BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: Sb 1162
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  Walters
                                                         VERSION: 4/6/10
          Analysis by:  Jennifer Gress                   FISCAL:  yes
          Hearing date:  April 20, 2010






          SUBJECT:

          Traffic violator schools:  fees

          DESCRIPTION:

          This bill eliminates the $50 fee that a traffic violator school  
          owner must pay to the Department of Motor Vehicles (DMV) to  
          renew the license for each of its branch or classroom locations.  


          ANALYSIS:

          Existing law defines a "traffic violator school" as a "business  
          which for compensation provides, or offers to provide,  
          instruction in traffic safety, including, but not limited to,  
          classroom defensive-driver concepts, for persons referred by the  
          courts?or to other persons who elect to attend." 

          A court may order a person to attend a licensed traffic violator  
          school, a licensed driving school, or other court-approved  
          program of driving instruction, under specified circumstances,  
          in lieu of adjudicating the traffic offense.  A person is  
          entitled to have a complaint relating to the safe operation of a  
          vehicle dismissed (masked) when he or she attends a  
          court-directed traffic violator school, licensed driving school,  
          or other court-approved program of driving instruction.

          DMV regulates the licensing and administration, including  
          minimum curriculum requirements, of classroom-based traffic  
          violator schools, but does not regulate "home study" programs,  
          which may offer instruction through a variety of non-classroom  
          means (e.g., internet, textbook, video, and CD ROM).  Home study  
          programs are not licensed by DMV.  Instead, each court approves  
          those home-study programs that it orders violators to attend.




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          Existing law establishes various fees that DMV charges to  
          license traffic violator school owners, operators, and  
          instructors.  The licenses for owners, operators, and  
          instructors are valid for one year and therefore must be renewed  
          on an annual basis.  With regard to fees charged to traffic  
          violator school owners, the fee for an original license is $150  
          with an additional $70 for each branch or classroom location  
          licensed.  The annual license renewal fee is $50 for a school  
          and for each branch or classroom location.

           This bill  eliminates the $50 fee that a traffic violator school  
          owner must pay DMV to renew the license for each of its branch  
          or classroom locations. 
          
          COMMENTS:

           1.Purpose  .   According to the sponsor, Traffic Safety  
            Consultants, Inc., which represents classroom-based traffic  
            violator schools, the funds collected by DMV from the annual  
            $50 classroom renewal fee are not significant for DMV, but are  
            for traffic school owners who are hard pressed to meet their  
            financial obligations.  Classroom-based programs are  
            experiencing low student enrollments due to their inability to  
            compete with home-study programs.  

            The sponsor explains that when a traffic school initially  
            secures a classroom location, the school pays DMV a $70  
            nonrefundable fee to have DMV inspect and approve the  
            particular location.  Even though different schools may use  
            the same hotel room to conduct classes, DMV will nonetheless  
            charge each school the same $70 fee for the same room.  The  
            sponsor further argues that DMV does not re-inspect classrooms  
            thereafter to justify the $50 annual renewable fee.  

            In light of the substantial loss of business arising from the  
            popularity of internet-based traffic violator programs,  
            classroom-based traffic programs, the sponsor would like the  
            renewal fee to be repealed.

           2.How DMV uses fee revenues  . The license fees (original and  
            renewal) pay for the following personnel and activities  
            necessary to oversee classroom-based traffic violator schools:

                 Inspectors who work with licensees to obtain correct  
               application forms, perform background checks, and issue  




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               temporary licenses.

                 Technicians who create automated records, store  
               documents, and issue final licenses.  

                 Handling of consumer complaints and the monitoring  
               reports provided by court-assistance programs (CAPs).  (A  
               CAP works under contract with a court to oversee both  
               classroom-based and home-study programs to which a court  
               may refer violators.)

                 Maintenance of a database of traffic violator schools  
               and their classroom locations, as well as the production  
               and distribution of lists of schools.   

            In response to the claim that DMV does not re-inspect  
            classrooms upon renewing a license, DMV notes that its  
            monitoring capabilities have diminished as its funding has  
            decreased.  DMV typically does a pre-licensing inspection and  
            follows up on complaints.  The number of consumer complaints  
            it investigated, a process which typically includes an office  
            audit and/or a classroom visit, for the past three years is  
            provided as follows:

                 Fiscal Year 2007-08:  461

                 Fiscal Year 2008-09:  862

                 Fiscal Year 2009-10:  574 to date

            From 2007 through 2009, those investigations resulted in the  
            revocation of 10 traffic violator schools' licenses, 3 schools  
            being put on probation, and 3 applicants for licenses being  
            denied.  

            DMV is currently assembling an updated number of classroom  
            locations, but estimates that there are about 3000 locations.   
            A loss of $50 per location would diminish annual revenue by  
            approximately $150,000.  

           1.A bigger problem  .  The laws and regulations that govern  
            traffic violator schools treat classroom-based programs and  
            home-study programs differently.  DMV licenses classroom-based  
            programs whereas each court approves the schools it refers  
            violators to attend.  State law prescribes no licensing  
            requirements or fees for court-approved programs.   




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            Furthermore, because each court approves the home-study  
            programs to which it sends violators, the rules and processes  
            governing these schools could vary for each of the courts  
            across the state.  For this reason, classroom-based programs  
            that pay DMV licensing fees may in fact experience a  
            competitive disadvantage over home-study programs that do not.  
             This problem, however, will not be solved by eliminating the  
            $50 renewal fee.  Doing so would serve only to hamper DMV's  
            efforts to oversee classroom-based programs further.

            To address the many issues that arise from having a fragmented  
            system of traffic violator schools, the Legislature passed and  
            the Governor signed AB 758 (Plescia and Portantino), Chapter  
            396, Statutes of 2007, that required DMV to develop a plan by  
            which licensing and oversight of all traffic violator schools,  
            regardless of modality, would be consolidated under DMV's  
            authority.  DMV submitted its report to the Legislature in  
            July 2008 and in it recommended a number of statutory and  
            regulatory changes that would be necessary to achieve that  
            objective.   Assembly Member Portantino is authoring a bill,  
            AB 2499, to make many of those changes.  That bill is  
            currently awaiting hearing in the Assembly Appropriations  
            Committee.  Given the larger problems posed by the fragmented  
            licensing system that exists today and the current effort to  
            consolidate the licensing of all traffic schools under DMV,  
            the committee may wish to hold this bill and consider the  
            broader changes contained in AB 2499.
          
           2.Suggested amendment  . The provision of law this bill amends  
            currently reads, "For annual renewal of the license for a  
            traffic violator school and for each branch or classroom  
            location, a fee of fifty dollars ($50)."  The bill only  
            deletes "or classroom," leaving "branch location" in tact.   
            There does not appear to be a meaningful difference between  
            "classroom" and "branch" locations, making the implementation  
            of this bill unclear.  For this reason, if the bill moves  
            forward, the committee may wish to consider an amendment to  
            delete "and for each branch or classroom location."

           POSITIONS:  (Communicated to the Committee before noon on  
                     Wednesday,                              
                      April 14, 2010)

               SUPPORT:  Traffic Safety Consultants, Inc. (sponsor)
                         California Traffic Classes, Inc. (Traffic School)
                         California Traffic School Association




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                         Instant Traffic School 
                         7 Days-A-Week and Evening Classes
          
               OPPOSED:  None received.