When we last visited the issue of municipal ID cards, the City Council agreed to endorse the idea, but asked staff to come back with a report explaining our options for creating a municipal ID card program that wouldn’t cost the City any money before they actually started issuing them.
I know what you’re thinking. Good luck with that, right? Well, the report came back to the Finance & Management Committee last week, and, unsurprisingly, it found (PDF) that we can’t issue secure cards with existing equipment owned by the City after all, and that the equipment we’d need to issue them would cost somewhere between $300,000 and $500,000 to buy the technology, or $75,000-$133,000 a year to rent it. And then, of course, there’s staffing costs for the program.
The report suggests a few different options for paying for and staffing the program, ranging from a first-year cost of $713,000 and annual costs thereafter of $156,000 if we were to buy expensive equipment and staff the program with permanent, benefitted employees, to a first year cost of $162,000 and annual costs of $143,000 if we were going to lease cheaper equipment and staff the program with temporary, non-benefitted employees.
On the revenue side of things, the report estimates that a municipal ID card program could generate between $30,000 and $140,000 annually, depending on how many cards get issued (they’re guessing 2,000-4,000) and how much the City charges for the card (estimates are between $15 and $35).
The unpromising figures were not really discussed much at last week’s Committee. Instead, the Committee basically agreed that we should issue an RFP to provide the services, and that the time to discuss costs will be when the RFP responses come back. Fair enough, I suppose, but it does make you wonder why they didn’t just issue the RFP in the first place instead of wasting four months preparing a report that doesn’t seem, to me anyway, particularly optimistic about this ever being a cost-covered program.
The biggest issue during public comment was that the report did not specify that the cards would offer a debit function, a feature that municipal ID card advocates deem essential to a successful program. Their concerns are three-fold. One, that without a debit function, the ID cards will not appeal to anyone other than undocumented immigrants or people who have no other valid forms of identification, which will stigmatize the card and therefore limit its utility to the undocumented immigrants who need it. Two, undocumented immigrants have limited or no access to banking, and therefore often end up wasting a lot of money on check-cashing. They see the inclusion of a debit function on the card as a way to avoid that problem. Three, they think that if the card offered a debit function, the City could take a small charge for each transaction, which would yield enough revenue to pay for the entire program, plus enough revenue to subsidize other city services.
On the first point, I’m moderately sympathetic. Obviously, if you’re going to create this whole new card to help undocumented immigrants, then you want the card to be useful to them. However, it seems like people aren’t really thinking this whole thing through. Under any scenario, Oakland will have limited capacity to issue the cards. It seems, therefore, logical, that if we were to move forward with this, we would want to prioritize getting cards out to those the program was created to serve – people without other valid forms of ID. But then only people without other ID have the cards, and the card is stigmatized, and you’re kind of back right where you started. But if you let just anyone sign up for the cards right away, then the people who need them most may not be able to get them in a reasonable time frame. (This is, of course, assuming that anyone who has normal ID will event want this damn card, which seems unlikely to me.)
Any way I try to look at it, I just can’t see how a municipal ID card program can get around this dilemma. There is, very simply, a serious scalability issue. 425,000 people live in Oakland. Let’s assume an absolute rosiest case scenario and say that we had the capacity to issue the same number of cards as San Francisco, roughly 8,000 a year (SF’s program, like ours will be, is currently limited by card issuance capacity, not interest). There is just no way we can issue enough cards to have widespread enough use that we escape the stigmatization problem. It just can’t happen.
I am less sympathetic to the second concern, about banking. Isn’t part of the point of making the ID cards that people without ID will then be able to use their IDs to get accounts at banks? I mean, seriously. Just find some local banks that will agree to accept the cards as ID to open an account and call it a freaking day. One of the girls from the Oakland City ID Card Coalition spoke at Committee about how the debit component was essential, and described the New Haven card’s debit function as a model, which she said allows people to load up to $150, and is accepted at “over 40 stores.”
Even if I had previously thought we should include a debit component, then that right there would have been the end of it for me. If the best the card advocates can come up with as an example is a limit of $150 and 40 stores in New Haven allowing people to use the card, then it’s just clearly not worth it. I mean, how many retail outlets are there in New Haven? They have 124,000 people. I am quite sure that there are a lot more than 40. And of course, if the debit function is maxed out at $150, then again, we’re not doing anything to solve the problem of people without bank accounts having to carry with them enormous sums of cash all the time.
And on the third point, about the City making money off the debit function, all I have to say is hahahahahahaha. Seriously, get real.
There’s also this whole issue of local currency tied into this debate, which is just so far divorced from reality that it isn’t really worth getting into that much, except to say that former City Councilmember Wilson Riles, a strong advocate of the ID cards, wants us to pay City employees in something called ACORNs:
Um. So, I work for the City. I am also a member of SEIU 1021. Let me say right now that I do not want to be paid in ACORNS ever, for a furlough day or any other day. My landlord does not accept ACORNS, Sallie Mae does not accept ACORNS, and I’m pretty damn sure that Verizon Wireless is not going to accept ACORNs.
Anyway, the Committee ended up directing staff to issue an RFP that solicited requests for issuing cards that include a debit component, but also allowed for responses without a debit component, a basically agreed that they’d figure out which they wanted to do once the responses came in.
The Committee’s recommendation will come to the City Council for approval tonight, accompanied by a fun letter from the City Attorney’s office. As you might imagine, they does not seem particularly thrilled (PDF) about the idea of the City getting into the debit card business:
We are writing to advise that this Office will retain a banking law expert to provide advice and recommendations regarding the legal issues and ramifications of the debit component if the Council approves the Committee’s recommendation. Adding a debit feature on the municipal identification card raises a number of legal issues under complex and dynamic state and federal banking laws and regulations, including but not limited to the Fair Credit Reporting Act, the Bank Secrecy Act, money service licensing regulations and anti-money laundering laws. Neither this Office nor any other municipal law office or practice has expertise in-house to address banking law issues as they are not typically at issue in municipal law practice.
The memo goes on to say that the City can expect to spend between $25,000 and $60,000 on outside legal advice if they decide to go this route.
Sigh. I am not at all unsympathetic to the problem immigrant communities face with respect to the unavailability of identification. There are problems with respect to access to social services. There are problems with respect to driving. There are problems with respect to interaction with the police. There are problems with respect to banking. If the City could do something about these problems, then I think they should. But we simply do not have the capacity, financial or even just functional, to solve these problems. This program does not solve these problems. It just costs money. And money is something that the City just doesn’t have right now.