Hitting Moving Targets

TPP-2012-11-Hitting Moving TargetsBy Mike Carneiro

In some parking enforcement jurisdictions, as few as 25 percent of parking fines are collected in full before the first enforcement escalation. Even the best-run parking programs only achieve voluntary payment rates in the 35 to 40 percent range unless they initiate a process of mailing follow-up notices. What happens to the rest of those tickets? They age and become increasingly difficult to collect.

The steps taken by a municipality, beginning with the issuance of a ticket, can be critical to both the effectiveness of the parking ordinance to helping traffic flow and curb turnover, and to the successful collection of the fine. There is one common thread to any successful enforcement effort: you have to know who the registered owner of the vehicle is and how to reach him or her.

Accurate steps must be taken early on, starting with a need for the ticket writer to properly record all pertinent data; if they fail to do so, the citation may prove to be uncollectible. If all key elements are recorded at the time of the violation, the success of finding the registered owner and ultimately collecting payment increases dramatically. It is critical that all the information used to contact a violator be accurate, not only to secure vehicle ownership and send notices in hopes that the municipality will receive payment, but also to reach the owner of the vehicle who is ultimately responsible for the violation under the law.

Go to the Source
The only place to obtain registered owner information is at the source—the state department of motor vehicles (DMV). DMVs are like fingerprints: every state has one, but no two are the same. The only common denominator is that they all issue license plates.

Just as the parking profession has the International Parking Institute (IPI) to help develop and promote practices to improve our operations, there is a similar industry association for DMV professionals. The American Association of Motor Vehicle Administrators (AAMVA) focuses exclusively on issues related to DMVs. Its members and constituents include 51 DMVs in the U.S. alone, and each one is preoccupied with issues.

Some of the leading priorities of DMVs are designed to make it difficult and complex to obtain registered owner data in the name of privacy protection. This requires that the party making a request provide sufficient information and credentials to prove its legitimacy.

“At the end of the day, it’s not just one person crafting these rules, but 51 governors, legislatures, and others, which can lend to widely variant requirements,” says Neil Schuster, president and CEO of the AAMVA.

In a perfect world, every vehicle would be issued a unique license plate. In the DMV world, the same license plate numbers are issued across as many as 40 different registration types. This may be the biggest challenge to proper identification. Without knowing the registration plate type, getting the correct violator is like shooting a bow and arrow while blindfolded.

Are there duplicate license plate numbers for different plate types within an individual state?

What happens to the license plate when a vehicle is sold? In 10 states, ownership of the plate is transferred with the vehicle upon sale, making the processing of backlogged violations more complicated and requiring a comparison of vehicle ownership effective dates to citation issue dates.

Does the state require a contract with the municipality before allowing it to make an inquiry? Nine states–Arizona, California, Connecticut, Illinois, Iowa, Michigan, New Jersey, New York, and Virginia–have such a requirement.

Each state has its own regulations for the number of characters on a plate, ranging from one to eight. According to the AAMVA’s Automated License Plate Reader Working Group, 23 jurisdictions will allow one character on a vanity plate, and 32 allow stacked characters on license plates.

Are there other data elements that must accompany the plate when an inquiry is made at the DMV, such as registration plate type, vehicle make, or violation date? Many DMVs require this information to help protect the privacy of motorists.

Intentional Barriers
Some of the barriers that DMVs have erected are intentional in an effort to protect the privacy and safety of motorists. For example, the change in federal statutes that occurred in 1994 with the Drivers Privacy Protection Act (DPPA) called for important changes in procedures. The intent was to protect the identity of vehicle owners, making it difficult, if not impossible, for anyone to acquire a name and address based on a license plate. The law was enacted after several high-profile stalking cases, at least one of which ended with a motorist being murdered by her stalker. The gauntlet put up by the Act also affected the parking industry as states tightened their grips on registration data. Today, if you are not DPPA-qualified, you will not be able to obtain personal data.

So how, in such a diverse world of license plate issuance, does a municipal government maintain a successful parking program? A good place to start is by employing experts who stay attuned to changes in each DMV’s rules, regularly gather data to ensure the greatest opportunity of locating a vehicle’s rightful registered owner, and who know all the nuances to requesting that information. Very high success rates have been achieved in locating registered owners by working with such experts.

One agency in the southeast was faced with more than 75,000 offender accounts that had undeliverable addresses. After the agency undertook a thorough DMV search for those addresses with the help of an experienced vendor, new address information was generated for 81 percent of those accounts, resulting in an additional $5.1 million in billable debt placed back in the collection stream.

To successfully locate registered owners, you have to be as proactive as possible and open a dialogue with every DMV. With an up-to-date knowledge of each DMV, an experienced team can continually tune the system, creating profiles on each motor vehicle division that help make specific determinations about which data elements are required to compile a qualified identification. Additionally, the profiles contain elements that identify whether the state reissues license plates or issues a multitude of plates with the same number but in different categories.

Focus on What Matters
In today’s mobile society, it’s not enough to know how to navigate your home state’s DMV regulations, particularly if your municipality is located near your state’s border. An analysis of license plates on citations will reveal where efforts should be focused.

The challenge of obtaining registered owner information for out-of-state license plates becomes more complex and paramount for cities that are tourist destinations, house major universities, or are close to state borders. New Haven, Conn., for example, is home to Yale University, is the regional center for arts and culture, and is within a 200 mile radius of 10 neighboring states. About 45,000 students attend New Haven’s five colleges and universities: 45.4 percent are from out of state.

“Annually, about 15 percent of all the parking tickets we write are to vehicles with out-of-state plates,” says Jim Travers, New Haven’s director, transportation, traffic, and parking. “If we were not able to accurately and efficiently work with various states’ DMVs, we would very quickly lose control of our ability to maintain parking compliance.”

For many municipalities, knowing the regulations in the home state and perhaps up to three others will drive effective enforcement efforts. University towns may need to know the regulations in as many as 15, depending on the home states of its students. For tourist towns, multiply that need for knowledge by as many as 51 state and district departments and even those of other countries.

Just the Beginning
One of the key techniques that has been developed and adopted among municipalities, DMVs, and professional service providers is vehicle make/model matching. If plate typing is not an issue for a given DMV, identifying and comparing the vehicle makes from both the violation and the registration data returned by the DMV will vet out possible misidentifications. Some states require or recommend validation and comparison of body styles. If a motorcycle’s body style does not match a tractor trailer’s, the comparison eliminates potential problems. Having the ability to disqualify records and avoid a public relations nightmare by using one, two, or all three of these methods lends to the success of the parking program.

No matter how advanced anyone’s system may be, there is no absolute toward proper identification when entering and navigating the DMV maze. What a parking program needs is to arm itself with subject matter experts whose sole focus is to understand, anticipate, and adapt to the ever-changing and diverse world of registered owner acquisition and DMV processing.

Mike Carneiro is manager of data acquisition services for Duncan Solutions. He can be reached at mcarneiro@duncansolutions.com or 718.715.1941.

TPP-2012-11-Hitting Moving Targets