Full Report (PDF) - Office of the Legislative Auditor

58MOTOR VEmCLE DEPUTY REGISTRARSDeputy Registrar Association contends that changing the fee structure is undesirablebecause it would make the system more complex. We think that it would beimpractical to set a different fee for every possible type of transaction, but that usingthree different fee levels would be reasonable.STATE REGULATION OF DEPUTYREGISTRARSThe state limitsthe number ofdeputies tocontrol the costof regulationand to makedeputieseconomicallyviable.In Chapter 1, we showed that much of the regulatory activity of the Department ofPublic Safety is designed to safeguard the collection of state funds and to maintainaccw:ate motor vehicle records. DPS criteria for the establishment of new deputyregistrar offices limit the number of deputies and protect the customer base for existingdeputies. For example, in metropolitan counties, the criteria prohibit establishinga new deputy registIar office within 5 miles of an existing deputy. Arationale for limiting the number of deputies is that adding more deputies addscost to the system and may make it harder to regulate. The Department of PublicSafety estimated that adding a new deputy would cost about $4,2QO per year tocover additional training, supervision, and record keeping by DPS staff. Therewould also be additional inventory costs of about $12,500 for license plates, tabs,and forms. Most of this additional inventory cost would be a one-time expensesince license plates can be used from year-to-year.Another rationale for the state's criteria is that they help ensure that existing deputyregistrars remain economically viable. Otherwise there could be high turnoverand, in the case of public deputies, citizens may have to pay higher taxes to supportthe deputy registrar. Our data show that there are economies of scale for deputyregistrars, though the effect appears to taper off as deputies become larger.However, stateregula tion doesnot adequatelyconsidercustomerservice.We think that there are legitimate reasons to consider how a new deputy may affectexisting deputies or state regulatory agencies. But, it is also important to considercustomer service. Currently, the system promotes access to deputy registrarsby allowing counties to operate or appoint deputy registrars throughout the state.State regulations impose minimum hour requirements (40 hours per week) andsome office-layout requirements on deputy registrars. I However, state criteria forestablishing new deputies protect the territory of existing deputies with little regardfor whether the public is being adequately served. The criteria do not considercustomer waiting times, whether a new location would be more convenientfor the customer, or other measures of customer satisfaction. Even if a deputy registraris providing poor service, nobody may establish a new office near that deputy.In addition, some innovative ways of improving customer service areprohibited by rule. For example, some deputies have been interested in setting upsatellite offices in regional shopping centers or near emission test stations. However,DPS rules do not pennit new offices, including branch offices that issue tabson site, to be located within 5 miles of another deputy.2 Furthermore, DPS does1 Deputy registrars must also meet federal requirements concerning access for disabled people.2 This restriction does not apply to drop-off sites as long as the transaction is processed at the deputy'smain office.