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					                                                                            ALABAMA
                                                     Jurisdiction Impact Analysis Real ID Act

         REAL ID ACT REQUIREMENT                                                      IMPACT                                     ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      May pose a major problem. We are currently limited to 60
(in Record, on Document)                                    characters horizontal, 56 characters vertical. Font size and real-
                                                            estate are the issues.

Have following data elements/features on the document:          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.   What defines principle residence? How will a homeless
                                                                     person be licensed?
    6.   Person’s Address of Principle Residence
                                                                7.   None
    7.   Person’s Signature
                                                                8.   None
    8.   Physical Security Features to prevent tampering,
         counterfeiting or duplication                          9.   None
    9.   Common Machine Readable Technology:

Introduce temporary DL/ID cards and tying end of stay to    None
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a          Limited impact – programming effort with associated costs.
temporary document with a “different than usual”
                                                            Why must it be called a temporary with a different than usual
expiration date
                                                            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.
        REAL ID ACT REQUIREMENT                                                         IMPACT                                              ASSUMPTIONS
Verification at Source:                                      1. None. We are on line.
Enabling your system to electronically verify                2. A work in progress. We have registered and are awaiting the
documentation with:                                          process to enter into the MOU.
 1. SSOLV                                                    3. Who knows? I have not been provided with enough
                                                             information to draw a conclusion or make an assumption.
 2. SAVE
 3. DEERS (DOD)
                                                                 4.   Limited if any.
 4. Other jurisdiction (DL/ID card)
                                                                 5.   Major. Who is going to provide even a list of telephone
 5. Birth certificate
                                                                      numbers? What about US citizens born in foreign
 6. Other…i.e. third party vendors                                    countries?
                                                                 6.   Who knows? I have not been provided with enough
                                                                      information to draw a conclusion or make an
                                                                      assumption.

Developing access capability to SAVE system                  Minor. This capability was built into our new system.

Introduce equipment into system to capture digital images    Massive. We have equipment available at our six (6) district
of identity source documents so that images can be           offices to accomplish this, however, we do not have the
retained in electronic storage in a transferable format      resources to equip all of our 79 offices.

Retain paper copies of source documents for a minimum of     We will not retain paper due primarily to security issues and cost   Why is there a difference in the time
7 years or images of source documents presented for a        of storage. The hardware and storage space required for this will    requirement for storage of paper and
minimum of 10 years                                          be extremely costly.                                                 electronic images? What is the logic behind
                                                                                                                                  this requirement?

Subject each person applying for a driver’s license or       None
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      Unknown. What defines “effective procedure’?
renewing applicant’s information

In the event that a social security account number is        Massive. Why should the state be required to resolve the
already registered to or associated with another person to   discrepancy? Why not place this burden on the individual to
which any state has issued a DL/ID card, the state shall
        REAL ID ACT REQUIREMENT                                                          IMPACT                                             ASSUMPTIONS
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      None
another state

Ensure physical security of locations where DL/ID cards        None, other than the cost of travel.                               We will conduct a yearly random inspection.
are produced

Subject all person’s authorized to manufacture or produce      None
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             In our state, probate judges and license commissioners act as
programs for appropriate employees engaged in the              agents of the state in issuing duplicate driver licenses and we
issuance of DL/ID cards                                        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           None. We are on a four (4) year license cycle.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        Not enough information provided to respond to this question.
standard

Legal Presence Requirement                                     None. We already have legislation in place.

Provide electronic access to all other states to information   Are you talking about just driver license information or are you
contained in the motor vehicle database of the state           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     None
minimum:
         All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         REAL ID ACT REQUIREMENT                                                      IMPACT                                  ASSUMPTIONS
          vehicle violations, suspensions and points on
          licenses

 Optional                                                    Alabama does not intend to license persons who are in this
                                                             country illegally. Therefore there would be no need for such a
Development and issuance of a certificate of driving – not
                                                             certificate.
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?

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                                                         IMPACT                            ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System (in Record, on Document)           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       Reprogramming to print principal
                                                                                          principal residence in database               residence address
    16. Person’s Signature
                                                                                          Currently Required
    17. Physical Security Features to prevent tampering, counterfeiting or duplication
                                                                                          Currently Incorporated
    18. Common Machine Readable Technology:
                                                                                          2D Machine readable bar code

Introduce temporary DL/ID cards and tying end of stay to expiration of DL/ID card (or     Reprogramming required
issuance for no more than 1 year)

Amending card design to show/indicate that it is a temporary document with a “different   Reformatting required
than usual” expiration date

Verification at Source:
Enabling your system to electronically verify documentation with:
 1. SSOLV                                                                                 SSOLV expected by 6/06
 2. SAVE                                                                                  SAVE must be developed
                        REAL ID ACT REQUIREMENT                                                                IMPACT                      ASSUMPTIONS
 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      Must develop
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        Must develop
documents presented for a minimum of 10 years

Subject each person applying for a driver’s license or identification card to mandatory     Currently required (digital image)
facial image capture

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   In state can identify duplicate number Must
with another person to which any state has issued a DL/ID card, the state shall resolve     connect to SSOLV and set up verification of
the discrepancy and take appropriate action                                                 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        Needs to be done
security clearance requirements

Establish fraudulent document recognition training programs for appropriate employees       Needs to be implemented
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    Current Licenses/ID’s expire in 5 yrs
8 years
                        REAL ID ACT REQUIREMENT                                                                  IMPACT                      ASSUMPTIONS
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   Needs to be developed
database of the state

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    Current practice
         and points on licenses

Optional
Development and issuance of a certificate of driving – not for federal identification         May consider as option
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?
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                                                IMPACT                                             ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing           Change to current process.
System (in Record, on Document)
                                                          Requires database expansion and programming
                                                          changes.
                                                          Requires legislation.
                                                          Requires funding.
                                                                                                                Requires additional information on driver
Have following data elements/features on the document:    Change to current process. Requires system redesign
                                                                                                                license/identification card.
                                                          and changes to forms, web and Customer Service
    19. Full Legal Name
                                                          Guide.
                                                                                                                Credential consumables provided by the industry meet the
    20. Person’s Date of Birth
                                                          1. Change                                             new security requirements.
    21. Person’s Gender
                                                          2. Currently capture
    22. Person’s DL or ID Card Number
                                                          3. Currently capture
    23. Digital Photograph of Person (and retention)
                                                          4. Currently capture
    24. Person’s Address of Principle Residence
                                                          5. Currently capture and retain
    25. Person’s Signature
                                                          6. Change
    26. Physical Security Features to prevent
                                                          7. Currently capture
        tampering, counterfeiting or duplication
                                                          8. Security features in place
    27. Common Machine Readable Technology:
                                                          9. Bar code and magnetic stripe on current DL/ID
       REAL ID ACT REQUIREMENT                                             IMPACT                              ASSUMPTIONS

                                                        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   Change to current process. Expiration is currently
to expiration of DL/ID card (or issuance for no more    tied to end of stay or issuance for no more than 2
than 1 year)                                            years.


                                                        Requires new credentials.


                                                            Modifications required:
                                                                •    System programming change
                                                                •    Testing
                                                                •    Policy change
                                                                •    Legislation
                                                                •    Training
       REAL ID ACT REQUIREMENT                                          IMPACT                                                ASSUMPTIONS
                                                              •   Rules
                                                              •   Funding



Amending card design to show/indicate that it is a   Change to current process. Requires new credentials.
temporary document with a “different than usual”
                                                     New credential templates required for driver license,
expiration date
                                                     instruction permit, identification card & restricted
                                                     driver permit (photo & paper credentials).
                                                         Modifications required:
                                                              •   Format changes to indicate “temporary”
                                                                  on the credential

                                                              •   System programming change
                                                              •   Testing
                                                              •   Funding



Verification at Source:                              Change to current process. Requires significant         New verification transactions will be routed through
                                                     system programming change.                              AAMVA similar to SSOLV and HAVV.
Enabling your system to electronically verify
documentation with:                                      •    Programming changes to verify SSN’s for
                                                              duplicate, photo update and endorsement            •   That national networks are functioning
 1. SSOLV
                                                              applicants via Social Security On-Line             •   DRIVerS (National network system currently does
 2. SAVE                                                      Verification (SSOLV)                                   not exist)
                                                         •    E Government Web applications for                  •   Vital Statistics (National network system currently
 3. DEERS (DOD)
                                                              duplicate and reinstated driver licenses               does not exist). May be others that need to be
 4. Other jurisdiction (DL/ID card)                      •    Policy memo                                            established
 5. Birth certificate                                    •    Customer service representative training
                                                         •    Capturing photograph of individual who
 6. Other…i.e. third party vendors                            may be denied a license
                                                         •    Legislation
                                                         •    Rules
                                                         •    Training
                                                         •    Set standards
                                                         •    Funding
       REAL ID ACT REQUIREMENT                                                    IMPACT                                             ASSUMPTIONS
Developing access capability to SAVE system                  Change in current process. Requires significant        That Homeland Security’s automated system known as
                                                             system programming change.                             SAVE (Systematic Alien Verification for Entitlements) will
                                                                                                                    be functioning.
                                                             Modifications required:
                                                                • Develop functionality to interface with
                                                                     Homeland Security’s SAVE program in            AAMVA will work with the states to establish a national
                                                                     both real-time and batch modes.                standard for legal presence verifications.
                                                                • Reporting
                                                                • New policies                                      INS will make upgrades to their systems to ensure data
                                                                • Training                                          integrity.


                                                                 •    Programming changes to send all duplicates,
                                                                      photo updates and endorsements to SSOLV
                                                                 •    Legislation
                                                                 •    Rules
                                                                 •    Funding



Introduce equipment into system to capture digital           Requires the purchase and placement of additional
images of identity source documents so that images can       equipment in each MVD field office.
be retained in electronic storage in a transferable format
                                                             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.
       REAL ID ACT REQUIREMENT                                                    IMPACT                                              ASSUMPTIONS
                                                             Requires funding.

Retain paper copies of source documents for a minimum        Change in current process. Creates significant
of 7 years or images of source documents presented for a     impact to record storage capacity and archival
minimum of 10 years                                          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       Change in current process. Increases customer
identification card to mandatory facial image capture        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      Change to current process. Modifies screening           AAMVA will work with the states to establish national
renewing applicant’s information                             process and impedes e-government.                       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        Change to current process. Increases transaction time   Social Security Administration will strengthen match
already registered to or associated with another person to
       REAL ID ACT REQUIREMENT                                                  IMPACT                                                  ASSUMPTIONS
which any state has issued a DL/ID card, the state shall    and customer wait/visit time.                             criteria to require an exact match.
resolve the discrepancy and take appropriate action
                                                            Requires states to resolve discrepancy involving
                                                            already registered/associated SSNs and take
                                                            appropriate action.

Check other states if a person already was issued a DL in   Increased incoming and outgoing data traffic.
another state
                                                            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     Process in place. Increases the quantity of secured
are produced                                                areas.

Subject all person’s authorized to manufacture or           Change to current process. Increases the number of
produce DL/ID cards to appropriate security clearance       security background checks conducted.
requirements
                                                            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          Process in place. Established Fraudulent Document         Fraudulent Document Recognition Training Program will
programs for appropriate employees engaged in the           Recognition Training Program in 2004.                     need to be expanded as requirements change.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not        Change to current process. Increases customer traffic     Limit the period of a driver license to a period that does not
temporary to a period not exceeding 8 years                 flow and customer wait/visit time in all field offices.   exceed 8 years.
                                                            Arizona issues an “extended” driver license that does
                                                            not expire until age 65.
                                                                Modifications required:
                                                                • Programming changes to driver license and
                                                                   ID card initial application program
       REAL ID ACT REQUIREMENT                                                   IMPACT                                                 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
Alternative document design if it does not meet federal      Change to current process. Prohibits access to
standard                                                     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             Change to current process.                                AAMVA will provide or facilitate electronic access to other
information contained in the motor vehicle database of                                                                 states databases.
                                                             Requires funding.
the state
                                                                                                                       Arizona maintains a motor vehicle database that contains all
Maintain a state motor vehicle database that contains at a   Process in place.
                                                                                                                       data field printed on the driver license/identification card
minimum:
                                                                                                                       including motor vehicle driver’s histories, motor vehicle
         All data fields printed on DL/ID cards                                                                        violations, suspensions and point on licenses.
         motor vehicle driver’s histories, including
         motor vehicle violations, suspensions and
         points on licenses
       REAL ID ACT REQUIREMENT                                               IMPACT                         ASSUMPTIONS
Optional                                                  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                                  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                                                            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         8. Already in compliance.
         duplication
                                                                                    9. Yes.
     36. Common Machine Readable Technology:

Introduce temporary DL/ID cards and tying end of stay to expiration of DL/ID card   Would have to implement.
(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                                                                        1. Because of state legislation, will implement 1-31-06.
                        REAL ID ACT REQUIREMENT                                                                 IMPACT                                   ASSUMPTIONS
 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           Will require new driver license system to capture document
documents so that images can be retained in electronic storage in a transferable       and retain to driver license record.
format

Retain paper copies of source documents for a minimum of 7 years or images of          Presently don’t have a system that would attach to record,
source documents presented for a minimum of 10 years                                   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          Presently persons because of religious beliefs are not required
mandatory facial image capture                                                         to have photo made.

Establish an effective procedure to confirm or verify a renewing applicant’s           Would require new process for verification of documents.
information

In the event that a social security account number is already registered to or         At present we have completed 75 percent of batch process
associated with another person to which any state has issued a DL/ID card, the state   with SSA. We had a 5 percent error rate. We are still
shall resolve the discrepancy and take appropriate action                              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               Presently we have not done background checks on employees
appropriate security clearance requirements                                            – looking into cost.
                      REAL ID ACT REQUIREMENT                                                                   IMPACT                                ASSUMPTIONS
Establish fraudulent document recognition training programs for appropriate             Have conducted an 8-hour training course for some revenue
employees engaged in the issuance of DL/ID cards                                        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          Presently Arkansas license are only valid for a four-year
exceeding 8 years                                                                       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     Would require system change, which could be a costly price.
vehicle database of the state

Maintain a state motor vehicle database that contains at a minimum:                     Current state issued driver license has AAMVA standard – 2-
                                                                                        D barcode and magstrip.
           All data fields printed on DL/ID cards
                                                                                        At the present time the state history screen includes MV
         motor vehicle driver’s histories, including motor vehicle violations,
                                                                                        violations, suspensions and points on license.
         suspensions and points on licenses

Optional
Development and issuance of a certificate of driving – not for federal identification   Do not plan on issuing license to anyone who can’t prove
purposes – for those who cannot prove lawful presence.                                  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.
                                                                   CALIFORNIA

                                                   Jurisdiction Impact Analysis Real ID Act

    REAL ID ACT REQUIREMENT                                      IMPACT                                                   ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing    California already uses the name on           The requirements for true full name will match our current regulations,
System (in Record, on Document).                   official documentation (e.g., birth           and the requirements for the length of the name(s) are not specified by
                                                   certificate, court name change,               regulation.
                                                   marriage certificate) as defined in
                                                   California Regulations for True Full
                                                   Name.


                                                   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       Potentially minimal, as DL/ID card            Assumption is that security features and machine-readable
document:                                          currently contains all items.                 requirements will be similar to existing feature technology.
    37. Full Legal Name                            If required by regulation to verify
                                                   address through presentation of
    38. Person’s Date of Birth
                                                   documents during the application
    39. Person’s Gender                            process (e.g., Utility bill), there will be
                                                   a personnel impact.
    40. Person’s DL or ID Card Number
                                                   If the requirement necessitates
    41. Digital Photograph of Person (and          verification of the address by a third
        retention)
                                                   party system there will be a need for
    42. Person’s Address of Principle Residence    California Regulations and increased
                                                   costs.
    43. Person’s Signature
    44. Physical Security Features to prevent
        tampering, counterfeiting or duplication
    REAL ID ACT REQUIREMENT                                       IMPACT                                                    ASSUMPTIONS
    45. Common Machine Readable Technology

Introduce temporary DL/ID cards and tying end of     Costs for personnel and IT                 California previously tied the expiration date of the DL/ID card to the expiration
stay to expiration of DL/ID card (or issuance for    programming changes (for renewal           date on the legal presence document for original applications only. Stopped this
no more than 1 year).                                applicants).                               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   Minimal.                                   Have a process in place that allows us to issue a DL/ID card (“temporary
temporary document with a “different than usual”                                                document”) for a period less than the regular card term. There will be IT costs
expiration date.                                                                                associated with applying this process and programming for renewal applicants
                                                                                                (see above).

Verification at Source:                              Major Impact (costs, state law) to         Currently verify electronically with SSOLV, SAVE and use CDLIS/PDPS.
                                                     electronically verify information with
Enabling your system to electronically verify
                                                     DEERS, Birth Certificate, and third
documentation with:
                                                     party vendors.                             Assumes that each state will have a centralized database and/or process for birth
 1. SSOLV                                                                                       document verification, and that DEERS will partner in development with
                                                                                                automated verification. Without such a system, the cost to verify
 2. SAVE
                                                                                                documentation is substantial.
 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.         None for current process and system        Assume that there will be no changes to the system currently used.
                                                     design (that now applies to original
                                                     applicants), but there are personnel and
                                                     IT costs associated with including
                                                     renewal applicants.

Introduce equipment into system to capture digital   Major Impact.                              We do not capture and store this information today. Requires new equipment,
images of identity source documents so that                                                     possible office layout modifications, major programming, and database
images can be retained in electronic storage in a                                               development.
transferable format.
    REAL ID ACT REQUIREMENT                                        IMPACT                                                  ASSUMPTIONS
Retain paper copies of source documents for a         Major Impact.                             We do not collect this information today. Requires database storage capabilities
minimum of 7 years or images of source                                                          for at least 25 million records.
documents presented for a minimum of 10 years.

Subject each person applying for a driver’s license   No impact.                                Assumes our current process is acceptable.
or identification card to mandatory facial image
capture.

Establish an effective procedure to confirm or        Unable to determine. There will be a      Currently, the department processes DL renewals by mail or by internet for
verify a renewing applicant’s information.            major impact if the regulation for the    customers that have the form we mailed to them. The internet process requires
                                                      verification of identity for renewals     the use of the last four of the SSN and the use of a “PIN Code” that appears on
                                                      establishes a document-based              the renewal notice mailed to the applicant. Renewals by Mail are mailed to the
                                                      requirement.                              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    To be determined.                         California has already been verifying SSNs with SSA. Entire database
is already registered to or associated with another                                             should be cleansed by the end of 2005 for any cardholders that have a
person to which any state has issued a DL/ID card,                                              valid DL/ID card. After 2005, if multiples exist on our database for active
the state shall resolve the discrepancy and take                                                cardholders, SSA would have to have verified the duplication of the
appropriate action.                                                                             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   To be determined.                         Assuming AAMVAnet makes programming changes to allow for this
DL in another state.                                                                            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     Probable minimal impact.                  This assumes that the current process our vendor uses for physical security of
cards are produced.                                                                             the manufacturing plant /materials and background checks meets any
                                                                                                regulations promulgated.

Subject all persons’ authorized to manufacture or     Unable to determine. It is unclear what   If the goal is to ensure that our vendor employees and the states’ field office
produce DL/ID cards to appropriate security           “producing cards” or “appropriate         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      Minimal Impact.                          We already have fraud document training. Assume that we would just be
programs for appropriate employees engaged in                                                    required to update our training.
the issuance of DL/ID cards.



Limit period of validity of DL/ID cards that are not    Major impact for identification cards.   This requires that we change state law for the term on our Senior ID cards
temporary to a period not exceeding 8 years.                                                     (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         Possibly minimal impact.                 Requires programming for our database, along with programming and physical
federal standard.                                                                                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     Unknown.                                               California currently allows other states information as
contained in the motor vehicle database of the state.                                                                   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
Maintain a state motor vehicle database that contains at a       No impact.
                                                                                                                        types of information we retain today.
minimum:
           All data fields printed on DL/ID cards.
         Motor vehicle drivers’ histories, including motor
         vehicle violations, suspensions and points on
         licenses.

Optional                                                         Major impact.                                          California currently has pending legislation concerning
                                                                                                                        this topic. Governor has stated that he would not sign
Development and issuance of a certificate of driving – not
                                                                                                                        this into law at this point. Awaiting federal regulations
for federal identification purposes – for those who cannot
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                                    IMPACT                                                 ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing    NO IMPACT – Colorado currently
System (in Record, on Document)                    captures, and stores in the database, the
                                                   full legal name and any other names
                                                   shown on all documents presented for
                                                   identification.

Have following data elements/features on the
document:
                                                   1.   NO IMPACT – Currently in
    46. Full Legal Name                                 compliance
    47. Person’s Date of Birth                     2.   NO IMPACT – Currently in
                                                        compliance
    48. Person’s Gender
                                                   3.   NO IMPACT – Currently in
    49. Person’s DL or ID Card Number
                                                        compliance
    50. Digital Photograph of Person (and
                                                   4.   NO IMPACT – Currently in
        retention)
                                                        compliance
    51. Person’s Address of Principle Residence
                                                   5.   NO IMPACT – Currently in
    52. Person’s Signature                              compliance
    53. Physical Security Features to prevent      6.   NO IMPACT – Currently in
        tampering, counterfeiting or duplication        compliance                             9. If the machine-readable technology (barcode) requirement means
                                                   7.   NO IMPACT – Currently in               to include ALL elements/features from the front of the card, there will
    54. Common Machine Readable Technology:
                                                        compliance                             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.
                                                   8. NO IMPACT – Currently in                 Clarification required.
                                                      compliance


                                                   9.   POTENTIAL IMPACT – The
                                                        current 2D-barcode does not
                                                        contain  the   photograph or
     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       NO IMPACT – Currently in
stay to expiration of DL/ID card (or issuance for no   compliance
more than 1 year)

Amending card design to show/indicate that it is a     POTENTIAL IMPACT –                          Fiscal impact from vendor to modify the back of the ID card and legislative
temporary document with a “different than usual”       modification required to ID card            impact to allow the text TEMPORARY ONLY on the ID card.
expiration date                                        processing map in DLS (IT) and to
                                                       the physical ID card to allow
                                                       variable text on the back indicating
                                                       TEMPORARY ONLY.

Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                       1.   NO IMPACT – Currently in
 1. SSOLV                                                   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
                                                                                                   5. Based on new cost-per-query information from NAPHSIS, regarding
                                                            compliance
  5. Birth certificate                                                                             the Electronic Verification of Vital Events (EVVE) system, Colorado will
                                                       5.   Currently, verification consists of    need to revisit participation. Latest estimates are $1.28 per query
                                                            contacting the issuing agency by       (down from $5.00 per query), based on the number of queries and
 6. Other…i.e. third party vendors                          telephone      to    verify     any    number of states participating.
                                                            questionable documents. Items are
                                                            also faxed to the issuing agency
                                                            for verification.
                                                       6.   N/A

Developing access capability to SAVE system            NO IMPACT – Currently in process.

Introduce equipment into system to capture digital     POTENTIAL IMPACT – cost of                  To comply with the requirement of this item, the cost of scanners, and
     REAL ID ACT REQUIREMENT                                          IMPACT                                                    ASSUMPTIONS
images of identity source documents so that images        scanners, office procedure changes,        potential vendor programming costs, have been proposed as a decision item
can be retained in electronic storage in a transferable   programming modifications (vendor          for section funding.
format                                                    and IT). Impact would also be on
                                                          customer wait times.

Retain paper copies of source documents for a             POTENTIAL IMPACT – See above
minimum of 7 years or images of source documents          item. Currently, only documents used
presented for a minimum of 10 years                       in exception processing are copied and
                                                          submitted for microfilming.

Subject each person applying for a driver’s license       POTENTIAL IMPACT – Only first-             The impact response is based on the assumption that the requirement is
or identification card to mandatory facial image          time applicants are subjected to the       referring to facial recognition processing and not the “valid without photo”
capture                                                   facial recognition (FR) process. Impact    document, currently issued by some states, for religious reasons. Clarification
                                                          would be on IT for programming and,        is required.
                                                          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       POTENTIAL IMPACT – Currently, the image,               Because this would be a drastic change in
applicant’s information                                                fingerprint and SSN are confirmed for renewal          established procedures, some type of public service
                                                                       applicants presenting their license/ID card.           announcement, to renewal customers particularly,
                                                                       However, because customers must renew if they          would be in order.
                                                                       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
     REAL ID ACT REQUIREMENT                                          IMPACT                                                 ASSUMPTIONS
                                                                      the public of the new renewal procedures.

In the event that a social security account number is already         NO IMPACT – Currently in compliance
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     POTENTIAL IMPACT – A system for this type of          Should a system go online that would accommodate
state                                                                 verification is not currently on-line.       If the   this requirement, such as the AAMVA-proposed
                                                                      customer has a license to surrender, currently only   DriverS, Colorado would participate.
                                                                      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           NO IMPACT – Currently in compliance
produced

Subject all person’s authorized to manufacture or produce DL/ID       POTENTIAL IMPACT – Applicants considered              The assumption is being made that the security
cards to appropriate security clearance requirements                  for employment are subjected to a criminal            clearance is mandatory not only for driver license
                                                                      background check, only. Fiscal impact is involved     employees but also for vendor employees.
                                                                      with a security clearance.                            Clarification is required.

Establish fraudulent document recognition training programs for       NO IMPACT – Currently in compliance. Colorado
appropriate employees engaged in the issuance of DL/ID cards          uses AAMVA’s FDR (Fraudulent Document
                                                                      Recognition) training program.

Limit period of validity of DL/ID cards that are not temporary to a   NO IMPACT – Currently in compliance
period not exceeding 8 years

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          POTENTIAL IMPACT – Colorado is in
contained in the motor vehicle database of the state                  compliance with the existing requirements of
     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           NO IMPACT – Currently in compliance
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor vehicle
         violations, suspensions and points on licenses

Optional                                                             NO IMPACT – State law does not allow issuance
                                                                     to applicants who cannot prove lawful presence.
Development and issuance of a certificate of driving – not for
federal identification purposes – for those 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
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)

Have following data elements/features on the document:     Yes. (current system limited to 35 characters); Do not   Regulations should define “name history.” Also, should
                                                           have current “name history” capability.                  clarify “legal” name (Connecticut is a “common law”
    55. Full Legal Name
                                                                                                                    state).
                                                           Yes
    56. Person’s Date of Birth
                                                           Yes
    57. Person’s Gender
                                                           Yes (9 digits)
    58. Person’s DL or ID Card Number
                                                           Yes
    59. Digital Photograph of Person (and retention)
                                                           Yes (must provide residence address)
    60. Person’s Address of Principle Residence
                                                           Yes
    61. Person’s Signature
                                                           7 security features
    62. Physical Security Features to prevent tampering,
        counterfeiting or duplication                      2-D Bar code
    63. Common Machine Readable Technology:

Introduce temporary DL/ID cards and tying end of stay to   Need enabling legislation
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a         Need enabling legislation
temporary document with a “different than usual”
expiration date

Verification at Source:                                    Connecticut now uses FLLQ (NCIC)                         Verification of Birth Certificates must be addressed
                                                                                                                    somehow in the regulations.
Enabling your system to electronically verify
documentation with:
         REAL ID ACT REQUIREMENT                                                        IMPACT                          ASSUMPTIONS
 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
                                                                 No
 6. Other…i.e. third party vendors
                                                                 Acxiom Address Verification System

Developing access capability to SAVE system                      Will commence work on MOU

Introduce equipment into system to capture digital images        No. CT DMV currently does not have such a system.
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         CTDMV does not currently have optical imaging
7 years or images of source documents presented for a            capability Yes
minimum of 10 years

Subject each person applying for a driver’s license or           Yes
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a          May have impact on privatized renewal stations
renewing applicant’s information                                 (AAA)No- No Driver’s system

In the event that a social security account number is already    No system available to access duplicate SS# in other
registered to or associated with another person to which         states. CTDMV can only verify duplicate SS# for
any state has issued a DL/ID card, the state shall resolve the   Connecticut residents.
discrepancy and take appropriate action

Check other states if a person already was issued a DL in        No- No DriverS system
another state

Ensure physical security of locations where DL/ID cards          Yes
are produced
         REAL ID ACT REQUIREMENT                                                     IMPACT                             ASSUMPTIONS


Subject all person’s authorized to manufacture or produce      Do background checks.                     Regulations must define “security clearance”
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             Use AAMVA system
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Ok CT CDL = 4 years; Non-CDL= 6 years
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        Intend to meet federal criteria
standard

Legal Presence Requirement                                     Yes

Provide electronic access to all other states to information   Current information systems limitations
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a
minimum:
                                                               Yes, currently resides in flat files
           All data fields printed on DL/ID cards
                                                               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   Unknown.                                California currently allows other states information as
contained in the motor vehicle database of the state.                                                  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
Maintain a state motor vehicle database that contains at a     No impact.
                                                                                                       types of information we retain today.
minimum:
           All data fields printed on DL/ID cards.
         Motor vehicle drivers’ histories, including motor
         vehicle violations, suspensions and points on
         licenses.

Optional                                                       Major impact.                           California currently has pending legislation concerning
                                                                                                       this topic. Governor has stated that he would not sign
Development and issuance of a certificate of driving – not
                                                                                                       this into law at this point. Awaiting federal regulations
for federal identification purposes – for those who cannot
                                                                                                       on HR 1268.
prove lawful presence.


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                                             IMPACT                                 ASSOCIATED                     ASSUMPTIONS
    REQUIREMENT                                                                                   IMPACT COST
                                 Driver’s License File:
Introduce Full Legal Name into                                                                                                   DMV will be responsible for
                                     Modify all inquiry – approximately 4 major interfaces,
Driver Licensing System (in                                                                                                      providing access to Safety and
                                     approximately 30 programs                                               Associated Cost:
Record, on Document)                                                                                                             Homeland Security, Law
                                     Modify to incorporate XML tags for name element                   6 months @ $75.00 hr =
                                                                                                                                 Enforcement and Criminal
                                                                                                                  $56,250.00
                                                                                                                                 Justice.
                                 ID File:
                                     ID File: approximately 4 programs
                                     Modify ID programs to incorporate the new name standards.               Associated Cost:
                                     Modify to incorporate XML tag for name element                    3 months@ $75.00 hr =
                                                                                                                  $33,750.00
                                 License/ID Card Print:
                                     1 program interface                                                      Associated Cost:
                                                                                                  37.h hrs @ 75.00 = $2,812.50

                                 Application Print:                                                           Associated Cost
                                    4 print programs                                             2 weeks @ $75.00 = $5,625.00

                                 External communication:
                                     United Network Interface – approximately 100 program,                   Associated Cost:
                                     approximately 40 transaction types                                6 months @ $75.00 hr =
                                                                                                                  $56,250.00
                                 Reporting:
                                    Modify approximately 300 programs
                                                                                                             Associated Cost:
                                 Document Imaging:                                                     3 months @$75.00 hr =
                                    5 programs indexes to be increased                                            $33,750.00

                                 Website Modifications:
                                    20 modules to identify the name element                                  Associated Cost:
                                                                                                       3 months @ $30.00 hr =
     REAL ID ACT                                             IMPACT                                     ASSOCIATED                    ASSUMPTIONS
     REQUIREMENT                                                                                       IMPACT COST
                                                                                                                       $13,500.00
                                 Restrictions to Issuance:
                                     Modify 10 programs to incorporate a restriction to limit the
Introduce Full Legal Name into                                                                                   Associated Cost:
                                     period of temporary stay
Driver Licensing System (in                                                                                 1 month @ $30.00 hr =
Record, on Document) –                                                                                                  $4,500.00
CONTINUED                                                                                                        Associated Cost:
                                                                                                    1 month @ $75.00 = $11,250.00

                                                                                                       Total System Modifications:
                                                                                                                     $217,687.50
                                                                                                                  Associated Cost:
Have following data                  Modify Driver’s License and Identification cards to                                             Delaware will be required to
                                                                                                         1 month @ $75.00 hr =
elements/features on the             incorporate Full Name requirements.                                                             completely replace driver’s
                                                                                                                     $11,250.00
document:                                                                                                                            license and identification card
                                                                                                                                     for all citizens prior to
    64. Full Legal Name                                                                              Associated Cost for AAMVA
                                                                                                                                     September 11, 2009. Instead of
                                                                                                     Logo (DL Vendor Estimate):
    65. Person’s Date of Birth                                                                                                       having the ability to replace the
                                                                                                    610,406 @ $1.00 per license
                                                                                                                                     DL/ID at the time of renewal.
    66. Person’s Gender                                                                                          = $610,406.00
                                                                                                                                     Delaware will be required to
    67. Person’s DL or ID
                                                                                                                                     include the new AAMVA
        Card Number                                                                                                                  (Jurisdictional) logo.
    68. Digital Photograph of                                                                                                            o    New Logo – cost
        Person (and retention)
                                                                                                                                              unknown - impact cost
    69. Person’s Address of                                                                                                                   based on limited
        Principle Residence                                                                                                                   information.
    70. Person’s Signature
    71. Physical Security
        Features to prevent
        tampering,
        counterfeiting or
        duplication
    72. Common Machine
        Readable Technology:
     REAL ID ACT                                            IMPACT                                  ASSOCIATED                       ASSUMPTIONS
     REQUIREMENT                                                                                   IMPACT COST
                                 Driver’s License File:                                                       Associated Cost:
Introduce temporary DL/ID
                                     Modify all inquiry – approximately 4 major interfaces,             6 months @ $75.00 hr =
cards and tying end of stay to
                                     approximately 30 programs                                                     $56,250.00
expiration of DL/ID card (or
                                     Modify to incorporate XML tags for name element
issuance for no more than 1
                                                                                                              Associated Cost:
year)
                                                                                                        3 months@ $75.00 hr =
                                                                                                                   $33,750.00
                                 ID File:
                                     ID File: approximately 4 programs                                        Associated Cost:
                                     Modify to incorporate XML tag for name element               37.h hrs @ 75.00 = $2,812.50

                                 License/ID Card Print:                                                      Associated Cost:
                                                                                                 2 weeks @ $75.00 = $5,625.00
                                 1 program interface
                                                                                                 Associated cost for issuing new
                                                                                                                            card:
                                                                                                                       $6,000.00
                                                                                                               Associated Cost:
Amending card design to              Modify license/ID programs to establish limits on                                              Delaware will have to
                                                                                                       6 months @ $75.00 hr =
show/indicate that it is a           expiration date to ensure consistency with                                                     specifically identify these types
                                                                                                                      $56,250.00
temporary document with a            documentation.                                                                                 of license, modify legislation to
“different than usual”                                                                                                              ensure consistency with
                                     Modify inquiry to identify those licenses/ID on a limited                Associated Cost:
expiration date                                                                                                                     expiration date of
                                     term bases. Modify DELJIS/State Police.                            3 months@ $75.00 hr =
                                                                                                                                    Visa/natural/etc., other than the
                                                                                                                   $33,750.00
                                     Establish reporting.                                                                           DOB (limited license/ID).
                                                                                                              Associated Cost:      Delaware will be required to
                                                                                                        3 months @ $30.00 hr =      create new cart design for
                                                                                                                   $13,500.00       limited term.
                                 DEERS Impact:                                                                Associated Cost:
Verification at Source:                                                                                                             SSOLV implemented, but will
                                 Driver’s License File:                                                 6 months @ $75.00 hr =
                                                                                                                                    have to incorporate mis-matches
Enabling your system to              Modify all inquiry – approximately 4 major interfaces,                        $56,250.00
                                                                                                                                    within denial system.
electronically verify                approximately 30 programs
documentation with:                  Modify to incorporate XML tags for name element                                                Delaware will utilize PROOFS
                                                                                                              Associated Cost:      application to validate
 1. SSOLV                        ID File:                                                               3 months@ $75.00 hr =       documents being presented as
                                     ID File: approximately 4 programs                                             $33,750.00       proof of citizenship.
     REAL ID ACT                                            IMPACT                                ASSOCIATED                     ASSUMPTIONS
     REQUIREMENT                                                                                 IMPACT COST
 2. SAVE                               Modify to incorporate XML tag for name element                                           No cost impact estimate
                                                                                                             Associated Cost:   provided for DEERS/other
 3. DEERS (DOD)
                                   License/ID Card Print:                                        37.h hrs @ 75.00 = $2,812.50   jurisdictions because they have
  4. Other jurisdiction (DL/ID                                                                                                  not been implemented.
                                   1 program interface
card)                                                                                                        Associated Cost
                                   Hire Additional Staff                                        2 weeks @ $75.00 = $5,625.00
 5. Birth certificate
                                   1 computer tech
  6. Other…i.e. third party                                                                                  Associated Cost:
vendors                                                                                                           $68,393.00
                                   SAVE Impact:                                                             Associated Cost:
Developing access capability to                                                                                                 SAVE – will be incorporated
                                   Driver’s License File:                                             6 months @ $75.00 hr =
SAVE system                                                                                                                     with Delaware’s license/ID
                                       Modify all inquiry – approximately 4 major interfaces,                    $56,250.00
                                                                                                                                denial.
                                       approximately 30 programs
                                       Modify to incorporate XML tags for name element                      Associated Cost:    Delaware will utilize PROOFS
                                                                                                      3 months@ $75.00 hr =     application to validate
                                   ID File:                                                                      $33,750.00     documents being presented as
                                       ID File: approximately 4 programs                                                        proof of citizenship.
                                       Modify to incorporate XML tag for name element                        Associated Cost:
                                                                                                 37.h hrs @ 75.00 = $2,812.50
                                   License/ID Card Print:
                                                                                                             Associated Cost
                                   1 program interface
                                                                                                2 weeks @ $75.00 = $5,625.00
                                   Hire Additional Staff
                                                                                                             Associated Cost:
                                   1 computer tech
                                                                                                                  $68,393.00

                                                                                                               Expected Cost
                                                                                                   610,406 x $.32 per query =
                                                                                                                 $195,329.00
                                                                                                            Associated Cost:
Introduce equipment into           Equipment/Training/Installation/Maintenance Agreement                                        Format stored in AAMVA
                                                                                                                 $450,000.00
system to capture digital                                                                                                       standard
                                   Hire Additional Staff
images of identity source
                                                                                                             Associated Cost:
documents so that images can       4 senior techs
                                                                                                            4 @ $30,000.00 =
be retained in electronic
                                                                                                                 $120,000.00
storage in a transferable format
     REAL ID ACT                                           IMPACT                                ASSOCIATED                      ASSUMPTIONS
     REQUIREMENT                                                                                IMPACT COST
Retain paper copies of source                                                                                                   No impact to Delaware – will
documents for a minimum of 7                                                                                                    utilize existing document
years or images of source                                                                                                       imaging application to store
documents presented for a                                                                                                       documents for a period of 10-
minimum of 10 years                                                                                                             years.

Subject each person applying                                                                                                    No impact to Delaware – DDL
for a driver’s license or                                                                                                       application utilizing AAMVA
identification card to                                                                                                          standards and capturing photo
mandatory facial image capture                                                                                                  on all transaction.




                                  Driver’s License File:                                                   Associated Cost:
Establish an effective                                                                                                          DMV will be responsible for
                                      Modify all inquiry – approximately 4 major interfaces,         6 months @ $75.00 hr =
procedure to confirm or verify                                                                                                  providing access to Safety and
                                      approximately 30 programs                                                 $56,250.00
a renewing applicant’s                                                                                                          Homeland Security, Law
                                      Modify to incorporate XML tags for name element
information                                                                                                                     Enforcement and Criminal
                                                                                                                                Justice.
                                  ID File:                                                                 Associated Cost:
                                      ID File: approximately 4 programs                              3 months@ $75.00 hr =
                                      Modify to incorporate XML tag for name element                            $33,750.00

                                  License/ID Card Print:                                                    Associated Cost:
                                                                                                37.h hrs @ 75.00 = $2,812.50
                                  1 program interface
                                                                                                            Associated Cost
                                                                                               2 weeks @ $75.00 = $5,625.00

                                  Driver’s License File:                                                   Associated Cost:
In the event that a social                                                                                                     DMV will be required to
                                      Modify all inquiry – approximately 4 major interfaces,         6 months @ $75.00 hr =
security account number is                                                                                                     coordinate with Social
                                      approximately 30 programs                                                 $56,250.00
already registered to or                                                                                                       Security office on notification,
                                      Modify to incorporate XML tags for name element
associated with another person                                                                                                 identify procedures and
to which any state has issued a                                                                                                provide the ability to deny
                                  ID File:                                                                  Associated Cost:
DL/ID card, the state shall                                                                                                    when applicant has been
     REAL ID ACT                                            IMPACT                                      ASSOCIATED                       ASSUMPTIONS
     REQUIREMENT                                                                                       IMPACT COST
resolve the discrepancy and           ID File: approximately 4 programs                                     3 months@ $75.00 hr =      determined as non-compliant.
take appropriate action               Modify to incorporate XML tag for name element                                  $33,750.00

                                  Send Applicant Notification                                                     Associated Cost:
                                         For all confirmation matches must send notification to       37.h hrs @ 75.00 = $2,812.50
                                         applicant regarding known problem to proceed with
                                         correction                                                               Associated Cost
                                                                                                     Approximately 20,000 error @
                                                                                                                 $.37 = $7,400.00

Check other states if a person                                                                                                          No Impact – Delaware
already was issued a DL in                                                                                                              presently conduct CDLIS and
another state                                                                                                                           PDPS search on all applicants.
                                                                                                                  Associated Cost:
Ensure physical security of       Examine management procedures and ensure secure supervision.
                                                                                                                 4 @ $30,000.00 =
locations where DL/ID cards
                                  Hire additional staff:                                                              $120,000.00
are produced
                                  4 Senior Techs (2 bi-lingual)



                                                                                                                 Associated Cost:
Subject all person’s authorized   Conduct Background checks on all DMV personnel.                                                       All DMV employees will be
                                                                                                     Approximately 400 employees
to manufacture or produce                                                                                                               required to complete a
                                                                                                           @ $50.00 = $20,000.00
DL/ID cards to appropriate                                                                                                              background check
security clearance requirements
                                                                                                                    Associated Cost:
Establish fraudulent document     Re-Certification will occur every two-year or depending on                                            Delaware will utilize existing
                                                                                                      Certification 400 @ $15.20 hr
recognition training programs     Federal/State Legislation that would impact document validation.                                      Fraudulent Document Training
                                                                                                              for 8 hrs = $48,640.00
for appropriate employees                                                                                                               program. All staff will be
                                                                                                     Re-Certification 400 @ $15.20
engaged in the issuance of                                                                                                              required to either obtain
                                                                                                              for 4 hrs.= $24,320.00
DL/ID cards                                                                                                                             certification or re-certification.

Limit period of validity of                                                                                                             No impact to Delaware –
DL/ID cards that are not                                                                                                                Legislation limits license/ID to
temporary to a period not                                                                                                               5-years.
     REAL ID ACT                                             IMPACT                                ASSOCIATED                       ASSUMPTIONS
     REQUIREMENT                                                                                  IMPACT COST
exceeding 8 years
                                    Driver’s License File:                                                   Associated Cost:
Alternative document design if
                                        Modify various card designs to conform to AAMVA DL/ID      One-time Cost - $20,000.00
it does not meet federal
                                        Design Specifications.
standard
                                    ID File:                                                    Associated cost for issuing new
                                        Modify various card designs to conform to AAMVA DL/ID                              card:
                                        Design Specifications.                                                        $6,000.00
                                    Additional Hearings                                                        Associated Cost
Legal Presence Requirement                                                                                                         Pass legislation requiring Legal
                                                                                                             2 @ $35,000.00 =
                                    Hire additional staff:                                                                         Presence.
                                                                                                                     $70,000.00
                                    2 Driver Improvement Officers (1 bi-lingual)

Provide electronic access to all                                                                                                   No impact to Delaware –
other states to information                                                                                                        CDLIS/PDPS/SSOLV
contained in the motor vehicle                                                                                                     communications has been
database of the state                                                                                                              established.

Maintain a state motor vehicle                                                                                                     No impact to Delaware – DMV
database that contains at a                                                                                                        has an established database.
minimum:
          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
    REAL ID ACT                IMPACT    ASSOCIATED   ASSUMPTIONS
    REQUIREMENT                         IMPACT COST
– for those who cannot prove
lawful presence.
                                                         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                                                 IMPACT                                                 ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     Already compliant
(in Record, on Document)

Have following data elements/features on the document:         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          Ballpark cost for data field medication to system
                                                                    creation of separate field in data base to store   ~$100,000
    79. Person’s Signature
                                                               8.   Will need re-design based on specific
    80. Physical Security Features to prevent tampering,
                                                                    standards which are pending. Level of security
        counterfeiting or duplication                                                                                  Costs will be a function of specifications
                                                                    will impact whether license should be
    81. Common Machine Readable Technology:                         produced centrally or locally.
                                                           9. Again, need specifics on standards to identify
                                                           impacts and costs

Introduce temporary DL/ID cards and tying end of stay to   Currently done, but will require creation of new data       Ballpark cost for data field medication to system
expiration of DL/ID card (or issuance for no more than 1   field to track in system                                    ~$100,000
year)

Amending card design to show/indicate that it is a         Depending on other general specifications, may require
temporary document with a “different than usual”           separate card type if so est. $50-100,000 system design
expiration date                                            changes
        REAL ID ACT REQUIREMENT                                                  IMPACT                                                ASSUMPTIONS
Verification at Source:                                     1. Already Compliant
Enabling your system to electronically verify               2. Need specifics re MOU requirements – requires new        Ballpark cost for any system interface ~$500,000
documentation with:                                         system interface
 1. SSOLV                                                   3. Need specifics on requirements– requires new
                                                                                                                        Ballpark cost for any system interface ~$500,000
                                                            system interface
 2. SAVE
                                                                                                                        Ballpark cost for interface enhancements/medication
                                                            4. Presumed will happen through AAMVAnet/PDPS
 3. DEERS (DOD)                                                                                                         $100-300,000
 4. Other jurisdiction (DL/ID card)
                                                                5.   No idea what will be required. If
 5. Birth certificate                                                                                                   One time system costs ~$1.0 million, with on-going
                                                                     incrementally via 3rd party software like
                                                                                                                        annual additional system maintenance and staffing costs
 6. Other…i.e. third party vendors                                   Viisage, etc. will require one-time system costs
                                                                                                                        of ~$500,000.
                                                                     and lesser on-going staff costs. If through
                                                                     completely manual interaction directly with        Fully manually system could require as much 35
                                                                     each jurisdiction, much higher on-going            additional staff (+30%) at approximately 1.75
                                                                     staffing costs.                                    million/year
                                                                6.   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   Will move to a front-end of process image capture at        Equipment estimate $500,000
of identity source documents so that images can be          each work station
retained in electronic storage in a transferable format

Retain paper copies of source documents for a minimum       Will integrate images into Driver data-base, for future     Programming estimate $500,000
of 7 years or images of source documents presented for a    storage and retrieval
minimum of 10 years

Subject each person applying for a driver’s license or      Will move to a front-end of process image capture at        Additional cameras for each workstation ~ $150,000
identification card to mandatory facial image capture       each work station
        REAL ID ACT REQUIREMENT                                                   IMPACT                                                  ASSUMPTIONS
Establish an effective procedure to confirm or verify a      Need clearer understanding of requirements. Will            Will require additional staff, processing time for all first-
renewing applicant’s information                             presumably have to apply “new applicant” standard on        cycle renewals ~750,000 in additional staffing costs
                                                             first renewal following Real ID effective date, then        annually for the first five year cycle
                                                             image capture and storage with driver record should
                                                             allow exception processing thereafter

In the event that a social security account number is        Requires expansion of internal “Service Integrity” Unit     Est. minimum 5 additional positions for all
already registered to or associated with another person to                                                               resolution/enforcement matters @ ~$350,000 annually
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    Hopefully via AAMVANet/PDPS –                               Costs a function of specifics to be determined
another state                                                expansion/modification

Ensure physical security of locations where DL/ID cards      Will require enhanced inventory control system, facility    With enhanced verification and un-likelihood of over-
are produced                                                 modifications, etc. Will need specifics on license          the-counter service, more likely to go centralized with
                                                             feature requirements to determine if a centralized versus   mail fulfillment. MAJOR CONCERN re effectiveness
                                                             decentralized issuance.                                     and security of any mailing processes – currently
                                                                                                                         experiencing sever unreliability of US Mail services.

Subject all person’s authorized to manufacture or produce    Will have to address local legislation/union contracts re   Minimum cost of $30,000 for background checks
DL/ID cards to appropriate security clearance                mandatory background checks for all employees. Will
requirements                                                 need enhanced contract provisions for some service
                                                             providers.

Establish fraudulent document recognition training           Will required updates and enhancements based on             ~ $100,000 for curriculum development and materials
programs for appropriate employees engaged in the            specifics of regulations and requirements. Key need is
issuance of DL/ID cards                                      access to specimen documents and fraud samples for
                                                             hands-on training. Will need computer-based and
                                                             classroom based materials

Limit period of validity of DL/ID cards that are not         Already Compliant
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal      Need specifics in order to determine
standard
        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   Hopefully via AAMVANet/PDPS                                  Funding a function of specifics
contained in the motor vehicle database of the state           enhancements/modification




Maintain a state motor vehicle database that contains at a     Addition of new data fields (immigration status,             ~$600,000 effort for integration and reprogramming
minimum:                                                       signature at minimum) as described above.
           All data fields printed on DL/ID cards              Requires automated linkage to court system on
                                                               violations, and update of driver records, point
         motor vehicle driver’s histories, including motor
                                                               assignment system
         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                                              IMPACT                          ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     Already in compliance
(in Record, on Document)

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
                                                           In compliance
    89. Physical Security Features to prevent tampering,
        counterfeiting or duplication                      In compliance
    90. Common Machine Readable Technology:                In compliance
        REAL ID ACT REQUIREMENT                                                     IMPACT              ASSUMPTIONS
Introduce temporary DL/ID cards and tying end of stay to      Currently 2 year Maximum
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a            In compliance with no design difference
temporary document with a “different than usual”
expiration date

Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                              Application in use
 1. SSOLV
                                                              Application in use
 2. SAVE
                                                              Not in use
 3. DEERS (DOD)
                                                              Application is in use through NLETS
 4. Other jurisdiction (DL/ID card)
                                                              Not in use
 5. Birth certificate
                                                              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     Currently we scan and retain documents
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      No. Scanned images are retained
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or        Required by statute
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a       In Standard Operating Procedure
renewing applicant’s information
         REAL ID ACT REQUIREMENT                                                       IMPACT                      ASSUMPTIONS
In the event that a social security account number is already    In Standard Operating Procedure
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        Automated Standard Operating Procedure
another state

Ensure physical security of locations where DL/ID cards          Security systems in place
are produced

Subject all person’s authorized to manufacture or produce        Background checks and fingerprinting in current
DL/ID cards to appropriate security clearance requirements       application

Establish fraudulent document recognition training               Used programs through DHS, AAMVA, and internal
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not             Currently 6 years maximum
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal          Not applicable
standard

Legal Presence Requirement                                       Required by statute

Provide electronic access to all other states to information     Available through NLETS and NDR
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a
minimum:
                                                                 In compliance
         All data fields printed on DL/ID cards
                                                                 In compliance
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses
        REAL ID ACT REQUIREMENT                                                  IMPACT                         ASSUMPTIONS
Optional
Development and issuance of a certificate of driving – not   At this time, we have no plans to implement this
for federal identification purposes – for those who cannot   alternative
prove
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                             ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System
(in Record, on Document)

Have following data elements/features on the document:     1. Georgia law was amended 07/01/2005 to require
                                                           full legal name. Our current system only has space
    91. Full Legal Name
                                                           for 26 characters. We will be releasing an RFP that
    92. Person’s Date of Birth                             requires the vendor to provide space for 125
                                                           characters.
    93. Person’s Gender
                                                           2. Included on current document.
    94. Person’s DL or ID Card Number
                                                           3. Included on current document.
    95. Digital Photograph of Person (and retention)
                                                           4. Included on current document.
    96. Person’s Address of Principle Residence
                                                           5. Included on current document.
    97. Person’s Signature
                                                           6. Current operation allows for use of mailing
    98. Physical Security Features to prevent tampering,
                                                           address. Traffic tickets will be written using the
        counterfeiting or duplication
                                                           residence address, but the licensee may not
    99. Common Machine Readable Technology:                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   Georgia law will contain an identical provision
expiration of DL/ID card (or issuance for no more than 1   effective July 1, 2006. Programming has been
year)                                                      completed.

Amending card design to show/indicate that it is a         Some similar messages are already required by
temporary document with a “different than usual”           Georgia law. However, technology may not
        REAL ID ACT REQUIREMENT                                                   IMPACT                               ASSUMPTIONS
expiration date                                               allow for the inclusion of multiple messages.

Verification at Source:                                       1. Georgia already uses SSOLV.
Enabling your system to electronically verify                 2. This will require substantial programming.
documentation with:
 1. SSOLV
 2. SAVE
                                                              3. This will require substantial programming.
 3. DEERS (DOD)
                                                              4. Some programming exists for this check (CDLIS,
 4. Other jurisdiction (DL/ID card)                           PDPS, etc.) Additional programming will be
                                                              required.
 5. Birth certificate
                                                              5. This will require substantial programming by
 6. Other…i.e. third party vendors
                                                              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     Georgia plans to include scanning of source
of identity source documents so that images can be retained   documents in its new RFP. If we are required to scan
in electronic storage in a transferable format                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      Significant cost. See supra.
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or        This is bad customer service for applicants who
identification card to mandatory facial image capture         are denied a license because they spend extra
        REAL ID ACT REQUIREMENT                                                     IMPACT                               ASSUMPTIONS
                                                                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         If verification is required at each renewal, automated
renewing applicant’s information                                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   The states have no ability to resolve a problem that
registered to or associated with another person to which        exists at the Social Security Administration.
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       Insufficient existing connectivity, and no funding to
another state                                                   create such connectivity. Delay to customers.

Ensure physical security of locations where DL/ID cards         Some measures already in place; no funding to
are produced                                                    expand.

Subject all person’s authorized to manufacture or produce       Already in place.
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training              Already in place.
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not            Georgia law allows licensees to get a 5-year or 10-
temporary to a period not exceeding 8 years                     year 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         Georgia has not reached a conclusion on this item.
standard

Legal Presence Requirement                                      Already in place.
         REAL ID ACT REQUIREMENT                                                   IMPACT                            ASSUMPTIONS
Provide electronic access to all other states to information   Requires additional programming for all states with
contained in the motor vehicle database of the state           no additional funding or resources.

Maintain a state motor vehicle database that contains at a     Already in place.
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.




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                                            Current Procedure
Full legal name on driver’s license and ID card                             DMVS uses the full legal name, but the current system only allows 26
                                                                            characters on the card
Address of principle residence                                              DMVS allows licensees to use a mailing address
Physical security features                                                  DMVS currently uses overt and covert security features on licenses and
                                                                            ID cards
Common machine-readable technology                                          DMVS currently uses an encrypted 2-D barcode
Mandatory facial image capture of all applicants                            DMVS currently takes digital photographs of each person to whom a
                                                                            DL or ID is issued
Expiration date of DL or ID card cannot exceed 8 years                      Currently, all DL’s and ID cards expire after 4 years; will expand to 5-
                                                                            10 years on 07/01/05

II.    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
                                                                             Administration will not issue an SSN
Documentation of name and principal residence                                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.
Prior to issuing a driver’s license or ID card the DMVS will be required     Document authenticity is not verified unless suspect.
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.                           DMVS will accept properly authenticated foreign documents as proof
                                                                             of identity.

III.   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                                             Current Procedure
Valid documentary evidence of citizenship                              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           Rather than tying expiration to the authorized stay, Georgia law currently
stay                                                                     mandates the revocation of any DL or ID card issued to a non-citizen if
                                                                         his/her INS status is terminated or revoked.
Card must reflect that it is temporary.                                  Non-citizens are issued regular licenses and IDs.
Renewal only permitted upon submission of documentary evidence           Once a license or ID card is issued, the DMVS does not check INS status
that status has been extended                                            again.


V.     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                        ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System (in Record, on          Currently being accomplished
Document)

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         Will require additional programming and
DL/ID card (or issuance for no more than 1 year)                               change in law. Cost unknown at this time.

Amending card design to show/indicate that it is a temporary document with     See above
a “different than usual” expiration date

Verification at Source:                                                        Hawaii is only using SSOLV. Additional
                                                                               electronic verification methods would
Enabling your system to electronically verify documentation with:
                                                                               require additional programming and
 1. SSOLV                                                                      unknown cost. All electronic verification
                  REAL ID ACT REQUIREMENT                                                        IMPACT                         ASSUMPTIONS
 2. SAVE                                                                         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     Hawaii does not have scanners. Additional
documents so that images can be retained in electronic storage in a              unknown costs.
transferable format

Retain paper copies of source documents for a minimum of 7 years or              Additional unknown cost for filing system.
images of source documents presented for a minimum of 10 years

Subject each person applying for a driver’s license or identification card to    Presently being accomplished. Need
mandatory facial image capture                                                   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     Need new system – facial recognition or
information                                                                      fingerprint comparison to retrieve record of
                                                                                 renewing applicant.

In the event that a social security account number is already registered to or   Applicants with duplicate SSN are presently
associated with another person to which any state has issued a DL/ID card,       being referred to SSA for resolution. No
the state shall resolve the discrepancy and take appropriate action              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         Need definition of “appropriate security
appropriate security clearance requirements                                      clearance”. All employees currently
                                                                                 undergo local background checks.
                  REAL ID ACT REQUIREMENT                                                       IMPACT                          ASSUMPTIONS
Establish fraudulent document recognition training programs for appropriate      Need to bring “train-the-trainer” program to
employees engaged in the issuance of DL/ID cards                                 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       No issue. Hawaii license valid for six
not exceeding 8 years                                                            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    Need change in computer programming.
motor vehicle database of the state                                              Cost unknown.

Maintain a state motor vehicle database that contains at a minimum:              Violation history is a separate database.
                                                                                 Need computer programming. Cost
           All data fields printed on DL/ID cards
                                                                                 unknown.
         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                                          ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      $30K                                             Database changes required to accommodate size
(in Record, on Document)

Have following data elements/features on the document:      No major impact other than that shown above.
    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    Legislation and Rule Changes. Development cost
expiration of DL/ID card (or issuance for no more than 1    of 70K
year)

Amending card design to show/indicate that it is a          Card development costs $30K
temporary document with a “different than usual”
expiration date

Verification at Source:                                                                                      All estimates assume an automated process is available to
                                                                                                             verify. Without the automated process, costs will be
Enabling your system to electronically verify
                                                                                                             significantly higher. For a manual process, will need 6
        REAL ID ACT REQUIREMENT                                                   IMPACT                                         ASSUMPTIONS
documentation with:                                          Developed and in place                            additional personnel (a document
                                                                                                               verification/correspondence/issue unit) with a set-up cost of
 1. SSOLV                                                    26K programming development (for online access)
                                                                                                               $30K for furniture and hardware, 35K for programming,
 2. SAVE                                                     26K programming development                       $219K ongoing cost per year for personnel and $2500 per
                                                                                                               month for office space and equipment lease. Additionally,
 3. DEERS (DOD)                                              26K programming development                       postage for ongoing mail verification will be $150K per
 4. Other jurisdiction (DL/ID card)                          26K programming development plus 180K per year    year.
                                                             cost for the verification
 5. Birth certificate
 6. Other…i.e. third party vendors

Developing access capability to SAVE system                  Costs stated above

Introduce equipment into system to capture digital images    800K initial cost, plus ongoing maintenance and   Images captured at front end.
of identity source documents so that images can be           equipment replacement.
retained in electronic storage in a transferable format

Retain paper copies of source documents for a minimum        No impact identified
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       There will be development cost. The amount is
identification card to mandatory facial image capture        unknown at this time.

Establish an effective procedure to confirm or verify a      No impact identified                              No additional technology required.
renewing applicant’s information

In the event that a social security account number is        No impact identified                              Similar to what is currently done
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    26K Programming development More if electronic    If electronic verification is available
another state                                                verification is not possible

Ensure physical security of locations where DL/ID cards      No impact identified                              If central issue can be negotiated
are produced
        REAL ID ACT REQUIREMENT                                                    IMPACT                           ASSUMPTIONS
Subject all person’s authorized to manufacture or produce      No impact identified               If central issue can be negotiated
DL/ID cards to appropriate security clearance
requirements

Establish fraudulent document recognition training             No impact identified               If central issue can be negotiated
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           No impact                          Compliant
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        30K                                Vendor charge may vary
standard

Legal Presence Requirement                                     Legislation to clarify

Provide electronic access to all other states to information   No impact identified
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     No impact identified
minimum:
           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     Specific Requirements                             IL Impact                              Assumptions

Authority                Sec. 205: Authorizes Secretary of       Illinois is slated to rebid digital       Assume move from DOT to DHS
                         Homeland Security to issue              license system in 2007. To the degree     could mean delays in rule publication
                         regulations, set standards and issue    that regulations are not available to     as DHS gears up for this new area.
                         grants, in consultation with the        spell out exact requirements, we will
                         Secretary of Transportation and the     face a much greater challenge in          Can we get any timetable on rule
                         states.                                 designing and bidding a system to         promulgation?
                                                                 fully comply with 2008 provisions.
                         Sec. 207: Nothing is to affect U.S.     Time is of the essence for us on rules.
                         DOT or state authorities under Ch.
                         303 of Title 49, U.S Code.

Applicability            Sec. 201:                                                                         Assume CDLS are included.
                                                                 3 years is a very short time, with two
                         Applies to all U. S states and          state budget and legislative cycles at
                         territories.                            most.
                         Applies to and defines DLs and IDs.
                         CDLs?

                         Sec. 202 (a): Effective 3 years after
                         enactment (enacted May 11, 2005).

Grants                   Sec. 204:                                                                         Assume no funds in 2005
                                                                                                           appropriations. Assume after 2008,
                         Authorizes appropriations for fiscal    Costs will be huge, esp. for a large      states must bear all on-going costs.
                         years 2005-2009 for the Secretary of    state that may well have to retool        Will extensions if needed also include
                         Homeland Security necessary to carry    much of its operation, including          funding extensions?
                         out this act.                           eligibility criteria.
                                                                                                           Suggests grants will be permissive.
                                                                                                           Assume based on need and
                                       Secretary of Homeland Security may
                                                                                                                              competitive applications rather than
                                       make grants to a state to assist in                                                    by a formula allocation. Assume state
                                       conforming to the minimum                                                              legislatures will delay making
                                       standards.                                                                             appropriations until the availability of
                                                                                                                              federal funds is known—introduce
                                                                                                                              additional delays.

Information Required on the Driver’s   Sec. 202 (b)                              We already have all the text on our
License and Identification Card                                                  DL/IDs except full legal name. May           General: Assume DL and ID records
                                       States shall include at                   need law change for some                     must be linked, and some information
                                       minimum, the following                    requirements. DL/ID records                  from both shared with any other state
                                       information and features on               belonging to same person not linked--        requestor. Should that be assumed?
                                       the driver’s license and                  need to be located, records linked, and
                                       identification card:                      SOS must require identical                   Who else will have to do major
                                           1. the person’s full legal name,      information be used on DL/ID records.        changes in their systems to
                                           2. date of birth,                                                                  obtain information from
                                           3. gender,                            1. Legal name requirement in IL in I         DMVS—law enforcement,
                                           4. driver license or identification   D Security bill effective 1/1/05, but
                                                                                                                              election authorities, insurance
                                              card number,                       currently not operationalized as full
                                                                                 legal name.
                                                                                                                              companies, etc.?
                                           5. a digital photograph,
                                           6. address of principal                                                            6. Assume that standard address
                                              residence,                         Once “full legal name” is defined in
                                                                                                                              verification methods that verify
                                           7. signature,                         federal rule, Illinois will likely need to
                                                                                                                              legitimacy of mailing address will
                                           8. physical security features to      change administrative rules. (In law
                                                                                                                              suffice as verification of principal
                                              prevent tampering,                 but generally.) Will need new facility
                                                                                                                              address. If not, we do not know how
                                              counterfeiting, or duplication     procedures; change programming on
                                                                                                                              we’ll verify that a person actually
                                              of the document for                every screen and databases to store
                                                                                                                              lives there esp. if they are not the
                                              fraudulent purposes and            longer names; change card design to
                                                                                                                              named person on documents used to
                                           9. a common machine-readable          print full legal name. 18 mo. to 2
                                                                                                                              establish address.
                                              technology, with defined           years programming estimated. Will
                                              minimum data elements.             require field changes for likely every
                                                                                 external user who comes into our
                                                                                 systems—law enforcement,
                                                                                 insurance.

                                                                                 5. Without an exception, to                  5.Assume no exceptions for
                                                                 photo/signature requirement,              inclusion of photo. This would
                                                                 Illinois will have to eliminate           be important clarification for
                                                                 Valid w/out Photo/signature               Illinois in rules.
                                                                 cards (religious exemptions,
                                                                 military, etc.) or re-design them         9. Assume MRT will be 2-D
                                                                 so they are not valid for federal         bar code with no requirement to
                                                                 purposes. Law change.                     include photo or biometric in it;
                                                                                                           need rule on this ASAP.
                                                                 9. Illinois DL/IDs have 1-D and 2-bar
                                                                 codes. MRT to be used is unknown.
                                                                 Could involve extra cost, legislation.
Minimum              Sec. 202 (c):
Issuance Standards
                     A state shall require, at minimum,          Will need to re-examine I D policies to   Assume all verifications before
                     presentation and verification of the        ensure that we meet these                 issuance means few if any new could
                     following information before issuing        requirements for these minimum            be over the counter unless it involves
                     a driver’s license or ID card to an         documents, and perhaps limit              a second visit, unless additional
                     individual:                                 acceptable documents to those that are    electronic verification methods are
                     • a photo identity document, except         verifiable with issuing source.           developed.
                       that a non-photo identity document
                       is acceptable if it includes both the     Must rely on manually prepared letters    Assume letters of ineligibility from
                       person’s full legal name and date of      from SSA to show ineligibility—           SSA do not have to be verified with
                       birth.                                    currently they are not verifiable as      the issuing source?
                     • documentation showing the person’s        validly obtained.
                       date of birth.
                     • proof of the person’s social security     Will have definition issues with full
                       account number or verification that       legal name and principal residence.
                       the person is not eligible for a social
                       security account number.
                     • documentation showing the person’s
                       name and address of 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):
                                                                                                             Big question in a nutshell for Illinois
                           A state shall require, before issuing a   Illinois has no legal presence          is will the requirement of SSN suffice
                           driver’s license or identification card   requirement in Illinois law,            as evidence of legal presence?
                           to a person, valid documentary            except for TVDL applicants              Neither holding an SSN nor SSOLV
                           evidence that an individual is            ineligible for SSNs. Law                responses indicates citizenship nor if
                              • a citizen of the United States;      change required, major overhaul         the non-citizen is still legally in the
                              • an alien lawfully admitted for       in eligibility criteria to add it.      country at time of DL/ID application,
                                 permanent or temporary                                                      so we assume not. The Question:
                                 residence;                          If Illinois needs to redefine regular   Under (c)(2)(B)(ii), a state may
                              • has conditional permanent            DL/ID eligibility to tie it to          issue a "regular" driver's license to
                                 resident status;                    citizenship or permanent residency      an alien that is lawfully admitted
                              • has a valid, unexpired               instead of to SSN, there could          for permanent or temporary
                                 nonimmigrant visa or                potentially be tens or likely           residence in the US. Under
                                 nonimmigrant visa status for        hundreds of thousands of non-           (c)(2)(B)(v), a state may issue only a
                                 entry;                              citizens with SSNs who will now         temporary driver's license to a
                              • has a pending or approved            have to get TVDL instead, with DL       person who has a valid, unexpired
                                 application for asylum; has         tied to authorized length of stay.      nonimmigrant visa or
                                 refugee status;                     Full legal review needed of this,       nonimmigrant visa status for entry
                              • has a pending or approved            Sanchez decree which currently          into the US. However, the
                                 application for temporary           prohibits us from requesting            definition of alien that is found in 8
                                 protected status;                   immigration documents for any           USC 1101, Section 101(3) defines
                              • has approved deferred action         applicant but TVDL.                     the term alien as "any person not a
                                 status;                                                                     citizen or national of the US."
                              • or has a pending application for     Need to evaluate potentially            Based on these definitions, it seems
                                 adjustment of status to that of     effects on reciprocity                  possible that a person could be an
                                 an alien lawfully admitted for      agreements with other                   alien (and be eligible for a regular
                                 permanent residence or              countries.                              driver's license), but holds a
                                 conditional permanent resident                                              nonimmigrant visa (and be eligible
                                 status.                                                                     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   Sec. 202 (c ) 2 (C):
Identification Cards
                                 States may only issue a temporary         Illinois has TVDL program, but      Assuming MAJOR operational
                                 driver’s license or identification card   is issuing regular DLs and IDs to   impact of shifting many non-citizens
                                 to applicants who present evidence of     persons who may have eligibility    with SSNs into TVDL program, and
                                 legal status for                                                              then limiting many TVDLs to one
                                                                           restricted to only getting a
                                     • a valid, unexpired                                                      year instead of three years—
                                                                           TVDL—that is, non-citizens with        More SAVE use--$ and delays
                                          nonimmigrant visa or
                                                                           SSNs with time-limited legal           TVDLs at all sites, not just 6
                                          nonimmigrant visa status,
                                                                           authorization to stay in the U.S.      More frequent renewals—
                                     • a pending application for
                                          asylum,                                                              3 yrs. to 1
                                     • pending or approved                 Illinois TVDL program allows
                                                                           DLs, not IDs. Federal law
                                    application for temporary          allows temporary IDs.
                                    protected status,
                                •   approved deferred action           MAJOR operational impact of shifting
                                    status or                          many non-citizens with SSNs into
                                •   has a pending application for      TVDL program, and then limiting
                                    adjustment of status to that of    many TVDLs to one year instead of
                                    an alien lawfully admitted for     three years—
                                    permanent resident in the             More SAVE use
                                    United States or conditional          TVDLs at all sites
                                    permanent resident status.            More frequent renewals

                            A temporary driver’s license or            Must change law and program
                            identification can only be valid for the   For TVDLs to be 1 year instead
                            period of time of the applicant’s          of 3 for those with no definite
                            authorized stay in the United States or
                                                                       end of authorized stay.
                            for a period of one year if there is no
                            definite end to the period 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    ADDRESS: Will need to find an           Assume Illinois is like every state in
                            card to a person, a state shall verify,    address verification method that gets   that we are currently unable to
                            with the issuing agency, the issuance,     to principal address, not just valid    comply with this for every breeder
                            validity, and completeness of each         mailing address.                        document. On-line verification
breeder document required to be                                                        systems for many are not available.
presented by the applicant.              PASSPORTS: No verification system             Manual systems especially in a state
                                         currently in place for passports. No          our size are simply not feasible or
    1) SSOLV                             mechanism to verify U.S. or foreign           cost-effective by any stretch. Expect
                                         ones.                                         cost, delays, and significant manual
    2) SAVE                                                                            exception processes.
                                         1) Illinois already verifies SSN
    3) DEERS                             through SSOLV—on line since                   Assume this could largely prevent
                                         6/14/04.                                      “instant” or “over the counter”
    4) Other jurisdiction (DL/ID                                                       (OTC) issuance of some or all of
       card)                             2) Illinois has signed an MOU for             our DLs and IDs, esp. new or
                                         SAVE (eff. 10/04) and already verifies        renewal (depending on renewal
    5) Birth certificate                 immigration documents in TVDL                 verification requirements.
                                         program only, for those not eligible for
    6) Other…i.e. third party            SSN, not for all non-citizens. ONLY           Assume it could reduce or end mail
       vendors                           AT 6 SITES. (SAVE is costly; not              and Internet address changes and
                                         built into our system to ensure its           renewals.
States must verify with the Social       usage like SSOLV but needs to be—
Security Administration a social         fraud risk; many delays in responses          Assume we will have to significantly
security number presented by a           from DHS.)                                    reduce the number and type of
person using the full social security                                                  acceptable documents used, to limit it
number.                                  3) Illinois has not looked at DEERS,          to those that are verifiable.
                                         need to first identify if it is going to be
A state may not accept any foreign       useful for a significant enough part of       Assume current MOAs with DHS
document, other than an official         population to warrant costs.                  already signed will suffice. Will
passport as proof of identification.                                                   they?
                                         5) There is no local, state or national
State must sign a Memorandum of          automated system for verification of          Assume only renewal requirements
Understanding with the Department        U.S. issued birth certificates, and           will apply to current DL/ID
of Homeland Security by September        certainly no automated system for             holders, not full verification as
11, 2005, to use the Systematic Alien    foreign birth certificate verification.       though they were new.
Verification Entitlements (SAVE) to      Illinois does not plan to participate in
verify the legal presence status of an   EVVE but design its own system.               Assume 3rd party verification or
applicant other than a United States                                                   verification of document’s physical
citizen.                                                                               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):
                                                                       Will need to electronically scan           Assume this scanning
                              (1, 2) Must capture images of identity   all identity source documents              requirement plus verification
                              source documents and retain              at the counter in facilities,              steps may significantly limit
                              electronic copies for minimum 10         have network capacity to                   mobile unit use, perhaps
                              years or paper copies for 7 years.       transmit to central electronic             make mobiles impractical?
                                                                       storage, and have them be
                                                                       retrievable and able to be                 Assume major cost not just for
                                                                       electronically shared.                     hardware but also for storage and to
                                                                                                                  redesign facility layouts to add space
                                                                       Need to assess Illinois record retention   at counter for scanners.
                                                                       laws for paper/electronic copies.
                                                                                                                  Assume privacy issues are bigger than
                                          Need to assess legal/privacy           we anticipate, as DMVs will now
                                          considerations for who can see,        have (and law enforcement, federal
                                          retrieve and receive this new          government, others will want)
                                          information kept by DMVs.              copies/information.

(3) A state must subject each person
applying for a driver’s license or ID
card to mandatory facial image
capture.                                  No Valid Without Photo/Signature?      Assume this by definition moves the
                                          Other state law changes on photo       camera to front of application
                                          requirement possible. Religious        process—must capture photo of all
                                          exemptions, military.                  applicants, not just cardholders:
                                                                                    Complete facility workflow
                                                                                 redesign
                                                                                     Major re-working of
(4) States must establish an effective                                           programming
procedure to confirm or verify a                                                    130-plus facility remodel/design
renewing applicant’s information.
                                          Unknown right now--could affect
                                          time to process renewals, ability to
                                                                                 We do not know what to assume.
                                          do them instantly OTC, and may
                                                                                 Need clarification here ASAP—what
                                          affect ability to have mail and
                                                                                 verification needs to be done will
                                          Internet Safe Driver Program.
                                                                                 affect central vs. instant issue, mail
                                          Potentially huge operational impact—
                                                                                 and Internet renewal options.
                                          the bulk of our applications are
(5) Confirm SSN and in the event that
                                          renewals each year.
a Social Security number is already
registered to or associated with
another person to whom any State has
                                          SSOLV does not indicate if SSN
issued a driver’s license or ID card,                                            Is this over and above the
                                          issued to another. Not all states
the state shall resolve the discrepancy                                          requirement to verify other DL or
                                          require SSN. At a minimum, this
and take appropriate action.                                                     ID issued or just DL? It looks like
                                          will require linkage of SOS database
                                                                                 it is to also verify if they used an
                                          with ALL DMV databases to do
                                                                                 SSN or if anyone else I that state is
                                          checks.
                                                                                 using same SSN. Is that correct
                                                                                 interpretation?
                                          SOS can, but does not do SSN or name
                                          checks on our own database. This
                                         “NA01” processing will need to be         Not all states require SSN. Privacy
                                         required.                                 issues for us, SSA, others?

(6) Must refuse to issue to person       Much clean-up on multiple SSN
holding other state’s DL or ID           records needed, esp. on unlinked DL
without confirming it is terminated or   and IDs.
is being terminated.
                                                                                   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
(7) Must ensure physical security of                                               systems, or new system directly to
locations where cards produced and                                                 states? New system through DHS?
card materials are stored.

                                         Locations currently include facilities,   Assume additional costs for secure
(10) Must limit validity of DL/IDs to    mobiles, and two warehouses. Likely       space and storage if it stays in
no more than 8 years.                    work to be done, potential costs for      facilities.
                                         locked areas or cabinets, safes, etc.
                                                                                   Assume possible additional steps or
                                                                                   audit systems for consumables.
                                         Non-expiring Senior and 10 year
                                         disabled IDs will not meet                Assume we may have to stop issuing
                                         requirement—will need to limit            non-expiring senior IDS and reduce
                                         them to 8 years or make them not          time for disabled IDs.
                                         valid for federal purposes.
                                                                                   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 Act-
                                                                                                             compliant card.




Personnel Requirements         Sec. 202 (d):

                               (8) Must subject all staff that    DHS must define clearance                  Do not know what to assume on
                               manufacture or produce DL/IDs to   requirements. Effect on personnel          security requirements. State and/or
                               security clearance.                policies, job requirements or titles?      federal criminal background check?
                                                                                                             Any checks through DHS on terror
                                                                                                             watch or no fly or other lists?


                                                                  Illinois does very limited training        Assume AAVA curriculum will be
                               (9) Must establish fraudulent      currently. If AAMVA curriculum is          adopted in rule as standard for
                               document training programs for     required, it is 12 hours before working,   compliance. Can we assume that?
                               DL/ID issuance staff.              and annual re-training.
                                                                                                             Assume major training needs for
                                                                  Likely need to look at potential           which we currently do not have
                                                                  specialist roles to have staff that        organizational capacity/resources.
                                                                  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):
Interoperability
                                (12) Must provide electronic access to     Need to assess needed state law to       Assume DRIVerS or its equivalent is
                                all other states to information in the     authorize sharing of data including      a prerequisite for all states.
                                SOS database.                              SSNs. Might include photo exchanges.     Establishing direct connections with
                                                                                                                    all other states and jurisdictions, esp.
                                                                                                                    in the absence of uniform standards
                                                                                                                    for information exchange, would be a
                                (13) State motor vehicle database                                                   nightmare for all states. (Can we go
                                must contain, at a minimum: all data                                                home now??)
                                fields printed on DL/IDs issued by the     SOS databases contain all this but
                                state; and motor vehicle drivers’          records are not linked. (Previously      Assume expansion of existing
                                histories, including motor vehicle         noted.)                                  AAMVA systems.
                                violations, suspensions, and points on
                                licenses.
Fraud Prevention and Security   Sec. 203:
Standards
                                The Act amends the fraud and related       Need to review Illinois DL/ID fraud
                                activity in connection with                and identity theft statutes to ensure
                                identification documents,                  they reflect this and other new
                                authentication features, and               requirements.
                                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, document-
                                making implements, or means of
                                identification.”




Compliance                      Sec. 202 (a): Federal agencies are         If Illinois DL/IDs do not meet federal   We need full explicit definition of
prohibited from accepting for any          minimum standards, they cannot be     federal purposes in rule ASAP.
official purpose a state-issued DL or      used for federal purposes.
ID three years after enactment of this                                           We do not know if we will issue
Act unless the state conforms to the       Definition of “federal purpose”       alternative non-Real I D Act
minimum standards established in the       will be key -- includes air travel,   compliant documents.
bill.                                      accessing federal facilities.
                                           Federal benefits? DHS                 Assume pressure to create one for
Sec. 202 (d) 11): States can still issue                                         persons not legally in the country.
                                           Secretary will determine.
DLs and IDs for driving or other
purposes to persons legally or not                                               Assume it might also be needed for
legally in the country that do not meet
                                        Could issue non-compliant          non-expiring senior IDs, Disabled
requirements, but cards must:           cards. Illinois will need to       IDs, non-photo DL/IDs IF those
    • clearly say that they are not     determine if it will create a two- continue to be issued.
         valid for federal purposes,    tiered system – some DL/IDs
         and                            good for federal purposes, some
    • use unique color or design to     not. And if so, will it be for
         alert federal agency and law   persons not able to meet legal
         enforcement personnel.         presence requirements be part
                                        or all of those eligible for non-
                                        federal 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
driver's license or ID card that does   change that would be federally
not conform to the minimum              funded.
standards, state must ensure that such
license or ID card:
    • clearly states on its face that
        it may not be accepted by any      Self-certification.
        federal agency for any
        official purpose; and
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.

Extensions                  Sec. 205 (b):

                            The Secretary of Homeland Security       Need to develop timetables that         Assume this might be needed, esp. if
                            may grant an extension of time           reflect:                                rulemaking process has unexpected
                            beyond 3 years if the state provides         • State budget cycles,              delays. If so, need explicit direction
                            adequate justification for                        resources                      in rules.
                            noncompliance.                               • State legislative and rule
                                                                              changes
                                                                         • DDLS contract term
                                                                         • Organizational capacity for
                                                                              change

Repeal                      Sec. 206:

                            This Act repeals Section 7212 of the     With repeal of the less stringent and
                            Intelligence Reform and Terrorism        more general provisions of the
                            Prevention Act of 2004 (P.A. 108-        Intelligence Reform Act, which
                            458) that required the Department of     became law in December 2004, the
                            Transportation to establish minimum      negotiated rule-making process
                            standards for the driver’s license and   already underway (in which AAMVA
                            ID card through negotiated               and states were participating) was
                            rulemaking.                              disbanded.

Questions & answers not included in response.
                                                                       .INDIANA

                                                     Jurisdiction Impact Analysis Real ID Act

        REAL ID ACT REQUIREMENT                                                  IMPACT                                               ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      New “STARS” system is set to do this. Will take a         No revisions in their requirements.
(in Record, on Document)                                    full license cycle once it is in place to be compliant.
                                                            Est. six years from final STARS implementation.

Have following data elements/features on the document:      All of this is in place with final STARS                  No revisions in their requirements.
                                                            implementation in December 2005. Need details of
    118. Full Legal Name
                                                            what the data in the “machine readable technology,
    119. Person’s Date of Birth                             2D UPC, is it same as DLA?
    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:

Introduce temporary DL/ID cards and tying end of stay to    Not currently offered. Needs to be added to our IT        No revisions in their requirements.
expiration of DL/ID card (or issuance for no more than 1    project. list. Requires programming time, passage of
year)                                                       legislation and design of unique document.

Amending card design to show/indicate that it is a          Not currently offered. Needs to be added to our IT        No revisions in their requirements.
temporary document with a “different than usual”            project. list. Programming time and design of unique
expiration date                                             document.

Verification at Source:                                     Not currently offered. Needs to be added to our IT        Standard method of transfer is established early enough
                                                            project. list. Programming requirements are
        REAL ID ACT REQUIREMENT                                                     IMPACT                                              ASSUMPTIONS
Enabling your system to electronically verify                   substantial.                                            for everyone to conform.
documentation with:
                                                                Will probably move Indiana from relatively instant      Originating agencies/sources are prepared to respond.
 1. SSOLV                                                       issuance to having to mail documents to them.
 2. SAVE                                                        License fees may need to be revised to cover
                                                                increased postal costs.
 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                     Currently able to do so with our CVP process.           No revisions in their requirements.

Introduce equipment into system to capture digital images       Substantial Programming and hardware costs.             No revisions in their requirements.
of identity source documents so that images can be retained
                                                                In our current IT plan to move as quickly as possible
in electronic storage in a transferable format
                                                                to achieve this information and digital signatures,
                                                                regardless of the Real ID status.

Retain paper copies of source documents for a minimum of        Currently in our statute.                               No revisions in their requirements.
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or          Will need to pass legislation as we have exemptions     No revisions in their requirements.
identification card to mandatory facial image capture           for religious reasons.

Establish an effective procedure to confirm or verify a         Currently in place depending on what is finally         No revisions in their requirements.
renewing applicant’s information                                mandated.

In the event that a social security account number is already   Currently a policy in place. If it does not comply      No revisions in their requirements.
registered to or associated with another person to which        with a standard established later, development and
any state has issued a DL/ID card, the state shall resolve      implementation of new policy.
the discrepancy and take appropriate action

Check other states if a person already was issued a DL in       CAROL?? Do we do this?                                  No revisions in their requirements.
another state
         REAL ID ACT REQUIREMENT                                                     IMPACT                                              ASSUMPTIONS
Ensure physical security of locations where DL/ID cards        Currently in place.                                       No revisions in their requirements.
are produced

Subject all person’s authorized to manufacture or produce      Currently in place but will need to revise if standards   No revisions in their requirements.
DL/ID cards to appropriate security clearance requirements     do not match ours.

Establish fraudulent document recognition training             Currently in one place and have an enhanced               No revisions in their requirements.
programs for appropriate employees engaged in the              fraudulent document recognition training program in
issuance of DL/ID cards                                        the works with AAMVA and our Investigations dept.

Limit period of validity of DL/ID cards that are not           Currently in place. Legislation passed in the last        No revisions in their requirements.
temporary to a period not exceeding 8 years                    session sets our period to 6 years.

Alternative document design if it does not meet federal        Not an issue at this time. Will revise as necessary as    No revisions in their requirements.
standard                                                       standards are set. Requires programming time,
                                                               passage of legislation and design of unique
                                                               document.

Legal Presence Requirement                                     Currently in place.                                       No revisions in their requirements.

Provide electronic access to all other states to information   Currently being developed with the new STARS              No revisions in their requirements.
contained in the motor vehicle database of the state           system.

Maintain a state motor vehicle database that contains at a     Currently in place.                                       No revisions in their requirements.
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       Currently under review.                                   No revisions in their requirements.
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                              IMPACT                                  ASSUMPTIONS                            Additional
       Requirement                                                                                                              Comments
Introduce Full Legal Name into   Should be none to minimal. Our new             Assume the AAMVA system and DL/ID
Driver Licensing System (in      driver license system, to be implemented       card document specs will meet
Record, on Document)             in April '06 will allow for 125 characters.    minimum DHS requirements for full
                                 Our new driver license allows for 111          name
                                 characters to printed on the card. We'll
                                 use the AAMVA truncation rule for any
                                 thing longer than 111 characters
Have following data              1-4: We have now                               1: we'll follow the truncation rules
elements/features on the         5: We have now for everyone except             5: Assume DHS will provde for same
document:                        persons with bona fide religious               Valid w/o photo exception based on
  1. Full Legal Name             objection. They are issued a license that      U.S. Constitution.
  2. Person’s Date of Birth      is "valid without photo"and no file photo is   7: Assume DHS will allow alternative       5: We can provide
                                 capured either.                                for those physically incapable of          background on case law
                                 6: we have now                                 signing.                                   if you'd like it
 3. Person’s Gender              7: we have now                                 8: Assume AAMVA DL/ID card spec will
                                 8: we exceed AAMVA card spec now               satisfy this requirement.
 4. Person’s DL or ID Card                                                                                                 7: We currently allow
                                 9: our new license will have 2D barcode,       9: Assume AAMVA DL/ID card spec
Number                                                                                                                     use of a stamp or
                                 mag stripe & digital watermark                 requirement for PDF417 will satisfy this
                                                                                                                           signature by power of
                                 Authentication/re-enrollment of those          requirement
                                                                                                                           attorney
                                 already in the system will have a
 5. Digital Photograph of
                                 customer impact
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           Will require a legislative change reducing
cards and tying end of stay to      term of issuance from 2 to 1 yr for person
expiration of DL/ID card (or        with indefinite end of stay.
issuance for no more than 1
year)
Amending card design to             We need guidelines. It may require some      We'd prefer to do this in the header.   The current AAMVA card
show/indicate that it is a          change to our photolicensing software.                                               spec shows Zone II for
temporary document with a                                                                                                "other data fields for
“different than usual” expiration                                                                                        national or jurisdictional
date                                                                                                                     purposes in human
                                                                                                                         readable format". May
                                                                                                                         need to change the
                                                                                                                         spec.
Verification at Source:             1: We will implement in July '05                                                     Our new DL system is
                                    2: We think we can implement easily                                                  designed to let us add
                                    with the existing external web access, but                                           external interfaces
                                    would prefer to have it fully intergated                                             easily.
Enabling your system to             within our system. That will take IT staff                                           Any electronic
electronically verify               time and money. Transaction fees seem                                                verification that does not
documentation with:                 high.                                                                                deliver 7-10 second
                                    3: not enough known to assess an impact                                              response may cause us
                                    4: none except potential response time                                               customer (wait time)
                                    issue                                                                                issues as we are an
                                    5: Major. Even though we participate in                                              OTC state.
 1. SSOLV                           EVVER, and it functions well, we don't
 2. SAVE                            anticipate the states' Vital Records
                                    agencies will be able to make the needed
 3. DEERS (DOD)
  4. Other jurisdiction (DL/ID     database/system upgrades within 3          4: Tasks 8&9 functionality will be
card)                              years.                                     implemented nationwide.
                                   6: Transaction fees will probably be our
                                   biggest impact.
 5. Birth certificate                                                                                                    5: At this time we don't
                                                                                                                         follow up on the bad hits
  6. Other…i.e. third party
vendors
Developing access capability to    Minor-see #2 above.                        CDLIS Response time parameter -
SAVE system                                                                   should be able to use the available web
                                                                              interface our assumption is that we
                                                                              would receive timely and accurate
                                                                              information
   Real ID Act Requirement                         Impact                                  Assumptions                    Additional Questions
Introduce equipment into           We currently have this capability
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      Technical – minor                          Assume we can do one or the other.
documents for a minimum of 7       Staffing - not clear                       Will require more staff time to            It's not clear that
years or images of source                                                     scan/index the documents.                  additional staff will be
documents presented for a                                                                                                needed at this time. We
minimum of 10 years                                                                                                      may be able to absorb
                                                                                                                         with current staff.
Subject each person applying       Our new DL/Photo Licensing system          Assume religious objector exemption
for a driver’s license or          allows for this.                           issue will be resolved at Federal level.
identification card to mandatory
facial image capture
Establish an effective             We need more information about             We believe our new system and card
procedure to confirm or verify a   requirements                               will allow us to meet reasonable
renewing applicant’s                                                          requirements
information
In the event that a social          Minor                                                                                       We're going to send the
security account number is                                                                                                      customer to the Social
already registered to or                                                                                                        Security Administration
associated with another person                                                                                                  to clear up the
to which any state has issued a                                                                                                 discrepancy
DL/ID card, the state shall
resolve the discrepancy and
take appropriate action
Check other states if a person      Minor                                            AAMVA provides this function
already was issued a DL in
another state
Ensure physical security of         We need information on minimum                   We believe we can meet reasonable
locations where DL/ID cards         requirements                                     requirements with little difficulty by
are produced                                                                         building on procedures in place now for
                                                                                     the secure storage of consumables and
                                                                                     equipment
Subject all person’s authorized     We need more information on minimum              Our MVE officers or local law
to manufacture or produce           requirements. If it's kept at the level of a     enforcement will conduct a background
DL/ID cards to appropriate          criminal history background check, it            check on anyone that is involved in the
security clearance requirements     should be little impact. If it requires an in-   issuance of DL & ID. Photo licensing
                                    depth security clearance review of the           vendors/card material suppliers will
                                    type used for prospective law                    conduct background checks of their
                                    enforcement employees within our                 own employees.
                                    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.
Establish fraudulent document       None.                                            Assume AAMVA FDR will meet/exceed
recognition training programs                                                        any minimum requirement
for appropriate employees
engaged in the issuance of
DL/ID cards
Limit period of validity of DL/ID   Already 5                                        Will impact our ability to offer renewal
cards that are not temporary to                                                      by mail or internet in the future.
a period not exceeding 8 years

Alternative document design if it   Minimal. Could require some change to      Our DL will meet and exceed the
does not meet federal standard      our photo licensing software.              federal standards
Legal Presence Requirement          We've required proof of legal              Will require a legislative change to
                                    presence/citizenship for new licensees     bring Iowa law into strict compliance
                                    since 2002. There will be some impact on   with Federal law
                                    those renewing who's legal
                                    presence/citizenship has never been
                                    verified.
Provide electronic access to all    Minor.                                     Assume this will be an
other states to information                                                    AAMVAnet/NLETS function
contained in the motor vehicle
database of the state
Maintain a state motor vehicle      None.                                      We currently have a data base that
database that contains at a                                                    contains all of this information.
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       Minor                                      We know this will be proposed. Don't
certificate of driving – not for                                               know what to expect.
federal identification purposes –
for those who cannot prove
lawful presence.
                                                                       KANSAS
                                                     Jurisdiction Impact Analysis Real ID Act

        REAL ID ACT REQUIREMENT                                                 IMPACT                                            ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      Currently being done.
(in Record, on Document)

Have following data elements/features on the document:      Currently being done
    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    Will require legislation to implement
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a          Will require legislation for unique card
temporary document with a “different than usual”
expiration date

Verification at Source:                                     Can be done when systems are in place for Kansas to   Assuming some national standard will be in place for
                                                            connect to.                                           programming and access to be built around.
Enabling your system to electronically verify
documentation with:
         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       Can be done by installing scanners to work with
of identity source documents so that images can be retained     current image capture units and interface with
in electronic storage in a transferable format                  current imaging system.

Retain paper copies of source documents for a minimum of        Same as above, retention of imaged documents is not
7 years or images of source documents presented for a           a problem.
minimum of 10 years

Subject each person applying for a driver’s license or          Currently being done
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a         Currently being done using facial recognition and     These will be acceptable methods in the final rule "to
renewing applicant’s information                                source data tracking.                                 confirm or verify".

In the event that a social security account number is already   Currently being done when SSN discrepancies arise.    Connectivity to other states available and allowed.
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       Can be done now if DL information is provided.        Connectivity or central clearing house available.
another state

Ensure physical security of locations where DL/ID cards         Currently done, central issued state
are produced
         REAL ID ACT REQUIREMENT                                                     IMPACT                         ASSUMPTIONS
Subject all person’s authorized to manufacture or produce      May require legislation for background checking of
DL/ID cards to appropriate security clearance requirements     dept. employees.

Establish fraudulent document recognition training             In place.
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           In place.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        N/A
standard

Legal Presence Requirement                                     In place since 2000

Provide electronic access to all other states to information   In place if requested
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     In place
minimum:
           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                                                 IMPACT                                ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      KY uses full legal name now on driving records.
(in Record, on Document)                                    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                                    Full name not on license, middle initial used and
                                                            truncation on long names over 35 characters
    137. Person’s Date of Birth
                                                            On license
    138. Person’s Gender
                                                            On license
    139. Person’s DL or ID Card Number
                                                            On license
    140. Digital Photograph of Person (and retention)
                                                            On license, yes retained since 3/2002
    141. Person’s Address of Principle Residence
                                                            Yes on license. Mail address in computer system
    142. Person’s Signature
                                                            Yes on license and stored with image
    143. Physical Security Features to prevent tampering,
         counterfeiting or duplication                      Yes
    144. Common Machine Readable Technology:                Yes 2D Barcode, AAMVA 2000 standard now

Introduce temporary DL/ID cards and tying end of stay to    KY issues license to end of legal stay or normal 4 year
expiration of DL/ID card (or issuance for no more than 1    expiration if stay longer.
year)

Amending card design to show/indicate that it is a          This would be a new requirement for KY
temporary document with a “different than usual”            temporary document currently license looks same
expiration date                                             except expiration date.
        REAL ID ACT REQUIREMENT                                                   IMPACT                                           ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                              Yes
 1. SSOLV
                                                              No
 2. SAVE
                                                              No
 3. DEERS (DOD)
                                                              No
 4. Other jurisdiction (DL/ID card)
                                                              No, however KY does have access to KY Vital Stats
 5. Birth certificate                                         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     KY has no means to address this requirement at this   KY has over 150 locations that would need this
of identity source documents so that images can be retained   time. This would be a very huge impact upon KY        technology. There are over 220 non-PCs (3270
in electronic storage in a transferable format                                                                      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      KY has no means to address this issue at this time.    KY has over 150 locations that would need this
7 years or images of source documents presented for a         Additional copy machines, employees handle at clerk   technology. There are over 220 non-PCs (3270
minimum of 10 years                                           & central offices, and office space needed to house   terminals) and 170 digitized license workstations in
                                                              information.                                          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           KY complies now, since 3/2002.
identification card to mandatory facial image capture



Establish an effective procedure to confirm or verify a          Previous image of applicant appears before issuance.    We assume this is more than showing existing license.
renewing applicant’s information                                 SSOLV ran on applicants. If this requirement goes
                                                                 further, then it would be a new requirement to KY.

In the event that a social security account number is already    Yes, upon proof of SSN w/SSA and other proof of         Implementation of DRIVERS would help this
registered to or associated with another person to which         identity license, bank, etc. KY will notify state to    requirement.
any state has issued a DL/ID card, the state shall resolve the   determine identity
discrepancy and take appropriate action

Check other states if a person already was issued a DL in                                                                States can ask the question to applicant but DRIVERS
another state                                                                                                            needed to enforce

Ensure physical security of locations where DL/ID cards          Requirement is very difficult in KY where court
are produced                                                     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        KY performs some level of background checks now         Background check in Real ID would be expanded.
DL/ID cards to appropriate security clearance requirements       but additional measures needed.                         Money needed.

Establish fraudulent document recognition training               Very large impact and concern for KY since court        The 20 hours FDT will be a very challenging
programs for appropriate employees engaged in the                clerk offices issue license, not DMV employees. There   requirement. No funding. There is concern that training
issuance of DL/ID cards                                          are over 800 users and there is a 25% turn over rate.   would not produce better results in the current
                                                                 No money currently set aside to perform this training   environment.
                                                                 and travel.

Limit period of validity of DL/ID cards that are not             KY issues a 4-year license. KY complies with
temporary to a period not exceeding 8 years                      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   Do no understand fully the meaning of this, but it is
contained in the motor vehicle database of the state           new requirement. It would seem that DRIVERS
                                                               needed to comply.



Maintain a state motor vehicle database that contains at a
                                                                                                                        KY 5-year purge would seem to be a problem on this
minimum:
                                                               Yes                                                      requirement especially for identification issues and
           All data fields printed on DL/ID cards                                                                       exchange of information with other states.
                                                               KY maintains record of traffic convictions for 5 years
           motor vehicle driver’s histories, including motor
           vehicle violations, suspensions and points on
           licenses

Optional                                                       KY opposes this option because government issued
                                                               document is issued to someone without proper
Development and issuance of a certificate of driving – not
                                                               identification credentials.
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?
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:      No Impact. Louisiana has all data elements/features
                                                            as listed #1 through #9
    145. Full Legal Name
    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    Louisiana is in process of re-engineering and this will
expiration of DL/ID card (or issuance for no more than 1    be accomplished; therefore, no impact. (NGMV)
year)

Amending card design to show/indicate that it is a          No real impact since this can be addressed with re-
temporary document with a “different than usual”            engineering process already started and/or new
expiration date                                             camera contract 2007.

Verification at Source:                                     1- SSOLV- currently in our processess                     Asstumptions: Should be one collection place to
                                                                                                                      dessiminate to all jurisdictions to ensure uniformity.
Enabling your system to electronically verify               2.-SAVE – (Immigration document verification) –
        REAL ID ACT REQUIREMENT                                                   IMPACT                             ASSUMPTIONS
documentation with:                                           monetary due to a change order in current RFP for
                                                              NGMV. Time it would add to customer wait if live.
 1. SSOLV
                                                              3. DEERS (DOD) –Military document verification) –
 2. SAVE
                                                              monetary due to change order in durrent RFP for
 3. DEERS (DOD)                                               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.
 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     THIS IS PART OF OUR NGMV (RE-
of identity source documents so that images can be retained   ENGINEERING) PROGRAM.
in electronic storage in a transferable format

Retain paper copies of source documents for a minimum of      Addressed in our NGMV project (will be imaged)
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or        We do currently.
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a       La. Has a photo retrieve system which is utilized in
renewing applicant’s information                              identification at renewal period, duplicates, etc.

In the event that a social security account number is         We do currently
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     MCSIA, effective 09/30/2005
another state
         REAL ID ACT REQUIREMENT                                                   IMPACT                            ASSUMPTIONS
Ensure physical security of locations where DL/ID cards        We do currently.
are produced

Subject all person’s authorized to manufacture or produce      We do currently.
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             We do currently
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Louisiana issues for 4 years and 2 years. NGMV will
temporary to a period not exceeding 8 years                    enable variations to dates less than 4 years.

Alternative document design if it does not meet federal        We believe that La. Will meet standards
standard

Legal Presence Requirement                                     We do currently.

Provide electronic access to all other states to information   MCSIA
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     MCSIA and NGMV. Louisiana’s re-engineering
minimum:                                                       program is going to customer centrix whereby all
                                                               information on an individual in readily available.
           All data fields printed on DL/ID cards
         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:
    154. Full Legal Name                                    Moderate                                            Middle name will have to be spelled out
    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,   No impact                                           regulatory requirements
         counterfeiting or duplication
    162. Common Machine Readable Technology:
                                                            No impact



Introduce temporary DL/ID cards and tying end of stay to    Moderate
expiration of DL/ID card (or issuance for no more than 1
                                                            Will necessitate statute, procedural, system, and
year)
                                                            contractual changes

Amending card design to show/indicate that it is a          Moderate
temporary document with a “different than usual”
                                                            Will necessitate statute, procedural, system, and
expiration date
                                                            contractual changes
        REAL ID ACT REQUIREMENT                                                  IMPACT                                              ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                             No impact                                               Existing system will satisfy regulatory requirements
 1. SSOLV
                                                             Major
 2. SAVE
                                                             Major
 3. DEERS (DOD)
                                                             Major, unless e-mail is used
 4. Other jurisdiction (DL/ID card)
                                                             Major
 5. Birth certificate
                                                             Major
 6. Other…i.e. third party vendors

Developing access capability to SAVE system                  Major

Introduce equipment into system to capture digital images    Major
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     No impact
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or       No impact
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      Minimum procedural changes, unless the same checks
renewing applicant’s information                             must be done as for an initial applicant, then major.

In the event that a social security account number is        No impact
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    No impact                                               CDLIS and PDPS will satisfy regulatory requirements
another state
        REAL ID ACT REQUIREMENT                                                    IMPACT                                              ASSUMPTIONS
Ensure physical security of locations where DL/ID cards        Impact indeterminable without further                   Private card manufacturer responsibility
are produced                                                   information/review



Subject all person’s authorized to manufacture or produce      Impact indeterminable without further                   Private card manufacturer responsibility
DL/ID cards to appropriate security clearance requirements     information/review

Establish fraudulent document recognition training             No impact
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           No impact
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        Contractual, statutory, system and procedural changes
standard

Legal Presence Requirement                                     Will necessitate statutory, procedural, and system
                                                               changes.
                                                               Moderate/Major

Provide electronic access to all other states to information   Major
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     No impact
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       Moderate                                                A non photo paper license
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
         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.   What is the DHS anticipated rule making plan, direction and process?
    2.   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?
    3.   What is the likely timeline for overall implementation of the requirements of the act.
    4.   How will compliance be determined or achieved regarding the document verification requirements in the absence of such a verification infrastructure?
    5.   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                                               ASSUMPTIONS
Full Legal Name into Driver Licensing System (DLS)       Modify DLS application and databases.                   Assumes MVA will maintain a single demographic
                                                                                                                 database for all business applications. This will
(In Record, on Document)                                 Modify MVA demographic databases.
                                                                                                                 necessitate applying the same identity standards to all
                                                         Modify all MVA business applications utilizing the      business applications and will require MD legislative
                                                         MVA demographic database.                               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       1.   Certain card features/graphics may need to be
                                                                  accommodate.                                            removed in order to physically fit the full legal
    163. Full Legal Name
                                                                                                                          name on the cards.
                                                             2.   Date of Birth – In compliance
    164. Person’s Date of Birth
                                                                                                                     2.   None
                                                             3.   Gender – In compliance
    165. Person’s Gender
                                                                                                                     3.   None
                                                             4.   Card Number – In compliance
    166. Person’s DL or ID Card Number
                                                                                                                     4.   None
                                                             5.   Digital Photo – In compliance
    167. Digital Photograph of Person (and retention)
                                                                                                                     5.   None
                                                             6.   Residence Address – In compliance
    168. Person’s Address of Principle Residence
                                                                                                                     6.   Assumes only a single address will be printed on
                                                             7.   Signature – In compliance
    169. Person’s Signature                                                                                               cards.
                                                             8.   Security features – In compliance
    170. Physical Security Features to prevent                                                                            CDL currently uses mailing address on card. MD
         tampering, counterfeiting or duplication            9.   Machine Readable – In compliance                        Legislative changes are required to place
                                                                                                                          residence address on CDL card.
    171. Common Machine Readable Technology:
                                                                                                                     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   Temporary Card design in compliance.                      MD legislation will be required in order to tie the
to expiration of DL/ID card (or issuance for no more                                                              expiration date to the end date of permitted stay.
                                                        Modify DLS to allow user definable expiration date on
than 1 year)
                                                        current temporary cards.

Amending card design to show/indicate that it is a      In compliance                                             Assumes AAMVA standard remains.
temporary document with a “different than usual”
expiration date

Verification at Source:                                     1.   SSOLV – In compliance                                1.   SSOLV – None
Enabling your system to electronically verify                    SSN Non-eligibility Letter - Modify DLS                   SSN Non-eligibility Letter - Assumes AAMVA
documentation with:                                              eligibility check to interface with AAMVA                 interface to SSA exists and that SSA will provide
                                                                 interface to SSA                                          verification
 1. SSOLV
                                                            2.   SAVE - Modify DLS eligibility check to               2.   SAVE – MVA currently has an MOU with DHS
  2. SAVE
                                                                 interface with SAVE.                                      to utilize SAVE in a stand-alone configuration.
 3. DEERS (DOD)
                                                            3.   DEERS - Modify DLS eligibility check to              3.   DEERS - Assumes AAMVA interface to DOD
 4. Other jurisdiction (DL/ID card)                              interface with AAMVA interface to DEERS.                  exists and that DOD will provide military ID
                                                                                                                           verification
 5. Birth certificate                                       4.   Other Jurisdictions (all data
                                                                 verification/exchange) - Modify DLS                  4.   Other Jurisdictions - Assumes AAMVA interface
 6. Other…i.e. third party vendors                               eligibility check to interface with AAMVA                 to other jurisdictions exists and that jurisdictions
                                                                 interface to other jurisdictions.                         will provide data and verifications.
                                                            5.   Birth Certificate: Modify DLS eligibility            5.   Birth Certificate: Assumes AAMVA interface to
                                                                 check to interface with AAMVA interface to                NAPHSIS / State Vital Record Agencies exists
                                                                 NAPHSIS / State Vital Record Agencies.                    and that NAPHSIS will provide verifications.
                                                            6.   Third Party Providers (address verification) -            In reality there will likely be varying combinations
                                                                 Modify DLS eligibility check to interface                 of electronic and manual validation occurring until
                                                                 with third party provider(s).                             fully automated systems are in place in all states.
                                                                                                                           There will be significant staffing / cost impacts
                                                            7.   General                                                   during the earlier years when there is a high
                                                                 Manual Verification – If any or all of the                percentage of manual verification occurring.
       REAL ID ACT REQUIREMENT                                                    IMPACT                                                     ASSUMPTIONS
                                                                      interfaces cannot be established electronically,
                                                                      significant increases in staffing, facilities and
                                                                                                                              6.   Third Party Providers (address verification) –
                                                                      customer wait time will result.                              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           Modify DLS to require capture of additional                  May require legislation to enable transmission of data and
images of identity source documents so that images can       documents.                                                   documents to other agencies depending on regulatory
be retained in electronic storage in a transferable format                                                                requirements.
                                                             Create application to transmit document images to
                                                             others.

Retain paper copies of source documents for a minimum        Increase long-term electronic storage capacity.              None
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       In compliance                                                None
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      Modify DLS to include indicators signifying that             Assumes renewal transactions will not require revalidation
renewing applicant’s information                             certain data and / or documents have been verified and       of all source documents / data.
                                                             validated.
                                                                                                                          Assumes a voluminous audit trail will not be required as
                                                                                                                          part of a validation indicator.

In the event that a social security account number is        Modify DLS eligibility check to interface with               Assumes AAMVA interface to other jurisdictions exists
already registered to or associated with another person to   AAMVA interface to other jurisdictions.                      and that jurisdictions will provide data and verifications.
which any state has issued a DL/ID card, the state shall
                                                             AAMVA to develop discrepancy resolution process.             Assumes AAMVA develops standardized resolution
       REAL ID ACT REQUIREMENT                                                  IMPACT                                               ASSUMPTIONS
resolve the discrepancy and take appropriate action                                                                 processes for discrepancies.

Check other states if a person already was issued a DL in   Modify DLS eligibility check to interface with          Assumes AAMVA interface to other jurisdictions exists
another state                                               AAMVA interface to other jurisdictions.                 and that jurisdictions will provide data and verifications.
                                                            AAMVA to develop process for requesting termination     Assumes AAMVA develops processes for requesting
                                                            of DL/ID in original jurisdiction upon issuance to      termination of DL/ID in original jurisdiction upon issuance
                                                            DL/ID in the new jurisdiction.                          to DL/ID in the new jurisdiction



Ensure physical security of locations where DL/ID cards     In compliance.                                          Assumes current procedures and physical / electronic
are produced                                                                                                        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           Possible significant cost and time impacts depending    Assumes standards for security clearances are established.
produce DL/ID cards to appropriate security clearance       on clearance standards established. Could cause
                                                                                                                    May require MD legislation authorizing MVA to conduct
requirements                                                staffing shortage if clearances are not completed
                                                                                                                    certain types of security checks.
                                                            quickly and temporary authority is not granted.

Establish fraudulent document recognition training          In compliance with current AAMVA level 1 & 2.           Assumes current AAMVA standard remains.
programs for appropriate employees engaged in the
                                                                                                                    In the likelihood that all personnel will require level 2
issuance of DL/ID cards
                                                                                                                    training an additional cost and staffing impact will occur
                                                                                                                    for initial and ongoing training.

Limit period of validity of DL/ID cards that are not        In compliance                                           MD Legislation required limiting the validity period of
temporary to a period not exceeding 8 years                                                                         military license holders who are stationed outside of
                                                                                                                    Maryland.

Alternative document design if it does not meet federal     None                                                    Assumes Maryland will fully comply with Real ID Act
standard                                                                                                            and will not issue a driving certificate.

Legal Presence Requirement                                  Transactions for temporary DL and ID cards should       State legislation required if this requirement is pursued.
                                                            decrease.
                                                            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             Develop and implement a data exchange server and        Significant data traffic demands will necessitate a separate
information contained in the motor vehicle database of       database separate from the production environment.      environment to minimize/eliminate impacts on the
the state                                                                                                            production DLS environment.
                                                                                                                     None
Maintain a state motor vehicle database that contains at a   Any change in the amount of data captured and stored
minimum:                                                     will require modifications to the DLS application and
                                                             the DLS databases.
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including
         motor vehicle violations, suspensions and
         points on licenses

Optional                                                     Create new product flow /eligibility requirements in    State legislation required if this option is pursued.
                                                             DLS to produce certificate.
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who
cannot prove lawful presence.

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                              ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System       We will need a statue change and software changes
(in Record, on Document)                                     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
    172. Full Legal Name
                                                             our license documents. We are in compliance with all
    173. Person’s Date of Birth                              of the other required fields.
    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     We do not have statutory authority to issue this type
expiration of DL/ID card (or issuance for no more than 1     of temporary license. Statutory change required.
year)

Amending card design to show/indicate that it is a           As above we will need the legal authority to create
temporary document with a “different than usual”             and issue this type of license document.
expiration date
        REAL ID ACT REQUIREMENT                                                  IMPACT                                             ASSUMPTIONS



Verification at Source:                                       We meet the requirements of #1 and #6. We are in      We are assuming that there will be a grant process to
                                                              the process of issuing a contract for Document        assist us in funding the verification systems that are
Enabling your system to electronically verify
                                                              Authentication Equipment to be installed in license   required to be in compliance with #2,3,4,and 5,
documentation with:
                                                              issuing locations.
 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                   We will need to develop our training process and      We assume that there will be grant money available to
                                                              sign an MOU with SAVE. This will also require         fund this requirement.
                                                              software changes to our system.

Introduce equipment into system to capture digital images     We are exploring the cost of implementing document    We assume that there will be grant money available to
of identity source documents so that images can be retained   digital imaging equipment to satisfy this             fund this requirement.
in electronic storage in a transferable format                requirement.
                                                              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      We are in compliance with the paper documents and
7 years or images of source documents presented for a         see the above response on the image requirement.
minimum of 10 years

Subject each person applying for a driver’s license or        We are in compliance.
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a       Depending on definitions used for “verifying” and     We assume that there will be large grants available to
                                                              “renew”, impact could be monumental if required to    fund the systems and networks required to perform these
         REAL ID ACT REQUIREMENT                                                     IMPACT                                         ASSUMPTIONS
renewing applicant’s information                                 “call back” entire license population.             functions.

In the event that a social security account number is already    We perform this resolution today
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        Depending on process defined, system and process   We assume that a national network and system will be in
another state                                                    implications could be major.                       place to do this electronicly.and grants will be available
                                                                                                                    to fund our requirements.

Ensure physical security of locations where DL/ID cards          We are in compliance
are produced

Subject all person’s authorized to manufacture or produce        We are in compliance
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training               We are introducing Document Authentication         We assume there will be grant money available to assist
programs for appropriate employees engaged in the                equipment and are exploring training programs.     us.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not             We are in compliance.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal          We are in compliance.                              We assume if the license card design is changed that
standard                                                                                                            grant money will be available to fund the changes and
                                                                                                                    implementation of a new license document.

Legal Presence Requirement                                       We are not in compliance. We will need a statue
                                                                 change.

Provide electronic access to all other states to information     We are in compliance.
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a       We are in compliance.
minimum:
        REAL ID ACT REQUIREMENT                                                  IMPACT                                ASSUMPTIONS
           All data fields printed on DL/ID cards
        motor vehicle driver’s histories, including motor
        vehicle violations, suspensions and points on
        licenses

Optional                                                     Our Legislature is not in favour of this option at this
                                                             time.
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
prove lawful presence.
                                                                       MICHIGAN
                                                     Jurisdiction Impact Analysis Real ID Act

            REAL ID ACT REQUIREMENT                                       IMPACT                                          ASSUMPTIONS

Introduce Full Legal Name into Driver Licensing       Requires programming to increase size of field.   One field or multiple fields to separate first, middle,
System (in Record, on Document)                       Need state law change to provide authority to     last names?
                                                      require full legal name.
Have following data elements/features on the          Card re-design to incorporate common machine      2D barcode as the common machine readable
document:                                             readable technology and physical security         technology?
                                                      features.                                         Will mag strip also be required?
Full Legal Name
                                                      Need state law change to specify “full legal      Need to know what data to encode.
Person’s Date of Birth                                name”.
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    Card re-design                                    Will there be a common design element to
temporary document with a “different than usual”                                                        distinguish all state’s temporary cards, such as
expiration date                                                                                         color of card?
Verification at source:                               Programming to interface with SSOLV, SAVE,        Will there be a national repository for birth records?
Enabling your system to electronically verify         DEERS.                                            Will PDPS be expanded to all drivers?
                                                      MOUs for exchange of data.
Documentation with:                                   Need state law change to authorize verification   What fees are charged by each verification
1.SSOLVE                                              for driver’s license and ID cards                 system?
2.SAVE
3. DEERS (DOD)                                        Need law change for ID law to parallel driver’s
4. Other jurisdiction (DL?ID card)                    license.
5. birth certificate
6. Other…i.e. third party vendors
            REAL ID ACT REQUIREMENT                                           IMPACT                                          ASSUMPTIONS

Developing access capability to SAVE system               Requires programming                                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?
Introduce equipment into system to capture digital        Requires purchase of scanning equipment for         All states will use the same common transferable
images of identity source documents so that images        field offices. Needs state law change to capture    format. Need to know what this format will be.
can be retained in electronic storage in a transferable   and retain digital images of identity source
format                                                    documents.
Retain paper copies of source documents for a             Increased storage costs                             Why are there different storage timeframes
minimum of 7 years or images of source documents                                                              between paper and electronic methods?
presented for a minimum of 10 years
Introduce temporary DL/ID cards and tying end of stay     Requires programming to create field for
to expiration of DL/ID card (or issuance for no more      temporary expiration date, state law change to
than 1 year)                                              authorize temporary expiration date.
Subject each person applying for a driver’s license or    Increased storage costs. May require
identification card to mandatory facial capture           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.
Establish an effective procedure to confirm or verify a   May require some type of authentication of          Need explanation of an effective proceedure
renewing applicant’s information                          renewing applicant. State law change required to
                                                          verify applicant’s information when renewing
                                                          license or card.
In the event that a social security account number is     May require a two-step process fro SSN              Need clarification on how state resolves the
already registered to or assicaited with another          verification involving both SSA and other states.   discrepancy.
person to which any state has issued a DL/ID card,        State law change to require SSN on Personal ID
the state shall resolve the discrepancy and take          cards
appropriate action.
Check other states if a person already was issued a       May require programming for an up-front check of    Expansion of PDPS. Also, will ID cards be covered
DL in another state                                       other states.                                       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.
Ensure physical security of locations where DL/ID         May need additional language in vendor contract     Will there be minimum or specific requirements for
cards are produced                                                                                            “physical security”?
            REAL ID ACT REQUIREMENT                                            IMPACT                                        ASSUMPTIONS

Subject all persons authorized to manufacture or          May need additional language in vendor contract   Need criteria for discharge or non-hire decisions.
produce DL/ID cards to appropriate security clearance                                                       Need specific definition of “appropriate security
requirements                                                                                                clearance requirements.”
Establish fraudulent document recognition training        Michigan complies.
programs for appropriate employees engaged in the
issuance of DL/ID cards.
Alternative document design if it does not meet           Card re-design                                    Will there be specific re-design standards?
federal standard
Legal presence requirement                                MI needs state law change to require legal
                                                          presence
Provide electronic access to all other states to          State law change needed to require access to      Will other states need access to images and
information contained in the motor vehicle database of    Personal ID card data and highly restricted       source documents? Need specific list of data
the state                                                 personal information.                             elements required.
Maintain a state motor vehicle database that              Michigan complies.
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.
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
      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.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               to track incomplete transactions. May
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               require state law change to authorize
       REAL ID ACT REQUIREMENT                                   IMPACT                                ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size       One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to          first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common          2D barcode as the common machine
document:                                    machine readable technology and               readable technology?
Full Legal Name                              physical security features.                   Will mag strip also be required?
                                             Need state law change to specify “full        Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                             Will there be a common design element to
it is a temporary document with a “different                                               distinguish all states’ temporary cards,
than usual” expiration date                                                                such as color of card?
                                               mandatory facial image capture at time of
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               application.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               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                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
or verify a renewing applicant’s information   of renewing applicant. State law change    procedure.
       REAL ID ACT REQUIREMENT                                   IMPACT                                 ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size        One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to           first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common           2D barcode as the common machine
document:                                    machine readable technology and                readable technology?
Full Legal Name                              physical security features.                    Will mag strip also be required?
                                             Need state law change to specify “full         Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                              Will there be a common design element to
it is a temporary document with a “different                                                distinguish all states’ temporary cards,
than usual” expiration date                                                                 such as color of card?
                                               required to verify applicant’s information
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               when renewing a license or card.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               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                                   IMPACT                                ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size       One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to          first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common          2D barcode as the common machine
document:                                    machine readable technology and               readable technology?
Full Legal Name                              physical security features.                   Will mag strip also be required?
                                             Need state law change to specify “full        Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                             Will there be a common design element to
it is a temporary document with a “different                                               distinguish all states’ temporary cards,
than usual” expiration date                                                                such as color of card?
number is already registered to or             verification involving both SSA and other   resolves the discrepancy.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
associated with another person to which any    states.
       REAL ID ACT REQUIREMENT                                     IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver            Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)        of field. Need state law change to         first, middle, last names?
                                                 provide authority to require full legal
                                                 name.
Have following data elements/features on the Card re-design to incorporate common           2D barcode as the common machine
document:                                    machine readable technology and                readable technology?
Full Legal Name                              physical security features.                    Will mag strip also be required?
                                             Need state law change to specify “full         Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying        Requires programming to create field for
end of stay to expiration of DL/ID card (or      temporary expiration date, state law
issuance for no more than 1 year)                change to authorize temporary expiration
                                                 date.
Amending card design to show/indicate that       Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                                distinguish all states’ temporary cards,
than usual” expiration date                                                                 such as color of card?
state has issued a DL/ID card, the state shall   State law change to require SSN on
       REAL ID ACT REQUIREMENT                                IMPACT                                  ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that   Card re-design.                              Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
resolve the discrepancy and take appropriate Personal ID Cards.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
action                                         State law change may be needed to
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               eliminate current waiver of requirement
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               for those with no SSN.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               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                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
issued a DL in another state                   check of other states.                     covered here? No information currently
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          shared with other states on IDs.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          Need clarification as to what “confirms the
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          person is terminating or has terminated”
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          the out of state license means.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               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                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
DL/ID cards are produced                       contract.                                  requirements for “physical security”?
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               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                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
manufacture or produce DL/ID cards to          contract.                                  decision.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
appropriate security clearance requirements                                               Need specific definition of “appropriate
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          security clearance requirements.”
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Establish fraudulent document recognition      Michigan complies.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
training programs for appropriate employees
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
engaged in the issuance of DL/ID cards
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Limit period of validity of DL/ID cards that are Michigan complies. Current licenses
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
not temporary to a period not exceeding 8      valid for four-year term.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
years
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Alternative document design if it does not     Card re-design.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
meet federal standard                                                                     Will there be specific design standards?
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Legal Presence Requirement                     Michigan needs state law change to
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                               require legal presence.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
       REAL ID ACT REQUIREMENT                                    IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver           Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)       of field. Need state law change to         first, middle, last names?
                                                provide authority to require full legal
                                                name.
Have following data elements/features on the Card re-design to incorporate common          2D barcode as the common machine
document:                                    machine readable technology and               readable technology?
Full Legal Name                              physical security features.                   Will mag strip also be required?
                                             Need state law change to specify “full        Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying       Requires programming to create field for
end of stay to expiration of DL/ID card (or     temporary expiration date, state law
issuance for no more than 1 year)               change to authorize temporary expiration
                                                date.
Amending card design to show/indicate that      Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                               distinguish all states’ temporary cards,
than usual” expiration date                                                                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                                    IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver           Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)       of field. Need state law change to         first, middle, last names?
                                                provide authority to require full legal
                                                name.
Have following data elements/features on the Card re-design to incorporate common          2D barcode as the common machine
document:                                    machine readable technology and               readable technology?
Full Legal Name                              physical security features.                   Will mag strip also be required?
                                             Need state law change to specify “full        Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying       Requires programming to create field for
end of stay to expiration of DL/ID card (or     temporary expiration date, state law
issuance for no more than 1 year)               change to authorize temporary expiration
                                                date.
Amending card design to show/indicate that      Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                               distinguish all states’ temporary cards,
than usual” expiration date                                                                such as color of card?
to information contained in the motor vehicle   access to Personal ID Card data and        and source documents?
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
database of the state                          highly restricted personal information.    Need specific list of data elements
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
                                                                                          required.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Maintain a state motor vehicle database that   Michigan complies.
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
contains at a minimum:
       REAL ID ACT REQUIREMENT                                    IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver           Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)       of field. Need state law change to         first, middle, last names?
                                                provide authority to require full legal
                                                name.
Have following data elements/features on the Card re-design to incorporate common          2D barcode as the common machine
document:                                    machine readable technology and               readable technology?
Full Legal Name                              physical security features.                   Will mag strip also be required?
                                             Need state law change to specify “full        Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying       Requires programming to create field for
end of stay to expiration of DL/ID card (or     temporary expiration date, state law
issuance for no more than 1 year)               change to authorize temporary expiration
                                                date.
Amending card design to show/indicate that      Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                               distinguish all states’ temporary cards,
than usual” expiration date                                                                such as color of card?
       All data fields printed on DL/ID cards
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
      motor vehicle driver’s histories,
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
including motor vehicle violations,
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
suspensions and points on licenses
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Optional
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
Development and issuance of a certificate of
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
driving – not for federal identification
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
purposes – for those who cannot prove
       REAL ID ACT REQUIREMENT                                   IMPACT                               ASSUMPTIONS

Introduce Full Legal Name into Driver          Requires programming to increase size      One field or multiple fields to separate
Licensing System (in Record, on Document)      of field. Need state law change to         first, middle, last names?
                                               provide authority to require full legal
                                               name.
Have following data elements/features on the Card re-design to incorporate common         2D barcode as the common machine
document:                                    machine readable technology and              readable technology?
Full Legal Name                              physical security features.                  Will mag strip also be required?
                                             Need state law change to specify “full       Need to know what data to encode.
Person’s Date of Birth                       legal name”.
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
Introduce temporary DL/ID cards and tying      Requires programming to create field for
end of stay to expiration of DL/ID card (or    temporary expiration date, state law
issuance for no more than 1 year)              change to authorize temporary expiration
                                               date.
Amending card design to show/indicate that     Card re-design.                            Will there be a common design element to
it is a temporary document with a “different                                              distinguish all states’ temporary cards,
than usual” expiration date                                                               such as color of card?
lawful presence.
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 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      None.                      Minnesota believes it currently meets this requirement.
(in Record, on Document)

Have following data elements/features on the document:      None.                      Minnesota believes it currently meets this requirement.
    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:

Introduce temporary DL/ID cards and tying end of stay to    None.                      Minnesota believes it currently meets this requirement.
expiration of DL/ID card (or issuance for no more than 1                               For persons who are authorized to temporarily reside in
year)                                                                                  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          None.                      See above.
temporary document with a “different than usual”
        REAL ID ACT REQUIREMENT                                                     IMPACT                                             ASSUMPTIONS
expiration date

Verification at Source:                                             1.   MN is in the preliminary planning stages of   Item 4. Minnesota assumes that verification of documents
                                                                         implementing SSOLV.                           with other states would be a national project coordinated
Enabling your system to electronically verify
                                                                                                                       by AAMVA.
documentation with:                                                 2.   SAVE has not been explored yet.
                                                                                                                       Item 6. It is not known what third party vendors of source
 1. SSOLV                                                           3.   MN is not familiar with DEERS (DOD).
                                                                                                                       documents exist.
 2. SAVE                                                            4.   Would require additional resources to
                                                                         implement.
 3. DEERS (DOD)
                                                                    5.   MN is exploring in-state vital records
 4. Other jurisdiction (DL/ID card)
                                                                         verification processes and is interested in
 5. Birth certificate                                                    EVVERS.
 6. Other…i.e. third party vendors

Developing access capability to SAVE system                     SAVE has not been explored yet. Would require          MN assumes there are costs to set up and use the system.
                                                                additional resources to implement.

Introduce equipment into system to capture digital images       May require enhancement of existing imaging            MN has a digital imaging system that is currently under
of identity source documents so that images can be retained     process.                                               review for process improvements.
in electronic storage in a transferable format

Retain paper copies of source documents for a minimum of        Will require amending legislation or administrative
7 years or images of source documents presented for a           rules related to document retention. There may be
minimum of 10 years                                             some storage or resource issues.

Subject each person applying for a driver’s license or          None.                                                  MN currently requires facial image capture, but accepts
identification card to mandatory facial image capture                                                                  applications for variances on a case by case basis
                                                                                                                       (primarily from persons with religious objections).

Establish an effective procedure to confirm or verify a         More detail is required to determine impact—           MN verifies the applicant’s image and residence address
renewing applicant’s information                                specifically which information.                        by mailing the card and prohibiting forwarding of mail.

In the event that a social security account number is already   This has not been implemented yet, but should not be   MN has a grant from FMCSA to assist in the verification
registered to or associated with another person to which        insurmountable.                                        process and will establish a procedure once our batch
any state has issued a DL/ID card, the state shall resolve                                                             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      Requires DRIVERS or some other mechanism for          MN assumes that other jurisdictions face the same
another state                                                  automated confirmation with other jurisdictions,      problem and a solution will be developed with
                                                               which does not currently exist.                       AAMVA’s assistance.



Ensure physical security of locations where DL/ID cards        None, if this refers to the card production factory   This is currently required of our contracted card vendor.
are produced                                                   only.

Subject all person’s authorized to manufacture or produce      None.                                                 This is currently required of our contracted card vendor
DL/ID cards to appropriate security clearance requirements                                                           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             Minimal                                               This is already in place, although the programs could be
programs for appropriate employees engaged in the                                                                    expanded.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           None.                                                 MN has a four-year renewal cycle.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        None.                                                 MN believes it meets the federal standard.
standard

Legal Presence Requirement                                     None.                                                 MN believes it meets the legal presence requirement.

Provide electronic access to all other states to information   Development required.                                 MN assumes that standards will be developed for
contained in the motor vehicle database of the state                                                                 information sharing among jurisdictions.

Maintain a state motor vehicle database that contains at a     None, except that MN does not use a point system.     MN will need to migrate its current technology system to
minimum:                                                                                                             a platform that will allow the data to be exchanged with
                                                                                                                     other states (currently using a mainframe system which
         All data fields printed on DL/ID cards
                                                                                                                     was created in the 1980s).
         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                                            ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      None
(in Record, on Document)

Have following data elements/features on the document:      None
    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    Introduce into law for legislative action. Currently   The 1 year Non-US citizen license/ID card we currently
expiration of DL/ID card (or issuance for no more than 1    have 1 year license for Non-US citizen license.        have in place will not meet the standards outlined.
year)

Amending card design to show/indicate that it is a          None
temporary document with a “different than usual”
expiration date

Verification at Source:                                     Software/Program changes                               Would have allowed access
Enabling your system to electronically verify
documentation with:
        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                            Will be made available to all states

Introduce equipment into system to capture digital images    Procurement process. Equipment & system/program
of identity source documents so that images can be           changes.
retained in electronic storage in a transferable format

Retain paper copies of source documents for a minimum of     None
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or       None
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      None
renewing applicant’s information

In the event that a social security account number is        None
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    System/program changes                            Assuming there was a national system.
another state

Ensure physical security of locations where DL/ID cards      None
are produced
        REAL ID ACT REQUIREMENT                                                  IMPACT                          ASSUMPTIONS


Subject all person’s authorized to manufacture or produce      None
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             Cost                              AAMVA will provide the training at little or no cost to
programs for appropriate employees engaged in the                                                the states.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           None
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        None
standard

Legal Presence Requirement                                     None

Provide electronic access to all other states to information   Currently use CDLIS information
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     None
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       None                              Mississippi will not provide this document.
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.
                                                                     MISSOURI

                                                     Jurisdiction Impact Analysis Real ID Act
                                                                     Missouri

        REAL ID ACT REQUIREMENT                                                  IMPACT                            ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      High – Requires system re-design    Committee needs to define “full legal name”
(in Record, on Document)

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.       Possible expansion based on requirements
    205. Person’s Signature                                     7.   No impact                      7.   .
    206. Physical Security Features to prevent tampering,       8.   High                           8.   New equipment, consumables and contract re-
         counterfeiting or duplication                                                                   bid??
                                                                9.   Low to moderate
    207. Common Machine Readable Technology:                                                        9.   (Low) Use PDF417 today (Moderate) If required
                                                                                                         to store digital signature and photo and zone
                                                                                                         change

Introduce temporary DL/ID cards and tying end of stay to    No to low impact                    7/1/05 implemented tie end of stay to expiration– (low) if
expiration of DL/ID card (or issuance for no more than 1                                        required to add “Temporary” to header
year)

Amending card design to show/indicate that it is a          Low impact                          (Low) if header change only
temporary document with a “different than usual”
expiration date
         REAL ID ACT REQUIREMENT                                                     IMPACT                                       ASSUMPTIONS
Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                                    1.   No impact                                    1.   Implemented
 1. SSOLV
                                                                    2.   No impact – implemented 7/1/05               2.   Implemented Web version – would prefer
 2. SAVE                                                                                                                   AAMVA interface with lower access fees
                                                                    3.   High
 3. DEERS (DOD)                                                                                                       3.   to 5 – (High) When will systems be available,
                                                                    4.   High
                                                                                                                           when will specs. be available and what are
 4. Other jurisdiction (DL/ID card)
                                                                    5.   High                                              associated cost??
 5. Birth certificate
                                                                                                                     6. What system will be available to verify US
 6. Other…i.e. third party vendors                                                                                passports?



Developing access capability to SAVE system                     High                                              If programming required to interface to AAMVA

Introduce equipment into system to capture digital images       High                                              Scanners in 184 offices
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        High                                              Data and paper storage considerations
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or          Moderate – based on definition of “facial image   If Facial image = Facial recognition will need legislation
identification card to mandatory facial image capture           capture”

Establish an effective procedure to confirm or verify a         TBD – Need to define
renewing applicant’s information

In the event that a social security account number is already   Define action – Low to High impact                Low – Today’s version we call another state
registered to or associated with another person to which any
                                                                                                                  High – Develop systematic approach
state has issued a DL/ID card, the state shall resolve the
discrepancy and take appropriate action
         REAL ID ACT REQUIREMENT                                                 IMPACT                         ASSUMPTIONS
Check other states if a person already was issued a DL in      High – Need to define           Electronic verification ????
another state

Ensure physical security of locations where DL/ID cards        High – Depends on requirement   Could be high if required to install cameras, special safes,
are produced                                                                                   etc.

Subject all person’s authorized to manufacture or produce      Low to moderate impact          BRC
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             Low to moderate impact          Would need to roll out to 184 offices, FTE time and
programs for appropriate employees engaged in the                                              travel.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Low                             Legislative change for non-expiring ID for 70 years and
temporary to a period not exceeding 8 years                                                    older. Already in place for other DL/ID types

Alternative document design if it does not meet federal        Assume High impact              Need requirements. We will need a complete re-design to
standard                                                                                       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   Low to High                     Need defined. (low) data exchange only as we do today
contained in the motor vehicle database of the state                                           (high) if we need to pass photo and signature

Maintain a state motor vehicle database that contains at a     No impact                       We do this today unless requirements are changed
minimum:
         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                                                     Assume High impact       Need requirements. We will need a complete re-design,
                                                                                      legislation and possible contract re-bid.
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?



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                                               IMPACT                       ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      $40,000 Will require database changes to
(in Record, on Document)                                    accommodate size

Have following data elements/features on the document:
    1.   Full Legal Name
    2.   Person’s Date of Birth                             Items 2-9 will have no impact
    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:
                                                            Montana already has the capability to issue a
Introduce temporary DL/ID cards and tying end of stay to    card for 1 to 8 year cycles
expiration of DL/ID card (or issuance for no more than 1    $!5,000 for system development
year)
                                                            $40,000
Amending card design to show/indicate that it is a
temporary document with a “different than usual”            This requirement will need a standard for all
expiration date                                             the jurisdictions to follow

Verification at Source:
Enabling your system to electronically verify
        REAL ID ACT REQUIREMENT                                                        IMPACT                  ASSUMPTIONS
documentation with:                                             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
 4. Other jurisdiction (DL/ID card)
 5. Birth certificate                                           5.   Birth Certificate - Will include in the
                                                                     card cost
 6. Other…i.e. third party vendors

Developing access capability to SAVE system                  $40,000
                                                             $1,300,000--initial cost plus maintenance and
Introduce equipment into system to capture digital images    equipment replacement
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     Included in $1,300,000 cost.
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or       No Impact current process
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      $20,000 for development and staff training
renewing applicant’s information

In the event that a social security account number is        $40,000 ---2 additional staff
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
                                                             $100,000-- 5 additional staff is process is
Check other states if a person already was issued a DL in    done manually. If electronic $500,000
another state
                                                             Note** Need DRIVerS

Ensure physical security of locations where DL/ID cards      No impact--current        process
        REAL ID ACT REQUIREMENT                                                   IMPACT     ASSUMPTIONS
are produced

Subject all person’s authorized to manufacture or produce      $200.00
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             $40,000
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        $30,000
standard

Legal Presence Requirement

Provide electronic access to all other states to information   $500,000
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     No Impact --current process
minimum:
           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?
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                              ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     Will require legislation – programming to AS400,
(in Record, on Document)                                   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                      Nebraska does not currently have a biometric –
                                                           would require programming and legislation - cost
    18. Common Machine Readable Technology:
                                                           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   Will require legislation – development of 35 new
expiration of DL/ID card (or issuance for no more than 1   card types
year)
                                                           Increase in workload unknown – cannot do with
                                                           existing staff
                                                           Cost unknown
         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

Verification at Source:                                       Comply with SSOLV
Enabling your system to electronically verify                 Nebraska accessed SAVE in a pilot project for 6
documentation with:                                           months. The system is not well developed, it
                                                              requires a great deal of staff time to follow up on
 1. SSOLV
                                                              additional contact with UCSIS and applicant –
 2. SAVE                                                      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
 5. Birth certificate
                                                              No link to Nebraska or national information
 6. Other…i.e. third party vendors                            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     Nebraska does not retain copies of source documents
of identity source documents so that images can be retained   – Will require building an imaging system and
in electronic storage in a transferable format                upgrading the State’s network infrastructure – impact
                                                              in the millions of dollars

Retain paper copies of source documents for a minimum of      See above – We will not retain paper copies
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or        Will require DMV examiners to have digital camera
identification card to mandatory facial image capture         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
         REAL ID ACT REQUIREMENT                                                    IMPACT                                ASSUMPTIONS
renewing applicant’s information                                uniform throughout the states

In the event that a social security account number is already   Will require staff time – cannot do with existing staff
registered to or associated with another person to which any    - cost unknown
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       No database exists for electronic checking – manual
another state                                                   process would be very time consuming if not
                                                                impossible - cost to develop unknown

Ensure physical security of locations where DL/ID cards         Cannot currently ensure physical security of
are produced                                                    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       Nebraska DMV does background checking on its
DL/ID cards to appropriate security clearance requirements      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              Nebraska DMV has engaged in a fraudulent doc
programs for appropriate employees engaged in the               recognition training program – County treasurers do
issuance of DL/ID cards                                         not have such a program
                                                                Cost unknown



Limit period of validity of DL/ID cards that are not            Nebraska’s card is valid for 5 years
temporary to a period not exceeding 8 years
         REAL ID ACT REQUIREMENT                                                   IMPACT                      ASSUMPTIONS
Alternative document design if it does not meet federal        Will require 35 new card types – cost unknown
standard

Legal Presence Requirement                                     Will require legislation

Provide electronic access to all other states to information   No such database exists - cost unknown
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     Comply
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       Not required under the federal law – not even
                                                               mentioned anywhere in the federal law -
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?

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                                                ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     No Impact
(in Record, on Document)

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 -                6. Current Nevada law with respects to the address on
                                                                                                                      the face of a driver’s license do not conform to H.R. 418
    24. Person’s Address of Principle Residence                •    Statutory change to NRS 483.340
    25. Person’s Signature                                     •    Several application and form changes,

    26. Physical Security Features to prevent tampering,       •    Approximately 250 hours of DMV application
        counterfeiting or duplication                               programming to complete computer change

    27. Common Machine Readable Technology:                    •    Public notices will need to be generated
                                                           7. No impact
                                                           8. Physical security features -                            8. If the established requirements are different or exceed
                                                               •    There will be a substantial impact on the         what is currently in place, an impact will exist to
                                                                    information technology staff to complete          implement the required features. For example, if
                                                                    DMV application programming changes               biometrics is mandated there will be a change to system
                                                                                                                      requirements. The assumption is the Secretary will
                                                               •    It will effect the card design                    require changes.
                                                               •    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.                     9. The assumption is the Secretary will maintain the
                                                                                                                      current AAMVA 2-D bar code standards.
        REAL ID ACT REQUIREMENT                                                 IMPACT                                              ASSUMPTIONS
                                                                •   9. No impact
                                                                •   Additional staff hours to effect policy and
Introduce temporary DL/ID cards and tying end of stay to                                                            Current Nevada law and practices do not conform with
                                                                    procedure changes
expiration of DL/ID card (or issuance for no more than 1                                                            the requirements of H.R. 418 regarding the one-year
year)                                                           •   MVIT programming to automate the                expiration period.
                                                                    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

Amending card design to show/indicate that it is a              •   Impact on the information technology staff to   Any changes from the existing design specifications are
temporary document with a “different than usual”                    complete DMV application programming            billable enhancements by the contractor.
expiration date                                                     changes
                                                                •   Fiscal Impact
                                                                •   Vendor Contract revisions



Verification at Source:                                     1. No Impact                                            2. Required fees for system use.
Enabling your system to electronically verify               2. Minor fiscal impact                                  3. Required fees for system use.
documentation with:
                                                            3. Minor fiscal impact                                  5. In state - $8.00 charge per verification and 2 to 6
 1. SSOLV                                                                                                           week process for manual verification.
                                                            4. No impact
 2. SAVE
                                                            5. Large fiscal impact and unreasonable delays in
 3. DEERS (DOD)                                             processing
 4. Other jurisdiction (DL/ID card)
 5. Birth certificate
 6. Other…i.e. third party vendors

Developing access capability to SAVE system                 No impact

Introduce equipment into system to capture digital images       •   Substantial fiscal impact to acquire hardware   All 21 field offices will need to be equipped with digital
        REAL ID ACT REQUIREMENT                                               IMPACT                                                 ASSUMPTIONS
of identity source documents so that images can be                and contract services                              document scanners and contractor services will be
retained in electronic storage in a transferable format                                                              required.
                                                              •   Impact on information technology staff to
                                                                  program DMV application to retain and
                                                                  transfer scanned imaged



Retain paper copies of source documents for a minimum         •   Large fiscal impact                                Additional scanners and copiers will need to be
of 7 years or images of source documents presented for a                                                             purchased to equip 21 field offices.
minimum of 10 years                                           •   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
                                                              •   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.

Subject each person applying for a driver’s license or     No impact
identification card to mandatory facial image capture
                                                              •   This requirement eliminates current alternate
Establish an effective procedure to confirm or verify a                                                              All required verification processes will not be accessible
                                                                  technologies for the renewal of a driver’s
renewing applicant’s information                                                                                     on-line which removes the alternate technology capacity
                                                                  license or identification card.
                                                                                                                     we currently have in place.
                                                              •   Statutory change
                                                              •   Verification procedures
                                                              •   Additional staff to review and verify
                                                                  documents
                                                              •   Regulation changes
        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        We would be unable to service a segment of Nevada’s       Nevada will deny issuance until the customer has
already registered to or associated with another person to   population if documentation to evidence non-eligibility   resolved the discrepancy with SSA.
which any state has issued a DL/ID card, the state shall     cannot be produced or if a discrepancy exists with
resolve the discrepancy and take appropriate action          SSA.

Check other states if a person already was issued a DL in    No impact
another state

Ensure physical security of locations where DL/ID cards      No impact
are produced

Subject all person’s authorized to manufacture or produce    The potential impact of this requirement is subjecting    The assumption is that contractors developing software
DL/ID cards to appropriate security clearance                potential contract vendors to security clearances.        and controlling card stock would be subjected to the
requirements                                                                                                           same security clearances as jurisdiction employees
                                                                                                                       issuing driver’s licenses and identification cards.

Establish fraudulent document recognition training           No impact
programs for appropriate employees engaged in the
issuance of DL/ID cards
        REAL ID ACT REQUIREMENT                                                  IMPACT                                               ASSUMPTIONS
Limit period of validity of DL/ID cards that are not           No impact
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal           •   Impact on the information technology staff to    Any changes from the existing design specifications are
standard                                                              complete DMV application programming             billable enhancements by the contractor.
                                                                      changes
                                                                  •   Large fiscal Impact
                                                                  •   Vendor Contract revisions
                                                                  •   Statutory change to enact legal presence law
Legal Presence Requirement                                                                                             Nevada does not currently have a legal presence law
                                                                  •   Regulation changes                               which require statutory changes to comply with H.R.
                                                                  •   Verification process will add to wait times in   418.
                                                                      offices
Provide electronic access to all other states to information   No impact
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     No impact
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                          •   Impact on the information technology staff to    Any changes from the existing design specifications are
                                                                      complete DMV application programming             billable enhancements by the contractor.
Development and issuance of a certificate of driving – not
                                                                      changes
for federal identification purposes – for those who cannot
prove lawful presence.                                            •   Fiscal Impact
                                                                  •   Vendor Contract revisions
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

                                                                                                         Are We
           Requirement of H.R. 418                       What We Currently Have In Place                                            Impacts of Implementation
                                                                                                        Compliant?
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     • Laminate Coating – tamper resistant                           If the established requirements are different or
         purposes                                            coating with optically variable image                      exceed what is currently in place, an impact will
                                                               of state seal                                                exist to implement the required features. For
                                                           •   Digital portrait and signature image                         example, if biometrics are mandated, there will be
                                                               printed on durable composite card                            a substantial impact on the information technology
                                                           •   State seal overlaps the top-left corner                      staff to complete DMV application programming
                                                               of the photo                                                 changes, it will effect the card design, the contract
                                                           •   First and last initial and last two digits                   with our vendor could require amendments,
                                                               of date of birth on the left of the                          increased costs under the vendor contract could
                                                               license/ID card in the mountains                             occur and ultimately, a request to increase the cost
                                                           •   DLN or ID number appears above the                           of the driver’s license to the public may be
                                                               issue date on the photograph area                            necessary to cover added expenses to produce the
                                                           •   Issue date in photo area                                     card.

        Common machine-readable technology,           The industry standard 2-D Bar Code with                 Yes           Federal regulations have not been written to
        with defined minimum data elements            AAMVA standard minimum requirements is                                determine if “minimum data elements” are
                                                      currently being used.                                                 provided in our current 2-D bar code.

                                                                                                                            The Secretary of Homeland Security has the
                                                                                                                            authority to establish parameters for machine-
                                                                                                                            readable technology that could present a
                                                                                                                            substantial impact on our Department, i.e., Mag-
                                                                                                                            Stripe.

                                                                                                                            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      To evidence name and/or date of birth, we accept once of        Yes   Unless specific documents are identified in Federal
non-photo identity document is acceptable     the following documents as a sole source:                             Regulation, we are in compliance
if it includes both the person’s full legal
name and date of birth.                           •    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
Documentation showing the person’s date                Government (can be expired)
of birth                                           • 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 I-
                                                       551”
                                                   • 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)

Proof of the person’s social security               •    Records of employment                                  Parti   We would be unable to service a segment of
number or verification that the person is not       •    Federal income tax records (not self prepared)          al     Nevada’s population if documentation to evidence
eligible for a social security number               •    Social Security Card -                                         non-eligibility cannot be produced.
                                                    •    Military personnel, spouse, or dependent ID card                   • Documentation will need to be
                                                    •    FAA (pilot license)                                                     determined that will evidence an applicant
                                                    •    Verification from Social Security Administration                        is NOT eligible for an SSN
                                                         (if person is drawing benefits)                                    • This may require regulatory changes to
                                                    •    Correspondence from IRS                                                 define what documents are accepted as
                                                                                                                                 evidence of SSN and evidence that the
                                                    •    Out-of-state license or identification card with the
                                                                                                                                 applicant is NOT eligible
                                                         social security number printed on the card
                                                                                                                            • If document indicating the applicant is not
                                                    •    DD-214, Military discharge papers                                       eligible for a Social Security Number is
                                                                                                                                 not available, the applicant is denied and
                                                Currently, the Department only requires the applicant sign                       the issuance process is delayed.
                                                an affidavit if they have not been issued a Social Security                 • If wait times increase beyond the
                                                Number. No documentation is required.                                            mandatory 1-hour limit, additional staff
                                                                                                                                 and field offices may be necessary.
                                                                                                                            • Public notices will need to be generated

Documentation showing the person’s name         We do not require evidence of principle place of residence      No          •   Statutory change
and address of principle residence                                                                                          •   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        Nevada does not have a legal presence law.                   No      •   Statutory change to enact the legal
        require, before issuing a driver’s license or    The Department only ensures the applicant, based on                      presence law
        identification card to a person, valid           immigration documentation, meets the definition of                   •   Verification procedures
        documentary evidence that the person:            “resident” according to NRS 483.141.                                 •   Additional staff to review and verify
            • Is a citizen of the United States          The Department accepts to following documents to                         documents
            • Is an alien lawfully admitted for          evidence name and age for applicant born outside of the              •   Regulation changes
                  permanent or temporary residence       US. They are also used to determine if the applicant meets           •   Verification process will add to wait times
                  in the United States                   the definition of resident.                                              in offices
            • Has conditional permanent                       • Certificate of Citizenship                                    •   Programming hours for DMV application
                  resident status in the United States        • Certificate of Naturalization                                     changes will be needed
            • Has an approved application for                 • Permanent Resident Card                                       •   If temporary documents are needed, this
                  asylum in the United States or has          • Temporary Resident Card                                           process could ultimately result in Central
                  entered into the United States in           • Employment Authorization Card, must be current                    Issuance of DL and/or ID’s
                  refugee status                                  – if expired, refer the customer to BCIS                    •   If wait times increase beyond the
            • Has a valid, unexpired                          • Permit to Reenter the United States                               mandatory 1-hour limit, additional staff
                  nonimmigrant visa or                        • Refugee Travel Document                                           and field offices may be necessary.
                  nonimmigrant visa status for entry          • Arrival-Departure Record (I-94) if accompanied                •   Public notices will need to be generated
                  into the United States                          by a valid passport
            • Has a pending application for                   • Alien Registration Receipt Card (I-551), Resident
                  asylum in the United States                     Alien Card
            • Has a pending or approved                       • Consular Report of Birth Abroad of the US
                  application for temporary                       Citizen Child issued by the Department of State
                  protected status in the United              • US Passport (can be expired)
                  States                                      • Valid foreign passport stamped “Processed for I-
            • Has approved deferred action                        551”
                  status; or                                  • Veterans Identification Card with photo
            • Has a pending application for                   • Military identification card or Military dependent
                  adjustment of status to that of an              identification card issued by any branch of the
                  alien lawfully admitted for                     U.S. Armed Forces. (Must have name, date of
                  permanent residence in the United               birth and photo)
                  States or conditional permanent
                  resident status in the United States
4. Temporary Driver’s License and Identification Cards

        If a person presents evidence under any         We currently issue the driver’s license or        Yes
        clause of above immigration documents,          identification card that expires with
        the State may only issue a temporary            immigration documents, when immigration
        driver’s license or temporary identification    documents are presented.
        card.
        A temporary driver’s license or temporary       Documents are issued to coincide with the       Partial       •      Policy and procedure changes
        identification card issued based on             immigration end-of-stay date. If no date is                   •      MVIT programming to automate the expiration at
        immigration documents should be valid           provided, a 4-year default is given.                                 one year
        only during the period of time of the                                                                         •      Statutory and/or regulatory changes identifying the
        applicant’s authorized stay in the United                                                                            one-year expiration if no immigration end-of-stay
        States, or if there is no definite end to the                                                                        date provided.
        period, a period of one year.                                                                                 •      Public notices will need to be generated
        A temporary driver’s license or                 If immigration information is in the system,      Yes
        identification card issued based on             new immigration documents must be presented
        immigration documents may be renewed            to evidence an extension in their stay before
        only upon presentation of valid                 the DL or ID will be renewed.
        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.
5. Verification of Documents – to meet the requirements of this section, a State shall implement the following procedures:
        Before issuing a   This is currently in place for Social Security Number.                         No      To verify each and every source document would require
        DL or ID, the      Verification is also made through PDPD/CDLIS for the DL/ID being                       staff to contact each issuing agency to ensure authenticity.
        State shall        surrendered                                                                                 • Statutory change
        verify, with the                                                                                               • Verification procedures
        issuing agency,                                                                                                • Additional staff to review and verify documents
the issuance,                                                                                          •    Regulation changes
validity, and                                                                                          •    Verification process will add to wait times in offices
completeness of                                                                                        •    Programming hours for DMV application changes
each document                                                                                               will be needed
required to be                                                                                         •    If temporary documents are needed, this process
presented by                                                                                                could ultimately result in Central Issuance of DL
the person.                                                                                                 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   Currently, the Department accepts the following by statute or regulation:   No   The impact of this requirement is the inability to issue a
not accept any        • Certificate of Citizenship                                                 driver’s license or identification card to foreign residents as
foreign                 •   Certificate of Naturalization                                             this requirement conflicts with Special Requirements –
documents,              •   Permanent Resident Card                                                   Evidence of Lawful Status.
other than an           •   Temporary Resident Card
official                •   Employment Authorization Card, must be current – if expired,
passport, to                refer the customer to BCIS
satisfy a                • Permit to Reenter the United States
requirement of           • Refugee Travel Document
the minimum              • Arrival-Departure Record (I-94) if accompanied by a valid
issuance
                            passport
standards.
                         • 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”
Not later than      The Department is currently verifying immigration information via       Compl
September 11,       telephone.                                                               iance
2005, the State                                                                                is
shall enter into    Information about SAVE has been received.                               forthco
a memorandum                                                                                 ming
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
         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      This process is currently in place           Ye    No impact for this requirement
         digital images of identity                                                      s
         sources documents so that the
         images can be retained in
         electronic storage in a
         transferable format.
         Retain paper copies of source     We do not currently maintain copies of       No    If paper copies are retained until scanned, the impact would include:
         documents for a minimum of 7      source documents                                        • Purchase of additional copy machines in field offices
         years or images of source                                                                 • Additional staff to verify and copy documents
         documents presented for a                                                                 • Additional storage will be needed until documents can be scanned and
         minimum of 10 years.                                                                          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      This process is currently in place           Ye    No impact for this requirements
         for a DL or ID to mandatory                                                     s
         facial image capture.
         Establish an effective            Verification of information takes place      No        •    This requirement eliminates current alternate technologies for the renewal
         procedure to confirm or verify    only during in-office renewals.                             of a driver’s license or identification card.
a renewing applicant’s                                                                   •    Statutory change
information.                      Applicants renewing based on                           •    Verification procedures
                                  immigration documents must renew in-                   •    Additional staff to review and verify documents
                                  office and they must bring current                     •    Regulation changes
                                  immigration documentation.                             •    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.
Confirm with the SSA a SSN        All SSN presented are verified through      Ye     No impact based on the assumption that the Department will not issue the driver’s
presented by a person using the   SSOLV.                                       s     license or identification card until the discrepancy is resolved by the customer.
full socials security account     Resolution of discrepancies is currently
number. In the event that a       the responsibility of the applicant.
SSN is already registered to or   If a discrepancy exists, the driver’s
associated with another person    license or identification card is not
to which any State has issued a   issued and the customer is requested to
DL or ID, the State shall         visit the Social Security office to clear
resolve the discrepancy and       the discrepancy.
take appropriate action.
Refuse to issue a DL or ID to a   Nevada DMV does not issue a DL or ID        Ye     No impact for this requirement
person holding a DL or ID         to an applicant if there is evidence that    s
issued by another State without   another valid document issued by this or
confirmation that the person is   any other jurisdiction has been issued.
terminating or has terminated     This is checked by using CDLIS/PDPS
the DL.                           systems.
Ensure the physical security of        • Physical locations are locked        Ye     Unless specific security measures are prescribed, we have met this requirement.
locations where DL or ID are               nightly.                            s
produced and the security of           • Materials and documents are
document materials and papers              secured nightly with revenue.
from which DL and ID are
produced.
Subject all persons authorized    All DMV employees undergo criminal          Par    The potential impact of this requirement is subjecting potential contract vendors to
to manufacturer or produce DL     background checks prior to employment.      tial   security clearances.
and ID to appropriate security
clearance requirements.
         Establish fraudulent document      Fraudulent document training is             Ye   No impact for this requirement
         recognition training programs      currently a part of the DMV field service    s
         for appropriate employees          technician training program.
         engaged in the issuance of DL
         and ID.
         Limit the period of validity of    DMV issues 4-year DL or ID unless           Ye   No impact for this requirement
         all DL and ID that are not         expiration is less due to immigration        s
         temporary to a period that does    papers
         not exceed 8 years.
         In any case in which the State     Nevada’s current issuance standards of      Ye   If the established requirements are different or exceed what is currently in place,
         issues a driver’s license or       driver’s license and identification cards    s   an impact will exist to implement the required features. There could be a
         identification card that does      meet the requirements of H.R. 418 and            substantial impact on the information technology staff to complete DMV
         not satisfy the requirements of    as such, these provisions would not              application programming changes, it will effect the card design, the contract with
         this section, ensure that such     apply under existing conditions.                 our vendor could require amendments, increased costs under the vendor contract
         license or identification card:                                                     could occur and ultimately, a request to increase the cost of the driver’s license to
1. Clearly states on its face that it may                                                    the public may be necessary to cover added expenses to produce the card.
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.
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:       Item 1 requires changes to current IT system. Will
                                                             result in additional unbudgeted expenses.
    28. Full Legal Name             NO
    29. Person’s Date of Birth      Yes
                                                             Item 6: Currently the applicant has option to have
    30. Person’s Gender           Yes
                                                             legal residence removed from their license. This
    31. Person’s DL or ID Card Number       Yes              requirement would require a change in current Law if
                                                             mandated.
    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 is tied to end of stay, Not using Temporary
expiration of DL/ID card (or issuance for no more than 1     after 45 days.
year)

Amending card design to show/indicate that it is a           Not currently amended, current initiatives by            This is intended to identify Non-US.
temporary document with a “different than usual”             advocates for Non-US citizens are to prevent the
         REAL ID ACT REQUIREMENT                                                      IMPACT                               ASSUMPTIONS
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)      Yes
 5. Birth certificate     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        Currently do not have imaging capability for licensing.
of identity source documents so that images can be retained      Would require additional hardware and OIT
in electronic storage in a transferable format                   modifications.

Retain paper copies of source documents for a minimum of         Currently maintain copies of source documents. In
7 years or images of source documents presented for a            compliance
minimum of 10 years

Subject each person applying for a driver’s license or           Currently take digital photos of face.
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a          Renewals are currently verified with existing system.
renewing applicant’s information

In the event that a social security account number is already    Currently rectifying SSNN discrepancies with SSA.
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
         REAL ID ACT REQUIREMENT                                                   IMPACT                               ASSUMPTIONS
Check other states if a person already was issued a DL in      State currently conducts motor vehicle record checks
another state                                                  before issuing permanent license.

Ensure physical security of locations where DL/ID cards        Procedures in place and being enhanced.
are produced

Subject all person’s authorized to manufacture or produce      Requires background checks not currently performed.
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             Currently conduct this training.
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Current expiration is 5 years. In compliance
temporary to a period not exceeding 8 years

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     Currently in compliance.
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
        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                                        IMPACT                                                   ASSUMPTIONS
      REQUIREMENT
Introduce Full Legal Name   NJ law allows the Motor Vehicle Commission to collect a legal          AAMVA's Uniform ID security model is the
into Driver Licensing       name. In the past, many records in the MVC database were               base for change. The CDLIS and PDPS
System (in Record, on       created with a name construction similar or close to a legal name      systems, which have specific naming
Document)                   – but not exactly the legal name (i.e., use of nicknames or            convention rules, will comply with the change
                            Americanization of a Foreign name). Introducing the full legal         to a name in a timely fashion to allow states to
                            name will lead to unhappy customers that may be forced to go           meet the three-year implementation
                            back to a legal name they have not used for many years.                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         NJ MVC’s current digital license contains all the data elements        That it’s not an “either/or” selection, but a
elements/features on the    and security features referred to except for the person’s principle    matter of showing principle and mailing
document:                   residence address. For the most part, the principle address is         address.
                            reflected on the card, but there are records in which a Post Office
       REAL ID ACT                                        IMPACT                                   ASSUMPTIONS
      REQUIREMENT
   37. Full Legal Name        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
   38. Person’s Date of
                              configuration, could mean a redesign of the digital document. A
       Birth
                              redesign will cost significant time and money.
   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
   45. Common Machine
       Readable
       Technology:

Introduce temporary DL/ID     NJ MVC issues a digital license today that is tied to an
cards and tying end of stay   individual’s length of stay.
to expiration of DL/ID card
(or issuance for no more
than 1 year)
      REAL ID ACT                                         IMPACT                                                   ASSUMPTIONS
      REQUIREMENT


Amending card design to       The digital license is limited in real estate, so this requirement,   Digimarc is the State’s digital license
show/indicate that it is a    along with others in the Real ID Act, will force a redesign of the    contractor and this redesign may require a long
temporary document with a     document. This change requires working with the State’s vendor        lead-time since Digimarc has a large number
“different than usual”        on a redesign and extensive testing of a new document; much like      of contracts in the country. Assuming many
expiration date               the effort put forth on the initial design of the State’s digital     states will have to do similar redesign, NJ
                              license.                                                              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
Enabling your system to
                              operational.
electronically verify
documentation with:           DEERS, other jurisdiction check, birth certificate and third party
                              would all be new interfaces with operational components not yet
 1. SSOLV
                              defined.
 2. SAVE
                              The electronic interfaces would be similar to what we have done
 3. DEERS (DOD)               to date with other outside entities. There are operational issues
  4. Other jurisdiction       bringing more data to the workstation. It adds complexity to the
(DL/ID card)                  decision making process and whether to license an individual or
                              not.
 5. Birth certificate
  6. Other…i.e. third party
vendors

Developing access capability NJ has access to the SAVE program and uses it to verify                That INS improves the timely application of
to SAVE system               information on select cases. To make it an integrated function         information to its database so States can use
                             with license issuance would be sizeable effort, and would require      that data in a more dynamic manner. Today,
       REAL ID ACT                                           IMPACT                                                   ASSUMPTIONS
       REQUIREMENT
                                INS to improve on the timely availability of data.                      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
Introduce equipment into
                                other need for imaging) will change the dynamics of Motor
system to capture digital
images of identity source       Vehicles’ IT systems. There will be several profound changes as
                                a result of this technology:
documents so that images
                                - Greatly enhanced document retrieval after capture
can be retained in electronic
                                - Possible implications to the customer throughput to take the time
storage in a transferable
format                          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          Significant influence on customer service. This State is an over-       That States do not have to maintain both
source documents for a          the-counter instant issuance service. It will be quite challenging to   physical copies and images
minimum of 7 years or           maintain a smooth license process and capture the images of
images of source documents      documents used to verify the identity of a license applicant. To
presented for a minimum of      maximize customer throughput, NJ recently re-engineered
       REAL ID ACT                                           IMPACT                                                  ASSUMPTIONS
      REQUIREMENT
10 years                         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              This is underway in NJ. According to current law, that image is
applying for a driver’s          good for eight years before another image is required.
license or identification card
to mandatory facial image
capture



Establish an effective           NJ MVC established a “6 Point Identification Verification”
procedure to confirm or          system which standardized how an applicant verifies his identity.
verify a renewing                Certain documents are considered “Primary” (and given a four-
applicant’s information          point 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       The CDLIS /PDPS helpdesk responsibility will have to be               Requires a State-to-State check of a driver
security account number is       expanded to include dealing inter-jurisdictional matters on non-      license, and that a master pointer record
already registered to or         commercial drivers. Should appropriate action be necessary, the       database is developed and operational by
associated with another          State can suspend the license of a driver who provides false          AAMVAnet.
        REAL ID ACT                                        IMPACT                                                  ASSUMPTIONS
        REQUIREMENT
person to which any state      information.
has issued a DL/ID card, the
state shall resolve the
discrepancy and take
appropriate action

Check other states if a        This is a large effort. On a scale of 1 to 10, this rates as a 10     This statement implies the “one driver, one
person already was issued a    effort. Introducing the “all driver license” search with licensing    record” concept and requires States put in
DL in another state            practices in the motor vehicle offices creates a number of            place standard practices to test and license
                               customer service challenges. The “all driver search” will increase    drivers so States can employ reciprocity among
                               the number of exceptions that have to be handled by field staff.      State licensing jurisdictions.
                               Technically, it will rival the commercial driver license project of
                                                                                                     Requires a State-to-State check of a driver
                               the late 80’s.                                                        license and that a master pointer record
                                                                                                     database is developed and operational by
                                                                                                     AAMVAnet.
Ensure physical security of    The NJMVC is currently issuing licenses at 45 field locations. In     Law Enforcement Agency Security
locations where DL/ID cards    October 2005, the 46th agency will open. All processes are            Enhancement (L.E.A.S.E.) Program will
are produced                   completed at agency counters. DDL hardware is secured to the          continue at two thirds of our agencies. An
                               counter with a locking device. Consumables are safely out of          assigned investigator of the MVC’s Security
                               reach from the general public. When not in use, the equipment is      and Investigations Unit will monitor agencies
                               shut down, the security key is removed, and all consumables are       without a L.E.A.S.E. Officer.
                               stored in a locked and alarmed safe.



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
       REAL ID ACT                                           IMPACT                                                  ASSUMPTIONS
       REQUIREMENT
Establish fraudulent           Training for all agency, and support staff, is a large part of the     Fraudulent document recognition training has
document recognition           initiative and of great importance to the Commission.                  been in place since the latter part of 2004.
training programs for                                                                                 This training will be expanded to include
appropriate employees                                                                                 field/regional locations.
engaged in the issuance of
DL/ID cards

Limit period of validity of    The current NJ card is good for four years before renewal and the
DL/ID cards that are not       picture is good for eight years. There is thought of moving the
temporary to a period not      card to an eight-year renewal cycle – so this requirement has little
exceeding 8 years              impact.

Alternative document design    As stated earlier, any alteration of the card, due to limited real
if it does not meet federal    estate, would necessitate a costly redesign of the card.
standard

Legal Presence Requirement     Current NJ Law requires authorized presence in the United States.      Due to the ever-changing aspect of the
                               Proof must be submitted in order to qualify for a NJ license.          business, we work closely with representatives
                                                                                                      from Immigration to be sure the latest
                                                                                                      information is available to our field staff.

Provide electronic access to   NJ would like to use the infrastructure in place to facilitate         If the State of record is known, then a State-to-
all other states to            commercial driver license access to State data. Absent that            State communication can be constructed. If not
information contained in the   system, the check can only be done if the customer identifies the      known, then a master pointer record database
motor vehicle database of      last State of record.                                                  has to be operational by AAMVAnet.
the state
       REAL ID ACT                                            IMPACT                                                ASSUMPTIONS
       REQUIREMENT
Maintain a state motor           Little impact as this already exists
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                         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
Development and issuance
                                 from a driver license/identity document.                           and the other cannot be for Federal purposes
of a certificate of driving –
                                                                                                    and must bear that clarification.
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?

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      Already capturing this information                             Only problem may be for individuals with only one (1) legal
System (in Record, on Document)                                                                                     name. One name will show on license or ID and the legal name
                                                     Does the full legal name mean having to use the full
                                                                                                                    will show in the “Last” name field with first name and MI
                                                     middle name or can just an initial be used?
                                                                                                                    fields blank. Not sure what problems with PDPS/CDLIS and
                                                                                                                    SSN this will have.

Have following data elements/features on the         Already capturing this information                             None
document:
                                                     Does the full legal name mean having to use the full
    46. Full Legal Name                              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     Possible legislative action due to political sensitivity. If   Will need legislative approval due to political sensitivity.
stay to expiration of DL/ID card (or issuance for    so, this will delay implementation, if approved, probably
no more than 1 year)                                 until our FY08 session (the next long session).

Amending card design to show/indicate that it is a   Possible legislative action due to political                   Had to take of “Foreign National” when we implemented
temporary document with a “different than usual”     sensitivity. If so, this will delay implementation, if         accepting the ITIN as a document to get a DL or ID. Expect
       REAL ID ACT REQUIREMENT                                             IMPACT                                                ASSUMPTIONS
expiration date                                      approved, probably until our FY08 session (the        legislature not to approve this.
                                                     next long session).

Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                          1.   Implemented                                    1.   None
 1. SSOLV
                                                          2.   Need to implement                              2.   Probably have to get legislative support for funding and
 2. SAVE                                                                                                           staff
                                                          3.   Need to implement
 3. DEERS (DOD)                                                                                               3.   Need to evaluate usefulness
 4. Other jurisdiction (DL/ID card)
                                                          4.   Visual now. Need to implement electronic
 5. Birth certificate                                          verification                                   4.   Need legislative support for funding for system
                                                                                                                   upgrade and staff
 6. Other…i.e. third party vendors                        5.   Implemented visually, not electronically
                                                                                                              5.   None
                                                          6.   DL and ID are over the counter.
                                                                                                              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.

Developing access capability to SAVE system          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   No budget for this. May need federal legislation to   Assuming it is legal, in New Mexico, to capture “all” types of
images of identity source documents so that          allow DMVs to copy any document used in issuance of   documents, will need legislative support for funding to develop
images can be retained in electronic storage in a    DL/Ids.                                               and maintain the entire system, which will cross several
transferable format                                                                                        public/private entities, that initiate/handle/store the transaction
                                                                                                           records.

Retain paper copies of source documents for a        Need to evaluate space requirements/needed            Will need legislative support for funding.
minimum of 7 years or images of source               budget/staff.
       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   Already doing this.                                        None
or identification card to mandatory facial image
capture

Establish an effective procedure to confirm or        Will need to evaluate current procedures against           Will get legislative support.
verify a renewing applicant’s information             minimum requirements and also evaluate need for any
                                                      legislation and/or regulations to implement.

In the event that a social security account number    Would need to develop and implement procedures to          Will get legislative support.
is already registered to or associated with another   accomplish this. Need funding.
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   Initially will require phone call to the previous state    Will need legislative support for funding for staff, workspace,
DL in another state                                   then, when electronic verification is available, check     and implementation of electronic verification system.
                                                      will be done electronically
                                                      Will require funding and large staff until electronic
                                                      verification is available.

Ensure physical security of locations where DL/ID     Will require re-evaluation of existing security measures   Any upgrades will be minor.
cards are produced                                    in the three types of offices (MVD owned and operated,
                                                      City/county owned and operated, private owned and
                                                      operated) offices
                                                      Possible need for funding to upgrade MVD offices and
                                                      similar funding need for other office types.

Subject all person’s authorized to manufacture or     Will require evaluation of all office type clearance       Minimum increase in clearance requirements.
produce DL/ID cards to appropriate security           procedures and standardizing them.
                                                                                                                 Possible legislative support for funding staff doing clearance
clearance requirements
                                                      Need to determine who will do the clearances for each      for state and city/county and maybe private personnel.
                                                      type of office and what the cost will be.

Establish fraudulent document recognition             Some training being conducted now.                         Will need legislative support for funding staff, travel expenses
       REAL ID ACT REQUIREMENT                                               IMPACT                                                     ASSUMPTIONS
training programs for appropriate employees           Will need classrooms strategically located throughout        of employees and training staff, will need classrooms
engaged in the issuance of DL/ID cards                the state
                                                      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      8-years is the maximum for New Mexico now.                   None
not temporary to a period not exceeding 8 years

Alternative document design if it does not meet       Will have to evaluate current procedures                     May require funding for new documents
federal standard

Legal Presence Requirement                            Will require legislative approval to change to requiring     Might be turned down by the legislative body due to the
                                                      legal presence                                               political sensitivity

Provide electronic access to all other states to      Will require legislative support for funding for IT staff,   Legislative support will be provided, but at what funding level
information contained in the motor vehicle            development and implementation of a system, training         is unknown.
database of the state                                 MVD staff, maintaining the system.

Maintain a state motor vehicle database that
contains at a minimum:
                                                      Already in existence
           All data fields printed on DL/ID cards
                                                      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          Will need legislative approval.                              Probably not happen due to the political nature of the certificate
driving – not for federal identification purposes –                                                                and “singling out” individuals
for those who cannot prove lawful presence.

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                                                IMPACT                              ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System                       MAJOR IMPACT
(in Record, on Document)
                                                           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.
Have following data elements/features on the document:                      NOMINAL IMPACT
    55. Full Legal Name                                    NYS DMV prints the DOB, gender, client ID,
    56. Person’s Date of Birth                             digital Image, signature and the mailing address on
    57. Person’s Gender                                    the license documents.
    58. Person’s DL or ID Card Number                      We already data enter both mailing and residence
    59. Digital Photograph of Person (and retention)
                                                           addresses, if applicable, but we would need to
                                                           change the information sent to the license print file.
    60. Person’s Address of Principle Residence            This would entail adding the residence address to
    61. Person’s Signature                                 the barcode information since this is what DeLarue
    62. Physical Security Features to prevent tampering,   uses to print the license. We would need to
        counterfeiting or duplication                      maintain the mailing address in the barcode. The
    63. Common Machine Readable Technology:                Onserts machine reads the mailing address in the
                                                           barcode and prints the address on the carrier card for
           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                    MAJOR IMPACT
                                                                                                                   A temporary driver’s license or
expiration of DL/ID card (or issuance for no more than 1                                                           identification can only be valid for the
year)                                                      This would require changes to the license file and
                                                           approximately sixteen other systems that process        period of time of the applicant’s
                                                           against it.                                             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.

Amending card design to show/indicate that it is a                            NO IMPACT
temporary document with a “different than usual”
expiration date                                            We currently have the ability to distinguish between
                                                           document types by printing legends on our
                                                           documents, for example: “Under 21”, “Temporary
                                                           Visitor”.

Verification at Source:                                      MODERATE IMPACT – to employ additional
Enabling your system to electronically verify                        verification systems
documentation with:                                        NYS DMV currently uses SSOLV. We also use the
 1. SSOLV                                                  Department of Homeland Security Systematic Alien
 2. SAVE                                                   Verification Entitlements (SAVE) system to verify
                                                           immigration documents when staff questions their
 3. DEERS (DOD)
                                                           validity. The additional verification systems would
 4. Other jurisdiction (DL/ID card)                        provide us with greater assurance of the authenticity
 5. Birth certificate                                      of source documents however, these additional
 6. Other…i.e. third party vendors                         verifications would result in increased transaction
                                                           time.
           REAL ID ACT REQUIREMENT                                               IMPACT                             ASSUMPTIONS
Developing access capability to SAVE system                  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                    MAJOR IMPACT
of identity source documents so that images can be
retained in electronic storage in a transferable format     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.
           REAL ID ACT REQUIREMENT                                                IMPACT                                       ASSUMPTIONS
Retain paper copies of source documents for a minimum of            MAJOR IMPACT (imaging system)
7 years or images of source documents presented for a
minimum of 10 years                                          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.

Subject each person applying for a driver’s license or                           NO IMPACT
identification card to mandatory facial image capture
                                                             This is a current requirement in NYS.

Establish an effective procedure to confirm or verify a              MODERATE TO MAJOR IMPACT                        We are assuming we could mitigate this
renewing applicant’s information                                                                                     requirement by pre-screening and
                                                             Before issuing the driver’s license or identification
                                                             card, the validity and completeness of the              approving renewals to minimize the
                                                             documents presented by the applicant as proof must      presentation and examination of
                                                             be verified. This must be done for original and         documents in the offices.
                                                             renewal transactions. Still, we will see an increase
                                                             in transaction times, requiring as many as 200
                                                             additional field staff to handle this effort

In the event that a social security account number is                            NO IMPACT
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall     We currently have a SSN index file in NYS. We
resolve the discrepancy and take appropriate action          also use SSOLV to verify the SSN presented prior
                                                             to issuance of a document.

Check other states if a person already was issued a DL in                   MODERATE IMPACT
another state
                                                             We would need an integrated system to do so.
                                                             Increased transaction time.

Ensure physical security of locations where DL/ID cards                          NO IMPACT
are produced
                                                             Our document production vendor is located in a
           REAL ID ACT REQUIREMENT                                               IMPACT                                       ASSUMPTIONS
                                                            secure area.

Subject all person’s authorized to manufacture or produce                      NO IMPACT
DL/ID cards to appropriate security clearance
requirements                                                All employees of our document production vendor
                                                            are subject to security clearance.

Establish fraudulent document recognition training                          NOMINAL IMPACT
programs for appropriate employees engaged in the
issuance of DL/ID cards                                     We currently have a FDR training program. We
                                                            would need to do additional training and enhance
                                                            this program area.

Limit period of validity of DL/ID cards that are not                        NOMINAL IMPACT                         We would be able to change the 10-year
temporary to a period not exceeding 8 years                                                                        period of validity to 8 years upon
                                                            Our licenses are valid for 8 years. We would need to
                                                            eliminate our 10-year Non-Driver ID cards and          renewal of the NDID.
                                                            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.

Alternative document design if it does not meet federal                        NO IMPACT
standard
                                                            We have recently re-designed our documents. These
                                                            documents meet or exceed federal standards.

Legal Presence Requirement                                                 MODERATE IMPACT                         State Legislation requiring legal
                                                            We would need to integrate SAVE into our               presence must be passed.
                                                            processing system to do online verification of DHS
                                                            documents.

Provide electronic access to all other states to                           MODERATE IMPACT
information contained in the motor vehicle database
of the state                                                Impacts cannot be established until the requirements
            REAL ID ACT REQUIREMENT                                                 IMPACT                           ASSUMPTIONS
                                                             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.

Maintain a state motor vehicle database that contains at a                      NO IMPACT
minimum:
                                                             Based on our interpretations we are compliant with
           All data fields printed on DL/ID cards
                                                             this. However, our motor vehicle histories are
         motor vehicle driver’s histories, including motor   limited based on file conditions.
         vehicle violations, suspensions and points on
         licenses

Optional                                                                     MAJOR IMPACT
Development and issuance of a certificate of driving – not   This would require us to have a “dual” system for
for federal identification purposes – for those who cannot
prove lawful presence.
                                                             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.
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 on-
      line 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                                               ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     $4,000,000                         In order to capture the full legal name over 30 characters, a full system
(in Record, on Document)                                                                      redesign will be required.

Have following data elements/features on the document:     None with the exception of noted
                                                           above.
    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:

Introduce temporary DL/ID cards and tying end of stay to   $10,000                            Legislation required. Bill submitted last session but it was defeated.
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a         $20,000                            Requires new card format. See alternative design for additional cost per
temporary document with a “different than usual”                                              card costs.
expiration date
           REAL ID ACT REQUIREMENT                                      IMPACT                                             ASSUMPTIONS
Verification at Source:                                       1) SSOLV – Implemented (No       4) Developing an automated state ot state verification or require a DRIVERS
                                                              impact)                          national database.
Enabling your system to electronically verify
documentation with:                                           2) SAVE - $.28-$.48 per query    5) Current est. from EVERS is $1.10 per check = $11,000
                                                              $7,600
 1. SSOLV
                                                              3) DEERS – UKN requirements
 2. SAVE
                                                              UKN Impact
 3. DEERS (DOD)
                                                              4) $100,000 to implement -
 4. Other jurisdiction (DL/ID card)                           $10,000 per annum
 5. Birth certificate                                         5) $20,000 Implementation -
                                                              $11,000 per annum
 6. Other…i.e. third party vendors
                                                              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     $528,000 (Document scanners)     Automated 16 additional sites and adding additional hardware to existing
of identity source documents so that images can be retained                                    sites.
                                                              $36,000 hardware,
in electronic storage in a transferable format
                                                              $160,000 network costs
                                                              $25,600 Printers
                                                              $320,000 Additional DDLS costs

Retain paper copies of source documents for a minimum of      $10,000                          Additional storage costs
7 years or images of source documents presented for a
minimum of 10 years

Subject each person applying for a driver’s license or        None
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a       UNK                              Dependent on the requirements
renewing applicant’s information

In the event that a social security account number is         None                             SSOLV in place
already registered to or associated with another person to
which any state has issued a DL/ID card, the state shall
            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      UNK                          Requires a National database. Defer to AAMVA for estimated costs for
another state                                                                               DRIVERS implementation.

Ensure physical security of locations where DL/ID cards        $220,000                     Surveillance cameras at each site.
are produced

Subject all person’s authorized to manufacture or produce      $2,400                       60 FTE’s at $40 ea
DL/ID cards to appropriate security clearance requirements

Establish fraudulent document recognition training             $15,000                      Annual training
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           $1,000                       ID Card is currently 10 years.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        $380,000                     Estimated annual cost increase for a replacement DDLS
standard

Legal Presence Requirement                                                                  Requires legislation

Provide electronic access to all other states to information   UNK                          National database required.
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     Addressed in question #1     Existing legacy system in need of redesign
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       $150,000 Salary & Benefits   5 Additional Examiners
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
Introduce Full Legal Name into Driver Licensing
System (in Record, on Document)

Have following data elements/features on the          The Ohio BMV is already in compliance          Ohio law provisions may need to be revised. At minimum, the BMV
document:                                             with all provisions with the following         Registrar would need to be permitted to adopt rules to conform to
                                                      exceptions:                                    federal requirements.
    73. Full Legal Name
                                                      1.   Full legal name – present capability to   Programming changes are necessitated to accommodate the space full
    74. Person’s Date of Birth
                                                           capture approx. 100 characters to be      legal name.
    75. Person’s Gender                                    displayed on license/ID. Full name
                                                                                                     Issuance policy revisions will be required to enforce requirements for
                                                           could be captured electronically;
    76. Person’s DL or ID Card Number                                                                capturing full legal name and principal residence.
                                                           however, names exceeding 100
    77. Digital Photograph of Person (and                  characters may have to be truncated as
        retention)                                         displayed on the card or require
                                                           programming to reformat the fields
    78. Person’s Address of Principal Residence            displayed on the card. Ohio complies
    79. Person’s Signature                                 with current AAMVA standards.
    80. Physical Security Features to prevent         2.   Principal residence – Ohio requires
        tampering, counterfeiting or duplication           street address (no P.O. boxes) and has
                                                           multiple address fields capability.
    81. Common Machine Readable
        Technology:

Introduce temporary DL/ID cards and tying end        Already in compliance.                          N/A
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   Already in compliance.                          N/A
temporary document with a “different than usual”
expiration date
         REAL ID ACT REQUIREMENT                                     IMPACT                                                    ASSUMPTIONS




Verification at Source:                               1.   Already in compliance                      1.     N/A
Enabling your system to electronically verify         2.   Noncompliant – MOU required                2-6.   Programming changes will be necessitated. May necessitate
documentation with:                                                                                          computer hardware/software requirements. Issuance policy
                                                      3.   Noncompliant – MOU required                       revisions will be required to incorporate electronic verification.
    1.    SSOLV
                                                      4.   Noncompliant                                      Transaction times could be decreased adversely impacting
    2.    SAVE                                                                                               customer wait times. Funding required.
                                                      5.   Noncompliant
    3.    DEERS (DOD)
                                                      6.   Noncompliant
    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.       Issuance policy revisions will be required to incorporate electronic
                                                                                                     verification. Transaction times could be decreased adversely impacting
                                                     MOU required by September 2005.
                                                                                                     customer wait times. Funding required.

Introduce equipment into system to capture           Programming changes will be necessitated.       Issuance policy revisions will be required to incorporate electronic
digital images of identity source documents so       Additional    equipment    and    computer      verification. Transaction times could be decreased adversely impacting
that images can be retained in electronic storage    hardware/software requirements.    Counter      customer wait times. BMV would be required to house an additional 30+
in a transferable format                             space requirements and power supply sources     million images annually. Significant funding is required to implement
                                                     may be impacted.                                for 216 satellite offices.

Retain paper copies of source documents for a        On-site storage space requirements would        Policy revisions will be required to incorporate additional storage space.
minimum of 7 years or images of source               increase.                                       Office square footage requirements will need to be revisited.
documents presented for a minimum of 10 years
                                                     Computer image storage requirements are
                                                     increased.

Subject each person applying for a driver’s          Already in compliance; however, the Amish do    Licenses/ID cards produced without photos would require “not
license or identification card to mandatory facial   not have photos produced on license/ID cards.   acceptable for federal purpose” printed somewhere on the cards.
       REAL ID ACT REQUIREMENT                                         IMPACT                                                       ASSUMPTIONS
image capture                                                                                            Additional programming required.

Establish an effective procedure to confirm or        Rapid retrieval for massive repository of stored   Additional programming required.
verify a renewing applicant’s information             images.
                                                                                                         Additional computer communications, hardware and software may be
                                                                                                         required.
                                                                                                         Funding required.

In the event that a social security account number    An individual must confirm Social Security         Policy revisions will be required to resolve SSN discrepancies.
is already registered to or associated with another   Number (SSN) with the Social Security
                                                                                                         Additional staffing and training requirements necessitated.
person to which any state has issued a DL/ID          Administration (SSA). If a discrepancy is
card, the state shall resolve the discrepancy and     found, an individual must resolve the issue        Additional training will be required for 216 satellite offices.
take appropriate action                               with SSA.
                                                                                                         Transaction and customer wait times could be adversely impacted.

Check other states if a person already was issued     Noncompliant                                       Only individuals who come to Ohio from out of state and previously held
a DL in another state                                                                                    an Ohio license can be verified electronically.
                                                                                                         Additional programming required.
                                                                                                         Transaction and customer wait times could be adversely impacted.

Ensure physical security of locations where           Compliant                                          Printer ribbons, security laminates and blank cards are secured in locking
DL/ID cards are produced                                                                                 cabinets on a daily basis.

Subject all person’s authorized to manufacture or     Compliant                                          All employees are required to submit to background checks through the
produce DL/ID cards to appropriate security                                                              Ohio Bureau of Criminal Identification and Investigation (BCII) prior to
clearance requirements                                                                                   issuing any licenses and ID cards.

Establish fraudulent document recognition             Noncompliant with AAMVA standard.                  BMV Investigations compiled and conducts fraudulent documents
training programs for appropriate employees                                                              training to local law enforcement agencies, courts, and all satellite license
engaged in the issuance of DL/ID cards                                                                   agency offices.
                                                                                                         Development of new presentation and training program required.
                                                                                                         Funding required.

Limit period of validity of DL/ID cards that are      Compliant (4-year license expiration currently)    N/A
not temporary to a period not exceeding 8 years
       REAL ID ACT REQUIREMENT                                        IMPACT                                            ASSUMPTIONS
Alternative document design if it does not meet       Compliant                                 N/A
federal standard

Legal Presence Requirement                            Compliant                                 N/A

Provide electronic access to all other states to      Noncompliant                              Additional programming required.
information contained in the motor vehicle
                                                                                                Funding required.
database of the state

Maintain a state motor vehicle database that          Compliant                                 N/A
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                                              Noncompliant – Ohio presently has legal   Additional programming required.
                                                      presence requirements
Development and issuance of a certificate of                                                    Additional computer hardware/software may be required.
driving – not for federal identification purposes –
                                                                                                Funding required.
for those who cannot prove lawful presence.


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                                           ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing         None. Oklahoma is already in compliance.
System (in Record, on Document)

Have following data elements/features on the            Minimal. Oklahoma is already in compliance,         Rules will define "address of principle residence".
document:                                               with the exception of the address of principle      Rules will take into account persons who reside in
                                                        residence. We currently collect both the            more than one state (i.e., "snowbirds", students),
    1.          Full Legal Name                         residence address and mailing address, but state    but who wish to maintain Oklahoma state as their
    2.          Person’s Date of Birth                  law requires the mailing address to appear on the   home state.
                                                        DL/ID card. To become compliant will require
    3.          Person’s Gender                         change in state law and internal programming
                                                        changes.
    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        None. Oklahoma is already compliant in practice
stay to expiration of DL/ID card (or issuance for no    (see next item).
more than 1 year)
            REAL ID ACT REQUIREMENT                                           IMPACT                                          ASSUMPTIONS
Amending card design to show/indicate that it is a        Minimal, although will require changes in law,     Rules will not make burdensome demands on
temporary document with a “different than usual”          programming, and design.                           design and content.
expiration date

Verification at Source:
Enabling your system to electronically verify
documentation with:
 1. SSOLV
 2. SAVE



 3. DEERS (DOD)
                                                          Significant. Even with the assumptions, startup    AAMVA will develop software interfaces to others
 4. Other jurisdiction (DL/ID card)
                                                          and ongoing funding for equipment and              systems in the same manner as SSLOV. Federal
 5. Birth certificate                                     personnel time will be required for Oklahoma to    agencies will cooperate with states. All states will
                                                          implement and develop interfaces to these          provide online/electronic birth certificate
 6. Other…i.e. third party vendors                        databases.                                         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    AAMVA will develop software interfaces SAVE in
                                                          and ongoing funding for equipment and              the same manner as SSLOV.
                                                          personnel time will be required for Oklahoma to
                                                          implement and develop interface to these
                                                          database.

Introduce equipment into system to capture digital        Significant. With about 70 examination sites and
images of identity source documents so that images        280 third party issuance sites, each site would
can be retained in electronic storage in a transferable   need to be equipped with a system capable of
format                                                    capturing and digitizing these source documents.
                                                          Our current DL/ID vendor has a system which
                                                          complies with many requirements of the Real ID
            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             None. Oklahoma is already in compliance.
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    None. Oklahoma is already in compliance.
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a   Unknown until assumptions are addressed. Non-       Rules will define "effective procedure" and explain
renewing applicant’s information                          CDL renewals are done by third parties with no      "confirm or verify". Will not require the issuance of
                                                          on-site oversight by the state. CDL renewals are    a temporary license while information is verified,
                                                          done by state Examiners, who will be able to        with a permanent license issued later from a
                                                          verify CDL renewals with equipment and              central site.
                                                          procedures required for initial source document
                                                          verification.

In the event that a social security account number is     Unknown until assumptions are addressed. What       Rules will address how the applicant is to be
already registered to or associated with another          Oklahoma has required the applicant to resolve is   treated until discrepancy is resolved (temporary
person to which any state has issued a DL/ID card,        now being put on the state to resolve.              card or denied). The discrepancy can be resolved
the state shall resolve the discrepancy and take                                                              through SSA.
appropriate action

Check other states if a person already was issued a       Unknown until assumptions are addressed, but        A driver pointer system for all licensees will
DL in another state                                       probably significant.                               developed, and all states will participate. Rules
                                                                                                              will provide detailed procedures.



Ensure physical security of locations where DL/ID         Significant, even before assumptions are            Rules will define "physical security".
cards are produced                                        addressed. Oklahoma has 280 third party
                                                          issuance sites. This requirement may cause
                                                          implementation of alternate issuance procedures.

Subject all person’s authorized to manufacture or         Significant, even before assumptions are            Rules will define "appropriate security clearance
produce DL/ID cards to appropriate security               addressed. Oklahoma has 280 third party             requirements".
            REAL ID ACT REQUIREMENT                                        IMPACT                                           ASSUMPTIONS
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      Significant, even before assumptions are           Rules will define "fraudulent document recognition
programs for appropriate employees engaged in the       addressed. Apparently the Real ID Act makes        training programs". Each state's training must be
issuance of DL/ID cards                                 the assumption that document verification and      the same. Rules will allow document verification
                                                        DL/ID issuance are done at the same location or    by state employees and DL/ID issuance by third
                                                        at least by the same entity. This is not true in   party vendors with no on-site oversight.
                                                        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    None. Oklahoma is in compliance.
temporary to a period not exceeding 8 years

Alternative document design if it does not meet         Unknown until assumptions are addressed.           Rules will establish a federal standard.
federal standard                                        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        Unknown until assumptions are addressed since      Rules will clarify how this requirement is different
information contained in the motor vehicle database     a nationwide system already exists.                from the current availability with NLETS, which
of the state                                                                                               allows for access to any driver's driving record
                                                                                                           from any state.

Maintain a state motor vehicle database that contains   None. Oklahoma is in compliance.
            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                                                  Oklahoma does not foresee implementing this   Rules will not require use of this option.
                                                          option.
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?

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                                                ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System     Requires rule change.                                         AAMVA standards for legal name (125 characters)
(in Record, on Document)                                   Requires system changes to allow for more characters.         will be required as specified in the Security
                                                                                                                         Framework and DLA.

Have following data elements/features on the document:     Mostly compliant.
    82. Full Legal Name                                    1. Requires rule change to use full legal name                1. Federal rulemaking may further clarify name
                                                              Requires System Changes to allow for more characters       specifications and whether or not names can be
    83. Person’s Date of Birth
                                                                                                                         truncated on the actual driver license if too long.
    84. Person’s Gender                                                                                                  Projected impacts are based on assumptions that
                                                                                                                         federal rulemaking mirror the requirements as
    85. Person’s DL or ID Card Number                                                                                    defined in the Security Framework. Name
    86. Digital Photograph of Person (and retention)                                                                     collection, use and maintenance procedures
                                                           6. Requires statute change. Current statute allows for        (Appendix 14-7.1-03) Card specifications
    87. Person’s Address of Principle Residence                                                                          (Appendix 17-7.3-05)
                                                           police officers and eligible employees to use their agency
    88. Person’s Signature                                 address.
                                                                                                                         6. Federal rulemaking may allow for police
    89. Physical Security Features to prevent tampering,                                                                 officers and eligible employees to use their agency
        counterfeiting or duplication                                                                                    address.
    90. Common Machine Readable Technology:
                                                           9. May require statute or policy change depending on the
                                                           federal rule restrictions on the data availability and use.   9. Federal rulemaking may define additional data
                                                              May require new card format depending on technology        element requirements for common machine-
                                                           chosen. We currently have 1D and 2D.                          readable technology than we use currently.

Introduce temporary DL/ID cards and tying end of stay to   Requires statute change.
expiration of DL/ID card (or issuance for no more than 1   Requires system changes.
year)                                                      Requires additional FTE.
                                                           Unfunded fiscal impact.
           REAL ID ACT REQUIREMENT                                           IMPACT                                             ASSUMPTIONS
Amending card design to show/indicate that it is a   Requires system changes.
temporary document with a “different than usual”     If only adding “temporary” and changing expiration date,
expiration date                                      will not need new vendor contract.
                                                     Unfunded fiscal impact.

Verification at Source:                              1. Requires Memorandum of Agreement (MOA)                    General - Federal rulemaking may need to define
                                                        Requires system changes to use SSOLV                      “verification”. Does all verification have to be
Enabling your system to electronically verify
                                                        Requires procedure changes.                               done electronically?
documentation with:
                                                        Requires additional FTE to verify
 1. SSOLV (SSN Verification)                            Requires legislative direction to verify for all
                                                     transactions.
 2. SAVE (Alien Registration # Verification)            Unfunded fiscal impact.
 3. DEERS (DOD) (Military Common Access Card         2. Requires rule or policy change.
Verification)                                           Requires MOA.
 4. Other jurisdiction (DL/ID card)                     Requires system changes to use SAVE
                                                        Requires procedure change.
 5. Birth certificate                                   Requires additional FTE to verify.
 6. Other…i.e. third party vendors                      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.                                  4. Homeland Security and/or AAMVA will need to
                                                        Requires procedure change.                                develop system connections for states to hook up to
                                                        Requires rule or policy change.                           for verifying other jurisdictions DL/ID cards.
                                                        Unfunded fiscal impact.
                                                     5. Requires system to easily access birth certificate
                                                     information.
                                                        Possible system changes.                                  5. Homeland Security and/or AAMVA will need to
                                                        Requires procedure change.                                develop system connections for states to hook up to
                                                        Requires rule or policy change.                           for verifying birth certificates.
                                                        Unfunded fiscal impact.
           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    Requires policy or rule changes.                              Federal rulemaking will be needed to clarify this
of identity source documents so that images can be           Requires purchase of new equipment                            requirement.
retained in electronic storage in a transferable format      Requires system changes to capture/store document images.
                                                             Requires additional FTE.
                                                             Unfunded fiscal impact.

Retain paper copies of source documents for a minimum        Requires rule or policy change. Do not retain copies of       Federal rulemaking will clarify. Can this process
of 7 years or images of source documents presented for a     identity documents now.                                       be done instead of capturing documents digitally
minimum of 10 years                                          Requires purchase of new equipment.                           and have state still be in compliance with the law.
                                                             Requires additional FTE.
                                                             Unfunded fiscal impact.

Subject each person applying for a driver’s license or       Requires a process change to take photo of person at
identification card to mandatory facial image capture        beginning of process.
                                                             Requires system changes.

Establish an effective procedure to confirm or verify a      No impact. We currently have a process to verify a persons    While we assume we are already in compliance, we
renewing applicant’s information                             identity at renewal time.                                     will not know for certain until federal rulemaking is
                                                                                                                           completed.

In the event that a social security account number is        Requires a process change.                                    Federal rule making may further define what
already registered to or associated with another person to   Requires additional FTE.                                      specific action a state is required to take.
which any state has issued a DL/ID card, the state shall     Unfunded fiscal impact.
resolve the discrepancy and take appropriate action

Check other states if a person already was issued a DL in    Need system (like CDLIS) that shows licenses in other         Federal rulemaking may clarify this requirement.
another state                                                states.                                                       Homeland Security/AAMVA will develop or
                                                             Cannot be done today.                                         revamp a system like CDLIS or PDPS.

Ensure physical security of locations where DL/ID cards      We currently have security procedures in place to make our    Federal rulemaking may specify details that would
are produced                                                 issuing offices and materials secure. We will only be         have more impact.
                                                             impacted if federal rules require specifications we are not
           REAL ID ACT REQUIREMENT                                                     IMPACT                                             ASSUMPTIONS
                                                               currently doing.

Subject all person’s authorized to manufacture or produce      Requires rule/policy changes.                               Federal rulemaking may clarify the extent to which
DL/ID cards to appropriate security clearance                  May require Union contractual agreements/change.            security checks will be required.
requirements                                                   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.

Establish fraudulent document recognition training             Currently do fraudulent document training. Possible         Federal rulemaking may clarify the extent of the
programs for appropriate employees engaged in the              changes to the training depending upon the federal rules.   fraudulent document training.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Requires system changes.                                    Federal rulemaking may clarify this requirement.
temporary to a period not exceeding 8 years                    Oregon DL/ID cards are valid for 8 years.

Alternative document design if it does not meet federal        Requires system changes. Current contract with vendor
standard                                                       allows for new card design.

Legal Presence Requirement                                     Requires statute change.                                    Federal rulemaking will clarify what is necessary to
                                                               Requires system changes.                                    prove legal presence.
                                                               Requires additional FTE.
                                                               Unfunded fiscal impact.

Provide electronic access to all other states to information   Requires statute changes.                                   Federal rulemaking will clarify information that
contained in the motor vehicle database of the state           Requires system changes.                                    needs to be available for states to see. AAMVA
                                                               Requires rule or policy change.                             will have an automated system to view or send the
                                                               Unfunded fiscal impact.                                     information.
                                                                                                                           Federal rulemaking may specify more data than we
Maintain a state motor vehicle database that contains at a     Possible rule or policy change.
                                                                                                                           are currently collecting or retaining.
minimum:
         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                                                  IMPACT                                ASSUMPTIONS
Development and issuance of a certificate of driving – not   Requires a new card design.
for federal identification purposes – for those who cannot   Unfunded fiscal impact.
prove lawful presence.



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                                                  IMPACT                                                  ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing         Requires extensive system modifications going from 35 bytes     No assumption
System (in Record, on Document)                         to a 125 byte field to an existing legacy system. Cost to
                                                        Pennsylvania – Please refer to Exhibit A - #2.

Have following data elements/features on the                1.   Requiring the full legal name will be a challenge to   1. No assumption
document:                                                        fit on the existing driver’s license.
                                                                                                                        2. N/A
    91. Full Legal Name                                     2.   Pennsylvania complies
                                                                                                                        3. N/A
    92. Person’s Date of Birth                              3.   Pennsylvania complies
                                                                                                                        4. N/A
    93. Person’s Gender                                     4.   Pennsylvania complies
                                                                                                                        5. Assumes that the law does not provide for religious
    94. Person’s DL or ID Card Number                       5.   Eliminates all valid-without-photo products. As        photo exemptions.
                                                                 well, may not be able to continue using temporary
    95. Digital Photograph of Person (and                                                                               6. N/A
                                                                 camera card as a valid license.
        retention)
                                                                                                                        7. N/A
                                                            6.   Pennsylvania complies
    96. Person’s Address of Principle Residence
                                                                                                                        8. Assumes that Homeland Security adopts AAMVA’s
                                                            7.   Pennsylvania complies
    97. Person’s Signature                                                                                              license standard.
                                                            8.   Pennsylvania currently does not have an OVD in
    98. Physical Security Features to prevent                                                                           9. Assumes that Homeland Security adopts the AAMVA
                                                                 license core.
        tampering, counterfeiting or duplication                                                                        standard to be used for magnetic stripes and 2D
                                                            9.   Pennsylvania will have to change the format of its     barcodes.
    99. Common Machine Readable Technology:
                                                                 magnetic stripe and 2D barcode.
                                                            Cost to Pennsylvania – Please refer to Exhibit A - #2

Introduce temporary DL/ID cards and tying end of        Pennsylvania already ties end of stay to license expiration.    N/A
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      Currently, the license expiration date coincides with the       Pennsylvania’s unique expiry date identifies, for law
temporary document with a “different than usual”        temporary INS credentials. This unique expiration date is       enforcement, that the product is temporary.
expiration date                                         used as a visual indicator for law enforcement. Pennsylvania
        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                  2. Requires a robust online interactive system to             2.   Assumes that SAVE information/data is up-to-
documentation with:                                            support efficient processing of customers.                         date and system is robust.
 1. SSOLV                                                      3. Need clarification                                         3.   N/A
 2. SAVE                                                       4. Pennsylvania does not accept other state’s                 4.   None
                                                               license/Id cards as source identification documents.
 3. DEERS (DOD)                                                                                                              5.   Homeland Security will host/develop the
                                                               5. Requires the development of an automated                        automated nationwide birth certificate
 4. Other jurisdiction (DL/ID card)
                                                               nationwide birth certificate verification system.                  verification system.
 5. Birth certificate
                                                               6. Integrate 3rd party address verification into              6.   The US Postal Service software for address
 6. Other…i.e. third party vendors                             licensing systems.                                                 verification in limited. A third party vendor
                                                                                                                                  could link person’s name to address.
                                                               Cost to Pennsylvania – please refer to Exhibit A - #2
                                                               and #3

Developing access capability to SAVE system                    Requires system modifications to support an               The SAVE system can provide sub-second response for
                                                               interactive online verification. Cost to Pennsylvania –   on-line verification to all states.
                                                               Please refer to Exhibit A - #2.

Introduce equipment into system to capture digital images      Will need imaging equipment and system                    AAMVA will provide the infrastructure to electronically
of identity source documents so that images can be             infrastructure at front line to capture, electronically   transfer images state to state. In addition, AAMVA
retained in electronic storage in a transferable format        transfer state-to-state, and store images. Cost to        assume the role for standardization. Standards are
                                                               Pennsylvania – Please refer to Exhibit A - #1 and #3.     adopted on or before May, 2007.

Retain paper copies of source documents for a minimum of       Pennsylvania will have to acquire more electronic         None
7 years or images of source documents presented for a          storage space. Cost to Pennsylvania – Please refer to
minimum of 10 years                                            Exhibit A - #2

Subject each person applying for a driver’s license or         Pennsylvania complies with the exception of the           Assumes that the law does not provide for religious
identification card to mandatory facial image capture          valid-without-photo driver’s license.                     exemptions.
Establish an effective procedure to confirm or verify a        If acceptable to only verify social security number, the   That social security verification will be accepted, and the
renewing applicant’s information                               impact would be minimal. If required to verify all         social security number has already been verified through
                                                               source documents. Cost to Pennsylvania – Please            SSOLV, and the results maintained.
                                                               refer to Exhibit A - #1.

In the event that a social security account number is          How will we determine that social security needs to        Each state will only issue a product for applicants whose
already registered to or associated with another person to     provide additional information? Currently, the             social security number verifies with the Social Security
which any state has issued a DL/ID card, the state shall       customer resolves discrepancies with social security       Administration.
resolve the discrepancy and take appropriate action            prior to a product being issued. This would be
                                                               impossible for the states to resolve.


Check other states if a person already was issued a DL in      The development of an all state non-commercial              The all state non-commercial driver’s license pointer
another state                                                  driver’s license pointer system and the integration of      system will be in place by the effective date.
                                                               the system into Pennsylvania’s system. Cost to
                                                               Pennsylvania – Please refer to Exhibit A - #2.

Ensure physical security of locations where DL/ID cards        Pennsylvania complies with numerous security                N/A
are produced                                                   measures such as alarms, motion detectors, back-up
                                                               battery systems, etc.

Subject all person’s authorized to manufacture or produce      Pennsylvania complies – criminal history checks are         N/A
DL/ID cards to appropriate security clearance requirements     completed on all employees and contractors.

Establish fraudulent document recognition training             Pennsylvania complies                                       AAMVA fraud training is acceptable.
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           Pennsylvania complies – currently valid for only 4          N/A
temporary to a period not exceeding 8 years                    years.

Alternative document design if it does not meet federal        Pennsylvania complies                                       In compliance
standard

Legal Presence Requirement                                     Pennsylvania complies                                       N/A

Provide electronic access to all other states to information   The development of an all state non-commercial              The all state non-commercial driver’s license pointer
contained in the motor vehicle database of the state           driver’s license pointer system and the integration of      system will be in place by the effective date.
                                                               the system into Pennsylvania’s system. Cost to
                                                             Pennsylvania – Please refer to Exhibit A - #2.
                                                                                                                      Does not require states to transfer driver history when
Maintain a state motor vehicle database that contains at a   Pennsylvania complies with the exception of full legal
                                                                                                                      transferring a license from another state.
minimum:                                                     name which will require extensive system
                                                             modifications to an existing legacy system. Cost to
           All data fields printed on DL/ID cards
                                                             Pennsylvania – Please refer to Exhibit A - #2.
         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               Pennsylvania                                        COSTS
                             IMPACT           FFY       FFY        FFY      FFY    FFY    FFY    FFY      FFY    TOTA
                                               06        07         08       09     10     11     12       13      L
1. Re-                 •    Additional
credentialing of all        contracted
existing drivers            staff on front
                            lines (200)
                       •    Additional
                                                       $10.15               $14    $14    $14                    $68.1
                            contracted         $0                $14 mil                         $2 mil   $0
                                                         mil                mil    mil    mil                    5 mil
                            facility and
                            equipment
                            needs (10
                            locations)

2. System              •    Will require
modifications               connection
                            and
                            transaction
                            costs for
                            electronic
                            verification               Legacy     Legacy
                       •    Capturing and              System     System
                            storing full     Legacy    Develop     Post
                            legal name       System     ment     Impleme
                       •    Image            Develop              ntation
                            storage           ment                Support
                                                                            $1.3   $1.3   $1.3   $1.3     $1.3   $16.5
                       •    Scanning                    $8.75
                                                                             mil    mil    mil    mil      mil   5 mil
                            equipment for                mil     $1.3 mil
                            Driver
                            License
                            Centers (250)
                       •    Interstate
                            Data
                            Exchange –
                       this will be
                       included in
                       system
                       modifications
                       as a part of
                       the system re-
                       write (Legacy
                       System)

3. Changes to      •   Temporary
license document       indicator for
                       non-US
                       citizens
                   •   DHS
                       standardizatio
                       n of security                                   $.05    $.05    $.05    $.05    $.05    $.35
                                          $0     $.05 mil   $.05 mil
                       features (e.g.                                   mil     mil     mil     mil     mil     mil
                       Optical
                       Variable
                       Device)
                   •   Contractual
                       costs

                                                 Legacy
                                                              Post
                                                 System
                                        Legacy              Legacy                                             TOTA
                                                 Develo
                                        System              Support    $15.3   $15.3   $15.3   $3.35   $1.35     L
TOTAL                                            pment
                                        Develo                and      5 mil   5 mil   5 mil    mil     mil    $85.0
                                                  and
                                        pment                $15.35                                              5
                                                 $18.95
                                                               mil
                                                   mil
                                                               RHODE ISLAND

                                                     Jurisdiction Impact Analysis Real ID Act

           REAL ID ACT REQUIREMENT                                              IMPACT                            ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      None
(in Record, on Document)

Have following data elements/features on the document:      None
    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    Technological / Financial            Software program changes to DMV computer system
expiration of DL/ID card (or issuance for no more than 1
year)

Amending card design to show/indicate that it is a          Technological / Financial            Software program changes to DMV computer
temporary document with a “different than usual”                                                 system and program changes to vendor system
                                                            Personnel – Training for DMV & Law
expiration date
                                                            Enforcement

Verification at Source:                                     Technological / Financial            The DMV’s antiquated computer system & database
                                                                                                 would inhibit the ability to interface with other
Enabling your system to electronically verify
                                                                                                 jurisdictions. DMV would be required to upgrade
           REAL ID ACT REQUIREMENT                                               IMPACT                     ASSUMPTIONS
documentation with:                                                                       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    Financial                    Purchase of image equipment (hardware & software) and
of identity source documents so that images can be                                        server for storage.
retained in electronic storage in a transferable format

Retain paper copies of source documents for a minimum        Financial                    Paper copies – rental of storage area
of 7 years or images of source documents presented for a
                                                                                          Image document – purchase of software & hardware for
minimum of 10 years
                                                                                          storage.

Subject each person applying for a driver’s license or       None
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        None
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    None
another state

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      None                         Requirement of vendor.
DL/ID cards to appropriate security clearance
requirements

Establish fraudulent document recognition training             Financial / Personnel        DMV would need to hirer law enforcement personnel to
programs for appropriate employees engaged in the                                           verify documents.
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           None
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        Technological / Financial    Systems change for both DMV and vendor.
standard

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   Technological / Financial    The DMV’s antiquated computer system & database
contained in the motor vehicle database of the state                                        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     None
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       Technological / Financial    Systems change for both DMV and vendor.
Development and issuance of a certificate of driving – not
for federal identification purposes – for those who cannot
           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                                                 IMPACT                                                 ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      Currently capture last, first and middle name, with suffix.   Need more clarification on what is required of “full
(in Record, on Document)                                    Last name field currently limited to _____ characters,        legal name”
                                                            First name ________ characters, _________middle name
                                                            _________ characters. System can accept hyphenated
                                                            names, up to character limitation. Characters limited by
                                                            available space on DL/ID credential.

Have following data elements/features on the document:                                                                    N/a
    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,   The following features are already on the credential
         counterfeiting or duplication                      _______________________________________
    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    Already tying expiration to end of stay for foreign           N/A
expiration of DL/ID card (or issuance for no more than 1    nationals, with a minimum one year expiration date
year)

Amending card design to show/indicate that it is a          Will require ________________                                 Reconfiguration of DL issuance equipment
temporary document with a “different than usual”
                                                            Estimated fiscal impact:                                      Training $100/employee x 700 employees
expiration date
           REAL ID ACT REQUIREMENT                                      IMPACT                                                ASSUMPTIONS
                                                Training $70,000

Verification at Source:
Enabling your system to electronically verify
documentation with:
                                                1. Currently real time for CDL. Going real time for all       SSOLV only on original DL/ID 30 seconds x _____
  1.   SSOLV                                    DL will increase processing time for each transaction by      original DLs per year
                                                about 30 seconds. Will increase repeat visits for
                                                customers not matching.

  2.   SAVE
                                                                                                              2. increase processing time for each original foreign
                                                  2.   Not currently connected – increase processing time
                                                                                                              national transaction by up to 1 minute. 1 minute x
                                                       since it requires manual entry for each transaction
                                                                                                              ____ original Non-citizen applications/year.
                                                       total processing cost _______________
  3.   DEERS (DOD)
                                                                                                              System update cost calculation:
                                                       System update costs _______________
                                                                                                              Concerns: System not up to date… months behind.
                                                  3.   Allow use of military ID to verify identity only for
                                                                                                              Have tried to use it to verify foreign nationals…
                                                       people born before 1918 and then only in
                                                                                                              totally unreliable.
                                                       conjunction with another identify document.
                                                       Impact negligible, more so as time goes forward.       Need system to system capability to increase
                                                       Don’t currently have access to DEERS system.           efficiency
 4. Other jurisdiction (DL/ID card)                    System update costs _________________                    3.   increase processing time for each original DL
 5. Birth certificate                                                                                                for which the customer uses military ID as
                                                                                                                     identification.
 6. Other…i.e. third party vendors                4.   Need to tie in through AAMVA’s new system
                                                                                                                4.   Assume that state to state verification will be
                                                       System update costs _______________                           through AAMVA
                                                                                                                5.   Not all states have electronic verification
                                                                                                                     capabilities – if manual process is required, the
                                                  5.   Tie in with states’ birth certificate databases
                                                                                                                     impact will include 5 additional FTE’s
                                                       System update costs _______________                           @$22,000/year
           REAL ID ACT REQUIREMENT                                                   IMPACT                                              ASSUMPTIONS
Developing access capability to SAVE system                   Need info here



Introduce equipment into system to capture digital images     Need info here
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      Additional storage hardware for document management       ? additional jukeboxes?
7 years or images of source documents presented for a         system
                                                                                                                        Additional high speed scanners
minimum of 10 years
                                                              _______________
                                                                                                                        5 FTE @ 20,000/year
                                                              Additional scanning staff

Subject each person applying for a driver’s license or        Already required – no impact (do we allow people to not
identification card to mandatory facial image capture         have their picture taken for religious reasons?)

Establish an effective procedure to confirm or verify a       Will require two step process or back end verification.   20 FTE @ $22,000/year
renewing applicant’s information                              Additional verification resources $440,000
                                                                                                                        Training $300 x 100 employees
                                                              Policy change
                                                              Process change
                                                              Training - $30,000

In the event that a social security account number is         Additional staff to resolve discrepancies with SS         10 FTE @ $22,000/year
already registered to or associated with another person to    administration and other primary agencies
which any state has issued a DL/ID card, the state shall
                                                              $$220,000
resolve the discrepancy and take appropriate action

Check other states if a person already was issued a DL in     Through PDPS and CDLIS?
another state

Ensure physical security of locations where DL/ID cards       Increased building security ___________                   Cameras ________
are produced
                                                                                                                        Safes in all offices?
            REAL ID ACT REQUIREMENT                                                    IMPACT                                             ASSUMPTIONS
Subject all person’s authorized to manufacture or produce       Already conduct local criminal background checks. If       $25/employee x ________current employees
DL/ID cards to appropriate security clearance requirements      additional FBI background checks are required,
                                                                                                                           $25/employee x _______ new employees per year
                                                                _________________

Establish fraudulent document recognition training              Expand fraud training $181,000                             Additional trainers 2 FTE @ $31,000/year
programs for appropriate employees engaged in the
                                                                                                                           Employee training cost $300/person x 500
issuance of DL/ID cards
                                                                                                                           employees/year



Limit period of validity of DL/ID cards that are not            Requires statuatory change
temporary to a period not exceeding 8 years
                                                                Program change

Alternative document design if it does not meet federal         Statuatory Change
standard (this requirement is to clearly state that DL/ID
                                                                Policy Change
cannot be used for identification purposes if we can’t meet
all standards)                                                  Program change ___________



Legal Presence Requirement verifying citizen’s legal            Statutory change
address and foreign citizen’s authorization to remain in this
                                                                Policy and process change
county. Required to use the SAVE system. Requires
periodic confirmation (after original issue)
                                                                Training $210,000                                          Training cost $300 x 700 employees

Provide electronic access to all other states to information    System requirements to link all state databases (through
contained in the motor vehicle database of the state            AAMVA?)
Requires that we meet DLA requirements for information
that must be maintained on the AAMVA database

Maintain a state motor vehicle database that contains at a      Need info here
minimum:
         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                                                     Could be paper document or separate credential   $100/employee x 100 employees
Development and issuance of a certificate of driving – not   Statutory change
for federal identification purposes – for those who cannot
                                                             Policy change
prove lawful presence.
                                                             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                                                          IMPACT                                                  ASSUMPTIONS
        REQUIREMENT
Introduce Full Legal Name into       SD already has the capability to include the full legal name in the DL system, both on the   This is assuming that we are
Driver Licensing System (in          Record and on the Document.                                                                  allowed to use the naming
Record, on Document)                                                                                                              conventions that we are
                                     May need to change SDCL 31-12-17.10, which states that the DL shall contain the full         currently using. If there is a
                                                                                                                                  change to the naming
                                     legal name or any other name lawfully taken. By policy, full legal name is used but there
                                                                                                                                  conventions in the system,
                                     are rare occasions when another name may be used if the person certifies that they are       we may need to make
                                     using the name for lawful purposes.                                                          system changes.



Have following data                  May need to change SDCL 31-12-17.10, which states that the DL shall contain the full
elements/features on the             legal name or any other name lawfully taken. By policy, full legal name is used but there
document:                            are rare occasions when another name may be used if the person certifies that they are
    118. Full Legal Name             using the name for lawful purposes.
    119. Person’s Date of Birth
                                     Need federal guidance regarding the definition of principal residence. Specifically
    120. Person’s Gender             what should the procedure be for a person who lives in a RV, has chosen a
    121. Person’s DL or ID Card      jurisdiction as their state of domicile but has only a RV park address or a Personal
         Number                      Mail Box Address. Are these types of addresses acceptable? This needs to be
    122. Digital Photograph of       addressed in the regulations.
         Person (and retention)
    123. Person’s Address of         SD DL/ID contains physical security requirements. The federal regulations should
         Principle Residence         state what types of security features must be included on the DL/ID.
    124. Person’s Signature
    125. Physical Security           SD driver licenses and ID cards currently contain a SD barcode that is the standard
         Features to prevent         according to the American Association of Motor Vehicle Administrators (AAMVA) –
         tampering, counterfeiting   Guidance is needed regarding if the AAMVA standard is acceptable, and if the
         or duplication              AAMVA standard is not the common machine readable technology, what is the
    126. Common Machine              common machine readable technology. Guidance is needed to define what the
        REAL ID ACT                                                            IMPACT                                              ASSUMPTIONS
        REQUIREMENT
         Readable Technology:          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        SD currently issues the DL/ID through the duration of stay of the applicant except for
and tying end of stay to expiration    those who have an indefinite status. Currently, those with an indefinite status receive a
of DL/ID card (or issuance for no      full 5 year license.
more than 1 year)
                                       The Regulations should outline specific immigration documents and which ones
                                       should have an issue date of no more than 1 year.

Amending card design to                SD will need to change our programming. The SD DL/ID that have a expiration date less
show/indicate that it is a temporary   than 5 years because the applicant presented a immigration document of less than 5 years
document with a “different than
usual” expiration date
                                       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.

Verification at Source:                Specific federal guidance needed in this area. Is manual verification acceptable?
                                       Manual verification will result in need for additional staff. Electronic processes will
Enabling your system to
electronically verify
                                       require programming and on-going maintenance costs. There is currently not an
documentation with:                    established nationwide system for verifying breeder documents including birth
                                       certificates and passports.
 1. SSOLV
                                       SD is currently working on programming to participate in a pilot funded by the Federal
 2. SAVE                               Motor Carrier Safety Administration (FMCSA) in cooperation with the American
 3. DEERS (DOD)                        Association of Motor Vehicle Administrators (AAMVA.) to verify birth records. Costs
  4. Other jurisdiction (DL/ID         for post pilot are yet to be determined. Currently, SD, MN, ND, and IA are participating
card)                                  in the pilot.
 5. Birth certificate
                                       SD is developing a system to verify SD birth and death records.
                                       1. SD currently utilizes SSOLV.
 6. Other…i.e. third party             2. SAVE is used in limited locations
          REAL ID ACT                                                          IMPACT                                                   ASSUMPTIONS
          REQUIREMENT
vendors                                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        SD has signed a MOU and currently utilizes the SAVE program in areas where the                SD will expand their current
SAVE system                            examiners have access to the internet. This will need to be expanded to all areas – This      utilization of the SAVE
                                                                                                                                     program – assuming that we
                                       will likely be a manual process (Examiner to contact an exam site with internet access to     will be allowed to use the
                                       run the check for them.) Current Cost – initial inquiry 26 cents. Secondary inquiry, if       existing MOU that we
                                       needed 48 cents per inquiry. Current monthly costs run from $50.00 - $75.00 per month         recently entered into.
                                       and are paid by Homeland Security. This will increase slightly to an estimated $100 per
                                       month.

Introduce equipment into system        SD currently copies all immigration documents as well as source documents presented to
to capture digital images of           obtain a commercial driver license with a Hazardous Materials Endorsement. These
identity source documents so that      copies are scanned into a document imaging system and retained in an electronic format.
images can be retained in              Will need to expand the copying, scanning and filing of documents to meet this
electronic storage in a transferable
                                       requirement.
format
                                       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
        REAL ID ACT                                                           IMPACT                                                   ASSUMPTIONS
        REQUIREMENT
                                      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 off-
                                      site. 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         The images are kept for an indefinite period of time. See above for additional costs
documents for a minimum of 7          associated with additional storage space
years or images of source
documents presented for a
minimum of 10 years

Subject each person applying for a    A process/system change will be required to capture a mandatory facial image of each
driver’s license or identification    applicant. Photo is currently only captured if DL/ID is issued. If a person is not issued a
card to mandatory facial image        DL/ID, a photo is not captured.
capture                               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   Guidance needed regarding what the effective procedure is for confirming or
confirm or verify a renewing          verifying a renewing applicant’s information
applicant’s information

In the event that a social security   SD meets this requirement                                                                     This is assuming that the
account number is already                                                                                                           way we handle these
registered to or associated with                                                                                                    situations is deemed
another person to which any state                                                                                                   appropriate. SD works
        REAL ID ACT                                                            IMPACT                                                ASSUMPTIONS
        REQUIREMENT
has issued a DL/ID card, the state                                                                                                through these situations
shall resolve the discrepancy and                                                                                                 currently and if there is
take appropriate action                                                                                                           fraud involved, law
                                                                                                                                  enforcement is contacted.

Check other states if a person       This is not possible at this time as there is no system in place. It seems that to do this   This is with the assumption
already was issued a DL in another   effectively, the Driver Record Information Verification System (DRIVerS) must be             that DRIVerS is the system
state                                                                                                                             that is utilized. Developing
                                     developed.                                                                                   an entire new system would
                                                                                                                                  be way too costly.

Ensure physical security of          SD has security measures in place at driver exam locations. Specific Federal guidance
locations where DL/ID cards are      is needed in this area to determine what steps are necessary to ensure physical
produced                             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   Specific Federal guidance is needed regarding what the background check is to
manufacture or produce DL/ID         consist of.
cards to appropriate security        All new DPS employees are subject to a background check. This will need to be
clearance requirements               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                                                                    IMPACT                                                            ASSUMPTIONS
        REQUIREMENT
recognition training programs for     was developed by AAMVA. This will need to be expanded to the county and city                                    Fraud Document
appropriate employees engaged in      officials that we have partnered with to provide DL services                                                    Recognition Training that
the issuance of DL/ID cards                                                                                                                           was developed by AAMVA
                                      Estimated costs - 3 trainings provided to local government employees – one night stay                           is the recommended course.
                                      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     Not an issue. SD driver licenses and ID cards are valid for 5 years or less.
cards that are not temporary to a
period not exceeding 8 years

Alternative document design if it     We intend to meet the standard. Creating a new design would require system changes and would be costly.
does not meet federal standard

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      This is not possible at this time as there is no system in place. It seems that to do this
other states to information           effectively, the Driver Record Information Verification System (DRIVerS) must be
contained in the motor vehicle
database of the state
                                      developed.

Maintain a state motor vehicle        SD Driver Licensing Database contains required information.
database that contains at a
minimum:
         All data fields printed on
         DL/ID cards
         motor vehicle driver’s
         histories, including motor
         vehicle violations,
        REAL ID ACT                                                                    IMPACT                                                          ASSUMPTIONS
        REQUIREMENT
         suspensions and points on
         licenses

OptionalDevelopment and                This would be costly. Our state law requires a person to be authorized to be in the United States to obtain a
issuance of a certificate of driving   driver license. To change this would require a statute change.
– 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 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                                                IMPACT                                             ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System (in   We need clarification on the number of characters that    Our current programs are limited to 12 characters
Record, on Document)                                         will be allowed. We would need to convert to DB2          for the first name, 12 characters for the middle name
                                                             database as our current record and issuance programs      and 20 characters for the last name. This would not
                                                             are limited.                                              allow for the “full legal name” to be maintained on
                                                                                                                       the record or be printed on the document.
                                                             The cost estimate for conversion is very roughly
                                                             estimated to be between $1 to 2 million.

Have following data elements/features on the document:       We currently meet requirements 2 thru 8.
    127. Full Legal Name                                     On #1, as stated above, we are limited to the number of
                                                             characters that we can store and print on the document
    128. Person’s Date of Birth
                                                             On #9, we currently have 1D and 2D bar codes
    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     This would require legislative changes including fee      We already have a system design that allows for
expiration of DL/ID card (or issuance for no more than 1     structure changes to set up an new classification of      issuance based on documentation presented and
year)                                                        driving privilege. There will be minor program changes    expiration dates based on the documentation. We
                                                             and associated costs. Approximate cost $15,000            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                                                  IMPACT                                            ASSUMPTIONS


Amending card design to show/indicate that it is a temporary   This will be handled as stated above
document with a “different than usual” expiration date

Verification at Source:
Enabling your system to electronically verify documentation
with:
                                                               1. We already utilize the SSOLV system
 1. SSOLV
                                                               2. We are reviewing the MOU for SAVE
 2. SAVE
                                                               3. I am in the process of obtaining information on the
 3. DEERS (DOD)                                                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   A system to fulfil this requirement would have to be     We currently do not capture identity source
identity source documents so that images can be retained in    procured                                                 documents in any manner. We are in the
electronic storage in a transferable format                                                                             processing of writing an RFP for a new digitized
                                                               Cost unknown at this time.
                                                                                                                        issuance system and this might be made part of the
                                                                                                                        contract.

Retain paper copies of source documents for a minimum of 7     None                                                     We anticipate having a system for digital capture of
years or images of source documents presented for a                                                                     identity source documents .
minimum of 10 years

Subject each person applying for a driver’s license or         We currently have a digitized issuance system however,   Currently, drivers over 60 years of age are allowed
identification card to mandatory facial image capture          legislation would be required to delete the exception.   to have “Valid without Photo” driver licenses
            REAL ID ACT REQUIREMENT                                                    IMPACT                                                 ASSUMPTIONS


Establish an effective procedure to confirm or verify a         This could eliminate our Internet and mail renewal
renewing applicant’s information                                programs if the rules require the documentation to be
                                                                presented in person.



In the event that a social security account number is already   We would need more staff at our Helpdesk to resolve            Currently, the applicant is required to resolve any
registered to or associated with another person to which any    these SS # issues. We would also need to receive               SS# discrepancy.
state has issued a DL/ID card, the state shall resolve the      additional information on our SSLOV inquiries.
discrepancy and take appropriate action

Check other states if a person already was issued a DL in       We currently electronically notify the other state that
another state                                                   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     None                                                           We feel that we currently meet this requirement to
produced                                                                                                                       the extent possible.

Subject all person’s authorized to manufacture or produce       Need a clarification on “appropriate security clearance”       Currently all DOS employees including temporaries
DL/ID cards to appropriate security clearance requirements      requirements                                                   undergo a Criminal History background check.
                                                                                                                               County Clerk contractors do not undergo this
                                                                                                                               background check.

Establish fraudulent document recognition training programs      We have already began this process by getting 24              We have 13 one week training sessions in the
for appropriate employees engaged in the issuance of DL/ID      employees certified thru AAMVA’s FDR Train-the-                planning stages which will provide the FDR training
cards                                                           Trainer Program                                                to all our dl field personnel.

Limit period of validity of DL/ID cards that are not            None                                                           We already have a basic 5 year issuance program
temporary to a period not exceeding 8 years                                                                                    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         None                                                           We currently have the CFD design
standard
              REAL ID ACT REQUIREMENT                                                IMPACT                                         ASSUMPTIONS
Legal Presence Requirement                                       None                                                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

Provide electronic access to all other states to information     This would require some major programming changes
contained in the motor vehicle database of the state             estimated at $200,000 to $300,000
                                                                                                                     We currently meet and exceed this requirement
Maintain a state motor vehicle database that contains at a       None
minimum:
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                         None                                                We implemented the Certificate for Driving
                                                                                                                     program in July, 2004
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 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                                ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      Utah allows 15 spaces for the last name, 15 spaces for the
(in Record, on Document)                                    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
                                                            Utah is in compliance with the other items.
    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:

Introduce temporary DL/ID cards and tying end of stay to    Utah will need to write computer programs for the
expiration of DL/ID card (or issuance for no more than 1    temporary DL/ID card and design the format of the card.
year)                                                       We will need statutory authority.

Amending card design to show/indicate that it is a          Utah will need to write computer programs for the
temporary document with a “different than usual”            temporary DL/ID card and design the format of the card.
expiration date                                             We will need statutory authority.
           REAL ID ACT REQUIREMENT                                                    IMPACT                                 ASSUMPTIONS
Verification at Source:                                       Utah is on-line with SSOLV
Enabling your system to electronically verify                 Utah will need to develop applications to verify documents
documentation with:                                           with SAVE, DEERS, birth certificates and other states.
                                                              Program languages and connectivity will be issues. Full
 1. SSOLV
                                                              impact and costs are unknown at this time.
 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     Utah has an optical imagining system at our central
of identity source documents so that images can be retained   facility. We need to expand the capability to include a
in electronic storage in a transferable format                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      Utah does not retain copies of source documents. We will
7 years or images of source documents presented for a         need additional staff at each field office to make copies or
minimum of 10 years                                           capture images of source documents.

Subject each person applying for a driver’s license or        Utah has alternate renewal programs (renewal by mail,
identification card to mandatory facial image capture         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       Utah has alternate renewal programs (renewal by mail,
renewing applicant’s information                              renewal by Internet and valid without photo). If these
                                                              processes are discontinued we will need more FTE’s in our
                                                              field offices.
            REAL ID ACT REQUIREMENT                                                      IMPACT                                ASSUMPTIONS
In the event that a social security account number is already   Under these circumstances our current procedure is to
registered to or associated with another person to which        require the applicant to resolve the issue. If the state is
any state has issued a DL/ID card, the state shall resolve      required to resolve these issues we will need at least one
the discrepancy and take appropriate action                     additional FTE.

Check other states if a person already was issued a DL in       We currently access PDPS and CDLIS.
another state

Ensure physical security of locations where DL/ID cards         There will costs associated if on-site visits are required.
are produced                                                    No impact if this can be accomplished by contract.

Subject all person’s authorized to manufacture or produce       There will be additional costs for necessary background
DL/ID cards to appropriate security clearance requirements      checks.

Establish fraudulent document recognition training              Utah has implemented AAMVA Fraudulent Document
programs for appropriate employees engaged in the               Recognition Program. There are on-going costs for this
issuance of DL/ID cards                                         training.

Limit period of validity of DL/ID cards that are not            In compliance for driver licenses. We will need to change
temporary to a period not exceeding 8 years                     statute for the expiration of ID cards.

Alternative document design if it does not meet federal         There will be costs for this requirement. Those costs will
standard                                                        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    There will be costs associated with this function. Does this
contained in the motor vehicle database of the state            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      Utah’s database does contain all data fields printed on
minimum:                                                        DL/ID cards. We will need programming changes if
                                                                modifications are made that require additional information
         All data fields printed on DL/ID cards
                                                                and to accommodate longer name fields.
           REAL ID ACT REQUIREMENT                                                   IMPACT                                 ASSUMPTIONS
        Motor vehicle driver’s histories, including motor    Utah driver’s histories include violations and suspensions.
        vehicle violations, suspensions and points on        Point systems are unique to each state, how useful will this
        licenses                                             information be to other states?

Optional                                                     Utah recently passed a law allowing a driving privilege
                                                             card to applicants who do not have legal presence.
Development and issuance of a certificate of driving – not
                                                             However this document is not valid identification for a
for federal identification purposes – for those who cannot
                                                             Utah government entity. We would need legislative
prove lawful presence.
                                                             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                                                IMPACT                                                   ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      This will require a system redesign. We currently can        We are currently in the process of getting a contract for a
(in Record, on Document)                                    only capture 25 characters for an applicant’s name.          new online system. Expanding the number of characters
                                                                                                                         we can capture will be part of the design.

Have following data elements/features on the document:          1.   We capture up to 25 characters.                     Regarding #1 - If the Real ID Act is similar to the DL/ID
                                                                                                                         Security Framework which proposes that we have room
    145. Full Legal Name                                        2.   Yes
                                                                                                                         to capture 100 characters for an individual’s full legal
    146. Person’s Date of Birth                                 3.   Yes                                                 name, it will be impossible for use to do this with our
                                                                                                                         current system. We would not be able to implement this
    147. Person’s Gender                                        4.   Yes
                                                                                                                         data element/feature until we get a new system.
    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.         Regarding #6 – We question what is AAMVA’s and
    150. Person’s Address of Principle Residence                7.   Yes                                                 Real ID’s definition of “Principal Residence”. Vermont
                                                                                                                         has definitions for both Mailing and Legal Addresses,
    151. Person’s Signature                                     8.   Yes                                                 however, they may or may not meet those required in
    152. Physical Security Features to prevent tampering,       9.   The Bar Code on our licenses/permits meet           this Act.
         counterfeiting or duplication                               the minimum AAMVA standards.
                                                                     Everything that is on the front of the license
    153. Common Machine Readable Technology:                                                                             Regarding #9 – We question whether or not our Bar
                                                                     is in the bar code with the exception of the
                                                                     signature and photo.                                Codes and Mag Stripes meet AAMVA’s and/or Real
                                                                                                                         ID’s standards.
                                                                     The Mag Stripe does not meet the minimum
                                                                     AAMVA standards. The Mag Stripe
                                                                     contains only the name, Date of Birth, height
                                                                     and weight.

Introduce temporary DL/ID cards and tying end of stay to    We do not issue “Temporary Licenses”, however, the           If forced to issue “Temporary Licenses”, it may require
expiration of DL/ID card (or issuance for no more than 1    expiration date of the license is tied to the end of stay.   the passage of legislation.
year)

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                                                IMPACT                                                ASSUMPTIONS
temporary document with a “different than usual”            licenses. The expiration date is the end of stay           creation of a new license. This would be very costly and
expiration date                                             date.                                                      may require the passage of legislation.



           REAL ID ACT REQUIREMENT                                                IMPACT                                                ASSUMPTIONS
Verification at Source:                                         1.   SSOLV – We are almost done with this and          The SAVE and DEERS (DOD) systems would be a big
                                                                     will be implemented within a month or two.        issue. We do not have the funds or personnel to
Enabling your system to electronically verify
                                                                                                                       implement these systems. It would require the hiring of
documentation with:                                             2.   SAVE – We do not use this system.
                                                                                                                       contractors to implement these systems. It would also
 1. SSOLV                                                       3.   DEERS (DOD) – We do not use this system.          require the dedication of personnel to work on these
                                                                                                                       systems with the contractors until the systems are
 2. SAVE                                                        4.   Other jurisdiction (DL/ID card) – We collect      implemented. In return, temporary employees would
                                                                     Driver Licenses from other jurisdictions and      need to be hired to replace those employees dedicated to
 3. DEERS (DOD)
                                                                     we periodically send them back to those
                                                                                                                       this project.
 4. Other jurisdiction (DL/ID card)                                  jurisdictions, who would then mail us paper
                                                                     copies of their driving record. We would
 5. Birth certificate                                                then take action if a suspension exists in that
 6. Other…i.e. third party vendors                                   jurisdiction.
                                                                     We also perform PDPS checks for Non-
                                                                     Commercial 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       We do not have the funds or personnel to implement this
                                                            to pursue implementing this system.                        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   Documents/images are non-transferable. They can be         This would require an entirely new imaging system than
of identity source documents so that images can be          seen from our in-house PC’s, but are not transferable      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        We currently do this. Source documents are imaged
of 7 years or images of source documents presented for a     then are placed in storage.
minimum of 10 years

Subject each person applying for a driver’s license or       We are now a mandatory license state, therefore, we     We question what is meant by “applying”. Is
identification card to mandatory facial image capture        capture an individual’s facial image when they obtain   AAMVA/Real ID requiring us to capture a facial image
                                                             a Driver’s License/Permit/ID Card.                      if, for example, an applicant takes and exam and fails,
                                                                                                                     therefore not obtaining a License/Permit?

Establish an effective procedure to confirm or verify a      We currently require 2 forms of ID for License/Permit
renewing applicant’s information                             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        We feel that the customer should be responsible for     If we were required to do this, we would need additional
already registered to or associated with another person to   resolving any SSN discrepancies.                        personnel, as it would take a lot longer to process a
which any state has issued a DL/ID card, the state shall                                                             license application. We do not have the funds for
resolve the discrepancy and take appropriate action                                                                  additional personnel.

Check other states if a person already was issued a DL in    We currently use PDPS and CDLIS for checking what       It is possible that we would need the DRIVerS system
another state                                                other states the applicant was previously licensed.     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      Our materials for making a License/Permit/ID are kept
are produced                                                 in locked cabinets/drawers.

Subject all person’s authorized to manufacture or produce    This is a huge issue. The Vermont State Employees       We would mostly likely need VSEA’s approval as well
DL/ID cards to appropriate security clearance                Association (Union) may not wish to have their          as a Departmental Policy.
           REAL ID ACT REQUIREMENT                                                     IMPACT                                            ASSUMPTIONS
requirements                                                   members undergo background checks.

Establish fraudulent document recognition training             We currently do fraudulent ID training.
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           We currently do this. The maximum renewal period
temporary to a period not exceeding 8 years                    for a License is 8 years.

Alternative document design if it does not meet federal        We have our own design.                                 If we have to redesign our Licenses/Permits/ID’s, it
standard                                                                                                               would be a huge financial impact.

Legal Presence Requirement                                     We only collect a “legal address” when the              We question exactly what is AAMVA’s/Real ID’s
                                                               individual’s address is a Post Office Box. The “legal   definition of “Legal Presence”. Does it match our
                                                               address” is usually the 911 address.                    definition of “legal address”?

Provide electronic access to all other states to information   Other states are able to access our records via PDPS
contained in the motor vehicle database of the state           and CDLIS.

Maintain a state motor vehicle database that contains at a     We currently do this.
minimum:
         All data fields printed on DL/ID cards
         Motor vehicle driver’s histories, including motor
         vehicle violations, suspensions and points on
         licenses

Optional                                                       We issue Driver Licenses and Permits to anyone. We      What is the definition of Federal identification purposes?
                                                               only issue Non-Driver ID’s to Vermont Residents.
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.    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   1. Most complete version of applicant’s
                                                                            redesigned to accommodate space for full       name as displayed on proof
1.   Full Legal Name
                                                                            legal name on DL/ID.                           documents will be used.
2.   Person’s Date of Birth
                                                                            2. Full compliance – No impact              2.
3.   Person’s Gender
4.   Person’s DL or ID Card Number                                          3. Full compliance – No impact              3.
5.   Digital Photograph of Person (and retention)
                                                                            4. Full compliance – No impact              4.
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     6. Statutory changes necessary to           6. Assume the license must show the
     duplication                                                               disallow the use of a mailing address       actual physical address of the holder’s
9.   Common Machine Readable Technology:                                       to show on the DL/ID.– will eliminate       residence.
                                                                               current “stalking protection law”

                                                                            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                                               IMPACT                                      ASSUMPTIONS
Introduce temporary DL/ID cards and tying end of stay to expiration of       Statutory, system, policy, and procedural
DL/ID card (or issuance for no more than 1 year)                             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   System and card design changes will be          DMV’s current practice of displaying a
a “different than usual” expiration date                                     necessary to “clearly” display the “different   restriction code that is defined on the back of
                                                                             than usual” expiration date.                    the license will need to be revised.

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
Enabling your system to electronically verify documentation with:
                                                                             would cause an increase in costs.
 1. SSOLV
                                                                             1. System changes would be necessary
                                                                                                                             1. Legislative change would be needed to
 2. SAVE                                                                     if DMV is able to electronically verify that
                                                                                                                             capture SSN of ID holders – this is currently
                                                                             an applicant has not been issued a SSN.
 3. DEERS (DOD)                                                                                                              prohibited by Federal law.
                                                                             Legislative change would be necessary to
 4. Other jurisdiction (DL/ID card)
                                                                             collect SSN for ID card issuance.
 5. Birth certificate
                                                                             Increased cost if DMV is required to verify
 6. Other…i.e. third party vendors                                           SSNs for holders of ID cards as well as DLs.
                     REAL ID ACT REQUIREMENT                                                     IMPACT                                     ASSUMPTIONS
                                                                                2. Increased cost with increased SAVE
                                                                                                                               2. All foreign-born applicants would need
                                                                                verifications sent and to cover required
                                                                                                                               to be verified through SAVE before being
                                                                                system changes.
                                                                                                                               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
                                                                                                                               3.
                                                                                DMV would need to enter into a MOU
                                                                                4. Increased costs for system changes          4. DRIVerS will need to be operational
                                                                                and for use of the DRIVerS program.            before this provision can be feasibly
                                                                                                                               implemented.
                                                                                DMV would need to enter into a MOU
                                                                                5. System changes
                                                                                                                               5.
                                                                                DMV would need to enter into a MOU
                                                                                6. System changes                              6. Real ID provisions will allow for verification
                                                                                                                               through third party vendors rather than the
                                                                                DMV would need to enter into a MOU
                                                                                                                               document source.
Developing access capability to SAVE system                                     See response to #2 above

Introduce equipment into system to capture digital images of identity source    Increased costs for scanning equipment,
documents so that images can be retained in electronic storage in a             system changes, and additional personnel
transferable format                                                             will be incurred.

Retain paper copies of source documents for a minimum of 7 years or images      Increased costs for additional electronic
of source documents presented for a minimum of 10 years                         storage space.

Subject each person applying for a driver’s license or identification card to   Full compliance – No impact
mandatory facial image capture
                     REAL ID ACT REQUIREMENT                                                     IMPACT                                       ASSUMPTIONS
                                                                                 Renewal through alternative methods will be
Establish an effective procedure to confirm or verify a renewing applicant’s                                                     Strict interpretation of the requirement – All
                                                                                 eliminated.
information                                                                                                                      renewals must be verified to include the first
                                                                                 New facilities and additional staff will be     renewal after the effective date of this act and
                                                                                 necessary for verification of documentation     all subsequent renewals.
                                                                                 presented by all applicants (whether original
                                                                                 or renewing)
                                                                                 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
In the event that a social security account number is already registered to or                                                   Stopping the transaction and not issuing a
                                                                                 cards.
associated with another person to which any state has issued a DL/ID card,                                                       DL/ID is not enough to resolve the SSN
the state shall resolve the discrepancy and take appropriate action                                                              discrepancy. The Agency must actually
                                                                                 Increased cost of SSN verifications with
                                                                                                                                 resolve the discrepancy.
                                                                                 increased volume to send.

                                                                                 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      AAMVA DRIVerS will need to be operational
                                                                                 use of the DRIVerS program.                     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                                                     IMPACT                                      ASSUMPTIONS
Subject all person’s authorized to manufacture or produce DL/ID cards to         Increased costs for background checks of       All employees of CSCs or HQ work areas that
appropriate security clearance requirements                                      DMV staff.                                     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      Increased cost to implement training program   All employees involved in the review of
employees engaged in the issuance of DL/ID cards                                 and to provide on-going training– could        customer documentation will be trained.
                                                                                 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   Full compliance – No impact
exceeding 8 years
                                                                                 Card redesign
Alternative document design if it does not meet federal standard
                                                                                 System changes
                                                                                 MOU with vendor would need to be revised.
                                                                                 Statutory changes
                                                                                 Statutory, system, policy, and procedural
Legal Presence Requirement
                                                                                 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    System changes would be necessary to           DRIVerS
motor vehicle database of the state                                              comply with data exchange elements
                                                                                 between states.
                         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
                                                                                             Full compliance – No impact
           motor vehicle driver’s histories, including motor vehicle violations,
           suspensions and points on licenses
Optional
                                                                                             Statutory and system changes.
Development and issuance of a certificate of driving – not for federal
identification purposes – for those who cannot prove lawful presence.                        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

                                                                      One-Time            Recurring (Annual)                FTEs        Number of New       Impact on Average
                          Scenario                                     Costs                   Costs1                      Needed      Facilities Needed   Customer Wait Time
Scenario 1: Separate DL/ID                                         $136,052,48                 $62,739,946                  1,464             40               No Impact
Centers/On-site Document Verification                                   1
• All DL/ID customers must present
  documents every time
• Separate field DL/ID Centers would be
  established


   1
       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           $2,268,049   $5,212,704   111   0     19% increase in
Headquarter Verification                                                         average wait time
• All DL/ID customers must present                                               (from approx. 20
  documents one time only                                                          minutes to 24
• All document verification conducted                                           minutes on average)
  centrally
• No increase in number of facilities or
  field staff; headquarters staff would
  increase by 111




Scenario 3: Two-Step Process with           $2,207,119   $3,797,351   77    0     13% increase in
Customer Choice and Headquarters                                                 average wait time
Verification                                                                     (from approx. 20
• DL/ID customers must present                                                     minutes to 23
   documents one time only; assumes                                             minutes on average)
   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              $2,384,762   $803,519      0    0    258% increase in
Environment                                 average wait time
• All DL/ID customers must present         range 1 hour and 11
  documents every time                     minutes to 24 hours
• All document verification conducted at     and 57 minutes
  the CSCs
• No increase in number of facilities or
  staff
                                                         WASHINGTON STATE

                                                     Jurisdiction Impact Analysis Real ID Act

          REAL ID ACT REQUIREMENT                                               IMPACT                                                ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System   Programming and form changes to provide room for long       Washington currently allows 28 characters
(in Record, on Document)                                 names
                                                         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                             Reformat of document is required for longer names
    1.Full Legal Name                                        1.   Name is currently limited to 28 characters             1.   Need to determine the maximum number of
                                                                                                                              characters
    2.Person’s Date of Birth                                 2.   no change
                                                                                                                         2.   currently supported
    3.Person’s Gender                                        3.   no change
                                                                                                                         3.   currently supported
    4.Person’s DL or ID Card Number                          4.   no change
                                                                                                                         4.   currently supported
    5.Digital Photograph of Person (and retention)           5.   no change
                                                                                                                         5.   currently supported
    6.Person’s Address of Principle Residence                6.    Amend state law that currently provides address
                                                                  confidentiality for victims of domestic violence       6.   currently supported – requires definition of
    7.Person’s Signature
                                                                  or sex crimes                                               principal res.
    8.Physical Security Features to prevent tampering,
                                                             7.   no change                                              7.   currently supported
    counterfeiting or duplication
                                                             8.   no change                                              8.   currently supported – subject to federal
    9.Common Machine Readable Technology:
                                                                                                                              requirements
                                                             9.   no change
                                                                                                                         9.   currently supported – subject to federal
                                                                                                                              requirements

Introduce temporary DL/ID cards and tying end of stay    Programming changes to issue temporary DL/ID                Washington’s documents all have fixed-term expiration
to expiration of DL/ID card (or issuance for no more     documents and documents with expiration dates tied to       periods based upon the date of birth or the date of
than 1 year)                                             lawful presence                                             document issue
                                                         Programming to record and maintain variable expiration
           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           Programming changes to issue temporary DL/ID             Washington’s documents are currently uniform in color
temporary document with a “different than usual”             documents that are unique in design and or color         and appearance with the exception of the document
expiration date                                                                                                       type label
                                                             Amend state law regarding appearance of document

Verification at Source:                                      Programming and equipment required to allow              Washington records document descriptions but does
Enabling your system to electronically verify                verification at source and electronic communication of   image them electronically or transmit documents to the
documentation with:                                          documents                                                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.   new process – depends on degree of AAMVA
                                                                                                                               support
                                                                    7.   Service delays as checks are made with the
                                                                         various systems

Developing access capability to SAVE system                  Programming required                                     New capability – not currently supported

Introduce equipment into system to capture digital           Installation of scanners, PC, servers and software to    New capability – not currently supported
images of identity source documents so that images can       support digital image capture, storage and retention
be retained in electronic storage in a transferable format
                                                             Service delays as documents are scanned and recorded

Retain paper copies of source documents for a minimum        Installation of scanners, PC, servers and software to    New capability – not currently supported
of 7 years or images of source documents presented for a     support digital image capture, storage and retention
minimum of 10 years
                                                             Amend state law regarding record retention
          REAL ID ACT REQUIREMENT                                                   IMPACT                                                ASSUMPTIONS
Subject each person applying for a driver’s license or       Amend state law to prohibit religious or other exemptions   Exceptions are currently allowed in some cases
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a      Undetermined, potential service delays as additional        None if visual verification using the prior photo is
renewing applicant’s information                             verification is performed                                   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        No impact                                                   Currently supported
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    Programming required                                        AAMVA “all-driver” pointer system connectivity
another state                                                                                                            required, or some alternative for state-to-state
                                                             Service delays stemming from checking with other states
                                                                                                                         verifications and exchange

Ensure physical security of locations where DL/ID cards      No impact                                                   Currently supported
are produced

Subject all person’s authorized to manufacture or            No impact                                                   Currently supported – does not include staff that
produce DL/ID cards to appropriate security clearance                                                                    process applications and collect fees for issue of 45-
requirements                                                                                                             day temporary documents. Permanent documents are
                                                                                                                         produced in a secure facility by staff that must meet
                                                                                                                         these requirements.

Establish fraudulent document recognition training           No impact                                                   Currently supported and using AAMVA training
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not         Amend state law to delete or alter open expiration period   Currently support maximum 5 year expiration (other
temporary to a period not exceeding 8 years                  for military personnel and dependents                       than licenses issued to military personnel and
                                                                                                                         dependents)

Alternative document design if it does not meet federal      Programming required                                        Requires the introduction of alternative formats and or
standard                                                                                                                 colors
                                                             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   Not currently supported
                                                             to obtain document valid for federal ID
                                                             Service delays as additional documents and proof of
                                                             lawful presence are determined

Provide electronic access to all other states to             Programming required                                         Not currently supported
information contained in the motor vehicle database of
                                                             Amend state law regarding availability of driving records
the state

Maintain a state motor vehicle database that contains at a   Potentially no impact                                        Depends on the definition of the driver history
minimum:                                                                                                                  elements
           All data fields printed on DL/ID cards
         motor vehicle driver’s histories, including
         motor vehicle violations, suspensions and points
         on licenses

Optional                                                     Programming required                                         Believe that Washington may choose to issue
Development and issuance of a certificate of driving –       Amend state law regarding document appearance
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?
 • 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             2 0 0 7 -0 9             2 0 0 9 -1 1          2 0 1 1 -1 3
                                          Av e rag e           B ie n n iu m            B ie n n iu m         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                16   .8           $ 3 ,6 7 8 ,0 0 0     $ 1 ,9 9 1 ,0 0 0       $ 1 ,4 2 7 ,0 0 0
In f o r m a t i o n S e r v i c e s               7   .0           $ 3 ,7 1 3 ,5 0 2     $ 2 ,2 1 7 ,5 0 2       $ 1 ,9 6 4 ,5 0 2
V e h ic le S e r v ic e s                         0   .0                         $0                    $0                      $0
D r iv e r S e r v ic e s                        350   .3         $ 8 2 ,2 3 0 ,0 0 0   $ 8 2 ,1 4 3 ,0 0 0     $ 5 3 ,1 7 0 ,0 0 0
B u s in e s s & P r o f S e r v ic e s            0   .0                         $0                    $0                      $0
T o t a l D ir e c t C o s t s                   374   .1         $ 8 9 ,6 2 1 ,5 0 2   $ 8 6 ,3 5 1 ,5 0 2     $ 5 6 ,5 6 1 ,5 0 2

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                3 0 .9           $ 4 ,1 7 0 ,0 0 0      $ 4 ,1 1 8 ,0 0 0      $ 2 ,6 7 3 ,0 0 0
In f o r m a t i o n S e r v i c e s              1 6 .1           $ 2 ,9 2 2 ,0 0 0      $ 2 ,8 8 3 ,0 0 0      $ 1 ,8 7 2 ,0 0 0
T o t a l A g e n c y In d ir e c t :             4 7 .0           $ 7 ,0 9 2 ,0 0 0      $ 7 ,0 0 1 ,0 0 0      $ 4 ,5 4 5 ,0 0 0

T o t a l E x p e n d it u r e s :               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
      REVENUE:
GF-State                                                                                            $0                           $0
All Other                                                                                  $65,248,570                  $77,127,263               $67,917,716
Total Revenue:                                                                             $65,248,570                  $77,127,263               $67,917,716

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.
   •   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.
   •   Explanation time for RIDA requirements 2 minutes for each customer.
   •   Thirty percent of customers will verify RIDA status through the webservice.
   •   Five percent of customers will verify RIDA status by phone at the LSO.
   •   Thirty-five percent of customers will verify RIDA status with DOL customer service by phone (see MSS tab for staff impact).
   •   Fifteen percent of customers will wait for DOL to verify RIDA by mail.
   •   Customer phone calls to the LSO for RIDA status updates 4 minutes each.
   •   Issuance of temporary RIDA documents 4 minutes each.
   •   Verification time needed for 80% of customer documents 3 minutes each.
   •   Verification time needed for 20% of customer documents 15 minutes each.
   •   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                                               ASSUMPTIONS
Introduce Full Legal Name into Driver Licensing System      None, already required
(in Record, on Document)

Have following data elements/features on the document:      None, already required
    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    Legal presence already required
expiration of DL/ID card (or issuance for no more than 1
                                                            DL/ID card expiration tied to legal presence
year)

Amending card design to show/indicate that it is a          No temporary license issued
temporary document with a “different than usual”
expiration date

Verification at Source:                                     1. SSOLV: In Place                                       General observation; as the number of required links
                                                                                                                     increases, the incidence of “system down” preventing the
Enabling your system to electronically verify               No estimate at this time on impact of required link to
                                                                                                                     issuance of a driver’s license will increase.
            REAL ID ACT REQUIREMENT                                                  IMPACT                                               ASSUMPTIONS
documentation with:                                             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       1. Digital image scan system in place                   Approximately 400,000 license transactions per year
of identity source documents so that images can be retained
                                                                2. Will require installation of scanning equipment at   West Virginia is an over the counter issuance state. This
in electronic storage in a transferable format
                                                                each licensing location                                 will either increase the transaction time for each
                                                                                                                        transaction or increase the number of employees needed
                                                                3. Additional labor required to scan these documents
                                                                                                                        to maintain present transaction time.

Retain paper copies of source documents for a minimum of        Do not anticipate problem storing these digital
7 years or images of source documents presented for a           images
minimum of 10 years

Subject each person applying for a driver’s license or          None, already required
identification card to mandatory facial image capture

Establish an effective procedure to confirm or verify a         This is dependant on the electronic verification        Currently only using SSOLV
renewing applicant’s information                                systems described on the previous page.

In the event that a social security account number is already   None, Already Required
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       1. Already done on original applications
another state
                                                                2. Do not anticipate problem check on renewals or
             REAL ID ACT REQUIREMENT                                                 IMPACT                  ASSUMPTIONS
                                                               duplicates as well

Ensure physical security of locations where DL/ID cards        Dependant on what standards are established
are produced

Subject all person’s authorized to manufacture or produce      1. Already done for driver examiners
DL/ID cards to appropriate security clearance requirements
                                                               2. Expand background check for all CSR

Establish fraudulent document recognition training             None, Training already in place
programs for appropriate employees engaged in the
issuance of DL/ID cards

Limit period of validity of DL/ID cards that are not           None, Already in place
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal        WV License meets federal standards
standard

Legal Presence Requirement                                     None, Already in Place

Provide electronic access to all other states to information   ? Already in place with CDLIS
contained in the motor vehicle database of the state

Maintain a state motor vehicle database that contains at a     None, Already in Place
minimum:
           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?
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          WI does not require full legal name, and does not print full   Full legal name includes full middle name
System (in Record, on Document)                          middle name on document.

Have following data elements/features on the             WI does not print full legal name on document.                 Common machine readable technology will not include
document:                                                                                                               biometric data
                                                         Wi uses digital facsimile of signature
    163. Full Legal Name                                                                                                Digital facsimile of signatures will be permitted
                                                         WI appears to be in compliance with other provisions
    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         Wisconsin must make extensive programming changes to           Temporary license will be a new product type
stay to expiration of DL/ID card (or issuance for no     create a temporary driver’s license and change business
more than 1 year)                                        rules that compute expiration dates.

Amending card design to show/indicate that it is a       Requires a new product type                                    Temporary license will be a new product type
temporary document with a “different than usual”
expiration date

Verification at Source:                                  WI just implemented SSOLV, but doesn’t have any other          Unclear what DEERS system is used for.
         REAL ID ACT REQUIREMENT                                                  IMPACT                                                     ASSUMPTIONS
Enabling your system to electronically verify             systems to verify information electronically.
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

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        WI does not capture digital images of source documents.         All field stations that issue driver’s licenses and
images of identity source documents so that images        All equipment must be purchased. Initial cost estimates         identification cards must have equipment.
can be retained in electronic storage in a transferable   indicate that placing equipment in all field stations will be
                                                                                                                          Customers applying for duplicate, occupational,
format                                                    cost prohibitive. WI may have to close some itinerant
                                                                                                                          reinstated license, etc, will not have to supply source
                                                          field stations, especially if there are no federal funds
                                                                                                                          documents.
                                                          available. Also, it is unclear if customers renewing their
                                                          DL/ID will have to provide source documents.

Retain paper copies of source documents for a             Since identity source documents must be kept in an              All field stations that issue driver’s licenses and
minimum of 7 years or images of source documents          electronic format, all source documents will be kept in an      identification cards must have equipment.
presented for a minimum of 10 years                       electronic format.
                                                          WI does not capture digital images of source documents.
                                                                                                                          Customers applying for duplicate, occupational,
                                                          All equipment must be purchased. Initial cost estimates
                                                                                                                          reinstated license, etc, will not have to supply source
                                                          indicate that placing equipment in all field stations will be
                                                                                                                          documents.
                                                          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    WI does not photograph persons who are denied. WI will          Applicants must be photographed at the beginning of the
identification card to mandatory facial image capture     have to reconfigure application process so photograph can       process.
                                                          be taken first.
         REAL ID ACT REQUIREMENT                                                 IMPACT                                                 ASSUMPTIONS
Establish an effective procedure to confirm or verify a   It is unclear what this means. How do you verify
renewing applicant’s information                          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     WI has procedures for handling discrepancies with Social    A centralized database for driver information will be
already registered to or associated with another person   Security number for Wisconsin residents, but has no way     built, which includes social security numbers.
to which any state has issued a DL/ID card, the state     of checking other states unless a centralized database or
shall resolve the discrepancy and take appropriate        pointer system is created.
action

Check other states if a person already was issued a DL    WI checks states where the driver was previously
in another state                                          licensed. No nationwide search is done.

Ensure physical security of locations where DL/ID         It is unclear what is meant by “physical security”. This
cards are produced                                        could lead to station remodelling or central office
                                                          issuance.

Subject all person’s authorized to manufacture or         WI does background checks on new employees. Existing        Applies to vendor employees as well.
produce DL/ID cards to appropriate security clearance     employees and employees of vendors would have to be
requirements                                              checked.

Establish fraudulent document recognition training        WI has a fraudulent document training program for field
programs for appropriate employees engaged in the         staff. This must be expanded to include central office
issuance of DL/ID cards                                   staff.

Limit period of validity of DL/ID cards that are not      In compliance
temporary to a period not exceeding 8 years

Alternative document design if it does not meet federal   WI must decide if the alternate document is going to be
standard                                                  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          WI does not have system to provide electronic access to     A centralized driver pointer system will be built.
information contained in the motor vehicle database of    other states. Extensive programming is needed to link to
the state                                                 a centralized database.
         REAL ID ACT REQUIREMENT                                                 IMPACT                                              ASSUMPTIONS
Maintain a state motor vehicle database that contains     WI is in compliance.
                                                                                                                    ISO standards, which require data fields to be numbered,
at a minimum:
                                                                                                                    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                                                  WI must decide if the alternate document is going to be
                                                          issued.
Development and issuance of a certificate of driving –
not for federal identification purposes – for those who   We currently license people without legal presence.
cannot prove lawful presence.




What questions does your jurisdiction have as a result of the passing of the Real ID Act?

•        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?
•   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                               1651 days BITS estimate, plus vendor
scanning, and add links to SAVE & DRIVerS,                                               $         1,503,350   charges




One-time Equipment and Software Costs for Document Verification Equipment &                                    Programming           Total One-
and Scanning*                                                   Software Costs                                 Costs                 time 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                  Automated verification of
                                                                  (Minutes per unit = verification of documents**** (Minutes                   documents****
                                                                         30)                          per unit= 20)                         (Minutes per unit = 10)

                                                                  FTE  Salary/Fringe              FTE                 Salary/Fringe          FTE           Salary/Fringe
                                                                             $
All applicants (original & renewal)*****                         227.2  8,698,300                       151.4     $        5,992,718               75.7    $ 3,287,135
                                                                             $
Original applicants only                                         60.4   2,196,941                        55.4     $        2,192,675               27.7    $ 1,202,730
                                                                             $
Non-citizens only                                                20.4    782,847                         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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