BILL ANALYSIS                                                                                                                                                                                                    �






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: ab 1864
          SENATOR MARK DESAULNIER, CHAIRMAN              AUTHOR:  daly
                                                         VERSION: 6/15/14
          Analysis by:  Carrie Cornwell                  FISCAL:  yes
          Hearing date:  June 24, 2014



          SUBJECT:

          Vehicles:  license plates 

          DESCRIPTION:

          This bill reduces from 90 to 75 days the maximum time during  
          which a car can operate without a license plate when the owner  
          has not received a license plate, and further requires the  
          Department of Motor Vehicles (DMV) to evaluate the need for  
          California to implement a new system for the temporary  
          identification of vehicles during the time before license plates  
          arrive.

          ANALYSIS:

          Existing law prohibits a person from driving, moving, or parking  
          a motor vehicle on the highway or in a public parking facility  
          unless it is registered with the DMV.  When someone buys a new  
          car, it is not yet registered, nor does it display license  
          plates.  Instead, the dealer must affix to the inside of the  
          vehicle's windshield a DMV-created report-of-sale form showing  
          that the vehicle is in the process of being registered.  The  
          report-of-sale provides temporary operating authority for that  
          vehicle.  This process is also followed for used cars that do  
          not have license plates.

          At the time of retail sale, existing law assigns the vehicle  
          dealer responsibility for submitting an application and  
          accompanying fees to DMV to register a new vehicle and to  
          transfer registration for a used vehicle.  The dealer has 20  
          days for a new vehicle or 30 days for a used vehicle to deliver  
          to DMV the application and fees necessary to register the  
          vehicle in the buyer's name. (This process typically occurs  
          through a third party, known as a DMV Business Partner.)

          Once DMV receives and processes the application, it issues and  
          then DMV (or its business partner) mails to the new owner two  




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          license plates, a vehicle registration card, and the appropriate  
          registration stickers for the vehicle's rear license plate.  The  
          owner must affix the two license plates upon receipt of them,  
          but the vehicle may be operated while displaying a  
          report-of-sale until the owner receives the license plates or 90  
          days, whichever occurs first.

           This bill  reduces to 75 days from 90 the maximum period during  
          which a vehicle can operate before displaying license plates.   
          The bill further directs DMV to assess the need for a temporary  
          vehicle identifier, beyond the report-of-sale, that vehicles  
          could display during this period and, if that assessment shows  
          the need, to examine various alternative systems.  Specifically,  
          DMV shall:

          1.Assess, in consultation with CHP, the need for a temporary  
            vehicle identification system different from the display of  
            the report-of-sale form.  In making this assessment, DMV shall  
            consider information from relevant entities, including local  
            government, other law enforcement, licensed vehicle dealers,  
            and consumer representatives as well as the experience in  
            other states with temporary license plates or other  
            alternative vehicle identification systems.

          2.Examine, if the assessment shows a need, the costs and  
            benefits of different temporary vehicle identification systems  
            that the state could put in place, including potential methods  
            for paying the costs associated with these systems. The bill  
            specifically directs DMV to consider:

                 An enhanced display of the report-of-sale beyond what is  
               required in existing law
                 A temporary license plate system that is not integrated  
               with either DMV's or law enforcement's databases
                 A temporary license plate system with its own database  
               that is accessible both to DMV and to law enforcement 
                 A temporary license plate system that is fully  
               integrated with DMV's database and the California Law  
               Enforcement Telecommunications System (CLETS)

          1.Submit a report by January 1, 2016 to the Assembly  
            Transportation Committee and to this committee that provides  
            the result of the assessment and the examination, if  
            conducted.  In this report, DMV, along with CHP, shall make a  
            recommendation as to whether the state should implement a new  
            temporary vehicle identification system.




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          COMMENTS:

           1.Purpose  .  The author introduced this bill to build upon prior  
            successful legislation from 2011,  AB 1215 (Blumenfield),  
            Chapter 329, that, among other things, mandated that new car  
            dealers use electronic vehicle registration starting July 1,  
            2012.  At the time of AB 1215's passage, DMV was under  
            considerable pressure to ensure the timeliness of the issuance  
            of license plates that sometimes took 90 or more days before  
            arrival.  All interested parties understood the importance of  
            getting the registration process completed in a timelier  
            manner, and AB 1215 accomplished that goal.  

            As a result of AB 1215's implementation, proponents of this  
            bill report that consumers are now getting license plates as  
            soon as two weeks after the purchase or lease of their  
            vehicles and that almost all license plates are now received  
            by vehicle owners within a month.  Because vehicle owners must  
            affix their license plates upon receipt of those plates, this  
            bill reduces the time period a person can drive without  
            permanent license plates from 90 days to 75 days.  This time  
            is still sufficient to account for the existing registration  
            process that allows dealers up to a total 50 days for used  
            vehicles and 40 days for new vehicles.  This existing process  
            prescribes that dealers must register new vehicles within 20  
            days and used vehicles within 30 days, but have an additional  
            20 days to correct any registration defects that DMV  
            discovers.  

            In addition, recent amendments will require DMV to assess the  
            problems, such as difficulties with camera enforcement at  
            stoplights and toll collection plazas, that occur when using  
            solely the report-of-sale as a temporary vehicle identifier  
            and to examine alternative methods to identify vehicles before  
            they display permanent license plates.  The problems caused by  
            vehicles without permanent plates are not well understood nor  
            quantified, and no one has conducted an evaluation of  
            potential temporary identifiers.  This bill fills that void by  
            fully examining the problems and the costs and benefits of  
            potential solutions, while also ensuring that needed  
            stakeholders are involved. 

           2.How much time for a temporary identifier  ?  State law requires  
            that a vehicle owner attach a license plate to a vehicle "upon  
            receipt" of that license plate, but allows up to 90 days - 75  




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            if this bill becomes law - for the license plate to arrive.   
            Typically, license plates arrive within a month, as state law  
            also provides dealers 20 days after selling a vehicle to  
            submit the required application and fees to DMV.  This 20-day  
            period is to ensure that the dealer has time to finish the  
            financing of the vehicle through a third-party lender and to  
            confirm other details of the new ownership arrangement.  It is  
            this period from time of sale to receipt of plates that a  
            temporary vehicle identifier - currently the report-of-sale -  
            fills.  In recent years, several proposals have surfaced to  
            mandate various temporary license plate systems to replace the  
            report-of-sale.  This bill charges DMV with assessing the need  
            for such a system, to examine options for how it could be  
            implemented, and to recommend a system that would most  
            cost-effectively meet the need. 

           3.Opposition  .  The Independent Automobile Dealers Association  
            opposes this bill's shortening from 75 to 90 days the time  
            during which a report-of-sale can serve as a valid temporary  
            vehicle registration.  The association, which represents  
            dealers that typically sell used vehicles, notes that it has  
            been less than two years since AB 1215 shortened this period  
            from six months to 90 days.  The association reports that its  
            member dealers find it difficult to complete title transfers  
            within that shortened time period, and the even shorter period  
            this bill allows would be even more difficult.

           4.Technical amendment  .  On page 3, line 14, delete "the chairs  
            of"

          Assembly Votes:

               Floor:    74-1
               Appr: 16-1
               Trans:    16-0

          POSITIONS:  (Communicated to the committee before noon on  
          Wednesday,                                             June 18,  
          2014.)

               SUPPORT:  California New Car Dealers Association (sponsor)

               OPPOSED:  Independent Automobile Dealers Association of  
          California






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