BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                      



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          |SENATE RULES COMMITTEE            |                  SB 1317|
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                                 THIRD READING


          Bill No:  SB 1317
          Author:   Kehoe (D)
          Amended:  5/25/12
          Vote:     21

           
           SENATE TRANSPORTATION & HOUSING COMM  :  5-3, 4/24/12
          AYES:  DeSaulnier, Kehoe, Pavley, Rubio, Simitian
          NOES:  Gaines, Harman, Wyland
          NO VOTE RECORDED:  Lowenthal

           SENATE APPROPRIATIONS COMMITTEE  :  5-2, 5/24/12
          AYES:  Kehoe, Alquist, Lieu, Price, Steinberg
          NOES:  Walters, Dutton


           SUBJECT  :    Vehicles:  traffic violator schools

           SOURCE  :     Traffic Violator School Association


           DIGEST  :    This bill clarifies what traffic violator school 
          information the Department of Motor Vehicles (DMV) makes 
          available and shifts some of DMVs administrative costs from 
          the schools to the violators.

           ANALYSIS  :    Existing law defines a traffic violator school 
          (TVS) as a business which provides traffic safety 
          instruction, such as classroom defensive-driver concepts, 
          for traffic law violators referred by the courts or people 
          who elect to attend to improve their own skills.  The TVS 
          program includes classroom-based programs as well as home 
          study programs, which may offer instruction through a 
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          variety of non-classroom means (e.g., internet, textbook, 
          video, and CD ROM).  Attending a TVS essentially allows a 
          traffic violator to pay a one-time fee to avoid receiving a 
          point against his or her driving record, which reduces 
          future car insurance costs, as well as the chance of DMV 
          suspending or revoking the violator's driving privileges. 

          In an effort to make the TVS program more effective and 
          uniform across instructional modalities, AB 2499 
          (Portantino), Chapter 599, Statutes of 2010, made a number 
          of changes to the program, including directing DMV to 
          administer it and licenses the schools as of September 
          2011.  In addition, AB 2499 changed specific implementing 
          details pertaining to the program, such as how DMV 
          disseminates information about these schools and how 
          schools notify courts of a violator's successful course 
          completion.  Finally, AB 2499 required DMV to charge fees 
          to the schools sufficient to cover its actual cost to 
          administer the TVS program.  Existing law allows DMV to 
          charge violators only a fee to cover the cost of routine 
          monitoring of instruction.

          This bill:

          1.Prohibits the DMV from adopting regulations that require 
            a TVS to provide or process paper-based course evaluation 
            documents.

          2.Requires the DMV class listings to specify the counties 
            where classroom instruction is offered, in addition to 
            providing that information by city.

          3.Requires the classroom-based list to include the name of 
            each traffic violator school, a telephone number used for 
            student information, and the county and the cities where 
            the classes are available.

          4.Requires a TVS to update course completion information on 
            DMV's web-based database within ten days of completion, 
            rather than the current three day requirement.

          5.Extends the time period in which a TVS must update course 
            completion information on DMV's web-based database from 
            within three days of completion to ten days.

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          6.Deletes the authority for DMV to charge fees for TVS 
            licenses at a level sufficient to defray costs to 
            administer the TVS program, and instead freeze the 
            schedule of fees charged for TVS licenses at 2011-12 
            levels, except the $100 fee charged for each separate TVS 
            branch or classroom location, which would be reduced to 
            $50.

          7.Requires the administrative fee charged to traffic 
            violators who participate in the TVS program to be 
            sufficient to defray DMV's costs to administer the TVS 
            program.  Under existing law, the administrative fee may 
            only be used to defray the costs of routine maintenance 
            of the program.

           Comments
           
          This bill seeks to improve DMV's implementation of some 
          elements of 2010's AB 2499.  According to the author, AB 
          2499 failed to provide TVSs with needed administrative 
          flexibility and imposed new fees on these schools in order 
          to provide sufficient funds for DMV to administer the TVS 
          program.  In addition, the author contends that information 
          provided by DMV and the courts regarding TVS locations 
          remains woefully inadequate.  The author states that these 
          changes have left the classroom-based schools unable to 
          financially sustain themselves.

           TVS information provided by DMV  .  Existing law requires DMV 
          to provide a list of licensed traffic violator schools, by 
          modality, on its website.  Due to concerns expressed by 
          some TVS operators, DMV, Judicial Council, and some 
          stakeholders have been meeting since January to address the 
          way the TVS information is being displayed on the DMV's 
          website.  According to DMV, all issues raised concerning 
          the content on the website that can be addressed will be 
          resolved by mid-April.  If enacted, this bill will 
          essentially codify DMV's current practice outside the 
          following two challenges:  1) Because TVSs do not provide 
          on their licensing record the judicial district in which 
          they operate, DMV is presently unable to add this field to 
          the database as mandated in this bill; and 2) DMV points 
          out that rotating the list instead of randomizing the order 

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          of schools could open up the system to manipulation that 
          could advantage one particular establishment over another.  


           Online database may reduce fraud  .  The online database 
          established by AB 2499 requires course instructors to log 
          in when entering course completion information, which 
          introduces accountability to the TVS process and makes 
          fraudulent behavior much easier to identify and prosecute.  
          On the other hand, paper completion certificates can be 
          sold, replicated, or stolen, and it is very difficult to 
          track down and prosecute perpetrators of such illegal 
          actions.  Nevertheless, fraud cases have been pursued when 
          possible.  For example, since 2006, Los Angeles County has 
          received 57 case referrals that have led to 19 arrests and 
          convictions.  

           How to fairly fund DMV's administrative costs  .  AB 2499 
          required DMV to seek full cost recovery for its 
          administration of the TVS program, which DMV was not doing 
          beforehand.  The law specifies what costs the fee collected 
          by the courts from each traffic violator can defray.  
          Legislative Counsel has published an opinion that existing 
          law does not allow DMV to charge violators for 
          administrative costs, except for the cost of routine 
          monitoring of instruction.  Because DMV is required to 
          recover its full costs, it has had to increase the fees on 
          the schools to cover the program costs.  

          This bill shifts two portions of DMV's costs from the 
          classroom-based schools to each violator by expanding the 
          administrative costs that can be defrayed by the violator's 
          court fees.  The first cost shifted is the cost of 
          providing course completion certificates, which is 
          discussed in a previous comment.  The second cost shifted 
          by this bill is for DMV's annual classroom location 
          approval.  Each classroom-based school is required annually 
          to seek approval of classroom locations from DMV, and DMV 
          has increased the fee to do so from $50 to $100 in order to 
          help cover the administrative costs of the TVS program.  
          This bill eliminates the classroom location renewal fee in 
          lieu of funding from higher fees on every violator who 
          takes advantage of the TVS program.


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           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  Yes

          According to the Senate Appropriations Committee:

           One-time DMV costs, likely in the range of $190,000 
            (Motor Vehicle Account), to create a new database capable 
            of a multi-step listing system for classroom locations 
            (first by county, then by city, then randomizing 
            locations).  Ongoing annual costs in the range of 
            $190,000 for database maintenance and data input.  
            Out-year ongoing costs could be offset if DMV increases 
            the recently adopted administrative fee charged on 
            traffic violators.

           Unknown annual revenue losses (Motor Vehicle Account) 
            related to reducing the fee charged for each TVS branch 
            or classroom location from $100 to $50.  Out-year revenue 
            losses could be mitigated if DMV increases the recently 
            adopted administrative fee charged on traffic violators.

           Unknown future revenue losses related to capping the fees 
            charged to TVS owners, operators, and instructors at 
            2011-12 levels, rather than authorizing DMV to charge 
            fees on TVSs sufficient to defray costs.  These potential 
            losses are offset by authorizing DMV to increase fees on 
            traffic violators to defray the costs to administer the 
            TVS program.

           SUPPORT  :   (Verified  5/24/12)

          Traffic Violator School Association (source) 
          Fun-N-Cheap Comedy Traffic School
          Never Speed Again Comedy Traffic Schools
          Gay Community Traffic School

           ARGUMENTS IN SUPPORT  :    Proponents argue that this bill 
          resolves two important issues by directing DMV to make 
          course completion certificates once again available to 
          classroom-based schools.  Before AB 2499, DMV provided 
          classroom-based schools with certificates of completion 
          which students submitted to the courts as proof of 
          attendance and completion.  Existing law requires schools 
          to begin inputting each student's information into an 

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          online database that courts can access to verify course 
          completion.  Proponents contend that one benefit of 
          returning to paper certificates is that the DMV can again 
          charge violators for the certificates, effectively reducing 
          the cost born by the classroom-based schools.  The second 
          benefit of eliminating the online database for the 
          classroom-based schools is that it reduces the potential 
          liability concerns for any mistakes made inputting the 
          data.


          JJA:nl  5/25/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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