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Chapter 5.1

Create County “One-stop Shops” for Vehicle Titling and Registration to Improve Customer Service


Summary

Titling and registration functions are performed by the Texas Department of Transportation’s (TxDOT) Austin headquarters, 17 Vehicle Titles and Registration regional offices and county assessor-collectors. Creating one-stop shops at the county level and focusing TxDOT’s regional offices on unique functions, including supporting counties, would improve customer service.


Background

State law requires all vehicles, with few exceptions, that are operated on public roads to be titled and registered in Texas.[1] TxDOT is the state agency responsible for this titling and registration, and state law designates county assessor-collectors as agents of the state. Although state law indicates that Texans would initiate all vehicle titling and registration transactions at their county assessor-collectors office, this is not the case.[2]

The TxDOT Austin headquarters, 17 TxDOT regional Vehicle Titles and Registration (VTR) offices, and 254 county assessor-collectors’ offices perform vehicle titling and registration transactions. Although most Texans are familiar with titling and registering their personal vehicles, other transactions include registering trucks engaged in interstate commerce under the International Registration Plan (IRP), issuing special license plates, issuing copies of titles, and supporting county operations. These various transactions are entered into TxDOT’s automated Registration and Titling System (RTS) or other automated systems.


Division of Responsibilities


Austin Headquarters

TxDOT’s Austin headquarters administers vehicle registration and titling with about 200 employees.[3] Operations are divided into four main areas: Administrative Operations, Technical Operations, Headquarters Operations and Field Operations. In general, Administrative Operations performs support functions such as human resources, internal mail and purchasing.[4] Technical Operations supports the internal and external users of RTS, tests new upgrades, and generates ad hoc reports to assist management and law enforcement.[5] Headquarters Operations develops policies and procedures for headquarters, regional offices and counties, administers the IRP, processes and prints vehicle titles, responds to written and e-mail correspondence, and administers the special plates program.[6] Field Operations directs the activities of the 17 regional offices and the division’s centralized Help Desk, develops policies and procedures used by the regional offices in support of 254 county assessor-collector offices, oversees the allocation and leasing of RTS workstations, and provides RTS technical support to the counties through the Help Desk. The Help Desk also provides telephone customer service to the general public. In addition, the regional offices work with state and local law enforcement agencies on registration and title issues.[7]


Regional Offices

TxDOT maintains 17 regional offices to provide customer support to the county assessor-collector offices and to perform a variety of registration and titling services for customers who call or come in.[8] About 203 TxDOT employees are located in the 17 regional offices.[9] The regional managers report to the director of Field Operations. The fiscal 2000 budget for these 17 regional offices totaled $7.7 million, with $6.3 million allocated to salaries.[10] The VTR regional offices are located in Abilene, Amarillo, Austin, Beaumont, Corpus Christi, Dallas-Carrollton, El Paso, Fort Worth-Arlington, Houston, Longview, Lubbock, Midland-Odessa, Pharr, San Angelo, San Antonio, Waco and Wichita Falls.[11] Historically, most of the regional offices were located in leased space; however, 10 of the offices have recently moved onto TxDOT district office campuses. Two offices will move into district facilities during fiscal 2001. By the end of fiscal 2001, only five regional offices will be located in leased space.[12]

The VTR regional offices’ primary duties include:

• Providing training for county assessor-collectors’ offices,

• Maintaining visibility through frequent visits to county assessor-collectors’ offices,

• Assisting walk-in and telephone customers related to the issuance of certified copies of original titles (CCOs), permits, refund authorization, motor vehicle record inquires, bonded title letters, and resolving registration and titles issues,

• Processing apportioned vehicle original and supplemental applications and registrations under the IRP, and

• Auditing apportioned vehicle mileage records in compliance with the IRP.[13]

Regional office employees provide training and maintain visibility through frequent visits to county assessor-collectors’ offices. During fiscal 1999, regional office managers and field auditors visited the county offices almost 4,900 times; each county office is visited at least once a month. The purpose of the visits is to maintain contact with the county assessor-collectors and their employees and to answer questions.[14] The regional office managers and field auditors provide training to the county employees on registration and titling procedures. The 27 field auditors spend approximately 45 percent of their time providing training. If major changes have been made to RTS, the field auditors may make a presentation to county employees, or observe them working with customers and provide immediate feedback on their use of system features.[15] In addition, the field auditors inventory expired items, such as registration stickers, each year and perform a full inventory whenever a new assessor-collector takes office.[16]

Regional office employees also provide walk-in and telephone customer assistance. The regional offices report responding to almost 854,000 calls in fiscal 1999 and assisting almost 463,000 walk-in customers.[17] Of the almost 854,000 telephone calls, 55 percent were from citizens and 45 percent were from county assessor-collectors’ offices.[18] The regional offices direct the technical questions to the central Help Desk in Austin, which also answers general information questions.[19] During calendar 1999 the Help Desk received almost 78,000 technical questions and approximately 228,000 non-technical questions in addition to the calls received by the regional offices.[20]

The regional offices filled almost 305,000 requests for CCOs during fiscal 1999 from walk-in customers.[21] The majority of the customers, 65 percent, are citizens who have lost their title and would like to obtain a certified copy for their files, about 25 percent were vehicle dealers or title service companies, and the remaining 10 percent were people selling their vehicle who needed a copy of the original title to complete the sale.[22] CCOs can also be obtained by mailing a request to the Austin headquarters or to one of the regional offices. During fiscal 1999, the regional offices responded to about 45,000 mail requests; Austin headquarters responded to about 89,600 mail-in request for CCOs in fiscal 1999.[23] TxDOT responds to these mail-in requests within five days.[24]

Owners of commercial vehicles unregistered in Texas, who wish to operate the vehicle in Texas for a short period of time, may go to a regional office to obtain a permit. The permit allows the vehicle to be operated for 72 hours, 144 hours, 30 days, or for a specific trip. The owner fills out the necessary forms, pays the appropriate fee and receives a permit. The regional offices processed almost 24,000 such permits in fiscal 1999 while the counties processed almost 155,000.[25] When permits are issued by the county, the county collects the fee, which is combined with all the registration fees it collects. The amount of the fee retained is determined by a complex remittance formula contained in state law. When permits are issued by the regional office, the fees are processed differently and the whole amount is kept by the state.[26] Although less than 15 percent of the permits are issued by the regional offices, these transactions represent fees the counties do not receive.

With the exception of Dallas County, all requests for registration refunds are initiated at the regional offices. The regional office provides the owner with a receipt, which the owner must take to the appropriate county assessor-collector’s office for payment.[27] This process requires the vehicle owner to drive to the regional office, which may be across town or more than 100 miles away, and then drive to the county assessor-collector’s office to receive the refund. During fiscal 1999, the regional offices handled about 17,100 such requests for refunds.[28] The Dallas County Assessor-Collector’s Office requested, and TxDOT granted, the authority to administer the entire registration refund process for its customers. By performing the entire transaction at the county level, customer service is improved by eliminating the trip to the regional office.[29] Better customer service could be provided statewide if all county assessor-collectors could perform the complete refund process, requiring only one trip for the customer instead of two.

The regional offices processed about 37,000 requests, called inquiries, for current ownership information in fiscal 1999.[30] The request may come from the owner, law enforcement, or the court system to verify who owns a particular vehicle. A regional office employee collects the $2 fee, accesses RTS and provides a printout of the current information. County assessor-collectors also perform this service and when they do, they keep the fee.[31]

The regional offices issue bonded title letters to owners who have lost their titles and lack documentation to prove they own the vehicle. The letters are issued for a one-year period. If no one contests the ownership of the vehicle within three years, a clear title can be issued to the owner. During fiscal 1999, the regional offices issued almost 5,700 bonded letters.[32] Although the regional offices are currently the only location for processing these letters, this function could be performed by the Austin headquarters. The forms could be added to the other forms available on TxDOT’s Web site and could be made available through the county offices. The owner could fill out the form and receive the bonded title letter through the mail.

The last two major duties of the regional offices relate to the registration of trucks involved in interstate commerce, often referred to as apportioned vehicles. Texas and the other states, the District of Columbia and several Canadian provinces, participate in a standard registration process. This process, IRP, requires the payment of state registration fees to be based on the percentage of miles traveled in each state.[33]

Texas truck owners seeking an apportioned registration to operate in various states must come to a regional office to fill out the necessary forms and to receive the appropriate license plates. Each new application takes an average of one hour to process; during fiscal 1999 the regional offices processed slightly more than 6,300 new applications.[34] Owners of apportioned vehicles must visit a regional office to make changes, called supplemental applications, to their original applications. Supplemental applications are required by such changes as operating the vehicle in a state not on the original application or adding vehicles to the owner’s fleet.[35] In fiscal 1999, the regional offices processed almost 28,000 supplemental applications.[36] Each supplemental application requires about 15 minutes to process.[37]

Apportioned vehicle registrations are renewed annually. The renewal notices, about 18,165 in fiscal 1999, are printed and mailed to owners by the Austin headquarters.[38] The owner can go to the regional office to pay the fees or can mail the form and appropriate fees, but must pick up the cab card that shows the states in which the vehicle has paid to operate, at the regional office. Processing a renewal in a regional office takes less than 30 minutes to complete on average.[39] When collecting fees, TxDOT uses a two-check process. One check, for the Texas portion of the fee, is written to the county assessor-collector of the county in which the business is located, and the check for payment due to all other jurisdictions is written to TxDOT. Each week regional offices send the checks by mail to the appropriate county assessor-collectors.[40]

Under the IRP, Texas must conduct audits to help ensure that each state receives the correct portion of registration fees. Owners of trucks that are registered as apportioned vehicles must submit all of the mileage records and supporting documents to TxDOT every three years. The field auditors spent almost 6,000 staff hours auditing mileage records during fiscal 1999.[41]

With only 17 regional offices, vehicle owners in 237 counties must travel to another county to process their renewal. In some cases, the distance is significant. For example, for vehicle owners in Laredo, the regional office is in Pharr, more than 145 miles away.[42] Allowing county assessor-collectors to process these transactions would allow vehicle owners to complete the registration process in their own county, decreasing the time required to complete the transaction.


County Assessor-Collectors

The county assessor-collectors initiate title transactions and register most vehicles. The assessor-collectors receive the documents and payments to begin the transaction to issue vehicle titles. The documents and a portion of the fee are forwarded to the Austin headquarters where the titles are printed and mailed to the owner or, when appropriate, to a lien holder. The assessor-collectors also register most vehicles. The assessor-collectors process the registration notices mailed by TxDOT to most vehicle owners, collect the appropriate fees and issue the windshield sticker. The counties are responsible for training all office personnel, but are assisted frequently by TxDOT regional office managers and field auditors.[43]


Improve Customer Service by Creating County One-Stop Shops and Refocusing Regional
Employees

Although state law would indicate that Texans initiate all titling and registration transactions at their county assessor-collectors office, this is not the current practice. As discussed above, TxDOT regional office employees perform a variety of tasks in place of county employees. The regional offices should perform unique functions and eliminate the duplication of services provided by county or Austin headquarters employees. In addition, several functions should be made available to the counties or transferred to the Austin headquarters.

The regional office employees should focus their resources on providing training and support to county assessor-collectors’ offices and serving apportioned vehicle customers. However, county assessor-collectors should be allowed to choose to serve apportioned vehicle customers in order to provide better customer service to their county residents.

To increase efficiencies, the regional offices should attempt to reduce the number of transactions it performs on a routine or emergency basis when the Austin headquarters generally performs or could perform these functions. Examples include the issuance of CCOs, bonded title letters and responding to telephone calls that could be answered by the Help Desk.

To create county one-stop shops, the regional offices should eliminate services such as permits and inquiries that can already be performed by counties. In addition, processing the entire refund transactions would need to be delegated to all counties to eliminate the trip to the regional office to initiate the refund transaction.

After the refocusing its efforts on unique transactions, the size of the regional offices could be reduced. About 128 regional office employees would be needed to perform these on-going functions.


Recommendation

Create county one-stop shops for vehicle titling and registration to improve customer service and refocus TxDOT’s regional offices to support county one-stop shops and to serve apportioned vehicle owners.

County assessor-collectors’ offices should be one-stop shops for vehicle registration and titling transactions. To create the one-stop shops, the Texas Department of Transportation (TxDOT) regional offices should cease to provide services that are also performed by the counties. In addition, counties should be allowed to choose, on a county-by-county basis, to register vehicles under the International Registration Plan. The regional offices would continue to perform these transactions for counties in their region that chose not to participate.

In addition to serving apportioned vehicle owners, TxDOT’s regional offices should focus on supporting county one-stop shops. TxDOT should reduce the number of transactions it performs on a routine or emergency basis when the Austin headquarters generally performs or could perform these functions. Examples include the issuance of CCOs, bonded title letters and responding to telephone calls that could be answered by the Help Desk.

After these changes are completed, the size of the regional office staff would be reduced by 74 employees. Regional office employees who are not currently located on the campus of a district office should be housed on a district or area office campus. TxDOT should implement these changes during the 2002-2003 biennium.


Fiscal Impact

Reducing the number of regional office employees by 74 would result in an annual savings of $2.87 million in salaries and benefits. In addition, co-locating the five regional offices on district or area office campuses would reduce lease costs, but the amount cannot be estimated.

Eliminating certain duties at the regional office level would reduce revenue to the State Highway Fund. Assuming a greater portion of CCOs are issued through the mail and that all inquiries are performed by the counties, the fund would lose about $337,000 annually. In addition, since the permit fees are combined with other registration revenues and the statutory formula applies to the total county collections, the effect on the fund cannot be estimated. The estimated savings below represent the amounts of the State Highway Fund revenue that could be redirected to other TxDOT programs or budget items.

Counties would realize an increase in revenue from inquiries of about $74,000 plus an increase in registration revenue that cannot be estimated.

Fiscal Year
Net Administrative Cost Savings
Available to Redirect to the StateHighway Fund
Change in FTEs
2002
$0
0
2003
$2,530,000
-74
2004
$2,530,000
-74
2005
$2,530,000
-74
2006
$2,530,000
-74

Endnotes

[1 ]V.T.C.A., Transportation Code §502.002 and §501.022.

[2 ]V.T.C.A., Transportation Code §501.023 and §502.002(b).

[3 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 9, 2000.

[4 ]Texas Department of Transportation, Vehicle Titles and Registration Division, Division Overview (Austin, Texas, March 28, 2000).

[5 ]Interview with Gary Bible, Production Data Control Branch, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 14, 2000; interview with John Calvin, chief, Registration and Titles System, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 14, 2000; interview with Tobe Hubbard, chief, Technical Operations and Support, Technical Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 14, 2000; and interview with Bob Tanner, director, Technical Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 14, 2000.

[6 ]Interview with David Linzey, director, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 11, 2000; interview with Duane Pufpaff, chief, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 11, 2000; interview with John Poole, International Registration Plan, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 11, 2000; interview with David Escamilla, Special Plates, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 11, 2000; interview with Judy Thorp, Customer Information Services, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 12, 2000; and interview with Sue Mainzer, Title Control System, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 12, 2000.

[7 ]Interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 10, 2000; and interview with Bill Pool, Customer Help Desk, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 12, 2000.

[8 ]Interview with Jerry Dike, director, and Darrel Hunt, deputy director, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, January 26, 2000; and Texas Department of Transportation, Vehicle Titles and Registration Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[9 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 9, 2000.

[10 ]Memorandum from Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, to Frank Smith, Hagler Bailly Services, Inc., Austin, Texas, August 14, 2000; and telephone conversation with Danny Garza, assistant director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, September 11, 2000.

[11 ]Texas Department of Transportation, Vehicle Titles and Registration Division, Form VTR-601, January 1999. (Map)

[12 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 9, 2000, and letter from Cathy J. Williams, PHR, assistant executive director for Support Operations, Texas Department of Transportation, to Clint Winters, Research and Policy Development, Texas Comptroller of Public Accounts, Austin, Texas, October 18, 2000.

[13 ]Memorandum from Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, to Frank Smith, Hagler Bailly Services, Inc., Austin, Texas, August 14, 2000, and letter from Cathy J. Williams, PHR, assistant executive director for Support Operations, Texas Department of Transportation, to Clint Winters, Research and Policy Development, Texas Comptroller of Public Accounts, Austin, Texas, October 18, 2000.

[14 ]Telephone interview with Danny Garza, assistant director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 18, 2000.

[15 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 9, 2000, and memorandum from Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, to Frank Smith, Hagler Bailly Services, Inc., Austin, Texas, August 14, 2000.

[16 ]Interview with Rexannes Meaux, regional office manager, Austin Regional Office, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 10, 2000.

[17 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000; and Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[18 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 9, 2000; and letter from Cathy J. Williams, PHR, assistant executive director for Support Operations, Texas Department of Transportation, to Clint Winters, Research and Policy Development, Texas Comptroller of Public Accounts, Austin, Texas, October 18, 2000.

[19 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000; and interview with Bill Pool, Customer Help Desk, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 12,2000.

[20 ]Texas Department of Transportation, “Automation and Public Calls for Calendar 1999,” Austin, Texas. (Computer printout.)

[21 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[22 ]Telephone interview with Danny Garza, assistant director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 18, 2000.

[23 ]Telephone interview with Duane Pufpaff, chief, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, September 11, 2000; Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas, and Texas Department of Transportation, “1998 Title Control Systems Branch Production Report,” Austin, Texas, (Computer printout.); Texas Department of Transportation, “1999 Title Control Systems Branch Production Report,” Austin, Texas, (Computer printout.), and Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[24 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 25, 2000.

[25 ]Letter from Cathy J. Williams, PHR, assistant executive director for Support Operations, Texas Department of Transportation, to Clint Winters, Research and Policy Development, Texas Comptroller of Public Accounts, Austin, Texas, October 18, 2000.

[26 ]V.T.C.A., Transportation Code §502.102, telephone interview with Duane Pufpaff, chief, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, November 21, 2000 and E-mail from Duane Pufpaff, chief, Headquarters Operations, Texas Department of Transportation, November 21, 2000.

[27 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[28 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[29 ]Telephone interview with Danny Garza, assistant director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 23, 2000.

[30 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[31 ]Telephone interview with Duane Pufpaff, chief, Headquarters Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, November 14, 2000.

[32 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas, and telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[33 ]Telephone interview with Julie Denniston, Apportioned Auditor, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, September 21, 2000.

[34 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas, and telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[35 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[36 ]Texas Department of Transportation, Vehicle Titles and Registration Division Regional Office Work Summary for Fiscal Year 1999, Austin, Texas.

[37 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[38 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[39 ]Telephone interview with Harry Morgan, director, Field Operations, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, August 21, 2000.

[40 ]Texas Department of Transportation, Apportioned Registration Instruction Manual Under the International Registration Plan, (Austin, Texas, July 1999), p. 2-3, and e-mail communication from Duane Pufpaff, Texas Department of Transportation, December 8, 2000.

[41 ]Texas Department of Transportation, “Apportion Audit Time and Work Summary Fiscal Year 1999,” Austin, Texas. (Computer printout.); E-mail from Denise Pittard, legislative information specialist, Texas Department of Transportation, Austin, Texas, June 20, 2000; International Registration Plan, Inc., International Registration Plan, Inc., with Official Commentary (Arlington, Virginia, August 22, 1994 (updated February 15, 1999)), p. 44; interview with Mary Ann Chapman, Internal Review, Vehicle Titles and Registration Division, Texas Department of Transportation, Austin, Texas, April 12, 2000 and on June 9, 2000.

[42 ]Texas Comptroller of Public Accounts, “Texas Mileage Guide,” March 1999 (http://www.window.state.tx.us/comptrol/texastra.html). (Internet document.)

[43 ]Interview with Jerry Dike, director, Vehicle Titles and Registration Division, and Vehicle Titles and Registration Division staff, Texas Department of Transportation, Austin, Texas, January 26, 2000.