An analysis of the Notice of Proposed Rulemaking performed by the Real ID team for the State of Rhode Island identified areas of impact on the State and its constituents. These impacts fall into various categories, which are expected to increase cost and administrative burdens, including:
Many aspects of the process of obtaining and renewing licenses and identification cards will change for the constituents of Rhode Island . The State must undertake a comprehensive process of informing people of the changes and preparing people for implementation, so that the DMV will continue to run smoothly upon implementation of the new requirements.
Stricter standards for determining eligibility for driver's licenses and identification cards will require the DMV to collect, authenticate, and store electronically more source documents. This will require every Rhode Islander, even those who currently have a driver's license or ID card, to submit certain documents such as a birth certificate, social security card, and proof of residency for authentication and scanning for electronic storage. These new procedures require more constituents to visit the DMV offices and will increase the transaction times for driver's license and ID card transactions. The DMV will implement new processes and procedures to make the transition to these new requirements as smooth and seamless as possible, as well as utilize state-of-the-art technology to assist in speeding up these transactions. Public education is also integral to this transition.
The driver's license and ID cards issued by the DMV will contain enhanced security features that aim to prevent tampering, counterfeiting, or duplication for fraudulent purposes.
Real ID requirements mandate that state facilities conform to minimum standards to prevent access to restricted areas by unauthorized persons, ensure the security and privacy of sensitive customer data, and that mechanisms are in place to respond to threats to security. The proposed regulations recommend that facilities conform to the specifications of NASPO (North American Security Products Organization) Class II Security Assurance Standards (ANSI/NASPO-SA-v3.OP-2005).
Real ID imposes requirements on states to ensure that personnel that have access to sensitive personal data and the information systems used to issue Real IDs have been subject to criminal and financial history background checks. Access to stock of the materials used in making licenses and IDs, data, and information systems by certain personnel must be controlled and monitored.
States must create electronic interfaces with multiple federal databases to authenticate information such as citizenship status and birth records. Every transaction related to licenses and IDs will have an additional cost associated with querying these databases (usually cents on the dollar), and states must absorb these costs.
States must share certain data on drivers and individuals so that states issuing Real IDs can verify certain information about a person from another state.
In order to issue Real IDs, DHS must certify that a state has met all of the requirements and has all of the necessary security mechanisms in place to ensure the integrity of the licenses and IDs it issues. Once a state has been certified by DHS, the Real IDs it issues will be accepted for “official purposes” such as boarding a Federally-regulated commercial airliner, accessing a Federal courthouse, or entering a nuclear power plant. After initial certification, states must retain certification by making extensive annual reports to DHS about security mechanisms and undergo comprehensive, periodic audits of compliance.