Testimony on Oversight: Implementation of ID NYC New York City’s Municipal Identification Program

Testimony on Oversight: Implementation of ID NYC New York City’s Municipal Identification Program

Submitted to New York City Council Committee on Immigration

Submitted by Fryda Guedes Program Coordinator for Immigration and Civic Engagement Hispanic Federation

May 1, 2015

Chair Menchaca and Members of the Committee on Immigration:

Good morning. My name is Fryda Guedes and I am the Program Coordinator for Immigration and Civic Engagement at the Hispanic Federation (HF). Hispanic Federation is the premier Latino membership organization in the nation founded to address the many inequities confronting Latinos and the nonprofits that serve them. For 25 years, Hispanic Federation has provided grants, administered human services and coordinated advocacy for our broad network of agencies that serve more than 2 million Latinos in areas of health, education, economic empowerment, immigration and civic engagement. Thank you for inviting us here today and affording us the opportunity to express comments and suggestions on the implementation of the ID NYC program.

I would like to start off by stating that HF strongly supports this program and the following reflections and recommendations are meant to enhance the great work, thoughtfulness and attention to detail that the administration has executed in creating this rule.

Success of Program

From the beginning of the program, our city has witnessed a high demand for ID NYC. Just days after ID NYC was released to the public, enrollment sites filled to capacity with applicants. Today, more than 150,000 New Yorkers carry a municipal ID and more than 400,000 have scheduled an appointment to get their ID. ID NYC has brought hope and opportunity to many.

Those of us in this room are familiar with the official benefits offered by this program. ID NYC allows holders to enter public buildings, access services and programs offered by city agencies, be issued a summons or desk appearance instead of getting arrested, check out books at the public library, and open a bank account. For undocumented immigrants in particular, the municipal ID offers the unprecedented option of legally engaging with local resources and agencies. ID NYC empowers cardholders by recognizing their right to feel safe and welcome in public spaces.

Hispanic Federation has helped to ensure that this message reaches critical populations. At the launch of the ID NYC program, Hispanic Federation and Telemundo partnered to create a media campaign to inform the Latino community about New York City’s municipal ID card program. During this initiative, HF and Telemundo produced several PSAs, news and TV segments, newspaper columns, and radio programs to educate the community about ID NYC. Through these efforts, HF’s information hotline, Linea Informativa, received more than 4,000 calls regarding ID NYC in the span of three weeks.

Our callers were assisted by fluent Spanish speakers and walked through important details about ID NYC benefits, eligibility, and documents. Hispanic Federation also helped callers schedule appointments to apply for ID NYC. The interactions were mostly positive and callers expressed excitement about the program. One caller, who was well-aware of both the benefits and the limitations of ID NYC, told us: “me siento que tengo mis papeles.” I feel like I have my papers.


Through our hotline, and through communication with other agencies, we have also learned about some of the struggles experienced by New Yorkers when applying for and using their municipal ID. We have used this to create a list of recommendations.

Expand List of Documents Serving as Proof of Identification

Many immigrants lack the specific documents required by ID NYC for proof of identity and residency. They often leave their country in a hurry or experience difficult circumstances which prevent them from carrying their birth certificates and other identifying documents in their journey to the US.

For this reason, Hispanic Federation proposes the following additions be included as acceptable proof of identification:

  • Although some of the below documents are acceptable as proof of residency we ask that all of the documents below count toward one point of proof of identity (note that the NYS Dept. of Motor Vehicles assigns one point to several of these items, for the purpose of issuing NYS driver’s licenses and non-driver IDs):
  • Pay stub with name*
    Bank or credit union account statement*
    ATM or credit card*
    Utility bill
    Canceled check*
    Health insurance or prescription card*
    Life insurance policy*
    Check casher card with signature*
    Department for the Aging ID/Barcode Cards (photo)
    Library cards
    *NYS DMV currently assigns these items one point towards proof of identity needed to obtain a NYS driver's license or NYS non-driver’s ID.

Accept Expired Documents as Proof of Identification

Immigrants may also rely on consular IDs or passports from countries that either do not maintain an active local consulate or charge high fees for document renewal as forms of identification. As of now, expired documents (other than NYC municipal IDs within 60 days of expiration or machine readable passports that expired within the last three years) are not accepted by the program. Fees and administrative hurdles should not continue to stand in the way of ID NYC applicants.

The Federation proposes that ID NYC accept government-issued IDs that have expired within 5 years of the date of the ID NYC application as proof of identity. Such expired documents should be assigned one or two points toward the three points required for proof of identity to obtain the ID NYC. Several DMVs throughout the country accept expired documents toward proof of identity to issue identification cards and driver’s licenses. New York, Washington, Colorado and Georgia are examples of states that accept documents ranging from 1 to 10 years of expiration. Since other state agencies that are obligated to comply with the REAL ID Act accept forms of expired documentation, HF recommends that HRA (which is not held to the standards of the REAL ID Act) accept expired forms of documentation under the ID NYC program.

Care of Address

The City’s ID NYC website states that homeless individuals or survivors of domestic violence may provide an “in care of” address for their ID NYC. In order to utilize the “in care of” address, applicants must submit a "care-of letter" issued by a nonprofit organization or religious institution in NYC that serves homeless individuals or survivors of domestic violence. The organization must receive City funding and the ID NYC applicant must have received services from the entity for past 60 days in order to use the entity's address for mailing purposes.

Although ID NYC card holders have taken all of the aforementioned steps to use an “in care of” address on their card, the NYPD has not committed to accepting “care of” addresses as valid addresses for mailing summonses. Although an NYPD officer may accept a municipal ID card with a “care of” address at their own discretion, the lack of uniformity for this policy is concerning. When interacting with NYPD, a homeless individual or survivor of domestic violence may be placed under arrest as opposed to being issued a summons due to their “care of” address on their ID NYC.

Hispanic Federation encourages conversations and trainings with NYPD on this topic so that this vulnerable group of New Yorkers have the same rights and respect as all ID NYC holders.


Thank you for your time and attention to these important issues. It is our hope that reflecting on the achievements and limitations of this strong and inclusive program will ensure that all New Yorkers are served by ID NYC.

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