On August 16, 2024, NYSACDL submitted public comments regarding the Department of Motor Vehicles’ Proposed Point System and Licensing After Revocation Action (revised from 2023.) Please read the submitted comments here (PDF).
From the Letter:
The proposed regulations reach far beyond the regulatory authority granted to the Department and it tramples upon the legislature’s authority and purview in violation of the separation of powers doctrine. Instead of seeking “to establish a system” where one already exists, the Action is expanding the punitive reach of the Department’s jurisdiction without legislative authority to do so and engaging in legislative policy making beyond its statutory authority.
The 2024 DMV proposed regulations if implemented would unduly impact poor and underserved communities.