Robert
L. Flanagan
Deputy Secretary
Maryland Department of Transportation
7201 Corporate Center Drive
P.O. Box 548
Hanover, MD 21076
Dear Mr. Deputy Secretary:
I write to you on behalf of several thousand Maryland taxpayers who have encountered (or will soon encounter) unreasonable obstacles when seeking to renew their Maryland driver's licenses. The problem is that current Maryland MDOT procedures appear not take into account the unique situation faced by the members of the U.S. Foreign Service who, although legally domiciled in Maryland, are sent overseas on long term assignments by their employer, the federal government.
By way of background, I am the President of the American Foreign Service Association, the professional association representing the 11,000 members of the U.S. Foreign Service (i.e., our nation's diplomats) serving in 260 locations overseas and in the United States. All U.S. Foreign Service members must, by federal regulation, designate a state of domicile on entry into government service. In the absence of a decision to change it, this state of domicile remains their state of domicile throughout their Foreign Service career, which may last thirty years or more, whether they are serving overseas or in a domestic assignment. It is this state of domicile in which they pay state income taxes, in which they vote (often by absentee ballot), and it is to this state that the U.S. Department of State will transport them, their family, and their possessions when they retire from government service.
A large proportion of the 11,000 members of the Foreign Service are domiciled in Maryland, having settled in the area while working in Washington, D.C. and thereafter retaining their Maryland domiciliary status while serving in later assignments overseas. Many, however, do not return to Maryland for years at a stretch, although they continue to pay Maryland taxes and cast absentee ballots in Maryland elections.
Most importantly for this discussion, these Maryland taxpayers continue to maintain their Maryland driver's licenses while they are assigned abroad. If this were not possible, they would have no way to possess any U.S. driver's license. This would obviously present quite a problem whenever they flew back to the United States for a temporary visit (say, to visit Disney World or attend a funeral in Seattle).
Unfortunately,
in recent months Foreign Service employees have found it difficult
to renew their Maryland driver's licenses because of regulations designed
to tighten the proof of residency requirements. We have gotten reports
that MDOT employees, both at the regional
offices and at the on-line renewal facility, have proven reluctant
to depart from their existing strict guidelines to accommodate U.S.
diplomats who cannot satisfy the requirement to produce a Maryland
street address.
What is needed is a clear MDOT policy on what a U.S. Foreign Service employee must produce in order to get a driver's license. That directive must recognize that the one thing that most Foreign Service employees serving overseas cannot provide is an actual address of residence in the state. The directive should explain mechanisms by which Foreign Service employees can renew their Maryland driver's licenses in two different situations:
o The first situation involves a Foreign Service employee who wishes to renew an expiring Maryland driver's license from overseas, either by mail or on-line. The renewal anniversary may well occur when an employee is overseas, so the employee needs a simple, understandable procedure that will work.
o The second involves the Foreign Service employee who is temporarily in Maryland on training or consultations when the time comes to renew his or her license, or who has let his Maryland license lapse and needs to get a new one. In this situation, the individual will likely visit one of the MDOT offices in Maryland. Foreign Service personnel who are Maryland residents will be able to produce a variety of documentation to support their claims of domicile - for example, previous year Maryland tax returns, local Maryland bank statements, Maryland voter's identification card, an old or expired Maryland driver's license - but the one thing that many of them will be unable to produce is a current Maryland street address. Likewise they will able to produce ample evidence that they are a U.S. State Department or U.S. Agency for International Development employee, to include a State Department or USAID picture ID card.
We seek your assistance in addressing these issues. Once new procedures are put in place, we will undertake a concerted effort (via our frequent communications with our members overseas) to make sure that our members get the word and comply with the revised requirements. If needed, I would be glad to discuss this issue with you or members of your staff in an effort to reach a solution to this problem. I may be reached at 202-338-4045, x502.
Sincerely,
John
K. Naland
President, American Foreign Service Association
cc: Governor
Robert Ehrlich Office of the Governor 100 State Circle
Annapolis, Maryland 21401
