CALIFORNIA STATE TRANSPORTATION AGENCY EDMUND G. BROWN JR. Governor

OFFICE OF THE DIRECTOR

DEPARTMENT OF MOTOR VEHICLES
Ro. BOX 932323

SACRAMENTO. CA 94232-3230

 

December 21, 2018

Mr. Steve Yonkers

Director of the REAL ID Program

US. Department of Homeland Security
245 Murray Lane SW, MS 0445
Washington, DC 20528-0445

Dear Mr. Yonkers:

I write in response to Assistant Secretary Elizabeth Neumann?s letter, dated November 21, 2018,
regarding California?s REAL ID compliance request. As you know, California submitted its final
compliance package to the Department of Homeland Security (DHS) on February 22, 2018. Over
the past nine months, the California Department of Motor Vehicles (CADMV) has responded to
several DHS inquiries and provided supplemental information to support a determination that
California is compliant with the REAL ID Act. The purpose of this letter is to respond to 
latest inquiry regarding compliance with ?37.l 1(f) of the REAL ID Act pertaining to
residency document requirements.

One of ?nal activities to begin offering REAL ID cards on January 22, 2018, was
pursuing regulations to require applicants to submit appropriate documents. For proof of
residency, CADMV reviewed the regulation and procedure adopted by Wisconsin (at state
currently determined to be in compliance with the REAL ID Act by DHS) where applicants
provide one residency document and the United States mail return service process serves as the
second residency document. In that process, Wisconsin, like CADMV, mails driver?s licenses
(DL) and identi?cation (ID) cards to the address provided on the card application, with a
return service requested. If the applicant is not recognized as an inhabitant or is no longer at
that address, the mail is not forwarded to another address and is returned to the sender.

The CADMV determined that this approach would be less burdensome on all applicants and
consulted with DHS on whether California could mirror Wisconsin and implement a similar
procedure. On June 6, 2017, DHS informed CADMV via email that the practice of mailing
cards with return service requested as the second proof of residency would be acceptable,
and we began using this method upon REAL ID implementation starting in January, 2018. To
date, 2,300,000 REAL ID cards have been issued.

On November 21, 2018, CADMV received a letter from DHS providing new direction that the
residency process described above does not comply with ?37.11(f) of the REAL ID Act. In order
to proceed with the review of California?s compliance certi?cation, DHS requested a corrective
action plan that identifies California?s timeline for implementing a revised residency document

California Relay Telephone Service for the deaf or hearing impaired from TDD Phones: 1-800-735-2929; from Voice Phones: 1-800-735-2922

EXEC 601 (REV. 712013) A Public Service Agency

Mr. Steve Yonkers
December 21, 2018
Page 2

process, where customers will be required to submit a second proof of residency to obtain a
REAL ID ID card.

Due to the programming efforts necessary at the department to implement this change, the
CADMV will begin requiring customers coming in for a new REAL ID card to provide
two proofs of residency starting in April, 2019.

As stated above, since CADMV began issuing REAL ID cards, more than 2,300,000 cards
have been issued. Pursuant to new direction, the CADMV starting in spring 2019, will begin collecting
a second residency document from customers already in possession of a REAL ID card and at the time
of their next renewal and give customers the option of submitting their second form of residency via
mail, online, or at a ?eld of?ce. This process was discussed with DHS on November 28, 2018 and we
understand this approach is acceptable to DHS. The types of documents that will be collected as the
second proof of residency document are already identi?ed on the list of acceptable residency
documents that was previously adopted via state regulations and is currently in use. This list includes,
among other items, a state-issued document such as the renewal notice that is sent to the individual?s .
residency address. In order to minimize confusion among our customers, the CADMV will work to
inform individuals who have been issued a REAL ID under the current process that their card will be
accepted for official federal purposes, even if their renewal occurs after the October 1, 2020, ?nal
enforcement date for REAL ID.

'With California?s current REAL ID extension ending on January 10, 2019, we hope that this
information will assist DHS in completing California?s compliance determination. For additional
information or questions, please contact Deputy Director of Licensing Wesley Goo at 

   

AN SHIOMOTO
Director