. On-line verification
breeder document required to be
presented by the applicant.
1) SSOLV
PASSPORTS: No verification system
currently in place for passports. No
mechanism to verify U.S. or foreign
ones.
2) SAVE
3) DEERS
4) Other jurisdiction (DL/ID
card)
5) Birth certificate
6) Other…i.e. third party
vendors
States must verify with the Social
Security Administration a social
security number presented by a
person using the full social security
number.
A state may not accept any foreign
document, other than an official
passport as proof of identification.
State must sign a Memorandum of
Understanding with the Department
of Homeland Security by September
11, 2005, to use the Systematic Alien
Verification Entitlements (SAVE) to
verify the legal presence status of an
applicant other than a United States
citizen.
1) Illinois already verifies SSN
through SSOLV—on line since
6/14/04.
2) Illinois has signed an MOU for
SAVE (eff. 10/04) and already verifies
immigration documents in TVDL
program only, for those not eligible for
SSN, not for all non-citizens. ONLY
AT 6 SITES. (SAVE is costly; not
built into our system to ensure its
usage like SSOLV but needs to be—
fraud risk; many delays in responses
from DHS.)
3) Illinois has not looked at DEERS,
need to first identify if it is going to be
useful for a significant enough part of
population to warrant costs.
5) There is no local, state or national
automated system for verification of
U.S. issued birth certificates, and
certainly no automated system for
foreign birth certificate verification.
Illinois does not plan to participate in
EVVE but design its own system.
systems for many are not available.
Manual systems especially in a state
our size are simply not feasible or
cost-effective by any stretch. Expect
cost, delays, and significant manual
exception processes.
Assume this could largely prevent
“instant” or “over the counter”
(OTC) issuance of some or all of
our DLs and IDs, esp. new or
renewal (depending on renewal
verification requirements.
Assume it could reduce or end mail
and Internet address changes and
renewals.
Assume we will have to significantly
reduce the number and type of
acceptable documents used, to limit it
to those that are verifiable.
Assume current MOAs with DHS
already signed will suffice. Will
they?
Assume only renewal requirements
will apply to current DL/ID
holders, not full verification as
though they were new.
Assume 3rd party verification or
verification of document’s physical
characteristics (security features,
paper, etc.) will not meet definition
of verification with “issuing
source”. Need definition of issuing
source. For example, for birth
certificates, is it state public health
department or local county? Or, if
SSA has already verified vital
records for DOB, and a code could
be added to SSOLV, would that
suffice for DMV DOB verification
with issuing source?
Does State Dept. intend to have
ability to verify U.S. passports?
Foreign passports?
Will verification of I-94, other
accompanying immigration
documents through SAVE, even
though we can only accept foreign
passports, suffice as verification
with the issuing source? If not,
what mechanism, will exist to verify
foreign passports?
Other Issuance Requirements
Sec. 202 (d):
(1, 2) Must capture images of identity
source documents and retain
electronic copies for minimum 10
years or paper copies for 7 years.
Will need to electronically scan
all identity source documents
at the counter in facilities,
have network capacity to
transmit to central electronic
storage, and have them be
retrievable and able to be
electronically shared.
Need to assess Illinois record retention
laws for paper/electronic copies.
Assume this scanning
requirement plus verification
steps may significantly limit
mobile unit use, perhaps
make mobiles impractical?
Assume major cost not just for
hardware but also for storage and to
redesign facility layouts to add space
at counter for scanners.
Assume privacy issues are bigger than
(3) A state must subject each person
applying for a driver’s license or ID
card to mandatory facial image
capture.
(4) States must establish an effective
procedure to confirm or verify a
renewing applicant’s information.
(5) Confirm SSN and in the event that
a Social Security number is already
registered to or associated with
another person to whom any State has
issued a driver’s license or ID card,
the state shall resolve the discrepancy
and take appropriate action.
Need to assess legal/privacy
considerations for who can see,
retrieve and receive this new
information kept by DMVs.
we anticipate, as DMVs will now
have (and law enforcement, federal
government, others will want)
copies/information.
No Valid Without Photo/Signature?
Other state law changes on photo
requirement possible. Religious
exemptions, military.
Assume this by definition moves the
camera to front of application
process—must capture photo of all
applicants, not just cardholders:
Complete facility workflow
redesign
Major re-working of
programming
130-plus facility remodel/design
Unknown right now--could affect
time to process renewals, ability to
do them instantly OTC, and may
affect ability to have mail and
Internet Safe Driver Program.
Potentially huge operational impact—
the bulk of our applications are
renewals each year.
SSOLV does not indicate if SSN
issued to another. Not all states
require SSN. At a minimum, this
will require linkage of SOS database
with ALL DMV databases to do
checks.
SOS can, but does not do SSN or name
checks on our own database. This
We do not know what to assume.
Need clarification here ASAP—what
verification needs to be done will
affect central vs. instant issue, mail
and Internet renewal options.
Is this over and above the
requirement to verify other DL or
ID issued or just DL? It looks like
it is to also verify if they used an
SSN or if anyone else I that state is
using same SSN. Is that correct
interpretation?
“NA01” processing will need to be
required.
(6) Must refuse to issue to person
holding other state’s DL or ID
without confirming it is terminated or
is being terminated.
Not all states require SSN. Privacy
issues for us, SSA, others?
Much clean-up on multiple SSN
records needed, esp. on unlinked DL
and IDs.
Will need all DMV databases linked,
and do checks with other states before
issuance. DRIVerS $ going to be
included in individual state grants?
To AAMVA?
Can we assume that this will be
through AAMVA’s existing
systems, or new system directly to
states? New system through DHS?
(7) Must ensure physical security of
locations where cards produced and
card materials are stored.
(10) Must limit validity of DL/IDs to
no more than 8 years.
Locations currently include facilities,
mobiles, and two warehouses. Likely
work to be done, potential costs for
locked areas or cabinets, safes, etc.
Assume additional costs for secure
space and storage if it stays in
facilities.
Assume possible additional steps or
audit systems for consumables.
Non-expiring Senior and 10 year
disabled IDs will not meet
requirement—will need to limit
them to 8 years or make them not
valid for federal purposes.
Assume we may have to stop issuing
non-expiring senior IDS and reduce
time for disabled IDs.
Assume those DL/IDs already in
existence will be gransfathered. Need
to know this for renewals, too,
ASAP.
Assume that federal purposes could
include federal benefits eligibility for
which seniors and disabled would
have definite need for Real I D Actcompliant card.
Personnel Requirements
Sec. 202 (d):
(8) Must subject all staff that
manufacture or produce DL/IDs to
security clearance.
DHS must define clearance
requirements. Effect on personnel
policies, job requirements or titles?
Do not know what to assume on
security requirements. State and/or
federal criminal background check?
Any checks through DHS on terror
watch or no fly or other lists?
(9) Must establish fraudulent
document training programs for
DL/ID issuance staff.
Illinois does very limited training
currently. If AAMVA curriculum is
required, it is 12 hours before working,
and annual re-training.
Assume AAVA curriculum will be
adopted in rule as standard for
compliance. Can we assume that?
Likely need to look at potential
specialist roles to have staff that
is adequately prepared for some
unique tasks, and/or specific
workstations in facilities in order
to manage diverse facility
customer flow.
Driver License Agreement and
Sec. 202 (d):
Assume major training needs for
which we currently do not have
organizational capacity/resources.
Interoperability
(12) Must provide electronic access to
all other states to information in the
SOS database.
Fraud Prevention and Security
Standards
Compliance
(13) State motor vehicle database
must contain, at a minimum: all data
fields printed on DL/IDs issued by the
state; and motor vehicle drivers’
histories, including motor vehicle
violations, suspensions, and points on
licenses.
Sec. 203:
Need to assess needed state law to
authorize sharing of data including
SSNs. Might include photo exchanges.
SOS databases contain all this but
records are not linked. (Previously
noted.)
The Act amends the fraud and related
activity in connection with
identification documents,
authentication features, and
information in 18 U.S.C. 1028 (a)(8)
by striking “false authentication
features” and inserting “false or actual
authentication features” so it reads
“knowingly traffic in false or actual
authentication features for use in false
identification documents, documentmaking implements, or means of
identification.”
Need to review Illinois DL/ID fraud
and identity theft statutes to ensure
they reflect this and other new
requirements.
Sec. 202 (a): Federal agencies are
If Illinois DL/IDs do not meet federal
Assume DRIVerS or its equivalent is
a prerequisite for all states.
Establishing direct connections with
all other states and jurisdictions, esp.
in the absence of uniform standards
for information exchange, would be a
nightmare for all states. (Can we go
home now??)
Assume expansion of existing
AAMVA systems.
We need full explicit definition of
prohibited from accepting for any
official purpose a state-issued DL or
ID three years after enactment of this
Act unless the state conforms to the
minimum standards established in the
bill.
Sec. 202 (d) 11): States can still issue
DLs and IDs for driving or other
purposes to persons legally or not
legally in the country that do not meet
requirements, but cards must:
• clearly say that they are not
valid for federal purposes,
and
• use unique color or design to
alert federal agency and law
enforcement personnel.
minimum standards, they cannot be
used for federal purposes.
Definition of “federal purpose”
will be key -- includes air travel,
accessing federal facilities.
Federal benefits? DHS
Secretary will determine.
federal purposes in rule ASAP.
We do not know if we will issue
alternative non-Real I D Act
compliant documents.
Assume pressure to create one for
persons not legally in the country.
Assume it might also be needed for
Could issue non-compliant
non-expiring senior IDs, Disabled
cards. Illinois will need to
IDs, non-photo DL/IDs IF those
determine if it will create a twocontinue to be issued.
tiered system – some DL/IDs
good for federal purposes, some
not. And if so, will it be for
persons not able to meet legal
presence requirements be part
or all of those eligible for nonfederal DLs or IDs?
Sec. 202 (a): Each state must certify
Operational impact of adding
to the Secretary of Homeland Security those not legally in country will
whether the state is meeting the
be very significant because of
minimum standards.
additional volume. Not a Real I
In any case in which the state issues a D Act requirement so not a
change that would be federally
driver's license or ID card that does
funded.
not conform to the minimum
standards, state must ensure that such
license or ID card:
• clearly states on its face that
it may not be accepted by any
federal agency for any
official purpose; and
uses a unique design or color
indicator to alert federal agency and
Self-certification.
other law enforcement personnel that
it may not be accepted for any such
purpose.
Extensions
Sec. 205 (b):
The Secretary of Homeland Security
may grant an extension of time
beyond 3 years if the state provides
adequate justification for
noncompliance.
Repeal
Need to develop timetables that
reflect:
• State budget cycles,
resources
• State legislative and rule
changes
• DDLS contract term
• Organizational capacity for
change
Sec. 206:
This Act repeals Section 7212 of the
Intelligence Reform and Terrorism
Prevention Act of 2004 (P.A. 108458) that required the Department of
Transportation to establish minimum
standards for the driver’s license and
ID card through negotiated
rulemaking.
Questions & answers not included in response.
With repeal of the less stringent and
more general provisions of the
Intelligence Reform Act, which
became law in December 2004, the
negotiated rule-making process
already underway (in which AAMVA
and states were participating) was
disbanded.
Assume this might be needed, esp. if
rulemaking process has unexpected
delays. If so, need explicit direction
in rules.
INDIANA
.
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
New “STARS” system is set to do this. Will take a
full license cycle once it is in place to be compliant.
Est. six years from final STARS implementation.
No revisions in their requirements.
Have following data elements/features on the document:
All of this is in place with final STARS
implementation in December 2005. Need details of
what the data in the “machine readable technology,
2D UPC, is it same as DLA?
No revisions in their requirements.
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Not currently offered. Needs to be added to our IT
project. list. Requires programming time, passage of
legislation and design of unique document.
No revisions in their requirements.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Not currently offered. Needs to be added to our IT
project. list. Programming time and design of unique
document.
No revisions in their requirements.
Verification at Source:
Not currently offered. Needs to be added to our IT
project. list. Programming requirements are
Standard method of transfer is established early enough
118. Full Legal Name
119. Person’s Date of Birth
120. Person’s Gender
121. Person’s DL or ID Card Number
122. Digital Photograph of Person (and retention)
123. Person’s Address of Principle Residence
124. Person’s Signature
125. Physical Security Features to prevent tampering,
counterfeiting or duplication
126. Common Machine Readable Technology:
REAL ID ACT REQUIREMENT
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
IMPACT
ASSUMPTIONS
substantial.
for everyone to conform.
Will probably move Indiana from relatively instant
issuance to having to mail documents to them.
Originating agencies/sources are prepared to respond.
License fees may need to be revised to cover
increased postal costs.
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Currently able to do so with our CVP process.
No revisions in their requirements.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Substantial Programming and hardware costs.
No revisions in their requirements.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Currently in our statute.
No revisions in their requirements.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Will need to pass legislation as we have exemptions
for religious reasons.
No revisions in their requirements.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Currently in place depending on what is finally
mandated.
No revisions in their requirements.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve
the discrepancy and take appropriate action
Currently a policy in place. If it does not comply
with a standard established later, development and
implementation of new policy.
No revisions in their requirements.
Check other states if a person already was issued a DL in
another state
CAROL?? Do we do this?
No revisions in their requirements.
In our current IT plan to move as quickly as possible
to achieve this information and digital signatures,
regardless of the Real ID status.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Ensure physical security of locations where DL/ID cards
are produced
Currently in place.
No revisions in their requirements.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Currently in place but will need to revise if standards
do not match ours.
No revisions in their requirements.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Currently in one place and have an enhanced
fraudulent document recognition training program in
the works with AAMVA and our Investigations dept.
No revisions in their requirements.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Currently in place. Legislation passed in the last
session sets our period to 6 years.
No revisions in their requirements.
Alternative document design if it does not meet federal
standard
Not an issue at this time. Will revise as necessary as
standards are set. Requires programming time,
passage of legislation and design of unique
document.
No revisions in their requirements.
Legal Presence Requirement
Currently in place.
No revisions in their requirements.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Currently being developed with the new STARS
system.
No revisions in their requirements.
Maintain a state motor vehicle database that contains at a
minimum:
Currently in place.
No revisions in their requirements.
Currently under review.
No revisions in their requirements.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
IOWA
Jurisdiction Impact Analysis Real ID Act
Real ID Act
Requirement
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into
Driver Licensing System (in
Record, on Document)
Should be none to minimal. Our new
driver license system, to be implemented
in April '06 will allow for 125 characters.
Our new driver license allows for 111
characters to printed on the card. We'll
use the AAMVA truncation rule for any
thing longer than 111 characters
1-4: We have now
5: We have now for everyone except
persons with bona fide religious
objection. They are issued a license that
is "valid without photo"and no file photo is
capured either.
6: we have now
7: we have now
8: we exceed AAMVA card spec now
9: our new license will have 2D barcode,
mag stripe & digital watermark
Authentication/re-enrollment of those
already in the system will have a
customer impact
Assume the AAMVA system and DL/ID
card document specs will meet
minimum DHS requirements for full
name
Have following data
elements/features on the
document:
1. Full Legal Name
2. Person’s Date of Birth
3. Person’s Gender
4. Person’s DL or ID Card
Number
5. Digital Photograph of
Person (and retention)
6. Person’s Address of
Principle Residence
7. Person’s Signature
1: we'll follow the truncation rules
5: Assume DHS will provde for same
Valid w/o photo exception based on
U.S. Constitution.
7: Assume DHS will allow alternative
for those physically incapable of
signing.
8: Assume AAMVA DL/ID card spec will
satisfy this requirement.
9: Assume AAMVA DL/ID card spec
requirement for PDF417 will satisfy this
requirement
Additional
Comments
5: We can provide
background on case law
if you'd like it
7: We currently allow
use of a stamp or
signature by power of
attorney
8. Physical Security Features
to prevent tampering,
counterfeiting or duplication
9. Common Machine
Readable Technology:
Introduce temporary DL/ID
cards and tying end of stay to
expiration of DL/ID card (or
issuance for no more than 1
year)
Amending card design to
show/indicate that it is a
temporary document with a
“different than usual” expiration
date
Will require a legislative change reducing
term of issuance from 2 to 1 yr for person
with indefinite end of stay.
Verification at Source:
1: We will implement in July '05
2: We think we can implement easily
with the existing external web access, but
would prefer to have it fully intergated
within our system. That will take IT staff
time and money. Transaction fees seem
high.
3: not enough known to assess an impact
4: none except potential response time
issue
5: Major. Even though we participate in
EVVER, and it functions well, we don't
anticipate the states' Vital Records
agencies will be able to make the needed
Enabling your system to
electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
We need guidelines. It may require some
change to our photolicensing software.
We'd prefer to do this in the header.
The current AAMVA card
spec shows Zone II for
"other data fields for
national or jurisdictional
purposes in human
readable format". May
need to change the
spec.
Our new DL system is
designed to let us add
external interfaces
easily.
Any electronic
verification that does not
deliver 7-10 second
response may cause us
customer (wait time)
issues as we are an
OTC state.
4. Other jurisdiction (DL/ID
card)
database/system upgrades within 3
years.
6: Transaction fees will probably be our
biggest impact.
4: Tasks 8&9 functionality will be
implemented nationwide.
5. Birth certificate
6. Other…i.e. third party
vendors
Developing access capability to
SAVE system
Real ID Act Requirement
Introduce equipment into
system to capture digital
images of identity source
documents so that images can
be retained in electronic
storage in a transferable format
Retain paper copies of source
documents for a minimum of 7
years or images of source
documents presented for a
minimum of 10 years
Subject each person applying
for a driver’s license or
identification card to mandatory
facial image capture
Establish an effective
procedure to confirm or verify a
renewing applicant’s
information
5: At this time we don't
follow up on the bad hits
Minor-see #2 above.
Impact
We currently have this capability
CDLIS Response time parameter should be able to use the available web
interface our assumption is that we
would receive timely and accurate
information
Assumptions
Technical – minor
Staffing - not clear
Assume we can do one or the other.
Will require more staff time to
scan/index the documents.
Our new DL/Photo Licensing system
allows for this.
Assume religious objector exemption
issue will be resolved at Federal level.
We need more information about
requirements
We believe our new system and card
will allow us to meet reasonable
requirements
Additional Questions
It's not clear that
additional staff will be
needed at this time. We
may be able to absorb
with current staff.
In the event that a social
security account number is
already registered to or
associated with another person
to which any state has issued a
DL/ID card, the state shall
resolve the discrepancy and
take appropriate action
Check other states if a person
already was issued a DL in
another state
Ensure physical security of
locations where DL/ID cards
are produced
Minor
We're going to send the
customer to the Social
Security Administration
to clear up the
discrepancy
Minor
AAMVA provides this function
We need information on minimum
requirements
We believe we can meet reasonable
requirements with little difficulty by
building on procedures in place now for
the secure storage of consumables and
equipment
Subject all person’s authorized
to manufacture or produce
DL/ID cards to appropriate
security clearance requirements
We need more information on minimum
requirements. If it's kept at the level of a
criminal history background check, it
should be little impact. If it requires an indepth security clearance review of the
type used for prospective law
enforcement employees within our
department it could be very time
consuming. In either case we believe
most of the costs will be associated with
law enforcement personnel already on
the state/local payroll.
Our MVE officers or local law
enforcement will conduct a background
check on anyone that is involved in the
issuance of DL & ID. Photo licensing
vendors/card material suppliers will
conduct background checks of their
own employees.
Establish fraudulent document
recognition training programs
for appropriate employees
engaged in the issuance of
DL/ID cards
Limit period of validity of DL/ID
cards that are not temporary to
None.
Assume AAMVA FDR will meet/exceed
any minimum requirement
Already 5
Will impact our ability to offer renewal
by mail or internet in the future.
a period not exceeding 8 years
Alternative document design if it
does not meet federal standard
Minimal. Could require some change to
our photo licensing software.
Our DL will meet and exceed the
federal standards
Legal Presence Requirement
We've required proof of legal
presence/citizenship for new licensees
since 2002. There will be some impact on
those renewing who's legal
presence/citizenship has never been
verified.
Minor.
Will require a legislative change to
bring Iowa law into strict compliance
with Federal law
None.
We currently have a data base that
contains all of this information.
Minor
We know this will be proposed. Don't
know what to expect.
Provide electronic access to all
other states to information
contained in the motor vehicle
database of the state
Maintain a state motor vehicle
database that contains at a
minimum:
All data fields printed on
DL/ID cards
motor vehicle driver’s
histories, including motor
vehicle violations, suspensions
and points on licenses
Optional
Development and issuance of a
certificate of driving – not for
federal identification purposes –
for those who cannot prove
lawful presence.
Assume this will be an
AAMVAnet/NLETS function
KANSAS
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Currently being done.
Have following data elements/features on the document:
Currently being done
ASSUMPTIONS
127. Full Legal Name
128. Person’s Date of Birth
129. Person’s Gender
130. Person’s DL or ID Card Number
131. Digital Photograph of Person (and retention)
132. Person’s Address of Principle Residence
133. Person’s Signature
134. Physical Security Features to prevent tampering,
counterfeiting or duplication
135. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Will require legislation to implement
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Will require legislation for unique card
Verification at Source:
Can be done when systems are in place for Kansas to
connect to.
Enabling your system to electronically verify
documentation with:
Assuming some national standard will be in place for
programming and access to be built around.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
In process
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Can be done by installing scanners to work with
current image capture units and interface with
current imaging system.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Same as above, retention of imaged documents is not
a problem.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Currently being done
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Currently being done using facial recognition and
source data tracking.
These will be acceptable methods in the final rule "to
confirm or verify".
In the event that a social security account number is already
registered to or associated with another person to which any
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
Currently being done when SSN discrepancies arise.
Connectivity to other states available and allowed.
Check other states if a person already was issued a DL in
another state
Can be done now if DL information is provided.
Connectivity or central clearing house available.
Ensure physical security of locations where DL/ID cards
are produced
Currently done, central issued state
REAL ID ACT REQUIREMENT
IMPACT
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
May require legislation for background checking of
dept. employees.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
In place.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
In place.
Alternative document design if it does not meet federal
standard
N/A
Legal Presence Requirement
In place since 2000
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
In place if requested
Maintain a state motor vehicle database that contains at a
minimum:
In place
ASSUMPTIONS
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
N/A
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
We will wait until final rule is in place before proceeding with some of the changes necessary.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
N/A
KENTUCKY
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
KY uses full legal name now on driving records.
Characters for each name; Last 25, First 15 and
Middle 10. Impact of expanding these fields would be
costly without benefit. Focus would be better spent on
standards defining first, middle and last names.
Have following data elements/features on the document:
136. Full Legal Name
137. Person’s Date of Birth
138. Person’s Gender
139. Person’s DL or ID Card Number
140. Digital Photograph of Person (and retention)
141. Person’s Address of Principle Residence
142. Person’s Signature
143. Physical Security Features to prevent tampering,
counterfeiting or duplication
144. Common Machine Readable Technology:
Full name not on license, middle initial used and
truncation on long names over 35 characters
On license
On license
On license
On license, yes retained since 3/2002
Yes on license. Mail address in computer system
Yes on license and stored with image
Yes
Yes 2D Barcode, AAMVA 2000 standard now
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
KY issues license to end of legal stay or normal 4 year
expiration if stay longer.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
This would be a new requirement for KY
temporary document currently license looks same
except expiration date.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
Yes
No
No
No
No, however KY does have access to KY Vital Stats
system for checks as needed.
6. Other…i.e. third party vendors
Developing access capability to SAVE system
KY has not started this process yet
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
KY has no means to address this requirement at this
time. This would be a very huge impact upon KY
KY has over 150 locations that would need this
technology. There are over 220 non-PCs (3270
terminals) and 170 digitized license workstations in
license system. Process could require up to additional
300 people to handle additional workload. Offices
would need estimated 300 scanners and a central server
to house the documents. The additional equipment and
people will create space problem that will lead to
requests for additional office space from courts, which
issue licenses.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
KY has no means to address this issue at this time.
Additional copy machines, employees handle at clerk
& central offices, and office space needed to house
information.
KY has over 150 locations that would need this
technology. There are over 220 non-PCs (3270
terminals) and 170 digitized license workstations in
license system. Process could require up to additional
300 people to handle additional workload. Offices
would need estimated 300 copy machines and a central
warehouse to house the documents. The additional
equipment and people will create space problem that
will lead to requests for additional office space from
courts, which issue licenses.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
KY complies now, since 3/2002.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Previous image of applicant appears before issuance.
SSOLV ran on applicants. If this requirement goes
further, then it would be a new requirement to KY.
We assume this is more than showing existing license.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
Yes, upon proof of SSN w/SSA and other proof of
identity license, bank, etc. KY will notify state to
determine identity
Implementation of DRIVERS would help this
requirement.
Check other states if a person already was issued a DL in
another state
States can ask the question to applicant but DRIVERS
needed to enforce
Ensure physical security of locations where DL/ID cards
are produced
Requirement is very difficult in KY where court
officials issue licenses over the counter and store
consumables at local offices. Division issues
procedures and security measures but it up to court
clerks to perform those security measures.
Subject all person’s authorised to manufacture or produce
DL/ID cards to appropriate security clearance requirements
KY performs some level of background checks now
but additional measures needed.
Background check in Real ID would be expanded.
Money needed.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Very large impact and concern for KY since court
clerk offices issue license, not DMV employees. There
are over 800 users and there is a 25% turn over rate.
No money currently set aside to perform this training
and travel.
The 20 hours FDT will be a very challenging
requirement. No funding. There is concern that training
would not produce better results in the current
environment.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
KY issues a 4-year license. KY complies with
requirement
Alternative document design if it does not meet federal
New requirement for KY. State may have a problem if
It takes a 4-year roll out of a new license once a change
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
standard
requirement in 3 years.
is made.
Legal Presence Requirement
Yes
Still could be a problem if applicant fraudulently
submits statement.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Do no understand fully the meaning of this, but it is
new requirement. It would seem that DRIVERS
needed to comply.
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
Yes
KY maintains record of traffic convictions for 5 years
KY 5-year purge would seem to be a problem on this
requirement especially for identification issues and
exchange of information with other states.
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
KY opposes this option because government issued
document is issued to someone without proper
identification credentials.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
The implementation of Real ID in just 3 years is a problem because rulemaking has not begun, the length of time for a change to take place on license
population (4 years), funding for training, equipment, PCs and employees needed to perform new duties related to scanning. Is there a possibility of
revisiting some REAL ID standards and some requirements?
It seem that the DLA model was used for allot of the REAL ID Act but state membership is not required. Why?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
LOUISIANA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
145. Full Legal Name
No Impact. Louisiana has all data elements/features
as listed #1 through #9
146. Person’s Date of Birth
147. Person’s Gender
148. Person’s DL or ID Card Number
149. Digital Photograph of Person (and retention)
150. Person’s Address of Principle Residence
151. Person’s Signature
152. Physical Security Features to prevent tampering,
counterfeiting or duplication
153. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Louisiana is in process of re-engineering and this will
be accomplished; therefore, no impact. (NGMV)
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
No real impact since this can be addressed with reengineering process already started and/or new
camera contract 2007.
Verification at Source:
1- SSOLV- currently in our processess
Enabling your system to electronically verify
2.-SAVE – (Immigration document verification) –
Asstumptions: Should be one collection place to
dessiminate to all jurisdictions to ensure uniformity.
REAL ID ACT REQUIREMENT
documentation with:
1. SSOLV
IMPACT
monetary due to a change order in current RFP for
NGMV. Time it would add to customer wait if live.
3. DEERS (DOD)
3. DEERS (DOD) –Military document verification) –
monetary due to change order in durrent RFP for
NGMV. Time it would add to customer wait if live.
4. Other jurisdiction (DL/ID card)
4. MCSIA
5. Birth certificate
5. BIRTH CERTIFICATE – Imagine it would be
huge to gather all information from all states.
2. SAVE
6. Other…i.e. third party vendors
6. OTHER – Death records, which Louisiana has
recently started.
Developing access capability to SAVE system
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
THIS IS PART OF OUR NGMV (REENGINEERING) PROGRAM.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Addressed in our NGMV project (will be imaged)
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
We do currently.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
La. Has a photo retrieve system which is utilized in
identification at renewal period, duplicates, etc.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
We do currently
Check other states if a person already was issued a DL in
another state
MCSIA, effective 09/30/2005
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Ensure physical security of locations where DL/ID cards
are produced
We do currently.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
We do currently.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
We do currently
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Louisiana issues for 4 years and 2 years. NGMV will
enable variations to dates less than 4 years.
Alternative document design if it does not meet federal
standard
We believe that La. Will meet standards
Legal Presence Requirement
We do currently.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
MCSIA
Maintain a state motor vehicle database that contains at a
minimum:
MCSIA and NGMV. Louisiana’s re-engineering
program is going to customer centrix whereby all
information on an individual in readily available.
All data fields printed on DL/ID cards
ASSUMPTIONS
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
NO
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?If your jurisdiction has
done an impact analysis please provide us with a copy of the analysis.
MAINE
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
Middle name will have to be spelled out
154. Full Legal Name
Moderate
155. Person’s Date of Birth
No impact
156. Person’s Gender
“
“
157. Person’s DL or ID Card Number
“
“
Current security features will satisfy
158. Digital Photograph of Person (and retention)
“
“
regulatory requirements
159. Person’s Address of Principle Residence
Minimal impact, will require statute change
160. Person’s Signature
No impact
Current barcodes will satisfy
161. Physical Security Features to prevent tampering,
counterfeiting or duplication
No impact
regulatory requirements
162. Common Machine Readable Technology:
No impact
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Moderate
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Moderate
Will necessitate statute, procedural, system, and
contractual changes
Will necessitate statute, procedural, system, and
contractual changes
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
No impact
Existing system will satisfy regulatory requirements
Major
Major
Major, unless e-mail is used
Major
Major
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Major
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Major
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
No impact
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
No impact
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Minimum procedural changes, unless the same checks
must be done as for an initial applicant, then major.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
No impact
Check other states if a person already was issued a DL in
another state
No impact
CDLIS and PDPS will satisfy regulatory requirements
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Ensure physical security of locations where DL/ID cards
are produced
Impact indeterminable without further
information/review
Private card manufacturer responsibility
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Impact indeterminable without further
information/review
Private card manufacturer responsibility
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
No impact
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
No impact
Alternative document design if it does not meet federal
standard
Contractual, statutory, system and procedural changes
Legal Presence Requirement
Will necessitate statutory, procedural, and system
changes.
Moderate/Major
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Major
Maintain a state motor vehicle database that contains at a
minimum:
No impact
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
Moderate
A non photo paper license
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
prove lawful presence.
MAINE
Jurisdiction Impact Analysis Real ID Act
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
1.
2.
3.
4.
5.
What is the DHS anticipated rule making plan, direction and process?
Are the eventual rules likely to require new IDs and licenses to be issued in place of existing IDs and licenses during a condensed period of time, or only in the
course of each state’s standard renewal cycle?
What is the likely timeline for overall implementation of the requirements of the act.
How will compliance be determined or achieved regarding the document verification requirements in the absence of such a verification infrastructure?
Who will pay the hundreds of millions or even billions which this currently unfunded federal mandate will cost in individual states and across the nation, and
how will DHS proceed if that funding continues to be absent.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Maine’s impact analysis necessarily ignores the significant uncertainty regarding DHS intentions for the actual implementation of the law. Consequently, this analysis
may vastly understate the impact on the State of Maine, but this can’t be known until the proposed rules or at least the likely direction of the rules are better understood.
Overall, the real ID act is estimated to have a major impact on Maine and on the motorists licensed by the state.
MARYLAND
Maryland MVA
Real ID Act - Impact Analysis
REAL ID ACT REQUIREMENT
IMPACT
Full Legal Name into Driver Licensing System (DLS)
Modify DLS application and databases.
(In Record, on Document)
Modify MVA demographic databases.
Modify all MVA business applications utilizing the
MVA demographic database.
ASSUMPTIONS
Assumes MVA will maintain a single demographic
database for all business applications. This will
necessitate applying the same identity standards to all
business applications and will require MD legislative
changes.
If segregated databases are utilized, the impact will be
limited to the DLS application and associated databases.
May require MD legislation to resolve database
discrepancy, precedence and synchronization issues.
Have following data elements/features on the document:
1.
Full legal name - Modify all card layouts to
accommodate.
2.
Date of Birth – In compliance
3.
Gender – In compliance
4.
Card Number – In compliance
5.
Digital Photo – In compliance
6.
Residence Address – In compliance
7.
Signature – In compliance
8.
Security features – In compliance
9.
Machine Readable – In compliance
163. Full Legal Name
164. Person’s Date of Birth
165. Person’s Gender
166. Person’s DL or ID Card Number
167. Digital Photograph of Person (and retention)
168. Person’s Address of Principle Residence
169. Person’s Signature
170. Physical Security Features to prevent
tampering, counterfeiting or duplication
171. Common Machine Readable Technology:
1.
Certain card features/graphics may need to be
removed in order to physically fit the full legal
name on the cards.
2.
None
3.
None
4.
None
5.
None
6.
Assumes only a single address will be printed on
cards.
CDL currently uses mailing address on card. MD
Legislative changes are required to place
residence address on CDL card.
7.
None
8.
Assumes that hologram, UV print, microprint
line, etc. are currently acceptable.
Card layout modification will be required when
future standards for AAMVA hologram and level 3
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
security features are implemented.
9. Assumes 2d barcode (PDF 417) is
acceptable and that additional data and
encryption will not be required.
Introduce temporary DL/ID cards and tying end of stay
to expiration of DL/ID card (or issuance for no more
than 1 year)
Temporary Card design in compliance.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
In compliance
Verification at Source:
Modify DLS to allow user definable expiration date on
current temporary cards.
1.
1. SSOLV
3. DEERS (DOD)
1.
SSOLV – None
SSN Non-eligibility Letter - Assumes AAMVA
interface to SSA exists and that SSA will provide
verification
2.
SAVE - Modify DLS eligibility check to
interface with SAVE.
2.
SAVE – MVA currently has an MOU with DHS
to utilize SAVE in a stand-alone configuration.
3.
DEERS - Modify DLS eligibility check to
interface with AAMVA interface to DEERS.
3.
4.
Other Jurisdictions (all data
verification/exchange) - Modify DLS
eligibility check to interface with AAMVA
interface to other jurisdictions.
DEERS - Assumes AAMVA interface to DOD
exists and that DOD will provide military ID
verification
4.
Other Jurisdictions - Assumes AAMVA interface
to other jurisdictions exists and that jurisdictions
will provide data and verifications.
5.
Birth Certificate: Assumes AAMVA interface to
NAPHSIS / State Vital Record Agencies exists
and that NAPHSIS will provide verifications.
4. Other jurisdiction (DL/ID card)
5. Birth certificate
Assumes AAMVA standard remains.
SSN Non-eligibility Letter - Modify DLS
eligibility check to interface with AAMVA
interface to SSA
Enabling your system to electronically verify
documentation with:
2. SAVE
SSOLV – In compliance
MD legislation will be required in order to tie the
expiration date to the end date of permitted stay.
6. Other…i.e. third party vendors
5.
Birth Certificate: Modify DLS eligibility
check to interface with AAMVA interface to
NAPHSIS / State Vital Record Agencies.
6.
Third Party Providers (address verification) Modify DLS eligibility check to interface
with third party provider(s).
7.
General
Manual Verification – If any or all of the
In reality there will likely be varying combinations
of electronic and manual validation occurring until
fully automated systems are in place in all states.
There will be significant staffing / cost impacts
during the earlier years when there is a high
percentage of manual verification occurring.
REAL ID ACT REQUIREMENT
IMPACT
interfaces cannot be established electronically,
significant increases in staffing, facilities and
customer wait time will result.
ASSUMPTIONS
6.
Third Party Providers (address verification) –
Assumes future federal regulation will allow third
party providers to verify certain data and that
interfaces can be implemented.
7.
General
Manual Verification – Electronic interfaces cannot
be established.
Developing access capability to SAVE system
Modify DLS eligibility check to interface with SAVE.
MVA currently has an MOU with DHS to utilize SAVE in
a stand-alone configuration. An amendment to the MOU
will be required to allow access to all required databases
and when a direct interface is implemented.
Introduce equipment into system to capture digital
images of identity source documents so that images can
be retained in electronic storage in a transferable format
Modify DLS to require capture of additional
documents.
May require legislation to enable transmission of data and
documents to other agencies depending on regulatory
requirements.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Increase long-term electronic storage capacity.
None
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
In compliance
None
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Modify DLS to include indicators signifying that
certain data and / or documents have been verified and
validated.
Assumes renewal transactions will not require revalidation
of all source documents / data.
Modify DLS eligibility check to interface with
AAMVA interface to other jurisdictions.
Assumes AAMVA interface to other jurisdictions exists
and that jurisdictions will provide data and verifications.
AAMVA to develop discrepancy resolution process.
Assumes AAMVA develops standardized resolution
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
Create application to transmit document images to
others.
Assumes a voluminous audit trail will not be required as
part of a validation indicator.
REAL ID ACT REQUIREMENT
IMPACT
resolve the discrepancy and take appropriate action
Check other states if a person already was issued a DL in
another state
Ensure physical security of locations where DL/ID cards
are produced
ASSUMPTIONS
processes for discrepancies.
Modify DLS eligibility check to interface with
AAMVA interface to other jurisdictions.
Assumes AAMVA interface to other jurisdictions exists
and that jurisdictions will provide data and verifications.
AAMVA to develop process for requesting termination
of DL/ID in original jurisdiction upon issuance to
DL/ID in the new jurisdiction.
Assumes AAMVA develops processes for requesting
termination of DL/ID in original jurisdiction upon issuance
to DL/ID in the new jurisdiction
In compliance.
Assumes current procedures and physical / electronic
security measures are adequate. This may be affected by
new regulations.
MVA is currently studying centralization / outsourcing of
card production and fulfillment.
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security clearance
requirements
Possible significant cost and time impacts depending
on clearance standards established. Could cause
staffing shortage if clearances are not completed
quickly and temporary authority is not granted.
Assumes standards for security clearances are established.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
In compliance with current AAMVA level 1 & 2.
Assumes current AAMVA standard remains.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
In compliance
MD Legislation required limiting the validity period of
military license holders who are stationed outside of
Maryland.
Alternative document design if it does not meet federal
standard
None
Assumes Maryland will fully comply with Real ID Act
and will not issue a driving certificate.
Legal Presence Requirement
Transactions for temporary DL and ID cards should
decrease.
State legislation required if this requirement is pursued.
May require MD legislation authorizing MVA to conduct
certain types of security checks.
In the likelihood that all personnel will require level 2
training an additional cost and staffing impact will occur
for initial and ongoing training.
Renewal transactions for those eligible will increase
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
due to shorter renewal periods although this will be
tempered by the limited number of renewal periods the
individual may qualify for.
Overall the expected outcome is a net decrease in DL
and ID transactions.
Provide electronic access to all other states to
information contained in the motor vehicle database of
the state
Develop and implement a data exchange server and
database separate from the production environment.
Maintain a state motor vehicle database that contains at a
minimum:
Any change in the amount of data captured and stored
will require modifications to the DLS application and
the DLS databases.
All data fields printed on DL/ID cards
Significant data traffic demands will necessitate a separate
environment to minimize/eliminate impacts on the
production DLS environment.
None
motor vehicle driver’s histories, including
motor vehicle violations, suspensions and
points on licenses
Optional
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
Create new product flow /eligibility requirements in
DLS to produce certificate.
State legislation required if this option is pursued.
Questions:
General
1)
What is the effective date that states must be compliant, not allowing for any extensions?
2)
Since the definition of "state" does not include Canada, does that affect reciprocity and the Driver License Compact?
Credential Review
3)
Our interpretation is that all existing driver license and identification card holders, as well as new applicants, will have to submit
qualifying ID documents upon their next renewal after the implementation date of the bill. That documentation would have to be
scanned and confirmed with the issuers. Is this a correct interpretation?
4)
Since it is highly unlikely that all state vital record agencies will be electronically connected for authentication upon the effective
date of the legislation, how are verifications of birth certificates expected to be handled?
MARYLAND
Maryland MVA
Real ID Act - Impact Analysis
5)
Will third party verification be permitted if direct verifications by the third party are made with the issuers of the source ID
documents?
6)
The retention cycle requires paper documentation be maintained for 7 years and, if electronically stored, for 10 years. How will this
affect required documents at the time of renewal? If once we authenticate the ID document, can we use an indicator on the record
and not require documentation at each renewal cycle?
7)
Does the Real ID Act preclude the establishment of license or ID card renewal by mail or internet on subsequent renewals after the
first renewal under the Real ID Act if a state establishes a reliable process to verify or confirm the renewing applicant’s information
and documents on file?
8)
What does "common machine readable technology" mean? What is the standard? Are states required to encrypt data?
9)
How do the requirements of The Real ID act apply to handling changes of address and name with respect to DL and ID cards.
10)
We have a policy that allows an individual to carry a change of name or address card until their next renewal cycle. Will this policy
need to be changed to be in accordance with the Real ID Act? In other words, would we have to require everyone to appear in
person to receive a new license with their new name or address?
11)
Maryland permits an individual, under the common law of the state, to change their name without a court process. Would a
common law name change meet the definition of a person's full legal name as defined in this law?
Minimum Issue Standards
12)
What is meant by the statement "…refuse to issue a driver's license or ID card to a person holding a driver's license issued by
another state without confirmation that the person is terminating or has terminated the driver's license."
MARYLAND
Maryland MVA
Real ID Act - Impact Analysis
13)
For people who are not authorized to have a social security number, how do we validate the authenticity of the letter they receive
from Social Security since that is not currently possible through SSOLV?
Verification of Documents
14)
What does Homeland Security consider an effective procedure to confirm or verify a renewing applicant's information?
15)
What if an issuer of a credential does not cooperate in providing information when MVA is trying to verify the ID source?
Background Checks
16)
What is the standard for an acceptable background check for employees involved in the process of establishing ID?
17)
What are disqualifying events in an employee's background that prevent them from being involved in confirming ID credentials?
MASSACHUSETTS
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
We will need a statue change and software changes
to meet this requirement. We currently require only
middle initial.
Have following data elements/features on the document:
We will need statue changes and software changes to
add the full legal name and gender requirements to
our license documents. We are in compliance with all
of the other required fields.
172. Full Legal Name
173. Person’s Date of Birth
174. Person’s Gender
175. Person’s DL or ID Card Number
176. Digital Photograph of Person (and retention)
177. Person’s Address of Principle Residence
178. Person’s Signature
179. Physical Security Features to prevent tampering,
counterfeiting or duplication
180. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
We do not have statutory authority to issue this type
of temporary license. Statutory change required.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
As above we will need the legal authority to create
and issue this type of license document.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
Verification at Source:
IMPACT
ASSUMPTIONS
We meet the requirements of #1 and #6. We are in
the process of issuing a contract for Document
Authentication Equipment to be installed in license
issuing locations.
We are assuming that there will be a grant process to
assist us in funding the verification systems that are
required to be in compliance with #2,3,4,and 5,
Developing access capability to SAVE system
We will need to develop our training process and
sign an MOU with SAVE. This will also require
software changes to our system.
We assume that there will be grant money available to
fund this requirement.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
We are exploring the cost of implementing document
digital imaging equipment to satisfy this
requirement.
We assume that there will be grant money available to
fund this requirement.
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
This equipment is very expensive! This requirement
will have a large impact on our Agency.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
We are in compliance with the paper documents and
see the above response on the image requirement.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
We are in compliance.
Establish an effective procedure to confirm or verify a
Depending on definitions used for “verifying” and
“renew”, impact could be monumental if required to
We assume that there will be large grants available to
fund the systems and networks required to perform these
REAL ID ACT REQUIREMENT
IMPACT
renewing applicant’s information
“call back” entire license population.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
We perform this resolution today
Check other states if a person already was issued a DL in
another state
Depending on process defined, system and process
implications could be major.
Ensure physical security of locations where DL/ID cards
are produced
We are in compliance
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
We are in compliance
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
We are introducing Document Authentication
equipment and are exploring training programs.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
We are in compliance.
Alternative document design if it does not meet federal
standard
We are in compliance.
Legal Presence Requirement
We are not in compliance. We will need a statue
change.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
We are in compliance.
Maintain a state motor vehicle database that contains at a
minimum:
We are in compliance.
ASSUMPTIONS
functions.
We assume that a national network and system will be in
place to do this electronicly.and grants will be available
to fund our requirements.
We assume there will be grant money available to assist
us.
We assume if the license card design is changed that
grant money will be available to fund the changes and
implementation of a new license document.
REAL ID ACT REQUIREMENT
IMPACT
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Our Legislature is not in favour of this option at this
time.
ASSUMPTIONS
MICHIGAN
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
Requires programming to increase size of field.
Need state law change to provide authority to
require full legal name.
One field or multiple fields to separate first, middle,
last names?
Have following data elements/features on the
document:
Card re-design to incorporate common machine
readable technology and physical security
features.
Need state law change to specify “full legal
name”.
2D barcode as the common machine readable
technology?
Will mag strip also be required?
Need to know what data to encode.
Card re-design
Will there be a common design element to
distinguish all state’s temporary cards, such as
color of card?
Will there be a national repository for birth records?
Will PDPS be expanded to all drivers?
Full Legal Name
Person’s Date of Birth
Person’s Gender
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent tampering,
counterfeiting or duplication
Common Machine Readable Technology
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Verification at source:
Enabling your system to electronically verify
Documentation with:
1.SSOLVE
2.SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL?ID card)
5. birth certificate
6. Other…i.e. third party vendors
Programming to interface with SSOLV, SAVE,
DEERS.
MOUs for exchange of data.
Need state law change to authorize verification
for driver’s license and ID cards
Need law change for ID law to parallel driver’s
license.
What fees are charged by each verification
system?
REAL ID ACT REQUIREMENT
IMPACT
Developing access capability to SAVE system
Requires programming
Introduce equipment into system to capture digital
images of identity source documents so that images
can be retained in electronic storage in a transferable
format
Retain paper copies of source documents for a
minimum of 7 years or images of source documents
presented for a minimum of 10 years
Requires purchase of scanning equipment for
field offices. Needs state law change to capture
and retain digital images of identity source
documents.
Increased storage costs
Introduce temporary DL/ID cards and tying end of stay
to expiration of DL/ID card (or issuance for no more
than 1 year)
Subject each person applying for a driver’s license or
identification card to mandatory facial capture
Requires programming to create field for
temporary expiration date, state law change to
authorize temporary expiration date.
Increased storage costs. May require
programming to indicate no license is issued.
Major procedure change if need to track
incomplete transactions. May require state law
change to authorize mandatory facial image
capture at time of application.
May require some type of authentication of
renewing applicant. State law change required to
verify applicant’s information when renewing
license or card.
May require a two-step process fro SSN
verification involving both SSA and other states.
State law change to require SSN on Personal ID
cards
Establish an effective procedure to confirm or verify a
renewing applicant’s information
In the event that a social security account number is
already registered to or assicaited with another
person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take
appropriate action.
Check other states if a person already was issued a
DL in another state
Ensure physical security of locations where DL/ID
cards are produced
May require programming for an up-front check of
other states.
May need additional language in vendor contract
ASSUMPTIONS
What steps are involved in entering into an MOU
for the SAVE system (required by 9/30/05)? Are
specifications available? Who is the contact?
All states will use the same common transferable
format. Need to know what this format will be.
Why are there different storage timeframes
between paper and electronic methods?
Need explanation of an effective proceedure
Need clarification on how state resolves the
discrepancy.
Expansion of PDPS. Also, will ID cards be covered
here? No information currently shared with other
states on IDs. Need clarification as to what
“confirms the person is terminating or has
terminated” the out of state license means.
Will there be minimum or specific requirements for
“physical security”?
REAL ID ACT REQUIREMENT
IMPACT
Subject all persons authorized to manufacture or
produce DL/ID cards to appropriate security clearance
requirements
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards.
Alternative document design if it does not meet
federal standard
Legal presence requirement
May need additional language in vendor contract
Provide electronic access to all other states to
information contained in the motor vehicle database of
the state
Maintain a state motor vehicle database that
Contains at a minimum:
All data fields printed on DL/ID cards
Motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on licenses
Optional
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
ASSUMPTIONS
Need criteria for discharge or non-hire decisions.
Need specific definition of “appropriate security
clearance requirements.”
Michigan complies.
Card re-design
MI needs state law change to require legal
presence
State law change needed to require access to
Personal ID card data and highly restricted
personal information.
Michigan complies.
Will there be specific re-design standards?
Will other states need access to images and
source documents? Need specific list of data
elements required.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
To what degree must states verify residency? For example, must they confirm an account with a utility, or is it sufficient for the
applicant to present a utility bill that we know “looks authentic”?
What photo identity documents will be acceptable identity documents? Could a state driver’s license be an acceptable photo identity
document?
Will a marriage license be acceptable documentary evidence of a name change? If so, what if the applicant has not yet changed
their name on Social Security records?
What documents are acceptable evidence of date of birth? (e.g., Government issued only? Hospital issued?)
What is proof of an SSN? Is a W-2 or pay stub acceptable or must the applicant present the card?
What is verification that a person is ineligible for a SSN? Is a passport with temporary visa evidence that the applicant has no SSN?
Will SSA provide a standard document that the person is ineligible or is not required to have a SSN?
Is proof of residence required only at issuance? Must license holders present proof of residence when they make a change of
address?
What is valid evidence of legal status? Can an SSN card be that evidence?
If an applicant presents a passport and temporary visa, do we need to verify the SSN?
How will the expiration date be determined for temporary licenses? Does the SAVE program provide information on Visa
expirations?
Can applicants under 18 have different requirements, especially for residency? What might be acceptable proof of residency for
these applicants? Will parental approval and/or parental documentation suffice?
Are corrections, duplicates, and renewals “applications?” Must applicants provide the same evidence of identity at each visit?
Must a state capture a new image for a license renewal, correction, or duplicate?
When a licensee moves from one state to another, does the former state transfer identity document images to the new state of
record?
The Congressional Record refers to “reissuing a license.” What is meant by re-issue a license? Are renewals covered? Duplicates
(in cases of lost licenses)? Corrections (in cases of name changes)?
What are effective procedures for confirming and verifying a renewing applicant’s information? Does this require a face-to-face
transaction or will capture of a signature suffice? Will a PIN authorization be considered effective? If so, under what
conditions would a PIN-based system be acceptable?
What must the state do to “resolve discrepancies” for SSN non-matches?
Per Brian, this is not what is required by law. See note above in table that says “Need clarification as to what “confirms the person
is terminating or has terminated” the out of state license means.”
How will the process work for ID card holders who move from state to state? Are states supposed to cancel an ID card? Can an
applicant hold an ID card in more than one state? Are states required to share ID card information?
Are the security clearance requirements only for employees at production facilities? What is the criteria for a discharge or non-hire
21.
decision? How often must the employee be checked?
What information will be required to be encoded on bar code? Will mag stripe be used as well?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
to track incomplete transactions. May
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
require state law change to authorize
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
mandatory facial image capture at time of
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
application.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Establish an effective procedure to confirm
May require some type of authentication
Need clarification of an effective
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
or verify a renewing applicant’s information
Card re-design.
of renewing applicant. State law change
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
procedure.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
required to verify applicant’s information
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
when renewing a license or card.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
In the event that a social security account
May require a two-step process for SSN
Need clarification of how the state
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
number is already registered to or
Card re-design.
verification involving both SSA and other
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
resolves the discrepancy.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
associated with another person to which any
Card re-design.
states.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
state has issued a DL/ID card, the state shall
Card re-design.
State law change to require SSN on
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
Card re-design.
it is a temporary document with a “different
than usual” expiration date
resolve the discrepancy and take appropriate Personal ID Cards.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
action
Card re-design.
State law change may be needed to
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
eliminate current waiver of requirement
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
for those with no SSN.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Check other states if a person already was
May require programming for an up-front
Expansion of PDPS. Also, will ID cards be
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
issued a DL in another state
Card re-design.
check of other states.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
covered here? No information currently
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
shared with other states on IDs.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Need clarification as to what “confirms the
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
person is terminating or has terminated”
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
the out of state license means.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Ensure physical security of locations where
May need additional language in vendor
Will there be minimum or specific
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
DL/ID cards are produced
Card re-design.
contract.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
requirements for “physical security”?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Subject all person’s authorized to
May need additional language in vendor
Need criteria for discharge or non-hire
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
manufacture or produce DL/ID cards to
Card re-design.
contract.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
decision.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
appropriate security clearance requirements
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Need specific definition of “appropriate
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
security clearance requirements.”
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Establish fraudulent document recognition
Michigan complies.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
training programs for appropriate employees
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
engaged in the issuance of DL/ID cards
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Limit period of validity of DL/ID cards that are Michigan complies. Current licenses
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
not temporary to a period not exceeding 8
Card re-design.
valid for four-year term.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
years
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Alternative document design if it does not
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
meet federal standard
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Will there be specific design standards?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Legal Presence Requirement
Michigan needs state law change to
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
require legal presence.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Provide electronic access to all other states
State law change needed to require
Will other states need access to images
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
to information contained in the motor vehicle
Card re-design.
access to Personal ID Card data and
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
and source documents?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
database of the state
Card re-design.
highly restricted personal information.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
Need specific list of data elements
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
required.
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Maintain a state motor vehicle database that
Michigan complies.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
contains at a minimum:
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
All data fields printed on DL/ID cards
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
motor vehicle driver’s histories,
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
including motor vehicle violations,
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
suspensions and points on licenses
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Optional
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
Card re-design.
Development and issuance of a certificate of
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
driving – not for federal identification
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
purposes – for those who cannot prove
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver
Licensing System (in Record, on Document)
IMPACT
Requires programming to increase size
of field. Need state law change to
provide authority to require full legal
name.
Have following data elements/features on the Card re-design to incorporate common
document:
machine readable technology and
physical security features.
Full Legal Name
Need state law change to specify “full
Person’s Date of Birth
legal name”.
Person’s Gender
ASSUMPTIONS
One field or multiple fields to separate
first, middle, last names?
2D barcode as the common machine
readable technology?
Will mag strip also be required?
Need to know what data to encode.
Person’s DL or ID Card Number
Digital Photograph of Person (and retention)
Person’s Address of Principle Residence
Person’s Signature
Physical Security Features to prevent
tampering, counterfeiting or duplication
Common Machine Readable Technology
Introduce temporary DL/ID cards and tying
end of stay to expiration of DL/ID card (or
issuance for no more than 1 year)
Requires programming to create field for
temporary expiration date, state law
change to authorize temporary expiration
date.
Amending card design to show/indicate that
it is a temporary document with a “different
than usual” expiration date
lawful presence.
Card re-design.
Will there be a common design element to
distinguish all states’ temporary cards,
such as color of card?
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
To what degree must states verify residency? For example, must they confirm an account with a utility, or is it sufficient for the
applicant to present a utility bill that we know “looks authentic”?
What photo identity documents will be acceptable identity documents? Could a state driver’s license be an acceptable photo
identity document?
Will a marriage license be acceptable documentary evidence of a name change? If so, what if the applicant has not yet
changed their name on Social Security records?
What documents are acceptable evidence of date of birth? (e.g., Government issued only? Hospital issued?)
What is proof of an SSN? Is a W-2 or pay stub acceptable or must the applicant present the card?
What is verification that a person is ineligible for a SSN? Is a passport with temporary visa evidence that the applicant has no
SSN? Will SSA provide a standard document that the person is ineligible or is not required to have a SSN?
Is proof of residence required only at issuance? Must license holders present proof of residence when they make a change of
address?
What is valid evidence of legal status? Can an SSN card be that evidence?
If an applicant presents a passport and temporary visa, do we need to verify the SSN?
How will the expiration date be determined for temporary licenses? Does the SAVE program provide information on Visa
expirations?
Can applicants under 18 have different requirements, especially for residency? What might be acceptable proof of residency
for these applicants? Will parental approval and/or parental documentation suffice?
Are corrections, duplicates, and renewals “applications?” Must applicants provide the same evidence of identity at each visit?
Must a state capture a new image for a license renewal, correction, or duplicate?
When a licensee moves from one state to another, does the former state transfer identity document images to the new state of
record?
The Congressional Record refers to “reissuing a license.” What is meant by re-issue a license? Are renewals covered?
Duplicates (in cases of lost licenses)? Corrections (in cases of name changes)?
What are effective procedures for confirming and verifying a renewing applicant’s information? Does this require a face-to-face
transaction or will capture of a signature suffice? Will a PIN authorization be considered effective? If so, under what
conditions would a PIN-based system be acceptable?
What must the state do to “resolve discrepancies” for SSN non-matches?
Per Brian, this is not what is required by law. See note above in table that says “Need clarification as to what “confirms the
person is terminating or has terminated” the out of state license means.”
How will the process work for ID card holders who move from state to state? Are states supposed to cancel an ID card? Can
an applicant hold an ID card in more than one state? Are states required to share ID card information?
Are the security clearance requirements only for employees at production facilities? What is the criteria for a discharge or nonhire decision? How often must the employee be checked?
21.
What information will be required to be encoded on bar code? Will mag stripe be used as well?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
MINNESOTA
Jurisdiction Impact Analysis Real ID Act (MINNESOTA)
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
None.
Minnesota believes it currently meets this requirement.
Have following data elements/features on the document:
None.
Minnesota believes it currently meets this requirement.
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
None.
Minnesota believes it currently meets this requirement.
For persons who are authorized to temporarily reside in
the US, on the lower right hand corner of the card is
printed “Status Check,” followed by the date on which
the card will be cancelled unless evidence of extended
authorization is presented and an application for a new
card is made. However, the card does not say
“TEMPORARY.”
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
None.
See above.
181. Full Legal Name
182. Person’s Date of Birth
183. Person’s Gender
184. Person’s DL or ID Card Number
185. Digital Photograph of Person (and retention)
186. Person’s Address of Principle Residence
187. Person’s Signature
188. Physical Security Features to prevent tampering,
counterfeiting or duplication
189. Common Machine Readable Technology:
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
expiration date
Verification at Source:
1.
Enabling your system to electronically verify
documentation with:
MN is in the preliminary planning stages of
implementing SSOLV.
2.
SAVE has not been explored yet.
1. SSOLV
3.
MN is not familiar with DEERS (DOD).
2. SAVE
4.
Would require additional resources to
implement.
5.
MN is exploring in-state vital records
verification processes and is interested in
EVVERS.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
Item 4. Minnesota assumes that verification of documents
with other states would be a national project coordinated
by AAMVA.
Item 6. It is not known what third party vendors of source
documents exist.
6. Other…i.e. third party vendors
Developing access capability to SAVE system
SAVE has not been explored yet. Would require
additional resources to implement.
MN assumes there are costs to set up and use the system.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
May require enhancement of existing imaging
process.
MN has a digital imaging system that is currently under
review for process improvements.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Will require amending legislation or administrative
rules related to document retention. There may be
some storage or resource issues.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None.
MN currently requires facial image capture, but accepts
applications for variances on a case by case basis
(primarily from persons with religious objections).
Establish an effective procedure to confirm or verify a
renewing applicant’s information
More detail is required to determine impact—
specifically which information.
MN verifies the applicant’s image and residence address
by mailing the card and prohibiting forwarding of mail.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve
This has not been implemented yet, but should not be
insurmountable.
MN has a grant from FMCSA to assist in the verification
process and will establish a procedure once our batch
verification with the SSA is completed.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
the discrepancy and take appropriate action
Check other states if a person already was issued a DL in
another state
Requires DRIVERS or some other mechanism for
automated confirmation with other jurisdictions,
which does not currently exist.
MN assumes that other jurisdictions face the same
problem and a solution will be developed with
AAMVA’s assistance.
Ensure physical security of locations where DL/ID cards
are produced
None, if this refers to the card production factory
only.
This is currently required of our contracted card vendor.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
None.
This is currently required of our contracted card vendor
and of new employees of the Driver and Vehicle Services
Division. MN assumes this requirement does not apply to
persons who accept applications but do not issue cards.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Minimal
This is already in place, although the programs could be
expanded.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None.
MN has a four-year renewal cycle.
Alternative document design if it does not meet federal
standard
None.
MN believes it meets the federal standard.
Legal Presence Requirement
None.
MN believes it meets the legal presence requirement.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Development required.
MN assumes that standards will be developed for
information sharing among jurisdictions.
Maintain a state motor vehicle database that contains at a
minimum:
None, except that MN does not use a point system.
MN will need to migrate its current technology system to
a platform that will allow the data to be exchanged with
other states (currently using a mainframe system which
was created in the 1980s).
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
licenses
Optional
N/A.
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
How will states exchange information between jurisdictions? How can states meet some of the requirements
until the federal systems are in place to allow exchange of information.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
MISSISSIPPI
Mississippi Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
None
Have following data elements/features on the document:
None
ASSUMPTIONS
190. Full Legal Name
191. Person’s Date of Birth
192. Person’s Gender
193. Person’s DL or ID Card Number
194. Digital Photograph of Person (and retention)
195. Person’s Address of Principle Residence
196. Person’s Signature
197. Physical Security Features to prevent tampering,
counterfeiting or duplication
198. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Introduce into law for legislative action. Currently
have 1 year license for Non-US citizen license.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
None
Verification at Source:
Software/Program changes
Enabling your system to electronically verify
documentation with:
The 1 year Non-US citizen license/ID card we currently
have in place will not meet the standards outlined.
Would have allowed access
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
System/Program changes
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Procurement process. Equipment & system/program
changes.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
None
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None
Establish an effective procedure to confirm or verify a
renewing applicant’s information
None
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
None
Check other states if a person already was issued a DL in
another state
System/program changes
Ensure physical security of locations where DL/ID cards
are produced
None
Will be made available to all states
Assuming there was a national system.
REAL ID ACT REQUIREMENT
IMPACT
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
None
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Cost
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None
Alternative document design if it does not meet federal
standard
None
Legal Presence Requirement
None
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Currently use CDLIS information
Maintain a state motor vehicle database that contains at a
minimum:
None
ASSUMPTIONS
AAMVA will provide the training at little or no cost to
the states.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
None
Mississippi will not provide this document.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
MISSOURI
Jurisdiction Impact Analysis Real ID Act
Missouri
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
High – Requires system re-design
ASSUMPTIONS
Committee needs to define “full legal name”
Have following data elements/features on the document:
199. Full Legal Name
1.
High
1.
.
200. Person’s Date of Birth
2.
No impact
2.
.
201. Person’s Gender
3.
No impact
3.
.
202. Person’s DL or ID Card Number
4.
No impact
4.
.
203. Digital Photograph of Person (and retention)
5.
No impact
5.
.
204. Person’s Address of Principle Residence
6.
No to low impact
6.
205. Person’s Signature
7.
No impact
7.
.
206. Physical Security Features to prevent tampering,
counterfeiting or duplication
8.
High
8.
9.
Low to moderate
New equipment, consumables and contract rebid??
9.
(Low) Use PDF417 today (Moderate) If required
to store digital signature and photo and zone
change
207. Common Machine Readable Technology:
Possible expansion based on requirements
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
No to low impact
7/1/05 implemented tie end of stay to expiration– (low) if
required to add “Temporary” to header
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Low impact
(Low) if header change only
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
1.
No impact
1.
Implemented
2.
No impact – implemented 7/1/05
2.
3.
High
Implemented Web version – would prefer
AAMVA interface with lower access fees
4.
High
3.
5.
High
to 5 – (High) When will systems be available,
when will specs. be available and what are
associated cost??
5. Birth certificate
6. What system will be available to verify US
passports?
6. Other…i.e. third party vendors
Developing access capability to SAVE system
High
If programming required to interface to AAMVA
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
High
Scanners in 184 offices
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
High
Data and paper storage considerations
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Moderate – based on definition of “facial image
capture”
If Facial image = Facial recognition will need legislation
Establish an effective procedure to confirm or verify a
renewing applicant’s information
TBD – Need to define
In the event that a social security account number is already
registered to or associated with another person to which any
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
Define action – Low to High impact
Low – Today’s version we call another state
High – Develop systematic approach
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Check other states if a person already was issued a DL in
another state
High – Need to define
Electronic verification ????
Ensure physical security of locations where DL/ID cards
are produced
High – Depends on requirement
Could be high if required to install cameras, special safes,
etc.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Low to moderate impact
BRC
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Low to moderate impact
Would need to roll out to 184 offices, FTE time and
travel.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Low
Legislative change for non-expiring ID for 70 years and
older. Already in place for other DL/ID types
Alternative document design if it does not meet federal
standard
Assume High impact
Need requirements. We will need a complete re-design to
adopt the UID AAMVA recommendations. Also will
require legislation and possible contract re-bid.
Legal Presence Requirement
Low to High
Missouri implemented new lawful presence requirements
7/1/05. Requirements will determine what changes will
need to be made,
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Low to High
Need defined. (low) data exchange only as we do today
(high) if we need to pass photo and signature
Maintain a state motor vehicle database that contains at a
minimum:
No impact
We do this today unless requirements are changed
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Assume High impact
Need requirements. We will need a complete re-design,
legislation and possible contract re-bid.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
When will requirements be defined and how much time will we have to program?
Three years is a very short period of time considering the requirements and the systems that are still under development.
Will grant money be available?If your jurisdiction has done an impact analysis please provide us with a copy of
the analysis.
MONTANA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
$40,000 Will require database changes to
accommodate size
Have following data elements/features on the document:
1.
Full Legal Name
2.
Person’s Date of Birth
3.
Person’s Gender
4.
Person’s DL or ID Card Number
5.
Digital Photograph of Person (and retention)
6.
Person’s Address of Principle Residence
7.
Person’s Signature
8.
Physical Security Features to prevent tampering,
counterfeiting or duplication
9.
Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Verification at Source:
Enabling your system to electronically verify
Items 2-9 will have no impact
Montana already has the capability to issue a
card for 1 to 8 year cycles
$!5,000 for system development
$40,000
This requirement will need a standard for all
the jurisdictions to follow
ASSUMPTIONS
REAL ID ACT REQUIREMENT
documentation with:
IMPACT
1.
SSOLV - $15,000
1. SSOLV
2.
SAVE - $40,000
2. SAVE
3. DEERS (DOD) $40,000
3. DEERS (DOD)
4.
Other jurisdiction (DL/ID) will include
in the card cost
5.
Birth Certificate - Will include in the
card cost
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
$40,000
$1,300,000--initial cost plus maintenance and
equipment replacement
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Included in $1,300,000 cost.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
No Impact current process
Establish an effective procedure to confirm or verify a
renewing applicant’s information
$20,000 for development and staff training
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
$40,000 ---2 additional staff
Check other states if a person already was issued a DL in
another state
Ensure physical security of locations where DL/ID cards
$100,000-- 5 additional staff is process is
done manually. If electronic $500,000
Note** Need DRIVerS
No impact--current
process
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
are produced
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
$200.00
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
$40,000
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Alternative document design if it does not meet federal
standard
$30,000
Legal Presence Requirement
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
$500,000
Maintain a state motor vehicle database that contains at a
minimum:
No Impact --current process
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Unknown at this time
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
ASSUMPTIONS
1.
Will there be federal funding for the requirement of the Real ID Act?
2. How does the federal Government envision how jurisdictions will check to see if a driver is licensed in
another state without a common infrastructure and license format?
3.
Will there be a standard developed for temporary DL/ID formats?
4.
Careful consideration to balancing customer service and requirements?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
NEBRASKA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Will require legislation – programming to AS400,
mainframe and vendor’s system to capture and store
full legal name
Have following data elements/features on the document:
Full legal name: see above
10. Full Legal Name
Comply
11. Person’s Date of Birth
Comply
12. Person’s Gender
Comply
13. Person’s DL or ID Card Number
Comply
14. Digital Photograph of Person (and retention)
Comply
15. Person’s Address of Principle Residence
Comply
16. Person’s Signature
DHS rule will dictate – anticipate some type of
biometric
17. Physical Security Features to prevent tampering,
counterfeiting or duplication
18. Common Machine Readable Technology:
Nebraska does not currently have a biometric –
would require programming and legislation - cost
unknown
DHS rule will dictate – Nebraska uses a bar code and
digital watermark - cost unknown
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Will require legislation – development of 35 new
card types
Increase in workload unknown – cannot do with
existing staff
Cost unknown
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Verification at Source:
Comply with SSOLV
Enabling your system to electronically verify
documentation with:
2. SAVE
Nebraska accessed SAVE in a pilot project for 6
months. The system is not well developed, it
requires a great deal of staff time to follow up on
additional contact with UCSIS and applicant –
cannot do with existing staff
3. DEERS (DOD)
I don’t know what this is
4. Other jurisdiction (DL/ID card)
No such database exists – manual process would be
virtually impossible
1. SSOLV
5. Birth certificate
6. Other…i.e. third party vendors
No link to Nebraska or national information
currently exists
Cost unknown
Developing access capability to SAVE system
This is not difficult - SAVE has an MOU and the
link is easy to develop.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Nebraska does not retain copies of source documents
– Will require building an imaging system and
upgrading the State’s network infrastructure – impact
in the millions of dollars
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
See above – We will not retain paper copies
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Will require DMV examiners to have digital camera
equipment that they currently do not have – cost
unknown
Establish an effective procedure to confirm or verify a
DHS Rule will have to state the process so it is
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
renewing applicant’s information
uniform throughout the states
In the event that a social security account number is already
registered to or associated with another person to which any
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
Will require staff time – cannot do with existing staff
- cost unknown
Check other states if a person already was issued a DL in
another state
No database exists for electronic checking – manual
process would be very time consuming if not
impossible - cost to develop unknown
Ensure physical security of locations where DL/ID cards
are produced
Cannot currently ensure physical security of
locations – Nebraska’s offices are located in county
courthouses – DMV has no control over the physical
security
The definition of “ensure physical security” will
control how this standard is met.
Cost unknown
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Nebraska DMV does background checking on its
staff – however cards are issued by county treasurer
– many do not do background checks – DMV has
absolutely no control over the locally elected
officials and how they run their offices
Cost unknown
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Nebraska DMV has engaged in a fraudulent doc
recognition training program – County treasurers do
not have such a program
Cost unknown
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Nebraska’s card is valid for 5 years
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Alternative document design if it does not meet federal
standard
Will require 35 new card types – cost unknown
Legal Presence Requirement
Will require legislation
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
No such database exists - cost unknown
Maintain a state motor vehicle database that contains at a
minimum:
Comply
ASSUMPTIONS
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Not required under the federal law – not even
mentioned anywhere in the federal law -
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
The law is ambiguous regarding whether this means that current valid documents are grandfathered or whether
a general reissuance of all documents that comply with the federal law is required.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Additional Comments from E-mail Message:
It is very difficult to put into just a few words the impact of the Real ID requirements. I believe that
Nebraska will be greatly impacted by the federal standards. By statute we are tied to using the county
treasurers (locally elected
officials) as agents for the DMV. The counties issue all of the documents. This process does not lend itself
well to complying with the new federal standards. Nebraska may have to consider extreme measures and possibly a
complete reorganization depending on what the DHS rule dictates. DHS must issue this rule in a timely fashion.
Beverly Neth
Director
Nebraska DMV
402.471.3900
NEVADA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
No Impact
Have following data elements/features on the document:
1. No impact
19. Full Legal Name
2. No impact
20. Person’s Date of Birth
3. No impact
21. Person’s Gender
4. No impact
22. Person’s DL or ID Card Number
5. No impact
23. Digital Photograph of Person (and retention)
6. Person’s Address of Principle Resident •
•
Statutory change to NRS 483.340
Several application and form changes,
26. Physical Security Features to prevent tampering,
counterfeiting or duplication
•
Approximately 250 hours of DMV application
programming to complete computer change
27. Common Machine Readable Technology:
•
Public notices will need to be generated
24. Person’s Address of Principle Residence
25. Person’s Signature
ASSUMPTIONS
6. Current Nevada law with respects to the address on
the face of a driver’s license do not conform to H.R. 418
7. No impact
8. Physical security features •
There will be a substantial impact on the
information technology staff to complete
DMV application programming changes
•
It will effect the card design
•
The contract with our vendor could require
amendments, increased costs under the vendor
contract could occur and ultimately, a request
to increase the cost of the driver’s license to
the public may be necessary to cover added
expenses to produce the card.
8. If the established requirements are different or exceed
what is currently in place, an impact will exist to
implement the required features. For example, if
biometrics is mandated there will be a change to system
requirements. The assumption is the Secretary will
require changes.
9. The assumption is the Secretary will maintain the
current AAMVA 2-D bar code standards.
REAL ID ACT REQUIREMENT
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
IMPACT
•
9. No impact
•
Additional staff hours to effect policy and
procedure changes
MVIT programming to automate the
expiration at one year
•
•
Statutory and/or regulatory changes
identifying the one-year expiration if no
immigration end-of-stay date provided.
•
Public notices will need to be generated
•
Impact on the information technology staff to
complete DMV application programming
changes
•
Fiscal Impact
•
Vendor Contract revisions
ASSUMPTIONS
Current Nevada law and practices do not conform with
the requirements of H.R. 418 regarding the one-year
expiration period.
Any changes from the existing design specifications are
billable enhancements by the contractor.
Verification at Source:
1. No Impact
2. Required fees for system use.
Enabling your system to electronically verify
documentation with:
2. Minor fiscal impact
3. Required fees for system use.
3. Minor fiscal impact
5. In state - $8.00 charge per verification and 2 to 6
week process for manual verification.
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. No impact
5. Large fiscal impact and unreasonable delays in
processing
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Introduce equipment into system to capture digital images
No impact
•
Substantial fiscal impact to acquire hardware
All 21 field offices will need to be equipped with digital
REAL ID ACT REQUIREMENT
of identity source documents so that images can be
retained in electronic storage in a transferable format
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
IMPACT
and contract services
•
Impact on information technology staff to
program DMV application to retain and
transfer scanned imaged
•
Large fiscal impact
•
Purchase of additional scanners and copy
machines in field offices
•
Additional staff to verify and scan/copy
documents
Additional storage will be needed until
documents can be scanned and destroyed
Additional staff to prep documents for
scanning to prevent backlog
The cost of disposal of documents would
increase
•
•
•
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Establish an effective procedure to confirm or verify a
renewing applicant’s information
•
Copying source documents will add to wait
times in offices
•
If wait times increase beyond the mandatory
1-hour limit, additional staff and field offices
may be necessary.
ASSUMPTIONS
document scanners and contractor services will be
required.
Additional scanners and copiers will need to be
purchased to equip 21 field offices.
No impact
•
•
•
•
•
This requirement eliminates current alternate
technologies for the renewal of a driver’s
license or identification card.
Statutory change
Verification procedures
Additional staff to review and verify
documents
Regulation changes
All required verification processes will not be accessible
on-line which removes the alternate technology capacity
we currently have in place.
REAL ID ACT REQUIREMENT
IMPACT
•
•
•
ASSUMPTIONS
Verification process will add to wait times in
offices. If wait times increase beyond the
mandatory 1-hour limit, additional staff and
field offices may be necessary.
Programming hours for DMV application
changes will be needed to include verification
edits
If temporary documents are needed, this
process could ultimately result in Central
Issuance of DL and/or ID’s
The Secretary of Homeland Security has the authority
to adopt regulations that could cause additional impact
from those noted above.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
We would be unable to service a segment of Nevada’s
population if documentation to evidence non-eligibility
cannot be produced or if a discrepancy exists with
SSA.
Check other states if a person already was issued a DL in
another state
No impact
Ensure physical security of locations where DL/ID cards
are produced
No impact
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
The potential impact of this requirement is subjecting
potential contract vendors to security clearances.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
No impact
Nevada will deny issuance until the customer has
resolved the discrepancy with SSA.
The assumption is that contractors developing software
and controlling card stock would be subjected to the
same security clearances as jurisdiction employees
issuing driver’s licenses and identification cards.
REAL ID ACT REQUIREMENT
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Alternative document design if it does not meet federal
standard
Legal Presence Requirement
IMPACT
ASSUMPTIONS
No impact
•
Impact on the information technology staff to
complete DMV application programming
changes
•
Large fiscal Impact
•
Vendor Contract revisions
•
•
•
Statutory change to enact legal presence law
Regulation changes
Verification process will add to wait times in
offices
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
No impact
Maintain a state motor vehicle database that contains at a
minimum:
No impact
Any changes from the existing design specifications are
billable enhancements by the contractor.
Nevada does not currently have a legal presence law
which require statutory changes to comply with H.R.
418.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
•
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Impact on the information technology staff to
complete DMV application programming
changes
•
Fiscal Impact
•
Vendor Contract revisions
Any changes from the existing design specifications are
billable enhancements by the contractor.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Our primary concern is the existence and availability of on-line verification processes to carry out the provisions of
H.R. 418 without adversely effecting Nevada’s citizens.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
See Attached.
NEVADA REAL ID IMPACT STUDY
Requirement of H.R. 418
What We Currently Have In Place
Are We
Compliant?
Impacts of Implementation
1. Minimum Document Requirements – To meet the requirements of this section, a State shall include at a minimum, the following information and features on each driver’s
license and identification card issued.
Person’s Full Name
Person’s Legal Name
Yes
No impact for this requirement
Person’s Date of Birth
Person’s Date of Birth
Yes
No impact for this requirement
Person’s Gender
Person’s Gender
Yes
No impact for this requirement
Driver’s License or Identification Card
Unique Driver’s License or Identification Card
Yes
No impact for this requirement
Number
Number
Person’s address of principle residence
Person’s mailing address
No
• Statutory change to NRS 483.340
• Several application and form changes,
• Approximately 250 hours of DMV
application programming to complete
computer change
• Public notices will need to be generated
Person’s Signature
Person’s Signature
Yes
No impact for this requirement
Physical security features designed to
We have the following security features in
Yes
The Secretary of Homeland Security has the
prevent tampering, counterfeiting, or
place:
authority to establish security feature requirements.
duplication of the document for fraudulent
If the established requirements are different or
• Laminate Coating – tamper resistant
purposes
exceed what is currently in place, an impact will
coating with optically variable image
•
•
•
•
•
Common machine-readable technology,
with defined minimum data elements
of state seal
Digital portrait and signature image
printed on durable composite card
State seal overlaps the top-left corner
of the photo
First and last initial and last two digits
of date of birth on the left of the
license/ID card in the mountains
DLN or ID number appears above the
issue date on the photograph area
Issue date in photo area
The industry standard 2-D Bar Code with
AAMVA standard minimum requirements is
currently being used.
exist to implement the required features. For
example, if biometrics are mandated, there will be
a substantial impact on the information technology
staff to complete DMV application programming
changes, it will effect the card design, the contract
with our vendor could require amendments,
increased costs under the vendor contract could
occur and ultimately, a request to increase the cost
of the driver’s license to the public may be
necessary to cover added expenses to produce the
card.
Yes
Federal regulations have not been written to
determine if “minimum data elements” are
provided in our current 2-D bar code.
The Secretary of Homeland Security has the
authority to establish parameters for machinereadable technology that could present a
substantial impact on our Department, i.e., MagStripe.
Should the Secretary of Homeland Security change
the standards, there will be a substantial impact on
the information technology staff to complete DMV
application programming changes, it will effect the
card design, the contract with our vendor could
require amendments, increased costs under the
vendor contract could occur and ultimately, a
request to increase the cost of the driver’s license
to the public may be necessary to cover added
expenses to produce the card.
2. Minimum Issuance Standards – To meet the requirements of this section, a State shall require, at a minimum, presentation and verification of the following information
before issuing a driver’s license or identification card:
A photo identity document, except that a
non-photo identity document is acceptable
if it includes both the person’s full legal
name and date of birth.
Documentation showing the person’s date
of birth
To evidence name and/or date of birth, we accept once of
the following documents as a sole source:
•
Birth Certificate issued by a state, the District of
Columbia, or any territory of the United States.
• U.S. Passport issued by the United State
Government (can be expired)
• Military identification card or Military dependent
identification card issued by any branch of the
U.S. Armed Forces. (Must have name, date of
birth and photo)
• Report of Separation from the Armed Forces
(DD214)
• Certificate of Degree of Indian Blood
• Veterans Identification Card with photo
• Bureau of Indian Affairs Card/Indian Treaty card
– with photo
• Identification Letter issued by U.S. District Court
Probation Office
If born outside of the United States:
• Certificate of Citizenship
• Certificate of Naturalization
• Permanent Resident Card
• Temporary Resident Card
• Employment Authorization Card, must be current
- if expired, refer the customer to BCIS
• Permit to Reenter the United States
• Refugee Travel Document
• Arrival-Departure Record (I-94) if accompanied
by a valid passport
• Alien Registration Receipt Card (I-551), Resident
Alien Card
• Consular Report of Birth Abroad of the US
Citizen Child issued by the Department of
• US Passport (can be expired)
• Valid foreign passport stamped “Processed for I551”
• Veterans Identification Card with photo
• Military identification card or Military dependent
Yes
Unless specific documents are identified in Federal
Regulation, we are in compliance
identification card issued by any branch of the
U.S. Armed Forces. (Must have name, date of
birth and photo)
Proof of the person’s social security
number or verification that the person is not
eligible for a social security number
•
•
•
•
•
•
•
•
•
Records of employment
Federal income tax records (not self prepared)
Social Security Card Military personnel, spouse, or dependent ID card
FAA (pilot license)
Verification from Social Security Administration
(if person is drawing benefits)
Correspondence from IRS
Out-of-state license or identification card with the
social security number printed on the card
DD-214, Military discharge papers
Parti
al
Currently, the Department only requires the applicant sign
an affidavit if they have not been issued a Social Security
Number. No documentation is required.
Documentation showing the person’s name
and address of principle residence
We do not require evidence of principle place of residence
No
We would be unable to service a segment of
Nevada’s population if documentation to evidence
non-eligibility cannot be produced.
• Documentation will need to be
determined that will evidence an applicant
is NOT eligible for an SSN
• This may require regulatory changes to
define what documents are accepted as
evidence of SSN and evidence that the
applicant is NOT eligible
• If document indicating the applicant is not
eligible for a Social Security Number is
not available, the applicant is denied and
the issuance process is delayed.
• If wait times increase beyond the
mandatory 1-hour limit, additional staff
and field offices may be necessary.
• Public notices will need to be generated
•
•
•
•
•
•
•
•
•
Statutory change
Verification procedures
Additional staff to review and verify
documents
Regulation changes
Verification process will add to wait times
in offices
Programming hours for DMV application
changes will be needed
If temporary documents are needed, this
process could ultimately result in Central
Issuance of DL and/or ID’s
If wait times increase beyond the
mandatory 1-hour limit, additional staff
and field offices may be necessary.
Public notices will need to be generated
3. Special Requirements – To meet the requirements of this section, a State shall comply with the minimum standards outlined below:
Evidence of Lawful Status – A State shall
require, before issuing a driver’s license or
identification card to a person, valid
documentary evidence that the person:
• Is a citizen of the United States
• Is an alien lawfully admitted for
permanent or temporary residence
in the United States
• Has conditional permanent
resident status in the United States
• Has an approved application for
asylum in the United States or has
entered into the United States in
refugee status
• Has a valid, unexpired
nonimmigrant visa or
nonimmigrant visa status for entry
into the United States
• Has a pending application for
asylum in the United States
• Has a pending or approved
application for temporary
protected status in the United
States
• Has approved deferred action
status; or
• Has a pending application for
adjustment of status to that of an
alien lawfully admitted for
permanent residence in the United
States or conditional permanent
resident status in the United States
Nevada does not have a legal presence law.
The Department only ensures the applicant, based on
immigration documentation, meets the definition of
“resident” according to NRS 483.141.
The Department accepts to following documents to
evidence name and age for applicant born outside of the
US. They are also used to determine if the applicant meets
the definition of resident.
• Certificate of Citizenship
• Certificate of Naturalization
• Permanent Resident Card
• Temporary Resident Card
• Employment Authorization Card, must be current
– if expired, refer the customer to BCIS
• Permit to Reenter the United States
• Refugee Travel Document
• Arrival-Departure Record (I-94) if accompanied
by a valid passport
• Alien Registration Receipt Card (I-551), Resident
Alien Card
• Consular Report of Birth Abroad of the US
Citizen Child issued by the Department of State
• US Passport (can be expired)
• Valid foreign passport stamped “Processed for I551”
• Veterans Identification Card with photo
• Military identification card or Military dependent
identification card issued by any branch of the
U.S. Armed Forces. (Must have name, date of
birth and photo)
No
•
•
•
•
•
•
•
•
•
Statutory change to enact the legal
presence law
Verification procedures
Additional staff to review and verify
documents
Regulation changes
Verification process will add to wait times
in offices
Programming hours for DMV application
changes will be needed
If temporary documents are needed, this
process could ultimately result in Central
Issuance of DL and/or ID’s
If wait times increase beyond the
mandatory 1-hour limit, additional staff
and field offices may be necessary.
Public notices will need to be generated
4. Temporary Driver’s License and Identification Cards
If a person presents evidence under any
clause of above immigration documents,
the State may only issue a temporary
driver’s license or temporary identification
card.
A temporary driver’s license or temporary
identification card issued based on
immigration documents should be valid
only during the period of time of the
applicant’s authorized stay in the United
States, or if there is no definite end to the
period, a period of one year.
A temporary driver’s license or
identification card issued based on
immigration documents may be renewed
only upon presentation of valid
documentary evidence that the status of by
which the applicant qualified for the
temporary DL or ID has been extended by
the Secretary of Homeland Security.
We currently issue the driver’s license or
identification card that expires with
immigration documents, when immigration
documents are presented.
Yes
Documents are issued to coincide with the
immigration end-of-stay date. If no date is
provided, a 4-year default is given.
Partial
•
•
•
•
If immigration information is in the system,
new immigration documents must be presented
to evidence an extension in their stay before
the DL or ID will be renewed.
Policy and procedure changes
MVIT programming to automate the expiration at
one year
Statutory and/or regulatory changes identifying the
one-year expiration if no immigration end-of-stay
date provided.
Public notices will need to be generated
Yes
5. Verification of Documents – to meet the requirements of this section, a State shall implement the following procedures:
Before issuing a
DL or ID, the
State shall
verify, with the
issuing agency,
This is currently in place for Social Security Number.
Verification is also made through PDPD/CDLIS for the DL/ID being
surrendered
No
To verify each and every source document would require
staff to contact each issuing agency to ensure authenticity.
• Statutory change
• Verification procedures
• Additional staff to review and verify documents
•
•
•
the issuance,
validity, and
completeness of
each document
required to be
presented by
the person.
•
•
Regulation changes
Verification process will add to wait times in offices
Programming hours for DMV application changes
will be needed
If temporary documents are needed, this process
could ultimately result in Central Issuance of DL
and/or ID’s
If wait times increase beyond the mandatory 1-hour
limit, additional staff and field offices may be
necessary.
In Nevada, verification of birth certificates would be a costly
and time-consuming issue. Nevada requires the verification
request in writing and accompanied by a check for $8.00 per
verification request. Turn-around time is expected to be
between 5 and 7 working days plus mailing allowance.
Based on time frames needed for verification of Nevada birth
certification, the process for issuing a driver’s license or
identification card could range from 2 to 6 weeks pending
approval of verified documents. The fees needed to verify
documents could potential impact the driver license fee
requiring an increase to cover the cost of verification.
Passports – Currently, there are no means to verify the
authenticity of a US Passport. The National Passport
Information Center (a unit within the Department of State)
indicated that there are 13 different passport agencies, all
issuing passports with different characteristics. There is not
one central information system.
The State shall
not accept any
Currently, the Department accepts the following by statute or regulation:
• Certificate of Citizenship
No
The impact of this requirement is the inability to issue a
driver’s license or identification card to foreign residents as
foreign
documents,
other than an
official
passport, to
satisfy a
requirement of
the minimum
issuance
standards.
Not later than
September 11,
2005, the State
shall enter into
a memorandum
of
understanding
with the
Secretary of
Homeland
Security to
routinely utilize
the automated
system known
as Systematic
Alien
Verification for
Entitlements
(SAVE), to
verify the legal
presence status
of a person,
other than a
United States
citizen,
applying for a
•
•
•
•
Certificate of Naturalization
Permanent Resident Card
Temporary Resident Card
Employment Authorization Card, must be current – if expired,
refer the customer to BCIS
• Permit to Reenter the United States
• Refugee Travel Document
• Arrival-Departure Record (I-94) if accompanied by a valid
passport
• Alien Registration Receipt Card (I-551), Resident Alien Card
• Consular Report of Birth Abroad of the US Citizen Child issued
by the Department of State.
• Valid foreign passport stamped “Processed for I-551”
The Department is currently verifying immigration information via
telephone.
Information about SAVE has been received.
this requirement conflicts with Special Requirements –
Evidence of Lawful Status.
Compl
iance
is
forthco
ming
DL or ID.
6. Other Requirements – to meet the requirements of this section, a State shall adopt the following practices in the issuance of a DL or ID:
Employ technology to capture
digital images of identity
sources documents so that the
images can be retained in
electronic storage in a
transferable format.
Retain paper copies of source
documents for a minimum of 7
years or images of source
documents presented for a
minimum of 10 years.
This process is currently in place
Ye
s
No impact for this requirement
We do not currently maintain copies of
source documents
No
If paper copies are retained until scanned, the impact would include:
• Purchase of additional copy machines in field offices
• Additional staff to verify and copy documents
• Additional storage will be needed until documents can be scanned and
destroyed
• Additional staff to prep documents for scanning to prevent backlog
• The cost of disposal of documents would increase
• Copying breeder documents will add to wait times in offices
• If wait times increase beyond the mandatory 1-hour limit, additional staff
and field offices may be necessary.
If the technicians scan the breeder documents at the time of issuance, the impact
will include:
• Purchase of scanning equipment for each field offices
• Additional staff to verify and scan documents
• Scanning breeder documents will add to wait times in offices
• If wait times increase beyond the mandatory 1-hour limit, additional staff
and field offices may be necessary.
Subject each person applying
for a DL or ID to mandatory
facial image capture.
Establish an effective
procedure to confirm or verify
This process is currently in place
Ye
s
Verification of information takes place
only during in-office renewals.
No
No impact for this requirements
•
This requirement eliminates current alternate technologies for the renewal
of a driver’s license or identification card.
a renewing applicant’s
information.
•
•
•
•
•
Applicants renewing based on
immigration documents must renew inoffice and they must bring current
immigration documentation.
•
•
Confirm with the SSA a SSN
presented by a person using the
full socials security account
number. In the event that a
SSN is already registered to or
associated with another person
to which any State has issued a
DL or ID, the State shall
resolve the discrepancy and
take appropriate action.
Refuse to issue a DL or ID to a
person holding a DL or ID
issued by another State without
confirmation that the person is
terminating or has terminated
the DL.
Ensure the physical security of
locations where DL or ID are
produced and the security of
document materials and papers
from which DL and ID are
produced.
Subject all persons authorized
to manufacturer or produce DL
and ID to appropriate security
clearance requirements.
Statutory change
Verification procedures
Additional staff to review and verify documents
Regulation changes
Verification process will add to wait times in offices. If wait times
increase beyond the mandatory 1-hour limit, additional staff and field
offices may be necessary.
Programming hours for DMV application changes will be needed to
include verification edits
If temporary documents are needed, this process could ultimately result in
Central Issuance of DL and/or ID’s
The Secretary of Homeland Security has the authority to adopt regulations that
could cause additional impact from those noted above.
No impact based on the assumption that the Department will not issue the driver’s
license or identification card until the discrepancy is resolved by the customer.
All SSN presented are verified through
SSOLV.
Resolution of discrepancies is currently
the responsibility of the applicant.
If a discrepancy exists, the driver’s
license or identification card is not
issued and the customer is requested to
visit the Social Security office to clear
the discrepancy.
Ye
s
Nevada DMV does not issue a DL or ID
to an applicant if there is evidence that
another valid document issued by this or
any other jurisdiction has been issued.
This is checked by using CDLIS/PDPS
systems.
• Physical locations are locked
nightly.
• Materials and documents are
secured nightly with revenue.
Ye
s
No impact for this requirement
Ye
s
Unless specific security measures are prescribed, we have met this requirement.
All DMV employees undergo criminal
background checks prior to employment.
Par
tial
The potential impact of this requirement is subjecting potential contract vendors to
security clearances.
Establish fraudulent document
recognition training programs
for appropriate employees
engaged in the issuance of DL
and ID.
Limit the period of validity of
all DL and ID that are not
temporary to a period that does
not exceed 8 years.
In any case in which the State
issues a driver’s license or
identification card that does
not satisfy the requirements of
this section, ensure that such
license or identification card:
1. Clearly states on its face that it may
not be accepted by any Federal agency
for any official purpose; and
2. Uses a unique design or color
indicator to alert Federal agency and
other law enforcement personnel that it
may not be accepted for any such
purpose.
Fraudulent document training is
currently a part of the DMV field service
technician training program.
Ye
s
No impact for this requirement
DMV issues 4-year DL or ID unless
expiration is less due to immigration
papers
Ye
s
No impact for this requirement
Nevada’s current issuance standards of
driver’s license and identification cards
meet the requirements of H.R. 418 and
as such, these provisions would not
apply under existing conditions.
Ye
s
If the established requirements are different or exceed what is currently in place,
an impact will exist to implement the required features. There could be a
substantial impact on the information technology staff to complete DMV
application programming changes, it will effect the card design, the contract with
our vendor could require amendments, increased costs under the vendor contract
could occur and ultimately, a request to increase the cost of the driver’s license to
the public may be necessary to cover added expenses to produce the card.
To be eligible for any grant or other type of financial assistance made available to implement these requirements, the State shall participate
in the interstate compact regarding sharing of driver license data, know as the “Driver License Agreement” in order to provide electronic
access by a State to information contained in the motor vehicle databases of all other States.
NEW HAMPSHIRE
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
28. Full Legal Name
NO
29. Person’s Date of Birth
Yes
30. Person’s Gender
Item 6: Currently the applicant has option to have
legal residence removed from their license. This
requirement would require a change in current Law if
mandated.
Yes
31. Person’s DL or ID Card Number
Item 1 requires changes to current IT system. Will
result in additional unbudgeted expenses.
Yes
32. Digital Photograph of Person (and retention)
Yes
33. Person’s Address of Principle Residence
Optional
34. Person’s Signature
Yes
35. Physical Security Features to prevent tampering,
counterfeiting or duplication
Yes
36. Common Machine Readable Technology:
Yes
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Expiration is tied to end of stay, Not using Temporary
after 45 days.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
Not currently amended, current initiatives by
advocates for Non-US citizens are to prevent the
This is intended to identify Non-US.
REAL ID ACT REQUIREMENT
IMPACT
expiration date
unique identification.
Verification at Source:
Item 2 & 3 will require modification to current IT
system. This will result In additional unfunded costs.
Enabling your system to electronically verify
documentation with:
1. SSOLV
Yes, effective 02/05
2. SAVE
No
3. DEERS (DOD)
No
4. Other jurisdiction (DL/ID card)
5. Birth certificate
Yes
Yes
6. Other…i.e. third party vendors
No
Developing access capability to SAVE system
Would require OIT participation. Unfunded
requirement
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Currently do not have imaging capability for licensing.
Would require additional hardware and OIT
modifications.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Currently maintain copies of source documents. In
compliance
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Currently take digital photos of face.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Renewals are currently verified with existing system.
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
Currently rectifying SSNN discrepancies with SSA.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Check other states if a person already was issued a DL in
another state
State currently conducts motor vehicle record checks
before issuing permanent license.
Ensure physical security of locations where DL/ID cards
are produced
Procedures in place and being enhanced.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Requires background checks not currently performed.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Currently conduct this training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Current expiration is 5 years. In compliance
Alternative document design if it does not meet federal
standard
Legal Presence Requirement
Current law defines legal presence. Verified before ID
issued.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
Currently in compliance.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Is there any funding available to implement requirements. Will further information regarding federal
requirements that will mandate State Law changes be provided. Particularly the Non-US citizen
recommendations.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
NEW JERSEY
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT
REQUIREMENT
Introduce Full Legal Name
into Driver Licensing
System (in Record, on
Document)
IMPACT
NJ law allows the Motor Vehicle Commission to collect a legal
name. In the past, many records in the MVC database were
created with a name construction similar or close to a legal name
– but not exactly the legal name (i.e., use of nicknames or
Americanization of a Foreign name). Introducing the full legal
name will lead to unhappy customers that may be forced to go
back to a legal name they have not used for many years.
ASSUMPTIONS
AAMVA's Uniform ID security model is the
base for change. The CDLIS and PDPS
systems, which have specific naming
convention rules, will comply with the change
to a name in a timely fashion to allow states to
meet the three-year implementation
requirement.
The bigger issue for NJ MVC is the requirement to have all name
records be a 125-character variable length field (40 for family, 80
for given, 5 for suffix). This requires a database change and a
significant number of programmatic changes to our system. Such
changes would involve the CDLIS/PDPS interface and third party
vendor interfaces (third party systems as well), along with our
internal and point of sale systems in the field. It will also mean a
change to the digital license, which has limited real estate.
We plan to accomplish the name requirement, complete with
history, in a new system that is still at least two years away. If
compelled to do so in the current system, it would be an extensive
amount of work. On a scale of 1 to 10, with 10 being most
complex, the effort would be a 9 or 10.
Have following data
elements/features on the
document:
NJ MVC’s current digital license contains all the data elements
and security features referred to except for the person’s principle
residence address. For the most part, the principle address is
reflected on the card, but there are records in which a Post Office
That it’s not an “either/or” selection, but a
matter of showing principle and mailing
address.
REAL ID ACT
REQUIREMENT
37. Full Legal Name
38. Person’s Date of
Birth
39. Person’s Gender
IMPACT
box appears. We do not have the real estate for more than one
address in the current design. So that, along with the larger name
configuration, could mean a redesign of the digital document. A
redesign will cost significant time and money.
40. Person’s DL or ID
Card Number
41. Digital Photograph
of Person (and
retention)
42. Person’s Address of
Principle Residence
43. Person’s Signature
44. Physical Security
Features to prevent
tampering,
counterfeiting or
duplication
45. Common Machine
Readable
Technology:
Introduce temporary DL/ID
cards and tying end of stay
to expiration of DL/ID card
(or issuance for no more
than 1 year)
NJ MVC issues a digital license today that is tied to an
individual’s length of stay.
ASSUMPTIONS
REAL ID ACT
REQUIREMENT
IMPACT
ASSUMPTIONS
Amending card design to
show/indicate that it is a
temporary document with a
“different than usual”
expiration date
The digital license is limited in real estate, so this requirement,
along with others in the Real ID Act, will force a redesign of the
document. This change requires working with the State’s vendor
on a redesign and extensive testing of a new document; much like
the effort put forth on the initial design of the State’s digital
license.
Digimarc is the State’s digital license
contractor and this redesign may require a long
lead-time since Digimarc has a large number
of contracts in the country. Assuming many
states will have to do similar redesign, NJ
assumes Digimarc will have enough resources
to support all contracts. If not, that could place
a burden on the States to affect timely response
to the Act.
Verification at Source:
Today, NJ MVC has a SSOLV interface (to verify a social
security number). A connection to the SAVE program is also
operational.
Enabling your system to
electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction
(DL/ID card)
5. Birth certificate
DEERS, other jurisdiction check, birth certificate and third party
would all be new interfaces with operational components not yet
defined.
The electronic interfaces would be similar to what we have done
to date with other outside entities. There are operational issues
bringing more data to the workstation. It adds complexity to the
decision making process and whether to license an individual or
not.
6. Other…i.e. third party
vendors
Developing access capability NJ has access to the SAVE program and uses it to verify
to SAVE system
information on select cases. To make it an integrated function
with license issuance would be sizeable effort, and would require
That INS improves the timely application of
information to its database so States can use
that data in a more dynamic manner. Today,
REAL ID ACT
REQUIREMENT
IMPACT
INS to improve on the timely availability of data.
Introduce equipment into
system to capture digital
images of identity source
documents so that images
can be retained in electronic
storage in a transferable
format
ASSUMPTIONS
the data may or may not be there because of
how long it takes for paper work to make it
from the INS field office to the INS system.
Requirements for the archiving of Identity documents (or any
other need for imaging) will change the dynamics of Motor
Vehicles’ IT systems. There will be several profound changes as
a result of this technology:
- Greatly enhanced document retrieval after capture
- Possible implications to the customer throughput to take the time
to capture documents
- Likely impact to the network traffic due to the bulk capture of
documents over a distributed network (point of service capture,
unlike taxation mail in processing for example).
Depending on the requirements of imaging, it may be necessary to
decentralize hardware to handle the load, and/or deal with
distributed capture but centralized enterprise-wide delivery of
imaging. Quality of document images is at odds with network
bandwidth to deliver the resulting images. Network traffic studies
including transaction volume, quality of images, retention,
geographic distribution and use, timeliness of retrieval, and
centralization vs. de-centralization are all factors that would be
appropriate in planning for imaging technology.
Retain paper copies of
source documents for a
minimum of 7 years or
images of source documents
presented for a minimum of
Significant influence on customer service. This State is an overthe-counter instant issuance service. It will be quite challenging to
maintain a smooth license process and capture the images of
documents used to verify the identity of a license applicant. To
maximize customer throughput, NJ recently re-engineered
That States do not have to maintain both
physical copies and images
REAL ID ACT
REQUIREMENT
10 years
IMPACT
ASSUMPTIONS
business to eliminate choke points in the process. The image
function has great potential to be a choke point unless some
mobile and more robust imaging technology is made available.
Maintaining physical copies, because of the enormity of the
retrieval process, would require extensive and costly warehousing
set-ups.
Subject each person
applying for a driver’s
license or identification card
to mandatory facial image
capture
This is underway in NJ. According to current law, that image is
good for eight years before another image is required.
Establish an effective
procedure to confirm or
verify a renewing
applicant’s information
NJ MVC established a “6 Point Identification Verification”
system which standardized how an applicant verifies his identity.
Certain documents are considered “Primary” (and given a fourpoint value), while others are considered “Secondary” (and carry
a two-point value). There is also a limit on the number of
secondary documents accepted. This process was implemented
with the digital license program to ensure that the right person is
enrolled in the digital picture database. Along with the “6 Point
ID” program, a check of the SSA database is made to verify SSN
before licensing a driver. In the renewal process, the picture can
be used as another means to verify identity.
In the event that a social
security account number is
already registered to or
associated with another
The CDLIS /PDPS helpdesk responsibility will have to be
expanded to include dealing inter-jurisdictional matters on noncommercial drivers. Should appropriate action be necessary, the
State can suspend the license of a driver who provides false
Requires a State-to-State check of a driver
license, and that a master pointer record
database is developed and operational by
AAMVAnet.
REAL ID ACT
REQUIREMENT
person to which any state
has issued a DL/ID card, the
state shall resolve the
discrepancy and take
appropriate action
Check other states if a
person already was issued a
DL in another state
Ensure physical security of
locations where DL/ID cards
are produced
IMPACT
ASSUMPTIONS
This is a large effort. On a scale of 1 to 10, this rates as a 10
effort. Introducing the “all driver license” search with licensing
practices in the motor vehicle offices creates a number of
customer service challenges. The “all driver search” will increase
the number of exceptions that have to be handled by field staff.
Technically, it will rival the commercial driver license project of
the late 80’s.
This statement implies the “one driver, one
record” concept and requires States put in
place standard practices to test and license
drivers so States can employ reciprocity among
State licensing jurisdictions.
The NJMVC is currently issuing licenses at 45 field locations. In
October 2005, the 46th agency will open. All processes are
completed at agency counters. DDL hardware is secured to the
counter with a locking device. Consumables are safely out of
reach from the general public. When not in use, the equipment is
shut down, the security key is removed, and all consumables are
stored in a locked and alarmed safe.
Law Enforcement Agency Security
Enhancement (L.E.A.S.E.) Program will
continue at two thirds of our agencies. An
assigned investigator of the MVC’s Security
and Investigations Unit will monitor agencies
without a L.E.A.S.E. Officer.
information.
Subject all person’s
The State already does a complete background check on all
authorized to manufacture or employees working for the Commission.
produce DL/ID cards to
appropriate security
clearance requirements
Requires a State-to-State check of a driver
license and that a master pointer record
database is developed and operational by
AAMVAnet.
REAL ID ACT
REQUIREMENT
IMPACT
ASSUMPTIONS
Establish fraudulent
document recognition
training programs for
appropriate employees
engaged in the issuance of
DL/ID cards
Training for all agency, and support staff, is a large part of the
initiative and of great importance to the Commission.
Limit period of validity of
DL/ID cards that are not
temporary to a period not
exceeding 8 years
The current NJ card is good for four years before renewal and the
picture is good for eight years. There is thought of moving the
card to an eight-year renewal cycle – so this requirement has little
impact.
Alternative document design
if it does not meet federal
standard
As stated earlier, any alteration of the card, due to limited real
estate, would necessitate a costly redesign of the card.
Legal Presence Requirement
Current NJ Law requires authorized presence in the United States.
Proof must be submitted in order to qualify for a NJ license.
Due to the ever-changing aspect of the
business, we work closely with representatives
from Immigration to be sure the latest
information is available to our field staff.
Provide electronic access to
all other states to
information contained in the
motor vehicle database of
the state
NJ would like to use the infrastructure in place to facilitate
commercial driver license access to State data. Absent that
system, the check can only be done if the customer identifies the
last State of record.
If the State of record is known, then a State-toState communication can be constructed. If not
known, then a master pointer record database
has to be operational by AAMVAnet.
Fraudulent document recognition training has
been in place since the latter part of 2004.
This training will be expanded to include
field/regional locations.
REAL ID ACT
REQUIREMENT
Maintain a state motor
vehicle database that
contains at a minimum:
IMPACT
ASSUMPTIONS
Little impact as this already exists
All data fields
printed on DL/ID
cards
Motor vehicle
driver’s histories,
including motor
vehicle violations,
suspensions and
points on licenses
Optional
Development and issuance
of a certificate of driving –
not for federal identification
purposes – for those who
cannot prove lawful
presence.
Again this would entail a re-design of the digital document and
The only difference functionally between the
some programming changes to differentiate a certificate of driving two is that one can be used to establish identity
from a driver license/identity document.
and the other cannot be for Federal purposes
and must bear that clarification.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
The Act requires that all states implement in a three (3) year period. States cannot move their entire population
through a new standard of licensing in that time period. How will States treat drivers with licenses not issued
under the new standard, such as proof of residence or checking another State database? Does the Act require
States to implement in three years and handle the new standards during renewal process (forcing all drivers into
a motor vehicle office one time) or is it implied that all states will have to take special steps so the entire
population of licensed drivers can be licensed according to the new standard and issued a new document in three
years. The latter seems unrealistic!
NJ has attempted to be consistent with the Uniformed ID Security model. With Homeland Security Office in
charge of the Act, does AAMVA have any idea whether the model will form a base for the new standards?
Answers to this survey are provided based on what we think we know. Should the eventual implementation rules
vary dramatically it will influence States’ ability to comply. When will the Federal Government provide
guidance on the program?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
NEW MEXICO
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
Already capturing this information
Does the full legal name mean having to use the full
middle name or can just an initial be used?
Only problem may be for individuals with only one (1) legal
name. One name will show on license or ID and the legal name
will show in the “Last” name field with first name and MI
fields blank. Not sure what problems with PDPS/CDLIS and
SSN this will have.
Have following data elements/features on the
document:
Already capturing this information
None
46. Full Legal Name
Does the full legal name mean having to use the full
middle name or can just an initial be used?
47. Person’s Date of Birth
48. Person’s Gender
49. Person’s DL or ID Card Number
50. Digital Photograph of Person (and
retention)
51. Person’s Address of Principle Residence
52. Person’s Signature
53. Physical Security Features to prevent
tampering, counterfeiting or duplication
54. Common Machine Readable
Technology:
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for
no more than 1 year)
Possible legislative action due to political sensitivity. If
so, this will delay implementation, if approved, probably
until our FY08 session (the next long session).
Will need legislative approval due to political sensitivity.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
Possible legislative action due to political
sensitivity. If so, this will delay implementation, if
Had to take of “Foreign National” when we implemented
accepting the ITIN as a document to get a DL or ID. Expect
REAL ID ACT REQUIREMENT
expiration date
IMPACT
approved, probably until our FY08 session (the
next long session).
ASSUMPTIONS
legislature not to approve this.
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
1.
Implemented
1.
None
2.
Need to implement
2.
3.
Need to implement
Probably have to get legislative support for funding and
staff
3.
Need to evaluate usefulness
4.
Need legislative support for funding for system
upgrade and staff
5.
None
6.
If go to central issue through vendor, vendor will either
have to have the ability to verify the information or the
state will have to verify the information before sending
the information to the vendor to produce the DL or ID
card. This will increase the issuance time.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
4.
Visual now. Need to implement electronic
verification
5.
Implemented visually, not electronically
6.
DL and ID are over the counter.
Need to implement
Two items need to be addressed
1.
Need for legislative support for funding
2.
Department ability to fill IT vacancies and the priority
of implementing the SAVE program
Introduce equipment into system to capture digital
images of identity source documents so that
images can be retained in electronic storage in a
transferable format
No budget for this. May need federal legislation to
allow DMVs to copy any document used in issuance of
DL/Ids.
Assuming it is legal, in New Mexico, to capture “all” types of
documents, will need legislative support for funding to develop
and maintain the entire system, which will cross several
public/private entities, that initiate/handle/store the transaction
records.
Retain paper copies of source documents for a
minimum of 7 years or images of source
Need to evaluate space requirements/needed
budget/staff.
Will need legislative support for funding.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
documents presented for a minimum of 10 years
May need federal legislation to allow DMVs to copy
any document used in issuance of DL/Ids.
Subject each person applying for a driver’s license
or identification card to mandatory facial image
capture
Already doing this.
None
Establish an effective procedure to confirm or
verify a renewing applicant’s information
Will need to evaluate current procedures against
minimum requirements and also evaluate need for any
legislation and/or regulations to implement.
Will get legislative support.
In the event that a social security account number
is already registered to or associated with another
person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take
appropriate action
Would need to develop and implement procedures to
accomplish this. Need funding.
Will get legislative support.
Check other states if a person already was issued a
DL in another state
Initially will require phone call to the previous state
then, when electronic verification is available, check
will be done electronically
Will need legislative support for funding for staff, workspace,
and implementation of electronic verification system.
Will require funding and large staff until electronic
verification is available.
Ensure physical security of locations where DL/ID
cards are produced
Will require re-evaluation of existing security measures
in the three types of offices (MVD owned and operated,
City/county owned and operated, private owned and
operated) offices
Any upgrades will be minor.
Possible need for funding to upgrade MVD offices and
similar funding need for other office types.
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security
clearance requirements
Establish fraudulent document recognition
Will require evaluation of all office type clearance
procedures and standardizing them.
Need to determine who will do the clearances for each
type of office and what the cost will be.
Some training being conducted now.
Minimum increase in clearance requirements.
Possible legislative support for funding staff doing clearance
for state and city/county and maybe private personnel.
Will need legislative support for funding staff, travel expenses
REAL ID ACT REQUIREMENT
training programs for appropriate employees
engaged in the issuance of DL/ID cards
IMPACT
Will need classrooms strategically located throughout
the state
ASSUMPTIONS
of employees and training staff, will need classrooms
Will have to expand the curriculum
Will have to increase the training staff.
Will have to get the training staff certified to teach the
course(s)
Limit period of validity of DL/ID cards that are
not temporary to a period not exceeding 8 years
8-years is the maximum for New Mexico now.
None
Alternative document design if it does not meet
federal standard
Will have to evaluate current procedures
May require funding for new documents
Legal Presence Requirement
Will require legislative approval to change to requiring
legal presence
Might be turned down by the legislative body due to the
political sensitivity
Provide electronic access to all other states to
information contained in the motor vehicle
database of the state
Will require legislative support for funding for IT staff,
development and implementation of a system, training
MVD staff, maintaining the system.
Legislative support will be provided, but at what funding level
is unknown.
Maintain a state motor vehicle database that
contains at a minimum:
All data fields printed on DL/ID cards
Already in existence
Already in existence
Motor vehicle driver’s histories,
including motor vehicle violations,
suspensions and points on licenses
Optional
Development and issuance of a certificate of
driving – not for federal identification purposes –
for those who cannot prove lawful presence.
Will need legislative approval.
Probably not happen due to the political nature of the certificate
and “singling out” individuals
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Where is the funding coming from?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
New Mexico just released an RFP to evaluate our MVD system against current and future needs. Results are
due later this year.
NEW YORK
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Have following data elements/features on the document:
55. Full Legal Name
56. Person’s Date of Birth
57. Person’s Gender
58. Person’s DL or ID Card Number
59. Digital Photograph of Person (and retention)
60. Person’s Address of Principle Residence
61. Person’s Signature
62. Physical Security Features to prevent tampering,
counterfeiting or duplication
63. Common Machine Readable Technology:
IMPACT
MAJOR IMPACT
We currently abbreviate the name to fit on our
legacy license file. In order to capture the full name,
we would need to develop a new license database
that contains the full name. We would also need to
modify several systems such as display and
processing systems to display the full name as it
appears on the license documents. The full name
would also have to be stored in the bar code of the
document. There are issues with file length that
depend on what standards are developed for
maximum field lengths.
NOMINAL IMPACT
NYS DMV prints the DOB, gender, client ID,
digital Image, signature and the mailing address on
the license documents.
We already data enter both mailing and residence
addresses, if applicable, but we would need to
change the information sent to the license print file.
This would entail adding the residence address to
the barcode information since this is what DeLarue
uses to print the license. We would need to
maintain the mailing address in the barcode. The
Onserts machine reads the mailing address in the
barcode and prints the address on the carrier card for
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
mailing the license.
Our documents have state of the art security features
to prevent tampering and counterfeiting.
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
MAJOR IMPACT
This would require changes to the license file and
approximately sixteen other systems that process
against it.
NO IMPACT
We currently have the ability to distinguish between
document types by printing legends on our
documents, for example: “Under 21”, “Temporary
Visitor”.
MODERATE IMPACT – to employ additional
verification systems
NYS DMV currently uses SSOLV. We also use the
Department of Homeland Security Systematic Alien
Verification Entitlements (SAVE) system to verify
immigration documents when staff questions their
validity. The additional verification systems would
provide us with greater assurance of the authenticity
of source documents however, these additional
verifications would result in increased transaction
time.
A temporary driver’s license or
identification can only be valid for the
period of time of the applicant’s
authorized stay in the United States or
for a period of one year if there is no
definite end to the period of authorized
stay.
REAL ID ACT REQUIREMENT
Developing access capability to SAVE system
IMPACT
MODERATE IMPACT – to fully integrate SAVE
We currently have this ability as a stand-alone
application. We would however need to integrate it
into our processing system.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
MAJOR IMPACT
We must employ technology to capture digital
images of the source documents so that the images
can be retained in electronic storage in a
transferable format. Digital images must be
retained for a minimum of ten years or paper
documents for seven. We have looked at a
proprietary system for digital imaging of documents
that also verifies the document’s authenticity. We
believe other companies will use this opportunity to
expand their product line to include systems for this
purpose. We would also have the option of
developing our own imaging system. In any case
there would be programming required for linkage of
the digital files, whether DMV created or not,
equipment purchases for scanning equipment and
image storage, software license and maintenance
fees and consulting for system design and
development.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
MAJOR IMPACT (imaging system)
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Establish an effective procedure to confirm or verify a
renewing applicant’s information
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
Check other states if a person already was issued a DL in
another state
Ensure physical security of locations where DL/ID cards
are produced
ASSUMPTIONS
We currently maintain paper files of our license
applications for a period of 9 years. We would need
to build or employ an imaging system that can
accommodate the required retention periods.
NO IMPACT
This is a current requirement in NYS.
MODERATE TO MAJOR IMPACT
Before issuing the driver’s license or identification
card, the validity and completeness of the
documents presented by the applicant as proof must
be verified. This must be done for original and
renewal transactions. Still, we will see an increase
in transaction times, requiring as many as 200
additional field staff to handle this effort
NO IMPACT
We currently have a SSN index file in NYS. We
also use SSOLV to verify the SSN presented prior
to issuance of a document.
MODERATE IMPACT
We would need an integrated system to do so.
Increased transaction time.
NO IMPACT
Our document production vendor is located in a
We are assuming we could mitigate this
requirement by pre-screening and
approving renewals to minimize the
presentation and examination of
documents in the offices.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
secure area.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Alternative document design if it does not meet federal
standard
Legal Presence Requirement
NO IMPACT
All employees of our document production vendor
are subject to security clearance.
NOMINAL IMPACT
We currently have a FDR training program. We
would need to do additional training and enhance
this program area.
NOMINAL IMPACT
Our licenses are valid for 8 years. We would need to
eliminate our 10-year Non-Driver ID cards and
issue them for a period of 8 years. This would
require a change in statute as well as programming
and production changes in order to meet this
requirement.
NO IMPACT
We have recently re-designed our documents. These
documents meet or exceed federal standards.
MODERATE IMPACT
We would need to integrate SAVE into our
processing system to do online verification of DHS
documents.
Provide electronic access to all other states to
information contained in the motor vehicle database
of the state
We would be able to change the 10-year
period of validity to 8 years upon
renewal of the NDID.
MODERATE IMPACT
Impacts cannot be established until the requirements
State Legislation requiring legal
presence must be passed.
REAL ID ACT REQUIREMENT
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
IMPACT
are further defined. Assuming this requirement is
less than the DRIVERS implementation but includes
more than the current conviction and CDL data,
there is also question as to what 'history' involves.
Also how States are provided access is in question.
NO IMPACT
Based on our interpretations we are compliant with
this. However, our motor vehicle histories are
limited based on file conditions.
MAJOR IMPACT
This would require us to have a “dual” system for
issuing either a secure DL or a driving permit only
that cannot be used for identification purposes. Such
a system would be very costly to implement and
maintain.
ASSUMPTIONS
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
What funding stream will be available and from what source, to assist with the implementation?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
NEW YORK STATE
DEPARTMENT OF MOTOR VEHICLES
6 EMPIRE STATE PLAZA, ALBANY NY 12228
RAYMOND P. MARTINEZ, COMMISSIONER
H.R. 418 Federal Real ID Act
Summary of Impact
DRAFT
Summary: This proposed legislation would require states to issue driver’s licenses with minimum document requirements such as
security features and the printing of the residence address on the license, verification of the validity of source documents presented for
identification, maintain copies of all source documents, require certain minimum standards for license issuance, require evidence of lawful
status and issue drivers licenses and identification cards valid coterminous with the period the individual is authorized to stay in the United
States. States would have 3 years to implement the legislation.
Note: Until final passage of legislation and, more importantly, adoption of associated federal rules and regulations, this assessment is necessarily
preliminary and, no doubt, incomplete.
Preliminary Assessment of Program & Fiscal Impact
Regulations will need to be promulgated to implement this legislation. Until this is done, we are estimating the impact of the legislation
based on our assumptions of how we might best implement this legislation. Regulations can greatly affect our time estimates if
requirements not envisioned below are required. Fortunately, New York State has already implemented many of the requirements of this
proposed law. Our security features and proof of identity as well as our social security number verification program put us at an advantage
to many other states. Still, there are significant program and fiscal implications to those provisions of the legislation that we would have to
implement.
1. Print a full legal name on the license documents- We abbreviate the name to fit on our legacy license file. In order to capture the full
name we would need to develop a new license database that contained the full name and also modify several systems such as display
and processing systems like Compass, WISE and Abstracts to display the full name as it appears on the license documents. The full
name would also have to stored in the bar code of the document too. There are also issues with file length that depend on what
standards are developed for maximum field lengths.
2. Print residence address on license document-We currently print the mailing address on the license documents. We already data
enter both addresses, if applicable, but we would need to change the information sent to the license print file. This would entail
adding the residence address to the barcode information since this is what DeLarue uses to print the license. We would need to
maintain the mailing address in the barcode. The Onserts machine reads the mailing address in the barcode and prints the address on
the carrier card for mailing the license.
3. Proof of residency-We would need to require proof of residency. This documentation would be added to our system as a check box
to show proof was submitted.
4. Evidence of lawful status-DMV currently uses the Department of Homeland Security Systematic Alien Verification Entitlements
(SAVE) system to verify immigration documents when staff questions their validity. When effective, HR-418 will likely require online interfaces with this and, conceivably, other data bases.
5. Coterminous term of license-A temporary driver’s license or identification can only be valid for the period of time of the applicant’s
authorized stay in the United States or for a period of one year if there is no definite end to the period of authorized stay. This would
require changes to the license file and approximately sixteen other systems that process against it.
6. Digital Images of all source documents-We must employ technology to capture digital images of the source documents so that the
images can be retained in electronic storage in a transferable format. Digital images must be retained for a minimum of ten years or
paper documents for seven. We have looked at a proprietary system for digital imaging of documents that also verifies the
document’s authenticity. We believe other companies will use this opportunity to expand their product line to include systems for
this purpose. We would also have the option of developing our own imaging system. In any case there would be programming
required for linkage of the digital files, whether DMV created or not, equipment purchases for scanning equipment and image
storage, software license and maintenance fees and consulting for system design and development.
7. Verification of data-Before issuing the driver’s license or identification card, the validity and completeness of the documents
presented by the applicant as proof must be verified. This must be done for original and renewal transactions. We are assuming we
could mitigate this requirement by prescreening and approving renewals to minimize the presentation and examination of documents
in the offices. Still, we will see an increase in transaction times, requiring as many as 200 additional field staff to handle this effort.
8. Miscellaneous-Several other program areas will require some effort. There are requirements for the license barcode to contain all of
the information on the document; documents can be valid for no more than a maximum 8-year term, the temporary license or ID
must clearly indicate it is temporary and the date it expires, etc. Numerous forms and procedures must be revised and re-issued.
Significant staffing effort will be required to conduct and coordinate project management, training, procurement, testing, and other
functions.
NORTH DAKOTA
Jurisdiction Impact Analysis Real ID Act
North Dakota Estimated Impact = $5,928,200.00
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
$4,000,000
Have following data elements/features on the document:
None with the exception of noted
above.
64. Full Legal Name
ASSUMPTIONS
In order to capture the full legal name over 30 characters, a full system
redesign will be required.
65. Person’s Date of Birth
66. Person’s Gender
67. Person’s DL or ID Card Number
68. Digital Photograph of Person (and retention)
69. Person’s Address of Principle Residence
70. Person’s Signature
71. Physical Security Features to prevent tampering,
counterfeiting or duplication
72. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
$10,000
Legislation required. Bill submitted last session but it was defeated.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
$20,000
Requires new card format. See alternative design for additional cost per
card costs.
REAL ID ACT REQUIREMENT
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
IMPACT
ASSUMPTIONS
1) SSOLV – Implemented (No
impact)
4) Developing an automated state ot state verification or require a DRIVERS
national database.
2) SAVE - $.28-$.48 per query
$7,600
5) Current est. from EVERS is $1.10 per check = $11,000
3) DEERS – UKN requirements
UKN Impact
4) $100,000 to implement $10,000 per annum
5) $20,000 Implementation $11,000 per annum
6) NA
Developing access capability to SAVE system
Minimal if site automated
Will opt for Internet Web access to application
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
$528,000 (Document scanners)
Automated 16 additional sites and adding additional hardware to existing
sites.
$36,000 hardware,
$160,000 network costs
$25,600 Printers
$320,000 Additional DDLS costs
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
$10,000
Additional storage costs
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None
Establish an effective procedure to confirm or verify a
renewing applicant’s information
UNK
Dependent on the requirements
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
None
SSOLV in place
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
resolve the discrepancy and take appropriate action
Check other states if a person already was issued a DL in
another state
UNK
Requires a National database. Defer to AAMVA for estimated costs for
DRIVERS implementation.
Ensure physical security of locations where DL/ID cards
are produced
$220,000
Surveillance cameras at each site.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
$2,400
60 FTE’s at $40 ea
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
$15,000
Annual training
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
$1,000
ID Card is currently 10 years.
Alternative document design if it does not meet federal
standard
$380,000
Estimated annual cost increase for a replacement DDLS
Legal Presence Requirement
Requires legislation
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
UNK
National database required.
Maintain a state motor vehicle database that contains at a
minimum:
Addressed in question #1
Existing legacy system in need of redesign
$150,000 Salary & Benefits
5 Additional Examiners
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Additional FTE requirements
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
How would the requirements be possible without the implementation of a National driver database?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
OHIO
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
The Ohio BMV is already in compliance
with all provisions with the following
exceptions:
Ohio law provisions may need to be revised. At minimum, the BMV
Registrar would need to be permitted to adopt rules to conform to
federal requirements.
1.
Programming changes are necessitated to accommodate the space full
legal name.
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
Have following data elements/features on the
document:
73. Full Legal Name
74. Person’s Date of Birth
75. Person’s Gender
76. Person’s DL or ID Card Number
77. Digital Photograph of Person (and
retention)
78. Person’s Address of Principal Residence
79. Person’s Signature
80. Physical Security Features to prevent
tampering, counterfeiting or duplication
81. Common Machine Readable
Technology:
2.
Full legal name – present capability to
capture approx. 100 characters to be
displayed on license/ID. Full name
could be captured electronically;
however, names exceeding 100
characters may have to be truncated as
displayed on the card or require
programming to reformat the fields
displayed on the card. Ohio complies
with current AAMVA standards.
Issuance policy revisions will be required to enforce requirements for
capturing full legal name and principal residence.
Principal residence – Ohio requires
street address (no P.O. boxes) and has
multiple address fields capability.
Introduce temporary DL/ID cards and tying end
of stay to expiration of DL/ID card (or issuance
for no more than 1 year)
Already in compliance.
N/A
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Already in compliance.
N/A
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Verification at Source:
1.
Already in compliance
1.
N/A
Enabling your system to electronically verify
documentation with:
2.
Noncompliant – MOU required
2-6.
3.
Noncompliant – MOU required
4.
Noncompliant
5.
Noncompliant
Programming changes will be necessitated. May necessitate
computer hardware/software requirements. Issuance policy
revisions will be required to incorporate electronic verification.
Transaction times could be decreased adversely impacting
customer wait times. Funding required.
6.
Noncompliant
1.
SSOLV
2.
SAVE
3.
DEERS (DOD)
4.
Other jurisdiction (DL/ID card)
5.
Birth certificate
6.
Other…i.e. third party vendors
Developing access capability to SAVE system
Programming changes will be necessitated.
MOU required by September 2005.
Issuance policy revisions will be required to incorporate electronic
verification. Transaction times could be decreased adversely impacting
customer wait times. Funding required.
Introduce equipment into system to capture
digital images of identity source documents so
that images can be retained in electronic storage
in a transferable format
Programming changes will be necessitated.
Additional
equipment
and
computer
hardware/software requirements.
Counter
space requirements and power supply sources
may be impacted.
Issuance policy revisions will be required to incorporate electronic
verification. Transaction times could be decreased adversely impacting
customer wait times. BMV would be required to house an additional 30+
million images annually. Significant funding is required to implement
for 216 satellite offices.
Retain paper copies of source documents for a
minimum of 7 years or images of source
documents presented for a minimum of 10 years
On-site storage space requirements would
increase.
Policy revisions will be required to incorporate additional storage space.
Office square footage requirements will need to be revisited.
Subject each person applying for a driver’s
license or identification card to mandatory facial
Already in compliance; however, the Amish do
not have photos produced on license/ID cards.
Computer image storage requirements are
increased.
Licenses/ID cards produced without photos would require “not
acceptable for federal purpose” printed somewhere on the cards.
REAL ID ACT REQUIREMENT
IMPACT
image capture
Establish an effective procedure to confirm or
verify a renewing applicant’s information
ASSUMPTIONS
Additional programming required.
Rapid retrieval for massive repository of stored
images.
Additional programming required.
Additional computer communications, hardware and software may be
required.
Funding required.
In the event that a social security account number
is already registered to or associated with another
person to which any state has issued a DL/ID
card, the state shall resolve the discrepancy and
take appropriate action
An individual must confirm Social Security
Number (SSN) with the Social Security
Administration (SSA). If a discrepancy is
found, an individual must resolve the issue
with SSA.
Policy revisions will be required to resolve SSN discrepancies.
Check other states if a person already was issued
a DL in another state
Noncompliant
Only individuals who come to Ohio from out of state and previously held
an Ohio license can be verified electronically.
Additional staffing and training requirements necessitated.
Additional training will be required for 216 satellite offices.
Transaction and customer wait times could be adversely impacted.
Additional programming required.
Transaction and customer wait times could be adversely impacted.
Ensure physical security of locations where
DL/ID cards are produced
Compliant
Printer ribbons, security laminates and blank cards are secured in locking
cabinets on a daily basis.
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security
clearance requirements
Compliant
All employees are required to submit to background checks through the
Ohio Bureau of Criminal Identification and Investigation (BCII) prior to
issuing any licenses and ID cards.
Establish fraudulent document recognition
training programs for appropriate employees
engaged in the issuance of DL/ID cards
Noncompliant with AAMVA standard.
BMV Investigations compiled and conducts fraudulent documents
training to local law enforcement agencies, courts, and all satellite license
agency offices.
Development of new presentation and training program required.
Funding required.
Limit period of validity of DL/ID cards that are
not temporary to a period not exceeding 8 years
Compliant (4-year license expiration currently)
N/A
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Alternative document design if it does not meet
federal standard
Compliant
N/A
Legal Presence Requirement
Compliant
N/A
Provide electronic access to all other states to
information contained in the motor vehicle
database of the state
Noncompliant
Additional programming required.
Maintain a state motor vehicle database that
contains at a minimum:
Compliant
N/A
Noncompliant – Ohio presently has legal
presence requirements
Additional programming required.
Funding required.
All data fields printed on DL/ID cards
motor vehicle driver’s histories,
including motor vehicle violations,
suspensions and points on licenses
Optional
Development and issuance of a certificate of
driving – not for federal identification purposes –
for those who cannot prove lawful presence.
Additional computer hardware/software may be required.
Funding required.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Funding and resources are the considerable impacts for implementation of the Real ID Act requirements. Will
federal funds be made available for implementation of the Real ID Act requirements?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
OKLAHOMA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
None. Oklahoma is already in compliance.
Have following data elements/features on the
document:
Minimal. Oklahoma is already in compliance,
with the exception of the address of principle
residence. We currently collect both the
residence address and mailing address, but state
law requires the mailing address to appear on the
DL/ID card. To become compliant will require
change in state law and internal programming
changes.
1.
Full Legal Name
2.
Person’s Date of Birth
3.
Person’s Gender
4.
Person’s DL or ID Card Number
5.
Digital Photograph of Person (and
retention)
6.
Person’s Address of Principle
Residence
7.
Person’s Signature
8.
Physical Security Features to prevent
tampering, counterfeiting or duplication
9.
Common Machine Readable
Technology:
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for no
more than 1 year)
None. Oklahoma is already compliant in practice
(see next item).
ASSUMPTIONS
Rules will define "address of principle residence".
Rules will take into account persons who reside in
more than one state (i.e., "snowbirds", students),
but who wish to maintain Oklahoma state as their
home state.
REAL ID ACT REQUIREMENT
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
IMPACT
ASSUMPTIONS
Minimal, although will require changes in law,
programming, and design.
Rules will not make burdensome demands on
design and content.
Significant. Even with the assumptions, startup
and ongoing funding for equipment and
personnel time will be required for Oklahoma to
implement and develop interfaces to these
databases.
AAMVA will develop software interfaces to others
systems in the same manner as SSLOV. Federal
agencies will cooperate with states. All states will
provide online/electronic birth certificate
verification. Third party vendors will be required by
state law to provide online/electronic verification.
All third party vendors will be required by state law
to verify and list all persons residing at a given
address (spouse, children, in-laws, boarders, etc.).
Developing access capability to SAVE system
Significant. Even with the assumptions, startup
and ongoing funding for equipment and
personnel time will be required for Oklahoma to
implement and develop interface to these
database.
AAMVA will develop software interfaces SAVE in
the same manner as SSLOV.
Introduce equipment into system to capture digital
images of identity source documents so that images
can be retained in electronic storage in a transferable
format
Significant. With about 70 examination sites and
280 third party issuance sites, each site would
need to be equipped with a system capable of
capturing and digitizing these source documents.
Our current DL/ID vendor has a system which
complies with many requirements of the Real ID
Verification at Source:
Enabling your system to electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Act (verifies documents and addresses, and
captures digital images) at a cost of $10,000 per
system.
Retain paper copies of source documents for a
minimum of 7 years or images of source documents
presented for a minimum of 10 years
None. Oklahoma is already in compliance.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None. Oklahoma is already in compliance.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Unknown until assumptions are addressed. NonCDL renewals are done by third parties with no
on-site oversight by the state. CDL renewals are
done by state Examiners, who will be able to
verify CDL renewals with equipment and
procedures required for initial source document
verification.
Rules will define "effective procedure" and explain
"confirm or verify". Will not require the issuance of
a temporary license while information is verified,
with a permanent license issued later from a
central site.
In the event that a social security account number is
already registered to or associated with another
person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take
appropriate action
Unknown until assumptions are addressed. What
Oklahoma has required the applicant to resolve is
now being put on the state to resolve.
Rules will address how the applicant is to be
treated until discrepancy is resolved (temporary
card or denied). The discrepancy can be resolved
through SSA.
Check other states if a person already was issued a
DL in another state
Unknown until assumptions are addressed, but
probably significant.
A driver pointer system for all licensees will
developed, and all states will participate. Rules
will provide detailed procedures.
Ensure physical security of locations where DL/ID
cards are produced
Significant, even before assumptions are
addressed. Oklahoma has 280 third party
issuance sites. This requirement may cause
implementation of alternate issuance procedures.
Rules will define "physical security".
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security
Significant, even before assumptions are
addressed. Oklahoma has 280 third party
Rules will define "appropriate security clearance
requirements".
REAL ID ACT REQUIREMENT
IMPACT
clearance requirements
issuance sites, with over 1,000 employees and a
high rate of turnover. This requirement may
cause implementation of alternate issuance
procedures.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Significant, even before assumptions are
addressed. Apparently the Real ID Act makes
the assumption that document verification and
DL/ID issuance are done at the same location or
at least by the same entity. This is not true in
Oklahoma, where DL Examiners (state
employees) verify documentation and authorize
issuance of the DL/ID, which is done by a third
party vendor. Oklahoma has 280 third party
issuance sites, with over 1,000 employees and a
high rate of turnover. While DL Examiners are
trained in AAMVA's FDR, the third party vendors
have never had this training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None. Oklahoma is in compliance.
Alternative document design if it does not meet
federal standard
Unknown until assumptions are addressed.
However, if current document design does not
meet federal standards, redesign would cause
significant expense.
Legal Presence Requirement
None. Oklahoma is in compliance.
Provide electronic access to all other states to
information contained in the motor vehicle database
of the state
Unknown until assumptions are addressed since
a nationwide system already exists.
Maintain a state motor vehicle database that contains
None. Oklahoma is in compliance.
ASSUMPTIONS
Rules will define "fraudulent document recognition
training programs". Each state's training must be
the same. Rules will allow document verification
by state employees and DL/ID issuance by third
party vendors with no on-site oversight.
Rules will establish a federal standard.
Rules will clarify how this requirement is different
from the current availability with NLETS, which
allows for access to any driver's driving record
from any state.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
at a minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including
motor vehicle violations, suspensions and
points on licenses
Optional
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
Oklahoma does not foresee implementing this
option.
Rules will not require use of this option.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
When will rulemaking be completed?
What documents will be allowed for ID?
What documents will be allowed for proof of residence and how will those documents be verified?
Will these requirements be for original, renewal and replacement DL/ID cards?
Where will funding come from?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
OREGON
Jurisdiction Impact Analysis Real ID Act Oregon
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Requires rule change.
Requires system changes to allow for more characters.
Have following data elements/features on the document:
Mostly compliant.
82. Full Legal Name
83. Person’s Date of Birth
1. Requires rule change to use full legal name
Requires System Changes to allow for more characters
84. Person’s Gender
85. Person’s DL or ID Card Number
86. Digital Photograph of Person (and retention)
87. Person’s Address of Principle Residence
88. Person’s Signature
6. Requires statute change. Current statute allows for
police officers and eligible employees to use their agency
address.
89. Physical Security Features to prevent tampering,
counterfeiting or duplication
90. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
9. May require statute or policy change depending on the
federal rule restrictions on the data availability and use.
May require new card format depending on technology
chosen. We currently have 1D and 2D.
Requires statute change.
Requires system changes.
Requires additional FTE.
Unfunded fiscal impact.
ASSUMPTIONS
AAMVA standards for legal name (125 characters)
will be required as specified in the Security
Framework and DLA.
1. Federal rulemaking may further clarify name
specifications and whether or not names can be
truncated on the actual driver license if too long.
Projected impacts are based on assumptions that
federal rulemaking mirror the requirements as
defined in the Security Framework. Name
collection, use and maintenance procedures
(Appendix 14-7.1-03) Card specifications
(Appendix 17-7.3-05)
6. Federal rulemaking may allow for police
officers and eligible employees to use their agency
address.
9. Federal rulemaking may define additional data
element requirements for common machinereadable technology than we use currently.
REAL ID ACT REQUIREMENT
IMPACT
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Requires system changes.
If only adding “temporary” and changing expiration date,
will not need new vendor contract.
Unfunded fiscal impact.
Verification at Source:
1. Requires Memorandum of Agreement (MOA)
Requires system changes to use SSOLV
Requires procedure changes.
Requires additional FTE to verify
Requires legislative direction to verify for all
transactions.
Unfunded fiscal impact.
Enabling your system to electronically verify
documentation with:
1. SSOLV (SSN Verification)
2. SAVE (Alien Registration # Verification)
3. DEERS (DOD) (Military Common Access Card
Verification)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
ASSUMPTIONS
General - Federal rulemaking may need to define
“verification”. Does all verification have to be
done electronically?
2. Requires rule or policy change.
Requires MOA.
Requires system changes to use SAVE
Requires procedure change.
Requires additional FTE to verify.
Unfunded fiscal impact.
3. Requires rule or policy change.
Requires MOA.
Requires system changes to access DEERS
Requires procedure change.
Requires additional FTE to verify.
Unfunded fiscal impact.
4. Requires system to easily access other states licenses.
Possible system changes.
Requires procedure change.
Requires rule or policy change.
Unfunded fiscal impact.
5. Requires system to easily access birth certificate
information.
Possible system changes.
Requires procedure change.
Requires rule or policy change.
Unfunded fiscal impact.
4. Homeland Security and/or AAMVA will need to
develop system connections for states to hook up to
for verifying other jurisdictions DL/ID cards.
5. Homeland Security and/or AAMVA will need to
develop system connections for states to hook up to
for verifying birth certificates.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
6. Don’t know of any other systems that can be used to
check identity documents.
Developing access capability to SAVE system
Requires system changes. Cost for programming and use.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Requires policy or rule changes.
Requires purchase of new equipment
Requires system changes to capture/store document images.
Requires additional FTE.
Unfunded fiscal impact.
Federal rulemaking will be needed to clarify this
requirement.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Requires rule or policy change. Do not retain copies of
identity documents now.
Requires purchase of new equipment.
Requires additional FTE.
Unfunded fiscal impact.
Federal rulemaking will clarify. Can this process
be done instead of capturing documents digitally
and have state still be in compliance with the law.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Requires a process change to take photo of person at
beginning of process.
Requires system changes.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
No impact. We currently have a process to verify a persons
identity at renewal time.
While we assume we are already in compliance, we
will not know for certain until federal rulemaking is
completed.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
Requires a process change.
Requires additional FTE.
Unfunded fiscal impact.
Federal rule making may further define what
specific action a state is required to take.
Check other states if a person already was issued a DL in
another state
Need system (like CDLIS) that shows licenses in other
states.
Cannot be done today.
Federal rulemaking may clarify this requirement.
Homeland Security/AAMVA will develop or
revamp a system like CDLIS or PDPS.
Ensure physical security of locations where DL/ID cards
are produced
We currently have security procedures in place to make our
issuing offices and materials secure. We will only be
impacted if federal rules require specifications we are not
Federal rulemaking may specify details that would
have more impact.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
currently doing.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
Requires rule/policy changes.
May require Union contractual agreements/change.
Unfunded fiscal impact to do background checks on all
employees who produce DLs/IDs. We currently do
background checks for all new field office employees.
Federal rulemaking may clarify the extent to which
security checks will be required.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Currently do fraudulent document training. Possible
changes to the training depending upon the federal rules.
Federal rulemaking may clarify the extent of the
fraudulent document training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Requires system changes.
Oregon DL/ID cards are valid for 8 years.
Federal rulemaking may clarify this requirement.
Alternative document design if it does not meet federal
standard
Requires system changes. Current contract with vendor
allows for new card design.
Legal Presence Requirement
Requires statute change.
Requires system changes.
Requires additional FTE.
Unfunded fiscal impact.
Federal rulemaking will clarify what is necessary to
prove legal presence.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Requires statute changes.
Requires system changes.
Requires rule or policy change.
Unfunded fiscal impact.
Federal rulemaking will clarify information that
needs to be available for states to see. AAMVA
will have an automated system to view or send the
information.
Maintain a state motor vehicle database that contains at a
minimum:
Possible rule or policy change.
Federal rulemaking may specify more data than we
are currently collecting or retaining.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Requires statute change.
Requires system changes.
REAL ID ACT REQUIREMENT
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
IMPACT
ASSUMPTIONS
Requires a new card design.
Unfunded fiscal impact.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
We currently have statute that allows police officers and other authorized personnel to use their agency address in lieu of their actual
residence address. Will the Real ID Act stop us from allowing this?
We assume that the bill does not apply to DL/ID cards already in circulation. We assume the new provisions can be rolled out over the
length of each state’s expiration period. For Oregon this would be 8 years. Is this a correct assumption?
The bill refers to keeping paper copies of identity documents for 7 years and images of identity documents for 10 years. Do states need to
do both?
The bill requires that a state refuse to issue a license or identification card without confirmation that the person is terminating or has
terminated their out of state driver license. What is the definition of “terminated”. Is surrendering their license enough? Are states
responsible to cancel or zero out a license once it is surrendered in another state?
How far back do drivers’ histories need to be kept?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Oregon has not done an impact analysis on the Real ID Act. There are too many unknowns to accurately analyze the impact.
PENNSYLVANIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
IMPACT
Requires extensive system modifications going from 35 bytes
to a 125 byte field to an existing legacy system. Cost to
Pennsylvania – Please refer to Exhibit A - #2.
1.
Requiring the full legal name will be a challenge to
fit on the existing driver’s license.
91. Full Legal Name
2.
Pennsylvania complies
92. Person’s Date of Birth
3.
Pennsylvania complies
93. Person’s Gender
4.
Pennsylvania complies
94. Person’s DL or ID Card Number
5.
Eliminates all valid-without-photo products. As
well, may not be able to continue using temporary
camera card as a valid license.
Have following data elements/features on the
document:
95. Digital Photograph of Person (and
retention)
96. Person’s Address of Principle Residence
97. Person’s Signature
98. Physical Security Features to prevent
tampering, counterfeiting or duplication
99. Common Machine Readable Technology:
6.
Pennsylvania complies
7.
Pennsylvania complies
8.
Pennsylvania currently does not have an OVD in
license core.
9.
Pennsylvania will have to change the format of its
magnetic stripe and 2D barcode.
ASSUMPTIONS
No assumption
1. No assumption
2. N/A
3. N/A
4. N/A
5. Assumes that the law does not provide for religious
photo exemptions.
6. N/A
7. N/A
8. Assumes that Homeland Security adopts AAMVA’s
license standard.
9. Assumes that Homeland Security adopts the AAMVA
standard to be used for magnetic stripes and 2D
barcodes.
Cost to Pennsylvania – Please refer to Exhibit A - #2
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for no
more than 1 year)
Pennsylvania already ties end of stay to license expiration.
N/A
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Currently, the license expiration date coincides with the
temporary INS credentials. This unique expiration date is
used as a visual indicator for law enforcement. Pennsylvania
Pennsylvania’s unique expiry date identifies, for law
enforcement, that the product is temporary.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
does not print “temporary” on the driver’s license.
Cost to Pennsylvania to change existing practice – Please
refer to Exhibit A - #3
Verification at Source:
1. Pennsylvania complies
1.
N/A
Enabling your system to electronically verify
documentation with:
2. Requires a robust online interactive system to
support efficient processing of customers.
2.
Assumes that SAVE information/data is up-todate and system is robust.
1. SSOLV
3. Need clarification
3.
N/A
2. SAVE
4. Pennsylvania does not accept other state’s
license/Id cards as source identification documents.
4.
None
5.
Homeland Security will host/develop the
automated nationwide birth certificate
verification system.
6.
The US Postal Service software for address
verification in limited. A third party vendor
could link person’s name to address.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
5. Requires the development of an automated
nationwide birth certificate verification system.
6. Integrate 3rd party address verification into
licensing systems.
Cost to Pennsylvania – please refer to Exhibit A - #2
and #3
Developing access capability to SAVE system
Requires system modifications to support an
interactive online verification. Cost to Pennsylvania –
Please refer to Exhibit A - #2.
The SAVE system can provide sub-second response for
on-line verification to all states.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Will need imaging equipment and system
infrastructure at front line to capture, electronically
transfer state-to-state, and store images. Cost to
Pennsylvania – Please refer to Exhibit A - #1 and #3.
AAMVA will provide the infrastructure to electronically
transfer images state to state. In addition, AAMVA
assume the role for standardization. Standards are
adopted on or before May, 2007.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Pennsylvania will have to acquire more electronic
storage space. Cost to Pennsylvania – Please refer to
Exhibit A - #2
None
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Pennsylvania complies with the exception of the
valid-without-photo driver’s license.
Assumes that the law does not provide for religious
exemptions.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
If acceptable to only verify social security number, the
impact would be minimal. If required to verify all
source documents. Cost to Pennsylvania – Please
refer to Exhibit A - #1.
That social security verification will be accepted, and the
social security number has already been verified through
SSOLV, and the results maintained.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
How will we determine that social security needs to
provide additional information? Currently, the
customer resolves discrepancies with social security
prior to a product being issued. This would be
impossible for the states to resolve.
Each state will only issue a product for applicants whose
social security number verifies with the Social Security
Administration.
Check other states if a person already was issued a DL in
another state
The development of an all state non-commercial
driver’s license pointer system and the integration of
the system into Pennsylvania’s system. Cost to
Pennsylvania – Please refer to Exhibit A - #2.
The all state non-commercial driver’s license pointer
system will be in place by the effective date.
Ensure physical security of locations where DL/ID cards
are produced
Pennsylvania complies with numerous security
measures such as alarms, motion detectors, back-up
battery systems, etc.
N/A
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Pennsylvania complies – criminal history checks are
completed on all employees and contractors.
N/A
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Pennsylvania complies
AAMVA fraud training is acceptable.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Pennsylvania complies – currently valid for only 4
years.
N/A
Alternative document design if it does not meet federal
standard
Pennsylvania complies
In compliance
Legal Presence Requirement
Pennsylvania complies
N/A
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
The development of an all state non-commercial
driver’s license pointer system and the integration of
the system into Pennsylvania’s system. Cost to
The all state non-commercial driver’s license pointer
system will be in place by the effective date.
Pennsylvania – Please refer to Exhibit A - #2.
Maintain a state motor vehicle database that contains at a
minimum:
All data fields printed on DL/ID cards
Pennsylvania complies with the exception of full legal
name which will require extensive system
modifications to an existing legacy system. Cost to
Pennsylvania – Please refer to Exhibit A - #2.
Does not require states to transfer driver history when
transferring a license from another state.
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Pennsylvania complies
N/A
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
1. What is the implementation date? Does implementation begin in three years or must state be fully
implemented (including having all customers re-credentialed) in three years?
2. For the purpose of recredentialing existing driver license holders, will the verification of social security be
enough?
3. Will rulemaking be required?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
A copy of Pennsylvania’s cost analysis is attached as Exhibit A.
Exhibit A: REAL ID ACT
REQUIREMENT
1. Recredentialing of all
existing drivers
Pennsylvania
IMPACT
•
•
2. System
modifications
•
•
•
•
•
Additional
contracted
staff on front
lines (200)
Additional
contracted
facility and
equipment
needs (10
locations)
Will require
connection
and
transaction
costs for
electronic
verification
Capturing and
storing full
legal name
Image
storage
Scanning
equipment for
Driver
License
Centers (250)
Interstate
Data
Exchange –
FFY
06
FFY
07
FFY
08
$0
$10.15
mil
$14 mil
Legacy
System
Develop
ment
Legacy
System
Develop
ment
$8.75
mil
Legacy
System
Post
Impleme
ntation
Support
$1.3 mil
COSTS
FFY
FFY
09
10
FFY
11
FFY
12
FFY
13
TOTA
L
$14
mil
$14
mil
$14
mil
$2 mil
$0
$68.1
5 mil
$1.3
mil
$1.3
mil
$1.3
mil
$1.3
mil
$1.3
mil
$16.5
5 mil
this will be
included in
system
modifications
as a part of
the system rewrite (Legacy
System)
3. Changes to
license document
•
•
•
TOTAL
Temporary
indicator for
non-US
citizens
DHS
standardizatio
n of security
features (e.g.
Optical
Variable
Device)
Contractual
costs
$0
$.05 mil
$.05 mil
$.05
mil
$.05
mil
$.05
mil
$.05
mil
$.05
mil
$.35
mil
Legacy
System
Develo
pment
Legacy
System
Develo
pment
and
$18.95
mil
Post
Legacy
Support
and
$15.35
mil
$15.3
5 mil
$15.3
5 mil
$15.3
5 mil
$3.35
mil
$1.35
mil
TOTA
L
$85.0
5
RHODE ISLAND
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
None
Have following data elements/features on the document:
None
ASSUMPTIONS
100. Full Legal Name
101. Person’s Date of Birth
102. Person’s Gender
103. Person’s DL or ID Card Number
104. Digital Photograph of Person (and retention)
105. Person’s Address of Principle Residence
106. Person’s Signature
107. Physical Security Features to prevent tampering,
counterfeiting or duplication
108. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Technological / Financial
Software program changes to DMV computer system
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Technological / Financial
Software program changes to DMV computer
system and program changes to vendor system
Verification at Source:
Technological / Financial
Enabling your system to electronically verify
Personnel – Training for DMV & Law
Enforcement
The DMV’s antiquated computer system & database
would inhibit the ability to interface with other
jurisdictions. DMV would be required to upgrade
REAL ID ACT REQUIREMENT
IMPACT
documentation with:
ASSUMPTIONS
computer system at a cost of $20 million.
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Technological / Financial
Develop interface between systems.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
retained in electronic storage in a transferable format
Financial
Purchase of image equipment (hardware & software) and
server for storage.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Financial
Paper copies – rental of storage area
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None
Image document – purchase of software & hardware for
storage.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
None
Check other states if a person already was issued a DL in
another state
None
Ensure physical security of locations where DL/ID cards
None
Requirement of vendor.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
are produced
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
requirements
None
Requirement of vendor.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Financial / Personnel
DMV would need to hirer law enforcement personnel to
verify documents.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None
Alternative document design if it does not meet federal
standard
Technological / Financial
Systems change for both DMV and vendor.
Legal Presence Requirement
Financial / Personnel
DMV would need to hirer law enforcement/immigration
personnel to verify documentation for legal presence.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Technological / Financial
The DMV’s antiquated computer system & database
would inhibit the ability to interface with other
jurisdictions. DMV would be required to upgrade
computer system at a cost of $20 million.
Maintain a state motor vehicle database that contains at a
minimum:
None
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
Technological / Financial
Systems change for both DMV and vendor.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
What funding will be available to states to help implement the Real ID Act?
Does the Federal Government plan to provide immigration personnel at the DMV license issuing sites?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
The RI DMV is in the process of forming a committee to examine the impact of the Real ID Act. A major
concern of the RI DMV is the inability of our circa 1979 COBOL based data processing system to handle
communications and change requirements for this Act. Simple changes to our computer system require months
of programming and are very costly. Estimated cost to update this antiquated system is a minimum of $20
million. Another major concern is the impact Real ID Act will have on current personnel. The already over
worked DMV clerks will have the additional burden of the requirements of the Real ID Act.
SOUTH CAROLINA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
Currently capture last, first and middle name, with suffix.
Last name field currently limited to _____ characters,
First name ________ characters, _________middle name
_________ characters. System can accept hyphenated
names, up to character limitation. Characters limited by
available space on DL/ID credential.
ASSUMPTIONS
Need more clarification on what is required of “full
legal name”
N/a
Have following data elements/features on the document:
109. Full Legal Name
See above
110. Person’s Date of Birth
Already captured
111. Person’s Gender
Already captured
112. Person’s DL or ID Card Number
Already captured
113. Digital Photograph of Person (and retention)
Already captured
114. Person’s Address of Principle Residence
Already captured
115. Person’s Signature
Already captured
116. Physical Security Features to prevent tampering,
counterfeiting or duplication
The following features are already on the credential
_______________________________________
117. Common Machine Readable Technology:
Mag stripe and bar code according to AAMVA standards
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Already tying expiration to end of stay for foreign
nationals, with a minimum one year expiration date
N/A
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Will require ________________
Reconfiguration of DL issuance equipment
Estimated fiscal impact:
Training $100/employee x 700 employees
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Training $70,000
Verification at Source:
Enabling your system to electronically verify
documentation with:
1.
SSOLV
2.
SAVE
1. Currently real time for CDL. Going real time for all
DL will increase processing time for each transaction by
about 30 seconds. Will increase repeat visits for
customers not matching.
2.
3.
DEERS (DOD)
Not currently connected – increase processing time
since it requires manual entry for each transaction
total processing cost _______________
System update costs _______________
3.
4. Other jurisdiction (DL/ID card)
Allow use of military ID to verify identity only for
people born before 1918 and then only in
conjunction with another identify document.
Impact negligible, more so as time goes forward.
Don’t currently have access to DEERS system.
System update costs _________________
SSOLV only on original DL/ID 30 seconds x _____
original DLs per year
2. increase processing time for each original foreign
national transaction by up to 1 minute. 1 minute x
____ original Non-citizen applications/year.
System update cost calculation:
Concerns: System not up to date… months behind.
Have tried to use it to verify foreign nationals…
totally unreliable.
Need system to system capability to increase
efficiency
3.
increase processing time for each original DL
for which the customer uses military ID as
identification.
4.
Assume that state to state verification will be
through AAMVA
5.
Not all states have electronic verification
capabilities – if manual process is required, the
impact will include 5 additional FTE’s
@$22,000/year
5. Birth certificate
6. Other…i.e. third party vendors
4.
Need to tie in through AAMVA’s new system
System update costs _______________
5.
Tie in with states’ birth certificate databases
System update costs _______________
REAL ID ACT REQUIREMENT
IMPACT
Developing access capability to SAVE system
Need info here
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Need info here
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Additional storage hardware for document management
system
_______________
ASSUMPTIONS
? additional jukeboxes?
Additional high speed scanners
5 FTE @ 20,000/year
Additional scanning staff
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Already required – no impact (do we allow people to not
have their picture taken for religious reasons?)
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Will require two step process or back end verification.
Additional verification resources $440,000
20 FTE @ $22,000/year
Training $300 x 100 employees
Policy change
Process change
Training - $30,000
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
Additional staff to resolve discrepancies with SS
administration and other primary agencies
Check other states if a person already was issued a DL in
another state
Through PDPS and CDLIS?
Ensure physical security of locations where DL/ID cards
are produced
Increased building security ___________
10 FTE @ $22,000/year
$$220,000
Cameras ________
Safes in all offices?
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Already conduct local criminal background checks. If
additional FBI background checks are required,
_________________
$25/employee x ________current employees
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Expand fraud training $181,000
Additional trainers 2 FTE @ $31,000/year
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Requires statuatory change
Alternative document design if it does not meet federal
standard (this requirement is to clearly state that DL/ID
cannot be used for identification purposes if we can’t meet
all standards)
Statuatory Change
Legal Presence Requirement verifying citizen’s legal
address and foreign citizen’s authorization to remain in this
county. Required to use the SAVE system. Requires
periodic confirmation (after original issue)
Statutory change
Employee training cost $300/person x 500
employees/year
Program change
Policy Change
Program change ___________
Policy and process change
Training $210,000
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Requires that we meet DLA requirements for information
that must be maintained on the AAMVA database
System requirements to link all state databases (through
AAMVA?)
Maintain a state motor vehicle database that contains at a
minimum:
Need info here
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
$25/employee x _______ new employees per year
Training cost $300 x 700 employees
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
licenses
Optional
Could be paper document or separate credential
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
Statutory change
$100/employee x 100 employees
Policy change
Process change
Training - $10,000
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
SAVE database is notoriously unreliable… months behind. Many states do not have electronic means of verifying birth certificates. How can states be
expected to conform to technology requirements that haven’t even been developed yet?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
SOUTH DAKOTA
SD Jurisdiction Impact Analysis Real ID Act
REAL ID ACT
REQUIREMENT
Introduce Full Legal Name into
Driver Licensing System (in
Record, on Document)
IMPACT
SD already has the capability to include the full legal name in the DL system, both on the
Record and on the Document.
May need to change SDCL 31-12-17.10, which states that the DL shall contain the full
legal name or any other name lawfully taken. By policy, full legal name is used but there
are rare occasions when another name may be used if the person certifies that they are
using the name for lawful purposes.
Have following data
elements/features on the
document:
118. Full Legal Name
119. Person’s Date of Birth
120. Person’s Gender
121. Person’s DL or ID Card
Number
122. Digital Photograph of
Person (and retention)
123. Person’s Address of
Principle Residence
May need to change SDCL 31-12-17.10, which states that the DL shall contain the full
legal name or any other name lawfully taken. By policy, full legal name is used but there
are rare occasions when another name may be used if the person certifies that they are
using the name for lawful purposes.
Need federal guidance regarding the definition of principal residence. Specifically
what should the procedure be for a person who lives in a RV, has chosen a
jurisdiction as their state of domicile but has only a RV park address or a Personal
Mail Box Address. Are these types of addresses acceptable? This needs to be
addressed in the regulations.
SD DL/ID contains physical security requirements. The federal regulations should
state what types of security features must be included on the DL/ID.
124. Person’s Signature
125. Physical Security
Features to prevent
tampering, counterfeiting
or duplication
126. Common Machine
SD driver licenses and ID cards currently contain a SD barcode that is the standard
according to the American Association of Motor Vehicle Administrators (AAMVA) –
Guidance is needed regarding if the AAMVA standard is acceptable, and if the
AAMVA standard is not the common machine readable technology, what is the
common machine readable technology. Guidance is needed to define what the
ASSUMPTIONS
This is assuming that we are
allowed to use the naming
conventions that we are
currently using. If there is a
change to the naming
conventions in the system,
we may need to make
system changes.
REAL ID ACT
REQUIREMENT
Readable Technology:
IMPACT
required data elements are in the machine readable technology.
Costs will depend upon what the regulations contain as far as required data elements and
required machine readable technology. We may need to make changes depending on
what the regulations require.
Introduce temporary DL/ID cards
and tying end of stay to expiration
of DL/ID card (or issuance for no
more than 1 year)
Amending card design to
show/indicate that it is a temporary
document with a “different than
usual” expiration date
Verification at Source:
Enabling your system to
electronically verify
documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID
card)
5. Birth certificate
6. Other…i.e. third party
SD currently issues the DL/ID through the duration of stay of the applicant except for
those who have an indefinite status. Currently, those with an indefinite status receive a
full 5 year license.
The Regulations should outline specific immigration documents and which ones
should have an issue date of no more than 1 year.
SD will need to change our programming. The SD DL/ID that have a expiration date less
than 5 years because the applicant presented a immigration document of less than 5 years
are not marked as a temporary. They look the same as any other DL/ID card except the
expiration date is less. This may also require legislation as we don’t have specific
authority to mark clearly as temporary. Estimated cost for programming change $7,000 –
$10,000.
Specific federal guidance needed in this area. Is manual verification acceptable?
Manual verification will result in need for additional staff. Electronic processes will
require programming and on-going maintenance costs. There is currently not an
established nationwide system for verifying breeder documents including birth
certificates and passports.
SD is currently working on programming to participate in a pilot funded by the Federal
Motor Carrier Safety Administration (FMCSA) in cooperation with the American
Association of Motor Vehicle Administrators (AAMVA.) to verify birth records. Costs
for post pilot are yet to be determined. Currently, SD, MN, ND, and IA are participating
in the pilot.
SD is developing a system to verify SD birth and death records.
1. SD currently utilizes SSOLV.
2. SAVE is used in limited locations
ASSUMPTIONS
REAL ID ACT
REQUIREMENT
vendors
IMPACT
ASSUMPTIONS
3. DEERS is not used in SD
4. All jurisdictions don’t have the capability to verify status and history information. SD
has gone production with TASK 9 but there are so few states involved that the benefits
are minimal.
5. Birth Certificate – no nationwide system is in place. SD currently involved in the
pilot EVVER program.
6. Any type of verification system will require changes to jurisdiction systems and will
cost states $.
Estimate that at least 1 additional staff member per exam team (16) may be needed to
implement the provisions of the REAL ID act and continue to provide efficient service.
Developing access capability to
SAVE system
Introduce equipment into system
to capture digital images of
identity source documents so that
images can be retained in
electronic storage in a transferable
format
SD has signed a MOU and currently utilizes the SAVE program in areas where the
examiners have access to the internet. This will need to be expanded to all areas – This
will likely be a manual process (Examiner to contact an exam site with internet access to
run the check for them.) Current Cost – initial inquiry 26 cents. Secondary inquiry, if
needed 48 cents per inquiry. Current monthly costs run from $50.00 - $75.00 per month
and are paid by Homeland Security. This will increase slightly to an estimated $100 per
month.
SD currently copies all immigration documents as well as source documents presented to
obtain a commercial driver license with a Hazardous Materials Endorsement. These
copies are scanned into a document imaging system and retained in an electronic format.
Will need to expand the copying, scanning and filing of documents to meet this
requirement.
Federal Guidance is needed regarding which types of applicants will be required to
show source documents. For example - Does an applicant need to show a birth
certificate at each issue and reissue including duplicates and renewals, or is this just
SD will expand their current
utilization of the SAVE
program – assuming that we
will be allowed to use the
existing MOU that we
recently entered into.
REAL ID ACT
REQUIREMENT
IMPACT
ASSUMPTIONS
for first time applicants in a jurisdiction (including transfers from out of state).
More copying will be required. This will take up more storage space and result in the
need to purchase additional disks for storage and eventually an additional jukebox.
Future storage needs will be greater as a result of the REAL ID Act.
Cost of storage disks - $80 each. Each disk is backed up on another disk and stored offsite. Thus, each disk needed results in 2 disks.
Cost of jukebox (64 disk) - $25,000.
Will result in need for additional staff to accommodate the extra copying and scanning of
documents. Estimate 1 additional full time employee to accommodate the copying,
scanning and filing of documents into a document imaging system.
Retain paper copies of source
documents for a minimum of 7
years or images of source
documents presented for a
minimum of 10 years
Subject each person applying for a
driver’s license or identification
card to mandatory facial image
capture
The images are kept for an indefinite period of time. See above for additional costs
associated with additional storage space
A process/system change will be required to capture a mandatory facial image of each
applicant. Photo is currently only captured if DL/ID is issued. If a person is not issued a
DL/ID, a photo is not captured.
SD is nearing the end of our current DL issuance contract. The timing is good to
incorporate this change into the new system development/redesign.
If we were required to make the software change as a separate change, the costs would be
much greater than if we work it into the redesigned system.
Establish an effective procedure to
confirm or verify a renewing
applicant’s information
Guidance needed regarding what the effective procedure is for confirming or
verifying a renewing applicant’s information
In the event that a social security
account number is already
registered to or associated with
another person to which any state
SD meets this requirement
This is assuming that the
way we handle these
situations is deemed
appropriate. SD works
REAL ID ACT
REQUIREMENT
IMPACT
has issued a DL/ID card, the state
shall resolve the discrepancy and
take appropriate action
Check other states if a person
already was issued a DL in another
state
Ensure physical security of
locations where DL/ID cards are
produced
ASSUMPTIONS
through these situations
currently and if there is
fraud involved, law
enforcement is contacted.
This is not possible at this time as there is no system in place. It seems that to do this
effectively, the Driver Record Information Verification System (DRIVerS) must be
developed.
This is with the assumption
that DRIVerS is the system
that is utilized. Developing
an entire new system would
be way too costly.
SD has security measures in place at driver exam locations. Specific Federal guidance
is needed in this area to determine what steps are necessary to ensure physical
security.
SD may need to hire a security specialist to develop and implement a security assessment,
and security plan including audit processes at all SD exam stations and local government
sites that partner with DL for driver licensing services.
SD may also need to purchase security systems for exam stations, car alarms and car
vaults for traveling exam teams.
Security Systems -$2000 per location – 52 locations - $104,000
Car alarms for traveling exam teams – 9 @ $200.00 - $1800.00
Vaults for traveling teams – 9 @ 350 - $3150.00
Subject all person’s authorized to
manufacture or produce DL/ID
cards to appropriate security
clearance requirements
Specific Federal guidance is needed regarding what the background check is to
consist of.
All new DPS employees are subject to a background check. This will need to be
expanded to include all existing driver licensing employees as well as the county and city
officials that Driver Licensing partners with to provide driver licensing services.
100 background checks at $10 each - $1000. Subject to change depending on what the
security clearance requirement consists of.
Establish fraudulent document
Driver Licensing currently has a fraudulent document recognition training program that
This is assuming that the
REAL ID ACT
REQUIREMENT
recognition training programs for
appropriate employees engaged in
the issuance of DL/ID cards
IMPACT
was developed by AAMVA. This will need to be expanded to the county and city
officials that we have partnered with to provide DL services
Estimated costs - 3 trainings provided to local government employees – one night stay
and meals - $11,000
Would recommend that the federal requirements specify that the AAMVA course is
an acceptable course.
Limit period of validity of DL/ID
cards that are not temporary to a
period not exceeding 8 years
Not an issue. SD driver licenses and ID cards are valid for 5 years or less.
Alternative document design if it
does not meet federal standard
We intend to meet the standard. Creating a new design would require system changes and would be costly.
Legal Presence Requirement
SD currently requires a person to be in the United States legally and we tie the expiration date of the DL to
the immigration document.
The Federal Regulations should list specific immigration documents and how states are required to
handle those types of documents to ensure that states have adequate guidance when encountering
different immigration documents.
Provide electronic access to all
other states to information
contained in the motor vehicle
database of the state
Maintain a state motor vehicle
database that contains at a
minimum:
All data fields printed on
DL/ID cards
motor vehicle driver’s
histories, including motor
vehicle violations,
This is not possible at this time as there is no system in place. It seems that to do this
effectively, the Driver Record Information Verification System (DRIVerS) must be
developed.
SD Driver Licensing Database contains required information.
ASSUMPTIONS
Fraud Document
Recognition Training that
was developed by AAMVA
is the recommended course.
REAL ID ACT
REQUIREMENT
IMPACT
ASSUMPTIONS
suspensions and points on
licenses
OptionalDevelopment and
issuance of a certificate of driving
– not for federal identification
purposes – for those who cannot
prove lawful presence.
This would be costly. Our state law requires a person to be authorized to be in the United States to obtain a
driver license. To change this would require a statute change.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
• Will there be a list of acceptable documents for driver license and identification card issuance?
• Do passports contain full legal name and if so, are passports considered an acceptable photo identity
document?
• What is address of principal residence? That needs to be clearly defined and there needs to be specific
guidance regarding what is acceptable documentation of residency for a person who claims a jurisdiction
to be there domicile but has no actual physical address.
• What is considered address verification? Is this looking at a utility bill or rental agreement or is this
referring to an electronic verification of some sort. If a manual verification is acceptable, the regulations
should indicate which documents are considered acceptable verification.
• I bolded several additional areas in the impact area of the template indicating where federal guidance is
needed.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
• The information from the impact analysis that I have done is included within the impact area of this
template.
TENNESSEE
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System (in
Record, on Document)
IMPACT
We need clarification on the number of characters that
will be allowed. We would need to convert to DB2
database as our current record and issuance programs
are limited.
The cost estimate for conversion is very roughly
estimated to be between $1 to 2 million.
Have following data elements/features on the document:
127. Full Legal Name
128. Person’s Date of Birth
129. Person’s Gender
ASSUMPTIONS
Our current programs are limited to 12 characters
for the first name, 12 characters for the middle name
and 20 characters for the last name. This would not
allow for the “full legal name” to be maintained on
the record or be printed on the document.
We currently meet requirements 2 thru 8.
On #1, as stated above, we are limited to the number of
characters that we can store and print on the document
On #9, we currently have 1D and 2D bar codes
130. Person’s DL or ID Card Number
131. Digital Photograph of Person (and retention)
132. Person’s Address of Principle Residence
133. Person’s Signature
134. Physical Security Features to prevent tampering,
counterfeiting or duplication
135. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
This would require legislative changes including fee
structure changes to set up an new classification of
driving privilege. There will be minor program changes
and associated costs. Approximate cost $15,000
We already have a system design that allows for
issuance based on documentation presented and
expiration dates based on the documentation. We
would need to “design” the new “temporary driver
license” which would at no cost due to our
stipulation in our current contract which provides
for new formats without cost.
REAL ID ACT REQUIREMENT
Amending card design to show/indicate that it is a temporary
document with a “different than usual” expiration date
IMPACT
ASSUMPTIONS
This will be handled as stated above
Verification at Source:
Enabling your system to electronically verify documentation
with:
1. SSOLV
2. SAVE
1. We already utilize the SSOLV system
2. We are reviewing the MOU for SAVE
3. DEERS (DOD)
3. I am in the process of obtaining information on the
DEERS (DOD) and exploring how we get acces.
4. Other jurisdiction (DL/ID card)
4.
5. Birth certificate
5. Unknown to our knowledge there is no system for the
electronic verification of Birth Certificates
6. Other…i.e. third party vendors
6. This alternative will be explored, however, at this
point, we do not have sufficient information to make a
determination.
Developing access capability to SAVE system
We are exploring web based access at this time
Introduce equipment into system to capture digital images of
identity source documents so that images can be retained in
electronic storage in a transferable format
A system to fulfil this requirement would have to be
procured
Retain paper copies of source documents for a minimum of 7
years or images of source documents presented for a
minimum of 10 years
None
We anticipate having a system for digital capture of
identity source documents .
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
We currently have a digitized issuance system however,
legislation would be required to delete the exception.
Currently, drivers over 60 years of age are allowed
to have “Valid without Photo” driver licenses
Cost unknown at this time.
We currently do not capture identity source
documents in any manner. We are in the
processing of writing an RFP for a new digitized
issuance system and this might be made part of the
contract.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Establish an effective procedure to confirm or verify a
renewing applicant’s information
This could eliminate our Internet and mail renewal
programs if the rules require the documentation to be
presented in person.
In the event that a social security account number is already
registered to or associated with another person to which any
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
We would need more staff at our Helpdesk to resolve
these SS # issues. We would also need to receive
additional information on our SSLOV inquiries.
Check other states if a person already was issued a DL in
another state
We currently electronically notify the other state that
their driver is surrendering the out-of-state driver license
and obtaining a TN driver license
Ensure physical security of locations where DL/ID cards are
produced
None
We feel that we currently meet this requirement to
the extent possible.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
Need a clarification on “appropriate security clearance”
requirements
Currently all DOS employees including temporaries
undergo a Criminal History background check.
County Clerk contractors do not undergo this
background check.
Establish fraudulent document recognition training programs
for appropriate employees engaged in the issuance of DL/ID
cards
We have already began this process by getting 24
employees certified thru AAMVA’s FDR Train-theTrainer Program
We have 13 one week training sessions in the
planning stages which will provide the FDR training
to all our dl field personnel.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None
We already have a basic 5 year issuance program
with approval for initial issuance periods of 3 years
to 7 years as needed to get the driver on a renewal
cycle on his/her birthday in a year divisible by 5 ie
25, 30
Alternative document design if it does not meet federal
standard
None
We currently have the CFD design
Currently, the applicant is required to resolve any
SS# discrepancy.
REAL ID ACT REQUIREMENT
IMPACT
Legal Presence Requirement
None
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
This would require some major programming changes
estimated at $200,000 to $300,000
Maintain a state motor vehicle database that contains at a
minimum:
None
ASSUMPTIONS
We are currently more stringent than this
requirement as we require proof of U.S. Citizenship
or Lawful Permanent Residency for qualification for
a TN Driver License or Photo Identification Only
License
We currently meet and exceed this requirement
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not for
federal identification purposes – for those who cannot prove
lawful presence.
None
We implemented the Certificate for Driving
program in July, 2004
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Need further clarification on the following:
1. What constitutes an appropriate security clearance? We currently do Criminal History checks on
our employees and potential employees can be disregarded if they have certain convictions on their
criminal history.
Will there be a set of standard convictions that will prohibit a person from working for or contracting with
driver license
Issuance?
2. What is the criteria for an effective procedure to confirm or verify a renewing applicant’s information?
Will we have to discontinue our Internet and Mail transactions and require that every driver come
into a driver license station or will alternative methods be considered?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
UTAH
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Utah allows 15 spaces for the last name, 15 spaces for the
middle name and 15 spaces for the first name. Utah will
need to program our system to allow for more characters
and redesign our card formats.
Have following data elements/features on the document:
Utah will need to make modifications to allow for more
characters in the name field.
136. Full Legal Name
137. Person’s Date of Birth
Utah is in compliance with the other items.
138. Person’s Gender
139. Person’s DL or ID Card Number
140. Digital Photograph of Person (and retention)
141. Person’s Address of Principle Residence
142. Person’s Signature
143. Physical Security Features to prevent tampering,
counterfeiting or duplication
144. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Utah will need to write computer programs for the
temporary DL/ID card and design the format of the card.
We will need statutory authority.
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Utah will need to write computer programs for the
temporary DL/ID card and design the format of the card.
We will need statutory authority.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
Verification at Source:
Utah is on-line with SSOLV
Enabling your system to electronically verify
documentation with:
Utah will need to develop applications to verify documents
with SAVE, DEERS, birth certificates and other states.
Program languages and connectivity will be issues. Full
impact and costs are unknown at this time.
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
Utah will need to develop this capability. Impact and cost
are unknown at this time.
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
Utah has an optical imagining system at our central
facility. We need to expand the capability to include a
transferable format. We would need to equip each office
with this system. We will need additional server space.
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Utah does not retain copies of source documents. We will
need additional staff at each field office to make copies or
capture images of source documents.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Utah has alternate renewal programs (renewal by mail,
renewal by Internet and valid without photo). If these
processes are discontinued, we will need more FTE’s in
our field offices. Computer programming will be required
to eliminate alternate renewal programs. We currently
have the ability to capture facial images.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Utah has alternate renewal programs (renewal by mail,
renewal by Internet and valid without photo). If these
processes are discontinued we will need more FTE’s in our
field offices.
ASSUMPTIONS
REAL ID ACT REQUIREMENT
IMPACT
In the event that a social security account number is already
registered to or associated with another person to which
any state has issued a DL/ID card, the state shall resolve
the discrepancy and take appropriate action
Under these circumstances our current procedure is to
require the applicant to resolve the issue. If the state is
required to resolve these issues we will need at least one
additional FTE.
Check other states if a person already was issued a DL in
another state
We currently access PDPS and CDLIS.
Ensure physical security of locations where DL/ID cards
are produced
There will costs associated if on-site visits are required.
No impact if this can be accomplished by contract.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
There will be additional costs for necessary background
checks.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
Utah has implemented AAMVA Fraudulent Document
Recognition Program. There are on-going costs for this
training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
In compliance for driver licenses. We will need to change
statute for the expiration of ID cards.
Alternative document design if it does not meet federal
standard
There will be costs for this requirement. Those costs will
depend on the federal standard design.
Legal Presence Requirement
Utah does not have legal presence law. Statutory changes
will be necessary. Increased workload to verify legal
presence.
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
There will be costs associated with this function. Does this
requirement apply only to MVA exchanges and will
DRIVERS be used? We will need to implement processes
to verify identification cards with other states.
Maintain a state motor vehicle database that contains at a
minimum:
Utah’s database does contain all data fields printed on
DL/ID cards. We will need programming changes if
modifications are made that require additional information
and to accommodate longer name fields.
All data fields printed on DL/ID cards
ASSUMPTIONS
REAL ID ACT REQUIREMENT
Motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
IMPACT
ASSUMPTIONS
Utah driver’s histories include violations and suspensions.
Point systems are unique to each state, how useful will this
information be to other states?
Utah recently passed a law allowing a driving privilege
card to applicants who do not have legal presence.
However this document is not valid identification for a
Utah government entity. We would need legislative
changes to implement this provision as well as computer
programming and card format changes.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
1. Will renewal by mail, renewal by Internet and valid without photo programs be prohibited by this Act?
2. Will DRIVERS be used to exchange information between states or will individual jurisdictions need to
address these issues?
3. Will AAMVA develop a system to access SAVE and DEERS?
4. Will this Act require electronic verification for birth certificates issued in any jurisdiction? What are the
parameters?
5. Will we need to verify documents for existing drivers or only those that apply after the effective date?
6. Will we need to capture a new facial image with each application? We currently allow the applicant to
chose a previous photo for a duplicate license.
7. How will states verify source documents if an electronic method is not available? Written verification?
Phone verification?
8. Can a jurisdiction issue a driver license and identification card to the same person? Can a person hold a
driver license in one jurisdiction and an identification card in another?
9. Will the Department of Homeland Security decide on the security clearance requirements?
10. Will grant money be available through the Department of Homeland Security?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
VERMONT
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
IMPACT
ASSUMPTIONS
This will require a system redesign. We currently can
only capture 25 characters for an applicant’s name.
We are currently in the process of getting a contract for a
new online system. Expanding the number of characters
we can capture will be part of the design.
1.
We capture up to 25 characters.
145. Full Legal Name
2.
Yes
146. Person’s Date of Birth
3.
Yes
147. Person’s Gender
4.
Yes
148. Person’s DL or ID Card Number
5.
Yes
149. Digital Photograph of Person (and retention)
6.
We capture the applicant’s mailing address.
150. Person’s Address of Principle Residence
7.
Yes
151. Person’s Signature
8.
Yes
152. Physical Security Features to prevent tampering,
counterfeiting or duplication
9.
The Bar Code on our licenses/permits meet
the minimum AAMVA standards.
Everything that is on the front of the license
is in the bar code with the exception of the
signature and photo.
Have following data elements/features on the document:
153. Common Machine Readable Technology:
The Mag Stripe does not meet the minimum
AAMVA standards. The Mag Stripe
contains only the name, Date of Birth, height
and weight.
Regarding #1 - If the Real ID Act is similar to the DL/ID
Security Framework which proposes that we have room
to capture 100 characters for an individual’s full legal
name, it will be impossible for use to do this with our
current system. We would not be able to implement this
data element/feature until we get a new system.
Regarding #6 – We question what is AAMVA’s and
Real ID’s definition of “Principal Residence”. Vermont
has definitions for both Mailing and Legal Addresses,
however, they may or may not meet those required in
this Act.
Regarding #9 – We question whether or not our Bar
Codes and Mag Stripes meet AAMVA’s and/or Real
ID’s standards.
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
We do not issue “Temporary Licenses”, however, the
expiration date of the license is tied to the end of stay.
If forced to issue “Temporary Licenses”, it may require
the passage of legislation.
Amending card design to show/indicate that it is a
As indicated above, we do not issue temporary
This would require a redesign of our license or the
REAL ID ACT REQUIREMENT
temporary document with a “different than usual”
expiration date
IMPACT
licenses. The expiration date is the end of stay
date.
REAL ID ACT REQUIREMENT
IMPACT
Verification at Source:
1.
Enabling your system to electronically verify
documentation with:
SSOLV – We are almost done with this and
will be implemented within a month or two.
2.
SAVE – We do not use this system.
1. SSOLV
3.
DEERS (DOD) – We do not use this system.
2. SAVE
4.
Other jurisdiction (DL/ID card) – We collect
Driver Licenses from other jurisdictions and
we periodically send them back to those
jurisdictions, who would then mail us paper
copies of their driving record. We would
then take action if a suspension exists in that
jurisdiction.
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
ASSUMPTIONS
creation of a new license. This would be very costly and
may require the passage of legislation.
ASSUMPTIONS
The SAVE and DEERS (DOD) systems would be a big
issue. We do not have the funds or personnel to
implement these systems. It would require the hiring of
contractors to implement these systems. It would also
require the dedication of personnel to work on these
systems with the contractors until the systems are
implemented. In return, temporary employees would
need to be hired to replace those employees dedicated to
this project.
We also perform PDPS checks for NonCommercial Vehicle License applications and
CDLIS checks for Commercial Vehicle License
applications.
5.
We accept only the original Birth Certificate
or a certified copy of the Birth Certificate.
6.
N/A
Developing access capability to SAVE system.
Big issue. We do not have the funds or the personnel
to pursue implementing this system.
We do not have the funds or personnel to implement this
system. It would require the hiring of contractors to
implement this system. It would also require the
dedication of personnel to work on this system with the
contractors until the system is implemented. In return,
temporary employees would need to be hired to replace
those employees dedicated to this project.
Introduce equipment into system to capture digital images
of identity source documents so that images can be
Documents/images are non-transferable. They can be
seen from our in-house PC’s, but are not transferable
This would require an entirely new imaging system than
the one we currently have. We do not have the funds to
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
retained in electronic storage in a transferable format
outside of the Department.
purchase a new system that would allow our
documents/photos to be digitally transferable.
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
We currently do this. Source documents are imaged
then are placed in storage.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
We are now a mandatory license state, therefore, we
capture an individual’s facial image when they obtain
a Driver’s License/Permit/ID Card.
Establish an effective procedure to confirm or verify a
renewing applicant’s information
We currently require 2 forms of ID for License/Permit
renewals. The applicant’s current License/Permit
serves as 1 form of ID and the 2nd form of ID is a
document that is on AAMVA’s list of acceptable ID’s.
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
We feel that the customer should be responsible for
resolving any SSN discrepancies.
If we were required to do this, we would need additional
personnel, as it would take a lot longer to process a
license application. We do not have the funds for
additional personnel.
Check other states if a person already was issued a DL in
another state
We currently use PDPS and CDLIS for checking what
other states the applicant was previously licensed.
It is possible that we would need the DRIVerS system
for this. If so, we do not have the funds or personnel to
implement this system. It would require the hiring of
contractors to implement this system. It would also
require the dedication of personnel to work on this
system with the contractors until the system is
implemented. In return, temporary employees would
need to be hired to replace those employees dedicated to
this project.
Ensure physical security of locations where DL/ID cards
are produced
Our materials for making a License/Permit/ID are kept
in locked cabinets/drawers.
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance
This is a huge issue. The Vermont State Employees
Association (Union) may not wish to have their
We question what is meant by “applying”. Is
AAMVA/Real ID requiring us to capture a facial image
if, for example, an applicant takes and exam and fails,
therefore not obtaining a License/Permit?
We would mostly likely need VSEA’s approval as well
as a Departmental Policy.
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
requirements
members undergo background checks.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
We currently do fraudulent ID training.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
We currently do this. The maximum renewal period
for a License is 8 years.
Alternative document design if it does not meet federal
standard
We have our own design.
If we have to redesign our Licenses/Permits/ID’s, it
would be a huge financial impact.
Legal Presence Requirement
We only collect a “legal address” when the
individual’s address is a Post Office Box. The “legal
address” is usually the 911 address.
We question exactly what is AAMVA’s/Real ID’s
definition of “Legal Presence”. Does it match our
definition of “legal address”?
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
Other states are able to access our records via PDPS
and CDLIS.
Maintain a state motor vehicle database that contains at a
minimum:
We currently do this.
All data fields printed on DL/ID cards
Motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
We issue Driver Licenses and Permits to anyone. We
only issue Non-Driver ID’s to Vermont Residents.
What is the definition of Federal identification purposes?
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
1.
By what date are states required to implement the Real ID Act?
2.
What are the consequences should we not meet the required implementation date?
3.
Will Federal funds be made available to implement the Real ID Act?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
We prepared a Cost Analysis Template which we have enclosed.
VIRGINIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System (in Record, on
Document)
Have following data elements/features on the document:
1. System and card format will need to be
redesigned to accommodate space for full
legal name on DL/ID.
1. Most complete version of applicant’s
name as displayed on proof
documents will be used.
2. Full compliance – No impact
2.
3. Full compliance – No impact
3.
4. Full compliance – No impact
4.
1.
Full Legal Name
2.
Person’s Date of Birth
3.
Person’s Gender
4.
Person’s DL or ID Card Number
5.
Digital Photograph of Person (and retention)
6.
Person’s Address of Principle Residence
7.
Person’s Signature
5. Full compliance – No impact
5.
8.
Physical Security Features to prevent tampering, counterfeiting or
duplication
9.
Common Machine Readable Technology:
6. Statutory changes necessary to
disallow the use of a mailing address
to show on the DL/ID.– will eliminate
current “stalking protection law”
6. Assume the license must show the
actual physical address of the holder’s
residence.
7. Full compliance – No impact
7.
8. No impact
8. New VA DL/ID (Fall of 2006) will
conform to guidelines established by
AAMVA.
9. Full compliance – No impact
REAL ID ACT REQUIREMENT
Introduce temporary DL/ID cards and tying end of stay to expiration of
DL/ID card (or issuance for no more than 1 year)
IMPACT
ASSUMPTIONS
Statutory, system, policy, and procedural
changes would be necessary to include
renewals and formerly *“grandfathered”
applicants.
*Any individual who held a driver’s license
on January 1, 2004 was not required to
provide proof of legal presence unless their
license expired or was suspended, cancelled,
revoked.
Amending card design to show/indicate that it is a temporary document with
a “different than usual” expiration date
System and card design changes will be
necessary to “clearly” display the “different
than usual” expiration date.
Verification at Source:
If DMV is not able to electronically verify documentation presented, and is therefore, required
to verify documentation manually, there will be a significant impact on staffing needs. This
would cause an increase in costs.
Enabling your system to electronically verify documentation with:
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
1. System changes would be necessary
if DMV is able to electronically verify that
an applicant has not been issued a SSN.
Legislative change would be necessary to
collect SSN for ID card issuance.
Increased cost if DMV is required to verify
SSNs for holders of ID cards as well as DLs.
DMV’s current practice of displaying a
restriction code that is defined on the back of
the license will need to be revised.
1. Legislative change would be needed to
capture SSN of ID holders – this is currently
prohibited by Federal law.
REAL ID ACT REQUIREMENT
IMPACT
2. Increased cost with increased SAVE
verifications sent and to cover required
system changes.
ASSUMPTIONS
2. All foreign-born applicants would need
to be verified through SAVE before being
issued a DL/ID.
Increase in staff required to send and
analyze responses.
Increase in customer wait time, as not all
inquiries sent will receive an immediate
response – response may not be available for
days.
Current MOU will need to be revised.
3. System changes
DMV would need to enter into a MOU
4. Increased costs for system changes
and for use of the DRIVerS program.
DMV would need to enter into a MOU
5. System changes
DMV would need to enter into a MOU
6. System changes
DMV would need to enter into a MOU
Developing access capability to SAVE system
See response to #2 above
Introduce equipment into system to capture digital images of identity source
documents so that images can be retained in electronic storage in a
transferable format
Increased costs for scanning equipment,
system changes, and additional personnel
will be incurred.
Retain paper copies of source documents for a minimum of 7 years or images
of source documents presented for a minimum of 10 years
Increased costs for additional electronic
storage space.
Subject each person applying for a driver’s license or identification card to
mandatory facial image capture
Full compliance – No impact
3.
4. DRIVerS will need to be operational
before this provision can be feasibly
implemented.
5.
6. Real ID provisions will allow for verification
through third party vendors rather than the
document source.
REAL ID ACT REQUIREMENT
Establish an effective procedure to confirm or verify a renewing applicant’s
information
IMPACT
Renewal through alternative methods will be
eliminated.
New facilities and additional staff will be
necessary for verification of documentation
presented by all applicants (whether original
or renewing)
In the event that a social security account number is already registered to or
associated with another person to which any state has issued a DL/ID card,
the state shall resolve the discrepancy and take appropriate action
Statutory and system changes would be
necessary to require proof documentation for
all renewals as well as original DMV
documents.
Statutory change to require SSNs for ID
cards.
Increased cost of SSN verifications with
increased volume to send.
ASSUMPTIONS
Strict interpretation of the requirement – All
renewals must be verified to include the first
renewal after the effective date of this act and
all subsequent renewals.
Stopping the transaction and not issuing a
DL/ID is not enough to resolve the SSN
discrepancy. The Agency must actually
resolve the discrepancy.
Additional staff to handle SSN
discrepancies.
Will need to revise current MOU.
Check other states if a person already was issued a DL in another state
Increased costs for system changes and for
use of the DRIVerS program.
AAMVA DRIVerS will need to be operational
to feasibly implement this provision.
If DRIVerS is not available, a significant
number of additional staff would be required
to check with other states to see if a person
was already issued a DL elsewhere.
Ensure physical security of locations where DL/ID cards are produced
No impact
These issues will be addressed through
implementation of DL Central Issue – expected
in the Fall of 2006.
Security requirements will be written into the
vendor contract.
REAL ID ACT REQUIREMENT
Subject all person’s authorized to manufacture or produce DL/ID cards to
appropriate security clearance requirements
IMPACT
Increased costs for background checks of
DMV staff.
ASSUMPTIONS
All employees of CSCs or HQ work areas that
handle any portion of the licensing process will
be required to have background checks done.
The requirement for background checks for
vendor employees will be written into the
vendor contract.
Establish fraudulent document recognition training programs for appropriate
employees engaged in the issuance of DL/ID cards
Increased cost to implement training program
and to provide on-going training– could
cause increased wait times and/or require
additional staff as the employees are pulled
from CSCs
Limit period of validity of DL/ID cards that are not temporary to a period not
exceeding 8 years
Full compliance – No impact
Alternative document design if it does not meet federal standard
Legal Presence Requirement
All employees involved in the review of
customer documentation will be trained.
Card redesign
System changes
MOU with vendor would need to be revised.
Statutory changes
Statutory, system, policy, and procedural
changes would be necessary to include
renewals and formerly *“grandfathered”
applicants.
*Any individual who held a driver’s license
on January 1, 2004 was not required to
provide proof of legal presence unless their
license expired. Or was suspended,
cancelled, revoked.
Provide electronic access to all other states to information contained in the
motor vehicle database of the state
System changes would be necessary to
comply with data exchange elements
between states.
DRIVerS
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Maintain a state motor vehicle database that contains at a minimum:
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor vehicle violations,
suspensions and points on licenses
Optional
Development and issuance of a certificate of driving – not for federal
identification purposes – for those who cannot prove lawful presence.
Full compliance – No impact
Statutory and system changes.
Would need to revise MOU.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
Must DMV verify/confirm documentation for EVERY renewal applicant? Or, is it sufficient to verify/confirm documentation for each
applicant the first time they renew after the effective date of this act?
With the exception of this question, we feel it is too early to identify other questions as they would depend on what is required by the
regulations.
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
See attached
Potential Impact of Federal Real ID Act on Virginia DMV
Scenario
Scenario 1: Separate DL/ID
Centers/On-site Document Verification
• All DL/ID customers must present
documents every time
• Separate field DL/ID Centers would be
established
1
One-Time
Costs
Recurring (Annual)
Costs1
FTEs
Needed
Number of New
Facilities Needed
Impact on Average
Customer Wait Time
$136,052,48
1
$62,739,946
1,464
40
No Impact
If regulations require renewal customers to only provide proof documents one time, recurring annual costs drop after 7 years.
• All document verification conducted at
the field DL/ID Centers
• Construction of 40 new facilities and
addition of 1,464 field and call center
staff
Scenario 2: Two-Step Process with
Headquarter Verification
• All DL/ID customers must present
documents one time only
• All document verification conducted
centrally
• No increase in number of facilities or
field staff; headquarters staff would
increase by 111
Scenario 3: Two-Step Process with
Customer Choice and Headquarters
Verification
• DL/ID customers must present
documents one time only; assumes
70% of customers obtain “compliant”
DL or ID
• All document verification conducted
centrally
• No increase in number of facilities or
field staff; headquarters staff would
increase by 77
Scenario 4: Real ID in Today’s
$2,268,049
$5,212,704
111
0
19% increase in
average wait time
(from approx. 20
minutes to 24
minutes on average)
$2,207,119
$3,797,351
77
0
13% increase in
average wait time
(from approx. 20
minutes to 23
minutes on average)
$2,384,762
$803,519
0
0
258% increase in
Environment
• All DL/ID customers must present
documents every time
• All document verification conducted at
the CSCs
• No increase in number of facilities or
staff
average wait time
range 1 hour and 11
minutes to 24 hours
and 57 minutes
WASHINGTON STATE
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
Programming and form changes to provide room for long
names
ASSUMPTIONS
Washington currently allows 28 characters
Service delays as names are documented and recorded
Amend state law to define “full legal name”
Have following data elements/features on the document:
Program changes for one element
1.Full Legal Name
1.
Name is currently limited to 28 characters
2.Person’s Date of Birth
2.
no change
3.Person’s Gender
3.
no change
4.Person’s DL or ID Card Number
4.
no change
5.Digital Photograph of Person (and retention)
5.
no change
6.Person’s Address of Principle Residence
6.
Amend state law that currently provides address
confidentiality for victims of domestic violence
or sex crimes
7.Person’s Signature
8.Physical Security Features to prevent tampering,
counterfeiting or duplication
9.Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay
to expiration of DL/ID card (or issuance for no more
than 1 year)
Reformat of document is required for longer names
1.
Need to determine the maximum number of
characters
2.
currently supported
3.
currently supported
4.
currently supported
5.
currently supported
6.
currently supported – requires definition of
principal res.
7.
no change
7.
currently supported
8.
no change
8.
9.
no change
currently supported – subject to federal
requirements
9.
currently supported – subject to federal
requirements
Programming changes to issue temporary DL/ID
documents and documents with expiration dates tied to
lawful presence
Programming to record and maintain variable expiration
Washington’s documents all have fixed-term expiration
periods based upon the date of birth or the date of
document issue
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
data
Service delays as documents are renewed or reissued
more often
Amend state law regarding expiration date
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Programming changes to issue temporary DL/ID
documents that are unique in design and or color
Verification at Source:
Enabling your system to electronically verify
documentation with:
Programming and equipment required to allow
verification at source and electronic communication of
documents
Amend state law regarding appearance of document
Washington’s documents are currently uniform in color
and appearance with the exception of the document
type label
Washington records document descriptions but does
image them electronically or transmit documents to the
issuing authority
1. SSOLV
1.
no change
1.
currently supported
2. SAVE
2.
programming/equipment required
2.
new process
3. DEERS (DOD)
3.
programming/equipment required
3.
new process
4. Other jurisdiction (DL/ID card)
4.
programming/equipment required
4.
new process
5.
Birth certificate
5.
programming/equipment required
5.
new process
6.
Other…i.e. third party vendors
6.
programming/equipment required
6.
7.
Service delays as checks are made with the
various systems
new process – depends on degree of AAMVA
support
Developing access capability to SAVE system
Programming required
New capability – not currently supported
Introduce equipment into system to capture digital
images of identity source documents so that images can
be retained in electronic storage in a transferable format
Installation of scanners, PC, servers and software to
support digital image capture, storage and retention
New capability – not currently supported
Retain paper copies of source documents for a minimum
of 7 years or images of source documents presented for a
minimum of 10 years
Installation of scanners, PC, servers and software to
support digital image capture, storage and retention
Service delays as documents are scanned and recorded
Amend state law regarding record retention
New capability – not currently supported
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
Amend state law to prohibit religious or other exemptions
Exceptions are currently allowed in some cases
Establish an effective procedure to confirm or verify a
renewing applicant’s information
Undetermined, potential service delays as additional
verification is performed
None if visual verification using the prior photo is
allowed. However, may require adoption of biometric
verification software or other means – PIN – to confirm
renewing applicant information
In the event that a social security account number is
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
resolve the discrepancy and take appropriate action
No impact
Currently supported
Check other states if a person already was issued a DL in
another state
Programming required
AAMVA “all-driver” pointer system connectivity
required, or some alternative for state-to-state
verifications and exchange
Ensure physical security of locations where DL/ID cards
are produced
No impact
Currently supported
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security clearance
requirements
No impact
Currently supported – does not include staff that
process applications and collect fees for issue of 45day temporary documents. Permanent documents are
produced in a secure facility by staff that must meet
these requirements.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
No impact
Currently supported and using AAMVA training
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
Amend state law to delete or alter open expiration period
for military personnel and dependents
Currently support maximum 5 year expiration (other
than licenses issued to military personnel and
dependents)
Alternative document design if it does not meet federal
standard
Programming required
Requires the introduction of alternative formats and or
colors
Service delays stemming from checking with other states
Service delays as alternative designs are introduced and
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
explained to the public
Amend state law regarding document appearance
Legal Presence Requirement
Adopt state law requiring proof of legal presence in order
to obtain document valid for federal ID
Not currently supported
Service delays as additional documents and proof of
lawful presence are determined
Provide electronic access to all other states to
information contained in the motor vehicle database of
the state
Programming required
Not currently supported
Maintain a state motor vehicle database that contains at a
minimum:
Potentially no impact
Depends on the definition of the driver history
elements
Optional
Programming required
Believe that Washington may choose to issue
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
Amend state law regarding document appearance
Amend state law regarding availability of driving records
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including
motor vehicle violations, suspensions and points
on licenses
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
• Full legal name is undefined
• Principal residence address is undefined
• Will alternative renewal – online and by mail –services be permitted
• Will current security features and machine readable technology meet standards to be adopted by DHS
• Will online databases be developed to support verification of source documents with private entities, such as
utility companies
• Who is considered the “issuing agency” for a US birth certificate—hospital, county, state department of
health
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
Fiscal Impact Statement
FT E s
0 7 -0 9
Av e rag e
2 0 0 7 -0 9
B ie n n iu m
2 0 0 9 -1 1
B ie n n iu m
2 0 1 1 -1 3
B ie n n iu m
E X P E N D IT U R E S :
D ir e c t C o s t s :
M a n a g e m e n t S e r v ic e s
In f o r m a t i o n S e r v i c e s
V e h ic le S e r v ic e s
D r iv e r S e r v ic e s
B u s in e s s & P r o f S e r v ic e s
T o t a l D ir e c t C o s t s
A g e n c y In d ir e c t :
M a n a g e m e n t S e r v ic e s
In f o r m a t i o n S e r v i c e s
T o t a l A g e n c y In d ir e c t :
T o t a l E x p e n d it u r e s :
REVENUE:
16
7
0
350
0
374
.8
.0
.0
.3
.0
.1
$ 3 ,6 7 8 ,0 0 0
$ 3 ,7 1 3 ,5 0 2
$0
$ 8 2 ,2 3 0 ,0 0 0
$0
$ 8 9 ,6 2 1 ,5 0 2
$ 1 ,9 9 1 ,0 0 0
$ 2 ,2 1 7 ,5 0 2
$0
$ 8 2 ,1 4 3 ,0 0 0
$0
$ 8 6 ,3 5 1 ,5 0 2
$ 1 ,4 2 7 ,0 0 0
$ 1 ,9 6 4 ,5 0 2
$0
$ 5 3 ,1 7 0 ,0 0 0
$0
$ 5 6 ,5 6 1 ,5 0 2
3 0 .9
1 6 .1
4 7 .0
$ 4 ,1 7 0 ,0 0 0
$ 2 ,9 2 2 ,0 0 0
$ 7 ,0 9 2 ,0 0 0
$ 4 ,1 1 8 ,0 0 0
$ 2 ,8 8 3 ,0 0 0
$ 7 ,0 0 1 ,0 0 0
$ 2 ,6 7 3 ,0 0 0
$ 1 ,8 7 2 ,0 0 0
$ 4 ,5 4 5 ,0 0 0
4 2 1 .1
$ 9 6 ,7 1 3 ,5 0 2
$ 9 3 ,3 5 2 ,5 0 2
$ 6 1 ,1 0 6 ,5 0 2
GF-State
All Other
Total Revenue:
$0
$65,248,570
$65,248,570
$0
$77,127,263
$77,127,263
The major cost driver is the requirement for verification by the issuing entity of the validity and completeness of all proof of identity and
lawful presence documents for applicants and current license and ID holders. This will add new tasks to the driver license issuance and
renewal process and greatly increase the cost of licensure. Following the first five years of implementation, most drivers will have received
a new or replacement license or ID conforming to the RIDA. As a result, costs will drop to approximately $12 million in the 2013-15
biennium. There is no need for a supplemental in 2006 anticipated as a result of this new legislation.
Costs affected by this requirement include:
•
Increased employee time to handle the 1.6 million (first full-year) annual license and ID holders and applicants who will submit an
estimated 4.7 million documents for scanning and indexing. Currently, documents are not scanned. This will add 4.2 minutes on
average per transaction. At this time, it is assumed that a $25.00 document review will need to be charged to the customer in order
to handle charges by verifying entities of the documents. (Example, DOH charges $8 for such verifications).
o 3 minutes for reviewing and scanning documents
o 2 minutes for explanations and instructions to 60 percent of customers
o 4 minute phone calls from 5 percent of customers.
By comparison, a simple renewal license takes approximately 3 minutes to complete.
Almost 500 employees in the first full-year of operations are required handle the increased workload at a cost of approximately $20
million the first full year.
•
These scanned documents will be sent electronically to a newly created Documents Verification Office. The additional staff needed
for the workload increase in licensing offices will require moving to 10 larger offices. The space for approximately 325 staff related
to document verification will require the lease of a new facility. It is assumed that he verification facility staff will perform in two
shifts in order to reduce costs and better manage interactions with entities in other time zones.
•
It is assumed that 80% of the documents can be verified in three minutes through electronic means while the other 20% will take15
minutes due to mailing requirements.
$67,917,716
$67,917,716
•
It is assumed that verifying entities will charge on average $5.00 per document. This assumption adds approximately $24 million a
year to the costs.
•
Other costs include increased mail costs, call center workload, IT programming, equipment for imaging and related storage and
servers, hearing costs, and support services costs such as HR, accounts payable, payroll, and desktop support.
Implementation Assumptions
•
DOL notification of the general public will begin one year prior to the bill's implementation deadline.
•
Six months prior to the implementation deadline, formal notification will be made of all customers due to renew a license or ID card
at time of implementation. (Existing renewal notice will be replaced with RIDA notice.)
•
Customers will present the required proof of identification and presence at any LSO within the several months before their renewal
date.
•
LSO staff will index and scan each document into document verification storage. Local LSO storage will hold documents for
eventual overnight upload to the document verification server.
•
A $25 document verification fee will be collected from each customer presenting documents.
•
After satisfying all other issuance requirements, customers will be retain their current license and be instructed to destroy it after
receipt of their new license. (except for commercial driver licenses).
•
IS will create and deploy a document image database, document scanners, computers, software, printers and network capacity
needed for scanning at all LSO. Application development or modifications will be required to facilitate image transfer, indexed
storage, retrieval and updates.
•
The Drivers Field System will be modified to communicate with and facilitate use of the document scanners. Customer name and
license number will be transmitted by DFS to the scanner computer. A print process will create an indexing cover sheet that bears a
customer's name and license number and a unique bar code.
•
IS will create and deploy a webservice for document status management. The service will allow customers to verify their RIDA
status.
•
Authorized agency staff will use the webservice to manage and update document status. When staff completes document verification
for a customer the webservice will generate a notice (new postcard) to the customer, or for customers issued a temporary, the
webservice will be used to issue a retake.
•
DOL connectivity with new AAMVA automated processes will allow staff to transmit document images to other license issuing
authorities with a request for verification of issuance, validity and completeness of the document.
•
Driver licensing authorities will NOT charge a fee for document verification among the states. Other document issuing authorities
WILL charge a fee for their verification services. (WA Department of Health charges DSHS $300,000 for real-time access to its
database of birth records.)
•
Assume every customer will have three documents that require paid verification and that the fee for verification is $5.
•
Where automated verification with an issuing agency is not possible, customer service staff will make email or mail contact with the
issuing authority to verify document authenticity and completeness.
•
Documents received by DOL from issuing agencies will be scanned and entered as part of the customer's document verification
record.
•
Customer document images and related verification documents will be maintained in a database for 10 years.
•
Document issues and concerns will require resolution between customers and DOL staff. This will require additional phone calls and
or correspondence.
•
Staff will be added to existing licensing offices where possible.
•
It is assumed that ten offices will be relocated to larger facilities to accommodate customers and driver license issuance staff.
•
These ten offices will operate on extended schedules offering six-day and eleven-hour service access to the public.
•
Additional supervisors will be assigned to provide coverage for these extended schedules.
•
It is assumed that one new facility will house two shifts of customer service staff doing document verification work. This will
facilitate cross country and overseas communication with other jurisdictions and countries.
•
This proposal installs document copying equipment, software and system infrastructure in all driver licensing offices, at licensing
headquarters and at a new "Document Verification Office".
•
The department will implement a media campaign costing $1.5 million in the first year of program implementation.
Equipment assumptions:
• 44 largest driver licensing offices will be equipped with three high speed optical flatbed scanners, desktop computers and software
(incl. one spare)
•
21 remaining driver licensing offices will be equipped with two high speed optical flatbed scanner, desktop computer and software
(incl. one spare)
•
the Document Verification Office will be equipped with 3 high speed auto-feed scanner stations, computers and software (incl. one
spare)
•
1 flatbed scanner and 1 scanner PC for the test lab.
•
the desktop computers will support the scanner software and locally store images until they are uploaded.
•
to mitigate network communications impacts the locally stored images will be uploaded overnight to the main imaging server.
•
the implementation will occur in two phases:
Phase 1, prior to December 1, 2007 will include:
•
project planning and requirements definition
•
system and equipment acquisition, software development/enhancement, installation at LSO locations
•
webservice development and deployment
•
integration of the document capture process with the Drivers Field System (to eliminate staff re-keying the document index
information)
•
policy and procedure development
•
Document Verification Office leasing and installation.
•
Staff hiring and training
•
Public Affairs and Driver coordination of an extensive communication plan.
•
Formal by-mail notification of customers due to renew.
Phase 2, after December 1, 2007 and beyond
• Document verification by DOL staff with issuing agencies.
•
Postcard notification of all non-renewal customers (potential duplicate and PLO customers) in a single mailing.
•
Future enhancement: automated process development to deploy document verification requests to a wider range of issuing agencies.
Workload assumptions:
• Customer document scanning (3 items) 3 minutes total, includes indexing, scanning and verifying image quality.
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Explanation time for RIDA requirements 2 minutes for each customer.
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Thirty percent of customers will verify RIDA status through the webservice.
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Five percent of customers will verify RIDA status by phone at the LSO.
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Thirty-five percent of customers will verify RIDA status with DOL customer service by phone (see MSS tab for staff impact).
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Fifteen percent of customers will wait for DOL to verify RIDA by mail.
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Customer phone calls to the LSO for RIDA status updates 4 minutes each.
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Issuance of temporary RIDA documents 4 minutes each.
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Verification time needed for 80% of customer documents 3 minutes each.
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Verification time needed for 20% of customer documents 15 minutes each.
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US Immigration service data indicate that there are 700,000 persons each year with a pending resident status. Washington's share of
these persons is 2.3%, who will be issued a temporary RIDA document awaiting resolution of their status.
H.R. 1268: Division B, Title II—Improved Security for Drivers’ Licenses and Personal Identification Cards
H.R. 1268, the Emergency Supplemental Appropriations Act for Defense, the Global War on Terror, and Tsunami Relief Act, 2005, was
amended in Conference Committee to include the Real ID provisions of H.R. 418, a bill that was originally introduced in the House of
Representatives by Congressman Jim Sensenbrenner.
Purpose:
As it pertains to state driver’s licenses and identification cards, H.R. 1268 provides that federal agencies will not accept state driver’s
licenses and identification cards for official purposes unless the issuing state meets the minimum document requirements and issuance
standards established in the bill. This limitation becomes effective three years following the date of enactment.
Minimum document requirements: Requires that state-issued driver’s license and identification card documents contain the applicant’s full
legal name, date of birth, gender, license or identification card number, digital photograph, principal residence address, and signature.
The licenses and identification cards must also include physical security features and common machine-readable
technology (presumably such as bar codes) with “defined minimum data elements.” The bill does not specify acceptable
physical security features, and provides no definition of the defined minimum data elements that must be included in the
machine-readable technology.
Driver’s licenses and identification cards issued by the Washington State Department of Licensing may currently meet these requirements,
depending upon how the federal Department of Homeland Security implements the requirements for physical security features and
machine-readable technology.
Minimum issuance standards: Sets minimum requirements for identification documentation and proof of legal status within the United
States that must be submitted by license and identification card applicants.
At a minimum, applicants must present a photo identity document (or a non-photo document with the person’s full legal name and date of
birth), documentation showing the person’s date of birth, proof of the person’s Social Security number (SSN) or verification that the person
is not eligible for an SSN, documentation showing the person’s name and address of principal residence, and evidence of citizenship or
lawful presence within the United States.
Temporary drivers’ licenses and identification cards: Licenses and identification cards issued to applicants who are temporarily within the
United States, or who have pending applications regarding legal status, must be temporary—valid only during the period of time the
applicant is authorized to stay in the United States, or for one year in the event that there is no definite end to the period the applicant is
authorized to stay.
Verification of documents: State licensing agencies are required to verify, with the issuing agency, the issuance, validity, and completeness
of each document submitted by an applicant for purposes of meeting the minimum issuance standards. The only foreign document that may
be used to meet the standards is a passport. The requirement that the state verify the validity of all required documentation with issuing
entities would be a major factor in the expense in implementing this bill.
Not later than September 11, 2005, states must enter into a memorandum of understanding with the Secretary of Homeland Security to
routinely utilize the Systematic Alien Verification for Entitlements system to verify the legal presence of persons other than U.S. citizens
applying for driver’s licenses and identification cards.
Additional requirements: H.R. 1268 includes additional requirements intended to improve security in issuing driver’s licenses and
identification cards and to reduce fraud, including:
•
•
•
•
•
•
•
Digital images of documents submitted must be made by the state licensing agency, and the documents must be maintained for either
seven years in paper format or ten years as digital images.
Persons applying for driver’s licenses and identification cards must be subject to mandatory facial image capture.
States must establish an effective procedure to confirm or verify a renewing applicant’s information.
SSNs must be verified with the Social Security Administration.
States must ensure the physical security of locations where license and identification cards are produced, ensure the security of
materials, require the security clearance of all persons authorized to manufacture or produce driver’s licenses and identification cards,
and establish fraudulent document recognition training programs for appropriate employees.
Limit the period of validity of all driver’s licenses and identification cards that are not temporary to no more than eight years.
Provide electronic access to all other states to information contained in the motor vehicle database.
Alternate driver’s licenses and identification cards: H.R. 1268 provides that driver’s licenses and identification cards that do not satisfy the
minimum document requirements and issuance standards must clearly state that they are not acceptable by any federal agency for official
purposes and must use a unique design or color to alert federal agencies and other law enforcement personnel that they may not be accepted
for such purposes.
Issues of concern:
Washington State is one of ten states that currently do not require proof of legal presence in the United States in order to obtain a driver’s
license or identification card. The requirement for such proof represents a major change in public policy, and will have an impact on all
licensed drivers and identification card holders in this state.
As mentioned above, the requirement to verify the validity of source documentation with issuing agencies will result in a significant fiscal
impact. This requirement may also significantly impact the time necessary to process license and identification card applications and would
most likely affect wait-times. Given the current limitations on database accessibility, the vast majority of this work will need to be
accomplished through manual processes.
There are a number of important elements in the bill that remain unspecified or undefined. For example, there is no precise definition of
“legal name” or “principal residence.” Although document security features are required, there is no indication of whether or not these will
later be specified by the Department of Homeland Security. A person who does not have an SSN is required to provide verification that he
or she is not eligible for an SSN, but there is no indication as to how this might be done. And as mentioned above, minimum data elements
required on unspecified machine-readable technology on the driver’s license or identification card document are not defined. Until these
issues are clarified, it will be difficult to know whether the state will be able to meet the three-year deadline that would be imposed for
compliance.
WEST VIRGINIA
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)
None, already required
Have following data elements/features on the document:
None, already required
ASSUMPTIONS
154. Full Legal Name
155. Person’s Date of Birth
156. Person’s Gender
157. Person’s DL or ID Card Number
158. Digital Photograph of Person (and retention)
159. Person’s Address of Principle Residence
160. Person’s Signature
161. Physical Security Features to prevent tampering,
counterfeiting or duplication
162. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of stay to
expiration of DL/ID card (or issuance for no more than 1
year)
Legal presence already required
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
No temporary license issued
Verification at Source:
1. SSOLV: In Place
Enabling your system to electronically verify
No estimate at this time on impact of required link to
DL/ID card expiration tied to legal presence
General observation; as the number of required links
increases, the incidence of “system down” preventing the
issuance of a driver’s license will increase.
REAL ID ACT REQUIREMENT
documentation with:
IMPACT
ASSUMPTIONS
other systems
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
No estimate at this time
Introduce equipment into system to capture digital images
of identity source documents so that images can be retained
in electronic storage in a transferable format
1. Digital image scan system in place
Approximately 400,000 license transactions per year
2. Will require installation of scanning equipment at
each licensing location
West Virginia is an over the counter issuance state. This
will either increase the transaction time for each
transaction or increase the number of employees needed
to maintain present transaction time.
3. Additional labor required to scan these documents
Retain paper copies of source documents for a minimum of
7 years or images of source documents presented for a
minimum of 10 years
Do not anticipate problem storing these digital
images
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
None, already required
Establish an effective procedure to confirm or verify a
renewing applicant’s information
This is dependant on the electronic verification
systems described on the previous page.
In the event that a social security account number is already
registered to or associated with another person to which any
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
None, Already Required
Check other states if a person already was issued a DL in
another state
1. Already done on original applications
2. Do not anticipate problem check on renewals or
Currently only using SSOLV
REAL ID ACT REQUIREMENT
IMPACT
duplicates as well
Ensure physical security of locations where DL/ID cards
are produced
Dependant on what standards are established
Subject all person’s authorized to manufacture or produce
DL/ID cards to appropriate security clearance requirements
1. Already done for driver examiners
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
None, Training already in place
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
None, Already in place
Alternative document design if it does not meet federal
standard
WV License meets federal standards
Legal Presence Requirement
None, Already in Place
Provide electronic access to all other states to information
contained in the motor vehicle database of the state
? Already in place with CDLIS
Maintain a state motor vehicle database that contains at a
minimum:
None, Already in Place
2. Expand background check for all CSR
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including motor
vehicle violations, suspensions and points on
licenses
Optional
No Plans at Present
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
ASSUMPTIONS
1. Minimum physical security requirements for driver licensing locations?
2. Cost of SAVE system for each jurisdiction under mandatory circumstances, as it is now an optional program?
3. Role and anticipated time line for availability of DEERS in driver licensing process?
4. Will implementing rules require each state to establish a driver’s license central issuance process?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
WISCONSIN
Jurisdiction Impact Analysis Real ID Act
REAL ID ACT REQUIREMENT
IMPACT
ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)
WI does not require full legal name, and does not print full
middle name on document.
Full legal name includes full middle name
Have following data elements/features on the
document:
WI does not print full legal name on document.
Common machine readable technology will not include
biometric data
163. Full Legal Name
Wi uses digital facsimile of signature
WI appears to be in compliance with other provisions
Digital facsimile of signatures will be permitted
164. Person’s Date of Birth
165. Person’s Gender
166. Person’s DL or ID Card Number
167. Digital Photograph of Person (and retention)
168. Person’s Address of Principle Residence
169. Person’s Signature
170. Physical Security Features to prevent
tampering, counterfeiting or duplication
171. Common Machine Readable Technology:
Introduce temporary DL/ID cards and tying end of
stay to expiration of DL/ID card (or issuance for no
more than 1 year)
Wisconsin must make extensive programming changes to
create a temporary driver’s license and change business
rules that compute expiration dates.
Temporary license will be a new product type
Amending card design to show/indicate that it is a
temporary document with a “different than usual”
expiration date
Requires a new product type
Temporary license will be a new product type
Verification at Source:
WI just implemented SSOLV, but doesn’t have any other
Unclear what DEERS system is used for.
REAL ID ACT REQUIREMENT
Enabling your system to electronically verify
documentation with:
IMPACT
ASSUMPTIONS
systems to verify information electronically.
1. SSOLV
2. SAVE
3. DEERS (DOD)
4. Other jurisdiction (DL/ID card)
5. Birth certificate
6. Other…i.e. third party vendors
Developing access capability to SAVE system
WI does not use the SAVE system, and must do extensive
programming to link to the system.
Introduce equipment into system to capture digital
images of identity source documents so that images
can be retained in electronic storage in a transferable
format
WI does not capture digital images of source documents.
All equipment must be purchased. Initial cost estimates
indicate that placing equipment in all field stations will be
cost prohibitive. WI may have to close some itinerant
field stations, especially if there are no federal funds
available. Also, it is unclear if customers renewing their
DL/ID will have to provide source documents.
All field stations that issue driver’s licenses and
identification cards must have equipment.
Retain paper copies of source documents for a
minimum of 7 years or images of source documents
presented for a minimum of 10 years
Since identity source documents must be kept in an
electronic format, all source documents will be kept in an
electronic format.
All field stations that issue driver’s licenses and
identification cards must have equipment.
WI does not capture digital images of source documents.
All equipment must be purchased. Initial cost estimates
indicate that placing equipment in all field stations will be
cost prohibitive. WI may have to close some itinerant
field stations, especially if there are no federal funds
available. Also, it is unclear if customers renewing their
DL/ID will have to provide source documents.
Subject each person applying for a driver’s license or
identification card to mandatory facial image capture
WI does not photograph persons who are denied. WI will
have to reconfigure application process so photograph can
be taken first.
Customers applying for duplicate, occupational,
reinstated license, etc, will not have to supply source
documents.
Customers applying for duplicate, occupational,
reinstated license, etc, will not have to supply source
documents.
Applicants must be photographed at the beginning of the
process.
REAL ID ACT REQUIREMENT
IMPACT
Establish an effective procedure to confirm or verify a
renewing applicant’s information
It is unclear what this means. How do you verify
information for a renewing customer? Do they have to
provide all of their source documents?
In the event that a social security account number is
already registered to or associated with another person
to which any state has issued a DL/ID card, the state
shall resolve the discrepancy and take appropriate
action
WI has procedures for handling discrepancies with Social
Security number for Wisconsin residents, but has no way
of checking other states unless a centralized database or
pointer system is created.
Check other states if a person already was issued a DL
in another state
WI checks states where the driver was previously
licensed. No nationwide search is done.
Ensure physical security of locations where DL/ID
cards are produced
It is unclear what is meant by “physical security”. This
could lead to station remodelling or central office
issuance.
Subject all person’s authorized to manufacture or
produce DL/ID cards to appropriate security clearance
requirements
WI does background checks on new employees. Existing
employees and employees of vendors would have to be
checked.
Establish fraudulent document recognition training
programs for appropriate employees engaged in the
issuance of DL/ID cards
WI has a fraudulent document training program for field
staff. This must be expanded to include central office
staff.
Limit period of validity of DL/ID cards that are not
temporary to a period not exceeding 8 years
In compliance
Alternative document design if it does not meet federal
standard
WI must decide if the alternate document is going to be
issued.
Legal Presence Requirement
WI does not have legal presence. Statutory language is
needed, and transactions will take longer to process.
Provide electronic access to all other states to
information contained in the motor vehicle database of
the state
WI does not have system to provide electronic access to
other states. Extensive programming is needed to link to
a centralized database.
ASSUMPTIONS
A centralized database for driver information will be
built, which includes social security numbers.
Applies to vendor employees as well.
A centralized driver pointer system will be built.
REAL ID ACT REQUIREMENT
Maintain a state motor vehicle database that contains
at a minimum:
IMPACT
WI is in compliance.
ASSUMPTIONS
ISO standards, which require data fields to be numbered,
will not be used.
All data fields printed on DL/ID cards
motor vehicle driver’s histories, including
motor vehicle violations, suspensions and
points on licenses
Optional
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.
WI must decide if the alternate document is going to be
issued.
We currently license people without legal presence.
What questions does your jurisdiction have as a result of the passing of the Real ID Act?
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What is the definition of compliance with the Act? In three years, does Wisconsin have to re-issue all driver’s licenses and
identification cards? Or, will Wisconsin be in compliance if all driver’s licenses and identification cards issued three years after
passage meet the requirements of the Act?
Are ALL applicants (including renewals, duplicates, reinstatements, reissues, changing restrictions or authorities) required to show
documentary evidence of identity, date of birth, Social Security #, residency and proof of lawful status? How do you prove
citizenship? Also, can we continue current practice of issuing driver’s licenses to military personnel overseas?
How do you verify documents with issuing agencies of documents? If the issuing agency is not a government agency, it will be
difficult to verify information without violating the federal Driver Privacy Protection Act.
Will a central clearinghouse for data be created?
Can a renewal applicant use a birth certificate on file to prove identity and date of birth?
There is a distinction between identity source documents and other source documents for document storage. Is that intentional?
(Identity source documents must be kept in an electronic format; other source documents could be paper or electronic.) Do
documents have to be stored in color format, or is black and white sufficient? Does the application have to be stored as well?
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What is definition of full legal name? Will AAMVA standard be used? How do you handle people with more than one legal name?
(For example, a married woman that uses her maiden name professionally, but her married name for everything else).
Will the federal rules require specific standards for photographs, similar to passports? What about religious and temporary
deformity exemptions for photographs?
Is digital facsimile of signature on driver’s license or identification card acceptable?
Does the facial image capture of all applicants have to be done as the first step in the application process?
What is considered an “effective procedure” to verify or confirm a renewing applicant’s information?
What are the security clearance requirements for employee background checks? Does this apply to vendors that produce DL/ID card
stock as well?
What is the definition of “physical security” for locations where driver’s licenses and identification cards is produced?
Will the federal rules use AAMVA standards whenever possible? If so, Wisconsin has a much better chance of being in compliance.
What impact will REAL ID have on international driver’s licenses treaties and reciprocal agreements with Germany, Switzerland,
and Mexico? Federal law cannot override international treaties.
What are minimum data elements for common machine technology? Will biometric data be included?
How are false DL/IDs handled? Are they confiscated? Do you notify the issuing agency or Department of Homeland Security?
Grant money is needed for vital records agencies in addition to motor vehicle agencies.
How long of an extension will the Department of Homeland Security grant to meet the requirements of Section 202 (1)(a)?
When will federal rulemaking begin? How long will it take to complete?
Why is MOU needed to utilize SAVE system required by September 11, 2005? States have 3 years to comply with other
requirements of the act, and Wisconsin must do extensive programming to link to the system.
What happens to Wisconsin residents during the transition time, ie, after REAL ID is implemented, but before their license expires?
If they need to board a plane, do they have to get a new license?
Will centralized database or national driver pointer system be created to satisfy requirement that all state motor vehicle databases
provide electronic access to all other States? Will database include birth and death record information as well?
If your jurisdiction has done an impact analysis please provide us with a copy of the analysis.
COST SUMMARY OF MAJOR ITEMS IN REAL ID
Assumptions used
Duplicates, occupational licenses, reinstatements, etc will not be impacted by REAL ID. No additional transaction time will be incurred.
All manual document verification would be done in central office, and licenses/ID cards would be issued here as well. Viisage would likely re-negotiate contract for
central office issuance; no cost estimate available at this time.
This summary only include major cost items in REAL ID. Costs will be incurred for other items, such as employee background checks, transaction
costs for new computer systems, station remodeling costs, etc.
Once source documentation is on file, renewal applicants will not have to re-verify information.
Implementation will be phased in over eight year renewal cycle.
One-time Programming Costs
Change expiration dates to issue temporary licenses, do programming for document
scanning, and add links to SAVE & DRIVerS,
$
1,503,350
1651 days BITS estimate, plus vendor
charges
One-time Equipment and Software Costs for Document Verification Equipment &
and Scanning*
Software Costs
Programming
Costs
Total Onetime Costs
Consolidated model (8 stations, statewide)**
$
722,500
$
1,503,350
$
2,225,850
Five-day stations only (29 stations)
$
2,367,500
$
1,503,350
$
3,870,850
5 day stations, plus travel teams (29 stations + 21 teams)**
$
2,916,000
$
1,503,350
$
4,419,350
*All models assume that some low-volume, itinerant driver licensing sites would close, optimizing remaining sites.
**Consolidated model CAN NOT be used if all original & renewal applicants must be checked.
Ongoing Software Licensing Costs (Annually)***
Regional model (8 stations, statewide)
$
88,350
Five-day stations only (29 stations)
$
285,350
5 day stations, plus travel teams (29 stations + 21 teams)
$
491,550
***Document libraries for verification systems must be updated semi-annually, plus licensing costs for document scanning and
document viewing software
Ongoing FTE, Salary & Fringe (Annually)
Manual verification of
documents****
Combination of manual/automated
(Minutes per unit = verification of documents**** (Minutes
per unit= 20)
30)
FTE
All applicants (original & renewal)*****
Original applicants only
Non-citizens only
Salary/Fringe
$
227.2
8,698,300
$
60.4
2,196,941
$
20.4
782,847
FTE
Salary/Fringe
Automated verification of
documents****
(Minutes per unit = 10)
FTE
Salary/Fringe
151.4
$
5,992,718
75.7
$ 3,287,135
55.4
$
2,192,675
27.7
$ 1,202,730
13.6
$
539,345
6.8
$
295,842
****Any manual verification of documents would be done in central office, resulting in central office issuance. No centralized, nationwide driver database exists at this
time. It will take a significant programming effort to create such a system. If verification were fully automated, customers may be issued DL/ID at field stations, if
physical security of DL/ID could be ensured.
*****After eight years, FTE costs would decrease if renewal applicants that are citizens do not have to re-verify information.
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