Overview
Title
Agency Information Collection Activities; Notice and Request for Comment; 23 CFR Part 1327 Procedures for Participating in and Receiving Information From the National Driver Register
Agencies
ELI5 AI
The NHTSA is asking people to share their thoughts on a plan to keep track of bad drivers to make roads safer. They want to make sure that drivers with big problems don't get away with driving in another state.
Summary AI
The National Highway Traffic Safety Administration (NHTSA) is seeking public comments on its plan to continue collecting information for the National Driver Register (NDR). This register helps states exchange information about drivers who have had their licenses suspended or revoked or who have been convicted of severe driving offenses. All 50 states and the District of Columbia participate in this program, which is intended to improve traffic safety by keeping problem drivers off the roads. Comments on this proposal must be submitted by May 27, 2025.
Abstract
The Department of Transportation (DOT) invites public comments about our intention to request approval from the Office of Management and Budget (OMB) for an extension of a currently approved information collection. Before a federal agency can collect certain information from the public, it must receive approval from the Office of Management and Budget (OMB). Under procedures established by the Paperwork Reduction Act of 1995, before seeking OMB approval, Federal agencies must solicit public comment on proposed collections of information, including extension and reinstatement of previously approved collections. This document describes a collection of information for which NHTSA intends to seek OMB approval titled "National Driver Register (NDR)."
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Sources
AnalysisAI
The Federal Register document discusses the intention of the National Highway Traffic Safety Administration (NHTSA) to extend its collection of information for the National Driver Register (NDR). This register is crucial for helping states exchange vital data about drivers whose licenses have been suspended or revoked, or who have been convicted of serious traffic offenses. All 50 states and the District of Columbia participate in this initiative, aiming to improve road safety by preventing problematic drivers from being on the road. The public is invited to comment on this proposal by May 27, 2025.
General Summary
The NHTSA is requesting public input on continuing an information collection that aids in improving traffic safety nationwide. This collection is part of a broader framework under the Paperwork Reduction Act that ensures federal agencies consult the public before gathering certain types of information. Specifically, the NDR serves as a centralized database facilitating the exchange of information among state driver licensing agencies, helping them identify problem drivers to prevent these individuals from obtaining a driver’s license elsewhere. The proposal includes detailed technical and procedural aspects, laying out how states will interact with the NDR system.
Significant Issues and Concerns
One of the significant issues in the document is the complex technical language and references, which might not be readily understandable to the general public. This could limit public engagement and reduce the quality and quantity of feedback that the NHTSA receives. Furthermore, the cost analysis is based on wage data last accessed in July 2021, potentially rendering it outdated compared to current economic circumstances. This may affect the accuracy of the projected costs related to maintaining the NDR.
Another concern is the assumption that there are no annual costs for respondents, despite the outlined breakdown of IT maintenance and clean file processes, which do imply recurring expenses for the states. Additionally, the document generalizes technical burdens and costs, which might not accurately reflect the diverse resources, systems, and capabilities across different states. The extrapolation from only two respondent states to the entire nation could result in miscalculations.
Public Impact
The document outlines a system that has the potential to significantly enhance traffic safety by limiting the mobility of drivers who present serious risks. By participating in the NDR, states can efficiently manage driver data, ensuring problem drivers are identified and addressed before they pose further risk. For the general public, this may lead to safer roads and potentially lower accident rates.
Stakeholder Impact
Specific stakeholders, such as state driver licensing authorities, might face challenges and opportunities with this information collection system. On one hand, it offers a streamlined process for verifying driver credentials and ensuring road safety. On the other hand, states must also invest in the necessary IT infrastructure and personnel to maintain and interact with the NDR, which could be a financial and logistical challenge, especially for states with fewer resources.
For employers in transportation sectors, this register could offer valuable insights into the driving records of current or prospective employees, enhancing hiring processes and reducing liability. Similarly, various federal organizations involved with safety regulations could benefit from easier access to detailed driving records, aiding their operations more effectively.
In summary, while the expansion of the NDR collection process yields considerable benefits in terms of safety and efficiency, there are significant challenges related to public understanding, fiscal implications, and state-specific capacities that need careful consideration and management.
Financial Assessment
The Federal Register document regarding the "Agency Information Collection Activities; Notice and Request for Comment" involves several key financial references that require careful examination.
Summary of Financial Allocations
The document estimates the cost of maintaining the National Driver Register (NDR) system and infrastructure. The key financial figures involved include:
- $17,400: The report mentions that from the two states surveyed, the combined burden for maintenance and labor cost totaled 530 hours, which corresponds to a labor cost of $17,400.
- $8,700: NHTSA uses this data to infer that each state's average yearly cost would be 265 hours of labor, equivalent to $8,700 annually.
- $443,700: Given the 51 respondents (50 states plus the District of Columbia), the total annual labor cost is estimated at $443,700.
- $23,647: The document also notes the cost of preparing and submitting "clean files" to the system. It estimates this annual IT labor cost at $23,647, calculated using an hourly rate of $95.35 derived from Bureau of Labor Statistics data.
Relation to Identified Issues
These financial allocations relate directly to several issues identified in the document:
Outdated Wage Data: The calculations reference wage data accessed in July 2021. Using data that may no longer accurately reflect current economic conditions could lead to underestimating or inaccurately projecting true labor costs. This poses a problem when trying to establish realistic budgetary requirements for maintaining the NDR.
Generalization From Limited States: The cost estimates for statewide NDR participation are based on submissions from only two states. Extrapolating these figures to all 51 participants without considering the diverse economic and infrastructural circumstances across different states might result in skewed financial forecasting. The document does not address how cost variations among states are accounted for, which could mean some states face significantly different financial burdens.
Recurring Costs and Assumptions: The document makes an assertion of "no annual costs," contradicting the outlined ongoing expenses related to IT infrastructure and clean file processing. These processes clearly indicate recurring costs for state participants, challenging the assumption that states do not incur additional annual expenses.
Uniformity of Costs: The document assumes uniform financial conditions across all states for implementing the NDR, ignoring potential discrepancies in state-specific IT capabilities and staffing resources. Such assumptions may overlook significant budgetary constraints or differences faced by individual states when interacting with the NDR.
By shedding light on these financial components and their related issues, the document outlines the level of complexity involved in maintaining the NDR, highlighting the importance of accurately understanding and projecting the associated costs.
Issues
• The document contains complex technical language and references that may be difficult for the general public to understand, particularly the detailed discussions related to the Paperwork Reduction Act and specific CFR references.
• The cost analysis uses outdated wage data from a document last accessed in July 2021, which might not accurately reflect current costs.
• There is an assumption of no annual costs for respondents, but the breakdown of IT maintenance and clean file processes suggests recurring costs for states.
• It is unclear how the burdens and costs, such as the maintenance cost estimations, per state, were generalized from only two respondent states to all 51 respondents.
• The document assumes that the infrastructure costs and technical burdens are uniform across all states without considering potential variances in state resources, systems, and staffing capabilities.