Public comments for: Municipal ID Card Program

Comments

Comment:
Being an immigrant and having lived in New York City for the past 10 years, I understand the importance of any government issued photo identification and the privileges that come with it. A couple of my friends happen to be undocumented immigrants and I see their struggles on daily basis. I am particularly concerned with the way the program will play out in New York City for the undocumented immigrants to access basic rights and freedoms: from opening a bank account to renting shoes in bowling alley. Personally, I think it is an important and valuable step towards opportunity and inclusion for all NYC residents. At the same time, I believe it will be challenging to motivate undocumented immigrants to apply for Municipal ID card. The fear of prosecution, detention and potential deportation as well as other possible legal battles is too real. People are afraid to loose whatever little they have. There is lack of trust in government especially with currently existing strong opposition to immigration reform in federal government. Some people will see the program as the way to control, monitor and track undocumented immigrants. Having Municipal ID card doesn’t lead to legalization process either and therefore might seem unnecessary to some. Record keeping is another issue that can keep people from obtaining Municipal ID card. It is great to have the local government that is concerned with well-being of vulnerable population and is in favor of immigration reform. However, the situation can change any day. People are worried about who will have access to their personal information and how it potentially can be shared. There is no clear decision in the proposed rule regarding record keeping and documents destruction. A whole set of problems can arise with the documents that are required to apply for Municipal ID card. For many people it will be close to impossible to collect necessary 4 points. It is stated in the proposal that no expired documentation will be accepted. The reality is that many undocumented immigrants have not left the country to renew their documents; their passports, visas and IDs are long expired, have been destroyed or lost. Education about real and meaningful benefits of Municipal ID program will be the key towards its acceptance and wide-spread usage by all residents regardless their social or immigration status. I think, it will make a big difference HOW HRA implements the new program, the way they will treat applicants and how open they will be to work with them and social service agencies. Even though I have the regular state ID, I am planning to apply for Municipal ID card to experience its benefits first hand and help fight stigma that can potentially be attached to the ID card holder. It is going to be an easy decision for me. But will it be easy for the targeted groups? I am not so sure.
Agency: HRA
Comment:
Make the Road New York Comments on Proposed Rule for Municipal ID Card Program *Below are abridged comments from Make the Road New York on the Proposed Rule for the Municipal ID Card Program. Make the Road's full comments are included as an attachment. As an organization that empowers immigrant communities who often lack any form of identification, Make the Road New York believes the Municipal ID program is a crucial step forward in fully integrating all members of our communities into the fabric of New York City. In an effort to ensure the success and inclusiveness of this program, we would like to make the following comments and recommendations: 1. HRA should accept expired identity documents as proof of ID By not accepting expired ID documents, the City risks excluding the very populations it seeks to benefit through the municipal ID program. Many municipal ID card applicants will be relying on consular IDs or passports from countries which either do not maintain an active local consulate, or which charge high fees for document renewal. Renewing foreign ID typically requires people to obtain copies of other documents (such as birth certificates or school records), which may be impossible or very costly. This could put the real cost of getting the NYC ID at hundreds of dollars. Many MRNY members have difficulty obtaining current identity documents, such as passports or consular IDs, due to financial reasons or lack of accessibility of consulates. At a minimum, identification documents issued by foreign governments, including but not limited to passports and consular IDs, should be accepted as valid proof of identity if they have expired within the last 5 years. 2. HRA should expand the list of documents accepted as proof of residency or identity and make it as flexible as possible We recommend expanding the list of documents used to prove residency and/or identity to include: o NYC Parks ID (photo) o DFTA ID/Barcode Cards (photo) o Library cards o Medicare and SSA Cards o Check casher card with signature* o ATM or credit card* o Canceled check* o Health insurance or prescription card* o Receipt Notice from U.S. Citizenship and Immigration Services (as distinct from approval notice) o Mail received at an address with the stamp of the USPS o Notarized letters from landlords testifying to the individual’s residency if the individual’s name is not on a lease o A notarized letter from a community based organization receiving city funding testifying that the individual resides at the stated address o A notarized letter from a roommate testifying that the individual lives at the same address o Any professional licenses or certifications with photos that also require ID verification in order to receive them, such as scaffold licenses. * Documents marked with an asterisk are given at least one point towards proof of identity by the Department of Motor Vehicles.
Agency: HRA
Comment:
My comment/suggestion are composed of many little comments and a suggestion at the end. As a Social worker, I have experienced HRA’s workers attitudes and a broken system first hand when assisting the people that I work with for many years. This experience has left me quite concerned with the new Municipal ID process due to the negative attitudes many HRA workers have towards those they are charged with helping. I have seen first-hand HRA workers who rather than being helpful humiliate people and abuse their power. I think the new Municipal ID is a good way for people without IDs to get one, but the implementation process must include extensive training for the HRA workers who are already struggling to provide services to an extremely vulnerable population. I am also concerned with the documentation requirements that are similar to the requirements for getting a state ID and Driver’s permit for citizens/documented New Yorkers or applying for benefits. I am wondering if a new unit is being created to handle the municipal ID cases. I also will like to know who the applicants can complain to if the process does not play out as supposed to. The Municipal ID is supposed to be for applicants who are 14 and older; however, I do not see how this is supposed to be a simple process for teenagers who are homeless or are not living with parents and don’t have their documents. Furthermore, this is not really a teenage friendly process because of all the documents that are required (if applying by themselves), and if they don’t have the documents then they need to be accompanied by a caretaker who can demonstrate proof of a relationship to them. Additionally, I think it’s a great idea to help undocumented residents have some kind of ID; nonetheless, the ID does not change anything in regards to helping them be more integrated in society (ability to drive as in other states) (they can open a bank account with their passport and use their passport in other places as identification). In my opinion, I don’t think a lot of undocumented residents will go for it because in a way it is a way to tract who is in the city rather than a help them with their immigration status. Furthermore, who can assure the confidentiality of undocumented applicants is protected; who can assure that their information will not be accessible to the United States Citizenship and Immigration Services. Despite of my concerns and ambivalence, I think is a good opportunity for all New Yorkers to have an alternative to the State ID; but in order for the Municipal ID initiative to be truly successful, the documentation needs to be revised to reflect the realities of many New Yorkers.
Agency: HRA
Comment:
I am a worker for a supportive housing facility located in Harlem. Many of our young adults who have failed to get a state ID due to certain circumstances can no longer obtain a state ID due to their age. Because they do not have a state ID it has been hard for them to obtain jobs and it has put them at risk in the streets. One can be arrested for not having an ID and also there is no way for a person to be identified if something happens to them. Its unfortunate that something so simple as an ID can set someone back. I believe the municipal ID is a great idea and it will help many of those be identified as an actual person and will be a new stepping stone for many people.
Agency: HRA
Comment:
Laurie Lieberman As a human service worker who has served various marginalized populations for the last seventeen years, I do applaud efforts to make idenfication available for all regardless of immigration or homeless status. its a great step in ensuring access to legitimate verification of identify in lieu of various other photo Idenfitication.However as I review the proposed plan I have several questions that surface. First, there seems to be a point system similar to the DMV procedure to obtain a non driver license. This may prove difficult for those who have been living homeless outside of the shelter system. Second, It may also be a challenge to gain the trust of these individuals to sign up for this card. This is particularly true for immigrants not here legally. Third, it is unclear to me exactly where this identification card will be legitimized and accepted. Fourth, the point system seems complicated and quite lengthy; it was hard time understand for a college educated individual and I am mindful that within the target populations exist people that has literacy issues, language barriers and traumatic Braun I juries among other limitations. Will there be an effort to streamline and simplify. The last concern I have is a question; what exactly is the ultimate goal of instituting such a costly ambitious program. What is the outcome measure the city is looking at to see whether it is successful or not. Are we looking at these marginalized people having any kind of life improvement. Thank you.
Agency: HRA
Comment:
This is a continuation of my previous comment: .For instance, there should be a fee waiver for a Birth Certificate and Social Security card for people who most need it. I suggest some buses going to all the five boroughs to help alleviate the long lines and alleviate the work for HRA staff (HRA staff aren't the nicest individuals). It will also help reaching the communities who are skeptical of this ID due to the fear of being deported. If there can be a department to help individuals obtain the most basic of documents, this ID will likely be a total success. I also suggest the face of the ID card be the same as the NYS ID card with a minute difference to help government agencies and workers differentiate between the two. I suggest this because there can be a negative stigma created for people with obvious Municipal ID cards. Also, I think that attaching incentives to the card, like attaching discounts to some grocery stores, movie theaters, or various yearly New York events will have everyone running to get a Municipal ID card.
Agency: HRA
Comment:
First, I'd like to say how I love that New York is recognizing the need for people who are undocumented to get ID's easier. The fact that the municipal ID needs only four points as opposed to a NYS ID which needs six points is great. The problem is that people who are undocumented in the first place do not have the documents needed to get these IDs. They may have one point (Benefit card without the picture) but nothing else. The homeless and other undocumented people like people just released from prison may have no documents. What can be done to help these people? I suggest a different department within the Municipal building to help these individuals obtain a Social Security card or Birth certificate. I also suggest widening the scope of required documents to obtain these basic needs. One of the most important documents needed to obtain anything in New York is a Birth Certificate. Without a birth certificate or any other ID, people that have lived in New York all of their lives are invisible. There needs to be focus on helping these people obtain these documents in order for them to be a seen by society and a part of the economy. A classmate of mine said it well, how does it help people who are undeserved if these people can't even obtain the most basics of these documents? I have an individual on my caseload who would like to open a bank account. Unfortunately, she cannot obtain any ID because she can't get her birth certificate. We have written her a letter to help her obtain the birth certificate, but it isn't enough. She doesn't have any utility bills in her name and doesn't have the second document needed to obtain a Birth certificate. What can be done to help her and others who are in her situation that want to be a part of the economy but cannot, due to the small scope of documents required to get the most basic document? Also, why should four points continue to be required for a Municipal ID if the person doesn't have a permanent residence? The requirements say that an address will not be on the ID if this were the case, among other situations (Section 8-02). There should be a reduction of points needed for Municipal IDs that do not have an address on it.I cannot stress enough the fact that some of the people in the population most needing the ID do not have the basic documents needed. It would be great if there were allowances or waivers in order for people who do not have a Birth Certificate or Social Security card to get one.
Agency: HRA
Comment:
First let me thank you for giving me this opportunity to comment on the rules generated to implement New York City’s ambitious Municipal ID program. My name is Harpreet Singh Toor and I represent The Sikh Cultural Society, Inc as a Chairman of Public Policy and External Affairs. The program as a whole is tremendous undertaking and the Mayor and the Office of Immigrant Affairs, HRA and all of the City Agencies should be commended for that. My one specific comment on the proposed rules in relation to Section 8-03. Under the proposed rules, HRA will require proof of identify and proof of residence that totals 4 point under the structure that the rules lay out. I want to applaud you for creating a system that takes into account those without stable addresses and allowing the ID Card to omit their addresses. Looking at the points allocated, many new immigrants to New York City will have a hard time proving a stable address since it is common for even documented new immigrants to live in the household of a relative or close family contact. They may not have the supporting documentation that proves their place of current residence. Your system appropriately accounts for their situation. The one item of concern in the rules relates to the retention and destruction of documentation. In the rules there is a lack of a penalty for anyone who intentionally or negligently releases confidential HRA collected municipal ID data. This needs to be included to explicitly to give confidence to municipal ID applicants and to deter anyone who would use this data for their own purposes Another item covers language access. The South Asian community is diverse and we speak many dozens of languages. The City’s language access rules should account for this diversity and materials promoting the Municipal ID program should be found in multiple South Asian languages.
Agency: HRA
Comment:
As a social worker who works with many adults who are living here illegally but their children are legal I think this is a great rule. It will give these people more than just an ID but it will give them access into public places without feeling humiliated. I recently was with a family whose child was hospitalized with cancer and her relatives were not given permission to visit the child in the hospital without showing ID. Also, I have had parents who are told they cannot apply for SSI for their child without proper ID, even though the child is a US citizen. Although I know this is not true many of the parents I work with have been turned away for this reason. Many of these same parents cannot open up bank accounts because they do not have ID. The less barriers for these people the better. I also feel that it is a basic human right to be counted as a person. Everyone deserves to be able to carry a document that says who they are. My concern however, is getting illegal persons to trust the process and to sign up for the card. They are very worried about getting caught in the country illegally, therefore I think there will need to be major training and sensitivity around this issue in order to get the most vulnerable population the card they deserve. Lastly, I am wondering how the people will prove who they are if they have no ID to begin with?
Agency: HRA