[NFBC-Info] Fwd: URGENT- Proposed DMV regulation changes that will affect Californians with low vision

[Laura Millar]

From: Rachelle Lin <rachelle.lin at gmail.com>
Date: Wed, Oct 28, 2026 at 10:55 AM
Subject: URGENT- Proposed DMV regulation changes that will affect
Californians with low vision
To: <laura at lauramillar.com>
CC: Rachelle Lin <rlin at ketchum.edu>


Hi Laura,
I pulled your contact info from the DOR email that you sent previously this
year.
In addition to my very seriousn concerns about decreases in DOR services,
which we can discuss also, I am writing today regarding the California
Optometric Association's concerns about proposed DMV regulation
changes. We would
appreciate if you could please share our concerns with the National
Federation of the Blind of California and your San Francisco Chapter.
Please see our letter below.
Thank you for your advocacy!

---

Good morning,



I’m writing to bring an important and time-sensitive issue to your
attention. The California Department of Motor Vehicles (DMV) has proposed
new regulations titled “Vision Screenings and Driving Evaluations” that
could have serious consequences for thousands of Californians with low
vision.



*The deadline to submit public comments is November 3 at 5:00 p.m.* We urge
your organization to review these proposed regulations and, if possible,
submit written comments before the deadline.



Review the proposed DMV regulations
<https://www.dmv.ca.gov/portal/about-the-california-department-of-motor-vehicles/california-dmv-rulemaking-actions/>


If adopted, these regulations would significantly limit optometrists’ and
ophthalmologists’ ability to provide input on the driving capabilities of
patients with low vision. Many patients could be required to obtain
restricted or limited-term driver’s licenses and repeatedly undergo driving
evaluations, even when those additional tests may not be necessary. Others
could lose their driving privileges unnecessarily. These restrictions could
significantly affect patients’ independence, mobility, and quality of life.



Our primary concern is that the proposed regulations would allow the Vision
Conditions and Action Chart (VCAC) to override an optometrist’s individual
assessment of a patient’s condition, particularly when determining whether
the condition is progressive or stable. This approach would limit
individualized assessments and rely on an outdated document that does not
reflect current research on low vision and safe driving. The proposal also
fails to clearly explain how the DMV would classify vision conditions that
are not included in the VCAC.



We have several additional concerns, including:



●     *Mandatory daytime-only driving restrictions:* The proposal would
automatically impose daytime driving restrictions on individuals with
visual acuity worse than 20/50 in both eyes. This 20/50 cutoff is not
supported by current research on vision and driving safety.

●     *Restrictions on bioptic telescope users:* The proposed changes would
impose daytime driving restrictions on all individuals who use bioptic
telescopic lenses, without adequately accounting for individual
capabilities.

●     *Lack of clarity:* Several provisions are unclear, creating
uncertainty for patients, optometrists, ophthalmologists, and driving
evaluators.



The California Optometric Association believes it is essential to preserve
the independence and mobility of individuals with low vision while
supporting public safety. Driving decisions should be based on current
evidence and individualized assessments, rather than outdated or overly
broad criteria that may unnecessarily restrict qualified drivers.



We are currently preparing the California Optometric Association’s comments
and would be happy to share them with your organization once they are
complete. However, given the approaching deadline, we wanted to alert you
to this proposal immediately, so your organization has time to conduct an
independent review and submit comments before *November 3 at 5:00 p.m*.



We strongly encourage you to review the proposed regulations and consider
submitting comments outlining your organization’s concerns. Your input
could help prevent unnecessary restrictions on the driving privileges and
independence of Californians with low vision.



Here is where you can send comments and please copy me on what you send:



Randi Calkins, Regulations Specialist

Department of Motor Vehicles

Legal Affairs Division

2415 First Avenue, MS C-128

Sacramento, CA 95818

Email: LADRegulations at dmv.ca.gov



Thank you for your prompt attention to this important issue and for
considering taking action before the deadline.



Best regards,

Rachelle Lin


-- 
Rachelle Lin, OD, MS, FAAO
President, California Optometric Association
Past-Chair, COA Low Vision Rehabilitation Section
Associate Professor, Marshall B. Ketchum University