BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 1317
                                                                  Page  1

          Date of Hearing:   June 25, 2012

                        ASSEMBLY COMMITTEE ON TRANSPORTATION
                               Bonnie Lowenthal, Chair
                    SB 1317 (Kehoe) - As Amended:  April 26, 2012

           SENATE VOTE  :  25-13
           
          SUBJECT  :  Traffic violator school

           SUMMARY  :  Reduces the renewal fee for approved classroom 
          locations and freezes various other fees related to the traffic 
          violator school (TVS) program.  Specifically,  this bill  :  

          1)Makes findings and declarations regarding the need for 
            classroom-based TVS instruction for drivers who do not have 
            Internet access and the importance of keeping fees for those 
            services reasonable.  

          2)Provides that existing TVS-related statutes do not abrogate or 
            limit the inherent powers of a court to order a traffic 
            violator to attend and complete a TVS program of any length or 
            duration, as determined by the court to be reasonable under 
            the circumstances of the case before it, except that a 
            conviction may be held confidential by the Department of Motor 
            Vehicles (DMV) only as permitted under existing law.  

          3)Prohibits DMV from adopting regulations that require TVSs to 
            provide or process paper-based documents for the purpose of 
            course instruction evaluations by students, unless expressly 
            authorized by statute.  

          4)Requires the classroom-based segment of DMV's list of licensed 
            TVSs to include the name of each TVS, a telephone number used 
            for student information, and the county and cities where 
            classes are available.  

          5)Allows each TVS owner to have one school name in a judicial 
            district.  

          6)Requires the classroom-based segment of the list to be 
            organized alphabetically in sections for each county.  

          7)Requires any hard-copy list of licensed TVSs provided by a 
            court or a traffic assistance program (TAP) to also include 








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            the name of each TVS, a telephone number used for student 
            information, and the county and cities where classes are 
            available.  

          8)Requires DMV to make available, for easy download by a 
            licensed TVS, and as may be required by a court, data that 
            includes that TVS's license number, name, primary business 
            office address, primary telephone number, and classroom 
            location addresses, if any.  

          9)Requires DMV to present the data for downloading in the form 
            of a comma-separated value formatted file.  

          10)Allows DMV to use and assign authorization codes and 
            passwords for the purpose of limiting unrestricted access to 
            this proprietary data.  

          11)Specifies that DMV's fees for issuing TVS-related licenses, 
            approving curricula, and administering examinations will be 
            equivalent to those imposed in the 2011-12 fiscal year except 
            for the fee for the renewal of an approved current classroom 
            location which will be set at $50 per year per location.  

          12)Requires the fee assessed by a court against a driver who 
            attends TVS to include an amount sufficient to defray DMV's 
            actual costs to administer its TVS program, except for the 
            costs defrayed by those other authorized fees described above. 
             

          13)Defines, for purposes of TVS-related statutes, "approved 
            current classroom location" to mean a classroom location that 
            received original approval from DMV, which was listed on the 
            classroom-based school's most recent classroom renewal 
            application, or any new classroom location subsequently added 
            by the classroom-based school and approved by DMV prior to the 
            school's next renewal application.  

          14)Requires the fee collected by the courts from traffic 
            violators referred to TVS to include sufficient funds to 
            defray DMM's costs to administer the TVS program.  

           EXISTING LAW  :  Requires DMV to license and regulate all TVSs, 
          regardless of whether they are classroom-based, online, or 
          presented in any other format.  









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           FISCAL EFFECT  :  According to the Senate Appropriations Committee 
          analysis, there will be:

          1)One-time DMV costs, likely in the range of $190,000, 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.  

          2)Unknown annual revenue losses 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.  

          3)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.  

           COMMENTS :  Existing law defines a TVS as a business which 
          provides traffic safety instruction, such as classroom 
          defensive-driver concepts, for traffic law violators referred by 
          the courts or for people who elect to attend to improve their 
          own skills.  TVSs may present their course materials through 
          classroom-based programs as well as through home study programs, 
          which may offer instruction via a variety of means such as 
          internet, textbook, video, or 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.  
          Approximately one million licensed drivers, or one fourth of all 
          minor traffic offenders, take a TVS course annually.  


          After a decade of torturous negotiations among the numerous 
          stakeholders to reform the TVS program by providing uniform 
          regulation and oversight across the various instructional 
          modalities, the Legislature was finally successful in enacting 
          AB 2499 (Portantino), Chapter 599, Statutes of 2010, which made 








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          a number of changes, including directing DMV to license 
          non-classroom TVSs 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.  Under this statute, as confirmed by a Legislative 
          Counsel opinion, TVS-related fees levied on violators may only 
          cover the cost of routine DMV monitoring of instruction.  
          Consequently, in order for DMV to fully recover its TVS-related 
          costs, it has had to increase its TVS license and approval fees. 
           

          According to the author, AB 2499 failed to provide TVSs with 
          needed administrative flexibility and caused the imposition of 
          fees that have left the classroom-based schools unable to 
          financially sustain themselves.  In addition, the author 
          contends that information provided by DMV and the courts 
          regarding TVS locations remains woefully inadequate.  
           
           One of the TVS mandates in statute requires each classroom-based 
          school to seek approval of each of its classroom locations 
          annually from DMV.  Subsequent to the passage of AB 2499, 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 
          permanently caps the classroom location renewal fee at $50 while 
          permanently freezing all other TVS fees at their current levels. 
           The bill replaces the loss in revenues, and assures full DMV 
          cost recovery, by requiring any shortfall to be made up from 
          higher fees on every violator who takes advantage of the TVS 
          program, regardless of whether they attend classroom-based TVSs 
          or take advantage of home study courses of instruction.  

          Aside from the issue of fees, this bill also reaffirms the power 
          of the courts to order violators to TVS programs outside of the 
          AB 2499 framework (a practice that the courts themselves sought 
          to end through the enactment of AB 2499), effectively bans DMV 
          from requiring TVSs to use paper-based documents for course 
          instruction evaluations by students (despite the fact that some 
          students may be attending classroom instruction precisely 
          because they are uncomfortable with non-paper formats), and 
          makes changes (at a cost described above) to the manner in which 
          DMV provides lists of licensed TVSs that are ultimately used by 
          traffic violators to choose a TVS that meets their needs.  








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           Suggested Committee amendments  :  Given that AB 2499 is only now 
          beginning to be implemented, it would appear that making 
          wholesale changes to its structure at this early date is at the 
          very least premature.  But it is clear that classroom-based TVSs 
          face a challenge in maintaining viability in the face of both 
          intensifying competition and increased fee costs.  As a means of 
          providing the industry of a period of transition, and in order 
          to give DMV the real-time experience that it needs to accurately 
          assess its fee-based costs, the Committee may wish to strike all 
          of this bill's provisions other than retaining its $50 renewal 
          fee for approved classroom locations, as well as its freeze on 
          all other fees, and make both of these requirements effective 
          only for calendar years 2013 and 2014.  Subsequently, DMV would 
          set all fees in accordance with AB 2499.  

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          California Traffic School Association, Inc.
          Fun-N-Cheap Comedy Traffic School
          Gay Community Traffic School
          Never Speed Again Comedy Traffic Schools
          Traffic Safety Consultants, Inc.
          Letters from 10 individual traffic violator school instructors
           
            Opposition 
           
          American Safety Council
          Distance Learning Company
          I Drive Safely, L.L.C.

           
          Analysis Prepared by  :   Howard Posner / TRANS. / (916) 319-2093