New York state’s county clerks have a few questions for the state Department of Motor Vehicles commissioner about the Green Light Bill.

Actually, they have 47 questions they’d like the state official to answer before the state Association of County Clerks holds its fall conference in Utica on October 7. Judith Hunter, Association of County Clerks president, sent the clerks’ questions to Mark Schroeder, state DMV commissioner, on Aug. 2 following the clerks’ association’s annual meeting.

“As you are aware, the NYS Association of County Clerks has had numerous discussions and several meetings in regards to the above,” Hunter wrote. “Since 51 of us serve as your agents, we not only appreciate your attention to the following, but anticipate and hope for awareness of our unique situation regarding the implementation of the above mentioned law and inclusion of said clerks in the interpretation and subsequent decisions related to the same.”

Among the clerk’s 47 issues are:

¯ Existing technology exists and should be activated to prevent someone without a Social Security number from having the option to sign up to vote.

¯ Clerks say those applying for a license under the Green Light Bill should be required to be vetted through the state Motor Vehicles Department offices in New York City, Nassau, Suffolk, Westchester, Rockland, Albany and Onondaga counties rather than at local offices.

¯ Will the state DMV provide fraud detection software to county DMV offices to expedite fraudulent document detection and make transactions move faster?

¯ Will New York adopt a rule requiring a criminal background check for applicants that don’t provide a Social Security number to ensure the person doesn’t have a conflict in identity?

¯ Will New York require a thumbprint or fingerprint as a way to identify a person, as California, Utah, New Mexico, Delaware and Illinois do?

¯ Clerks ask that if fraudulent documents are found, the applicant be banned from applying again for at least a year. Also, clerks say anyone with a criminal history of identity theft should be permanently disqualified from receiving a driver’s license under the Green Light Bill, something Connecticut also bars.

¯ How are foreign documents to be verified?

¯ Will there be a check or verification made on individuals who claim not to have a Social Security number to ensure they do not have one?

¯ What documentation will be allowed and what will the point values be? Will the six points of identification still be in place?

¯ Colorado requires any foreign documents contain the applicant’s full legal name, date of birth, date of issuance, country of issuance and a photograph. Clerks wonder if New York will follow suit.

¯ How will undocumented immigrants with existing New York records be handled? Will the state clear the existing record prior to the issuance of a Green Light license? Also, clerks wonder under what circumstances a Green Light license would be suspended — speeding, driving while intoxicated, traffic violations, insurance lapses, child support, failure to pay taxes, etc.

¯ If the state is not the first step in the process, the clerks are asking for training every six months so they know how to examine foreign documents for fraud or mutations. New hires should be offered training within the first 30 days of their hiring.

The clerks also have several questions about implementation of the Green Light Bill, including the Dec. 14, 2019, date it takes effect and the Oct. 1, 2020, date for the federal REAL ID to go into effect. The clerks reason that issuing “not for federal purpose licenses” to undocumented immigrants starting Dec. 16, it could mean the federal government moves up the date for REAL ID compliance — which means state residents would have six months to upgrade their standard driver’s licenses rather than 15 months. The clerks association also had concerns about costs.

“There are many concerns about implementation within small offices, in particular, the cost-effectiveness of processing in offices with limited staff, lack of professional translators available within the community and the necessity of increased security — all of which could come with additional financial burden to the local budget (as well our revenue v. cost of operation is becoming increasingly tight – my understanding being that according to Vehicle and Traffic, the cost of operating a county DMV is not to exceed revenue generated),” the letter states. “When and if policies, procedures and regulations are identified, reviewed by both New York state and county clerks, and ultimately readied for implementation, any processing of permits/licenses for undocumented immigrants must be directed to the much larger New York state district offices. It would be the only way to maintain systematic/consistent processing of these transactions.”