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Michigan Registration Fee

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I wrote an email to our new Secretary of State last night. I suggest *everyone* here do the same! [email protected]
Please be respectful and clear. My email was pretty long, but I will paste it here to give an idea of what I think might be helpful to solve the problem:

Ms. Benson:

Firstly, thank you for running for Michigan’s Secretary of State position. I was very happy to see that you won in November and am optimistic about the progress and repairs that our democratic leadership will effect in the coming years.

One of the injustices I hope to see corrected is Michigan’s treatment of buyers of Tesla’s vehicles. The major problem is the sales and service ban that Michigan has in place for the American car manufacturer. But I’m writing today about the more specific issue of vehicle registrations.

Michigan’s Secretary of State website clearly describes the method for determining vehicle registration fees, and yet the organization charges apparently random registration fees for Tesla vehicles. My own car’s registration required four trips to SoS offices and many phone calls, and I have learned quite a lot about the process. Over the past two months I have been offering advice and guidance to buyers on a volunteer basis and often get reports from fellow Michiganders that the SoS charges very different fees for the same car model. I think the reason is that the SoS relies on the National Auto Dealer Association’s pricing database to determine the base price of a vehicle, but the NADA does not sell Tesla vehicles and has no authority regarding their pricing. Instead, the buyer must be aware of this problem and furnish her own proof of the vehicle’s base price set by the manufacturer (Monroney sticker or Motor Vehicle Purchase Agreement) and the SoS typically chooses to ignore this and uses an apparently random number to set the category fee code. I can provide examples of cars being coded six different ways for the same car model when the base price is clearly always the same.

This causes frustration on the part of the SoS staff and the vehicle owners, as well as wasting time and making the SoS appear incompetent. Worst of all, our neighbors are each being overcharged by hundreds of dollars each year due to the incorrect coding, and refunds on overpayment are either denied, ignored, or extremely delayed.

I will be happy to help resolve this problem by providing specifics and examples of problems if you can put me in touch with someone on your staff with the authority to assist. This appears to be a clerical problem with a simple solution.

Essentially, the solution, as I understand it after wading into the details for several months, is that the SoS needs to refer to a non-NADA price list to set fee categories for vehicles that the NADA is unaffiliated with, specifically, Tesla vehicles. Tesla has so far only made four models in the company’s history, so the list will be short and simple. I’m confident that the automaker will provide us a concise list of their vehicles’ base prices for each model year upon request.

Thank you for reading what was intended to be a short e-mail message! I look forward to working with your staff to simplify/standardize the fee category coding of Tesla vehicles and solve the problem.

Sincerely,

Joseph Willett
Howell, MI
 
I have received a response back from the Secretary of State regarding this topic (link to the correspondence below). They say, Tesla is not providing the pricing information, which is provided by other manufactures. So, they have to depend on NADA.

I see the following options, not necessarily exclusive to each other:
1. We could except that the drive-train is part of the base price.
2. Tesla could provide pricing information to the SOS.
3. NADA could improve their base price values.
4. The State could further clarify the law.
5. The SOS could take actions to make one or more of the above happen.

Which of these options should the community pursue?

SOS Tesla Vehicle Base Prices
 
On my dual motor Model 3, I was charged registration not only on the dual motor but also AP and FSD (56001E fee category). Has anyone had any success at all getting this fixed after titling? Or is SOS still standing on "we use NADA, too bad?"
 
Yep, I took my window stick in with me last year and they adjusted to the base price of my model S.
That's great to hear - I'm going to try the same thing and will report back. I could live with the dual motor being included, but paint, AP, and FSD are truly options and there's no reasonable interpretation I can conjure that would justify including them in "base price."

Only remaining step if the SoS visit fails (short of moving out of the state) would be writing legislators. My state rep voted for the EV surcharge legislation so doubt I'll get far writing him. Senator wasn't in office in 2015 so didn't vote on it but is a Dem so it might be worth pursuing with him.
 
That's great to hear - I'm going to try the same thing and will report back. I could live with the dual motor being included, but paint, AP, and FSD are truly options and there's no reasonable interpretation I can conjure that would justify including them in "base price."

Only remaining step if the SoS visit fails (short of moving out of the state) would be writing legislators. My state rep voted for the EV surcharge legislation so doubt I'll get far writing him. Senator wasn't in office in 2015 so didn't vote on it but is a Dem so it might be worth pursuing with him.
Take your original title with you at the same time. If you have paid already, you can request the refund form while you are there.
 
Update - brought the title and the window sticker. They still insisted in trying to look up the VIN in NADA's database. What I didn't know before that I learned today is that their NADA product is returning a "VIN error" on the VIN for my Model 3. So at the time of my original registration, they defaulted not to the Monroney sticker but to the full price on the MVPA, which of course includes options (in my case, paint, AP, and FSD--so not a trivial addition to the fee basis).

The person I spoke with today said their compliance people told them that they have to use the total price paid if there is no hit on the VIN and suggested I contact NADA. While everyone was nice and helpful to the extent they could be, I'm pretty confident that I would not get any help from NADA.

So based on previous efforts chronicled here, it looks like unless I wanted to bang my head against the wall with NADA and help them to troubleshoot or augment their database (which I'm sure probably doesn't get a direct feed from Tesla), I'm left with doing a close read of the Motor Vehicle Code and taking a shot with my state senator.

I don't mind paying my taxes, but I'm not enjoying the prospect of being overcharged each year over the life of the car. If I were a conspiracy theorist, I'd be convinced the Big Three and the short sellers are somehow behind this.

P.S.: The person I spoke with also mentioned that there have been "quite a few" Model 3 owners with similar issues. Which means that despite all the barriers, Michigan residents are increasingly choosing Tesla. Maybe I'll live long enough to see GM's next bankruptcy and pour out a gallon of gas (at a hazardous waste recycling center, of course) in their memory.
 
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The person I spoke with today said their compliance people told them that they have to use the total price paid if there is no hit on the VIN and suggested I contact NADA. While everyone was nice and helpful to the extent they could be, I'm pretty confident that I would not get any help from NADA.

Yeah, that is correct, but lame. Base price only applies if it comes from the SOS list, otherwise Monroney or purchase price apply.

Relevent sections of 257.801
fee schedule: (1)(i)(A)
Definition (5)(b):
"List price" means:
  • the manufacturer's suggested base list price as published by the secretary of state,
  • or the manufacturer's suggested retail price as shown on the label required to be affixed to the vehicle under 15 USC 1232, if the secretary of state has not at the time of the sale of the vehicle published a manufacturer's suggested retail price for that vehicle,
  • or the purchase price of the vehicle if the manufacturer's suggested base list price is unavailable from the sources described in this subdivision.
 
Yeah, that is correct, but lame. Base price only applies if it comes from the SOS list, otherwise Monroney or purchase price apply.

Relevent sections of 257.801
fee schedule: (1)(i)(A)
Definition (5)(b):
"List price" means:
  • the manufacturer's suggested base list price as published by the secretary of state,
  • or the manufacturer's suggested retail price as shown on the label required to be affixed to the vehicle under 15 USC 1232, if the secretary of state has not at the time of the sale of the vehicle published a manufacturer's suggested retail price for that vehicle,
  • or the purchase price of the vehicle if the manufacturer's suggested base list price is unavailable from the sources described in this subdivision.
Thanks! I took a read after and my plain language (i.e. not a "nuanced" one of a lawyer or a policy wonk) says that the "purchase price" can only be used if neither the Monroney sticker ("label required to be affixed . . . 15 USC 1232") nor the price "published" by the SoS (in this case, apparently NADA) are available.

I don't know whether to keep trying different SoS offices, to bring a copy of the MCL and talk to the same person (who was helpful but clearly had no interest in running anything up the flagpole on his end--and I don't really blame him for that), or to write to the AG and/or state senator. Or to give up and hope that someone with more time and/or influence causes greater attention to the matter.

Edit: The reason it matters in my case is that the Monroney sticker doesn't include AP or FSD. And although the first line is the base price, I can't find support for that in 15 USC 1232; have only seen it stated indirectly. And while Wikipedia is hardly a great authority, the example window sticker in the Monroney entry explicitly calls out the base price as "manufacturer's suggested retail price." I understand that Tesla doesn't suggest any prices; it just sells, but it would be helpful for future owners if they'd just play along a little since 12 USC 1232 does repeatedly refer to the price "suggested by the manufacturer."

Thanks for reading another wall of text and hope some of this helps at some point.
 
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Finally got the docs off the Ohio dealer, and went to register the car. They seem to have NADA working now, but not automatically. The first rep wanted to charge as 62k msrp. His supervisor said that Teslas need some special stuff. Asked me whether it was SR,SR+, LR, LR AWD. So, I ended up paying registration fees off 'base' LR AWD 'list price' of 47k, which seems fair, given that the performance upgrade is pretty much is just a software option.
 
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I'm in the Ann Arbor area and will be embarking on this journey in the next couple of weeks. Has anyone had particularly positive or negative experiences at any of the SOS branches in the area?

I have to assume that A2 has one of the higher Tesla concentrations in Michigan, so I'm not sure if that is a benefit or a liability when it comes to getting the coveted "35E" classification. Not sure if going to Ann Arbor or Chelsea branches will be the best bet on this one.
 
I'm in the Ann Arbor area and will be embarking on this journey in the next couple of weeks. Has anyone had particularly positive or negative experiences at any of the SOS branches in the area?

I have to assume that A2 has one of the higher Tesla concentrations in Michigan, so I'm not sure if that is a benefit or a liability when it comes to getting the coveted "35E" classification. Not sure if going to Ann Arbor or Chelsea branches will be the best bet on this one.

At the least, Chelsea is usually less of a wait...
 
In Michigan the registration fee is based upon the purchase price of the vehicle. Further there is a gas tax recoup value added.

For my P85 with custom plates my renewal is just shy of $600.
I was a resident of MI for 35 years and boy what a relief when it comes to vehicle registration in Florida! The cost is WAY lower here plus we get the option of 2-year tabs. My Porsches were $444 - $470 in MI. Reg. and vanity plate here less than half for Turbo Porsche.
 
I'm in the Ann Arbor area and will be embarking on this journey in the next couple of weeks. Has anyone had particularly positive or negative experiences at any of the SOS branches in the area?

I have to assume that A2 has one of the higher Tesla concentrations in Michigan, so I'm not sure if that is a benefit or a liability when it comes to getting the coveted "35E" classification. Not sure if going to Ann Arbor or Chelsea branches will be the best bet on this one.
AA branch upper level people know about Teslas, and NADA now has fairly reasonable values in their system (which may or may not have caught up with the recent price cuts).
So, getting the 35E class in AA is unlikely. See my post above.
Try Chelsea, maybe.