Texas Revoking Titles (and how you can help)


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OMG what a grind! For me, it doesn't get much worse than a room full of bureaucrats deciding how we should live in the land of the free. Even the interactions and banter is just painful!

Big thanks to everyone working to make this right. Everyone was sooooooo patient. It would've been hard for me to go in there and not spew anger at the board. At least some of the board members seem like good rational folks, like the guy who commented the slingshot was less than a goblin from a safety standpoint. Not impressed by Mr Kunz however... in the sections I watched, he didn't seem to have a satisfactory answer for... anything. Especially not the question everyone wants answered: what triggered this action?!

The thing I would stress in this situation would be your simple Ben Franklin pro/con argument. The benefits to allowing these vehicles on the road FAR outweigh the cons. no question about it. And Texas is the last place I would expect this type of government overreach. Baffling!

Hopefully you guys have your titles and registrations reinstated some time this century, this video makes it seem there might be a long road ahead, and that makes me sad
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I couldn't have said it any better myself Alex. I agree about Mr. Kuntz - he was informed on so much other stuff, but couldn't answer my biggest question of what propagated this?

Justin and Lonny - thanks for speaking up at the meeting - I know that wasn't easy.

My take-away from watching it all was that it seems like they (DMV Board members) want a reasonable solution to keep everyone happy. If the working group can come up with a more refined definition of what a dune buggy, kit car, street rod and assembled vehicle are, and maybe more importantly, are not, they would be willing to support those legislative changes.

I can't figure out why Kuntz has such an issue with the Ariel Atom? I also have a hard time believing all his rhetoric about the federal laws and the current safety requirements that small manufacturers have to meet. Think of how many small manufacturers are already out there...have they all found a loophole that we don't know about yet?


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This isn't directed to you Slider so please don't take offense. :) It doesn't make sense to further define what a dune buggy, kit car, or assembled vehicle is. If a dune buggy can be loosely defined as a recreational vehicle with an open chassis, large wheels, and a maybe a VW engine, why does that matter? And what if you replace the motor with an LS? Is it no longer a dune buggy? To me it's a who cares issue because at the end of the day it comes down to the safety of the other driver. I don't think there is a manufacturer or hobbyist builder out there who doesn't think about safety of their own person or the safety of others.

Safety is for the most part common sense. Further defining or sub-classing assembled vehicles doesn't really do anything to address the safety aspect. There instead needs to be further clarification on exactly what safety features are required on these types of assembled vehicles. From there, a comprehensive inspection for road worthiness should be all that's needed.


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Good job to Justin and Lonny for keeping your cool and not letting your frustration boil over! I don't know if I could of done the same.

It does seem like they want to work on a solution to resolve the title/licensing issue.
What I don't understand though is revoking a title of the vehicle that meets or exceeds safety standards. So what if "they" don't have a category to put the vehicle today. What difference does that make.
When they do figure it out, they can reissue title/registration with the update.

And the Ariel Atom. If they did research like they said they did, they would find it is a "Track day" street car.
Made for the street and take to the track.
Does that make any super car, hyper car a track only vehicle?
It's only because the Goblin doesn't meet some bean counters limited experience of what a car is,can be or how the actual components work together.

I guess if it does look like a Prius, it's not a car?

I'm glad I wasn't there.

Ok, I'm done. For now.

Anyway good job guys! Keep us posted.


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Brian - no offense taken at all. I enjoy hearing other people's viewpoints in a friendly debate. I also agree with what you are saying and also believe that further defining vehicles will eventually lead to even more troublesome interpretations of whatever that ended up being. I was just saying that the definitions seemed to be the boards hangup, not that I agree with them.

I also read through the Texas assembled vehicle manual today and think the Goblin meets all the existing requirements for a 'custom vehicle'.

I guess for some reason the TXDMV is now saying that their manual is in violation of the US code.

The TXDMV could publish their interpretation of the US code and how they view the difference between being a manufacturer and an assembler, which to me is the Goblin customer's main concern. I think the assembler should be able to follow the existing guidelines that TX has outlined in their assembled vehicle manual.


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Just as an additional thought, when safety comes up we should all be reminded that living is inherently unsafe. However, Texas the State Legislature allows other personal unsafe activities as long as that activity does not impose a safety risk to others. Case in point, motorcycles to be operated without the use of helmet for adult drivers because the motorcycle does not pose a significant risk to any one other than the driver.


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We’ve still been plugging away. The formal meeting is not yet scheduled but we’ve been informed it will be in February.


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the Texas dmv is up for review. This could be very beneficial for us. I ask that you copy the below letter and send it one of two ways:

1. electronically at

2. Letter to the Texas Sunset Commission at Sunset Advisory Commission, PO
Box 13066, Austin, Texas 78711, attn.: Amy Tripp. Ms. Tripp is the project
manager working on the TxDMV sunset issue

If you send it electronically there are two comment boxes. One for the problem and one for the solution. Paste the last paragraph into the solution box.


My name is _______________ and I am providing comments regarding the Texas Department of Motor Vehicles Sunset self-evaluation report on major issue regarding the department’s decision to refuse revoke or suspend a title. Titles and registration on certain vehicles have either been revoked or the department has refused to issue titles and registrations on certain vehicles. The problem with these revocations is that the department has not established a consistent and firm position as to why the revocations and the decision not to issues titles and registration have been done.

More specifically, the department has made a rule not to allow Dune Buggies to be titled and registered for street use. In addition, the department has also made arbitrary rulings on other vehicles called Sandrails as well as Kitcars and has made similar and inconsistent decisions on the title and registration of those vehicles. Dune Buggies, Sandrails, and Kitcars, are essentially assembled vehicles.

At a December 7, 2017 TxDMV board meeting numerous owners of assembled vehicles provided expert testimony on the facts of persons owning fabricating and assembling these vehicles. The department decision is not consistent with the market place and federal laws and rulings and its own state laws. Below are facts provided to the department during the December 7 board meeting:

1. An assembled vehicle by definition in the TxDMV manual is a vehicle assembled from the three basic component parts (motor, frame, and body), except that a motorcycle must have a frame and motor, and a trailer or travel trailer will have no motor, and that is:
(i)assembled from new or used materials and parts by someone not regulated as a motor vehicle manufacturer;
(ii)altered or modified to the extent that it no longer reflects the original manufacturer's configuration; or
(iii)assembled from a kit even if a Manufacturer's Certificate of Origin or Manufacturer's Statement of Origin is provided.

Dune Buggies, Sandrail, & Kitcars are assembled vehicles that meet these standards.

2. Dune Buggies, prior to the department’s effective date of April 6, 2014 are not specifically addressed in department rules. This inconsistency allows the same type of dune buggy prior to the aforementioned 2014 date to operate legally in Texas. I request the department reinstate the title and registration of my dune buggy to be consistent with other similar vehicles safely and legally operating in Texas. Dune Buggies are not defined in Texas law, therefore, it is difficult to see how the department can determine the legality of a vehicle that is not defined.

3. Transportation Code Sections 501 and 504 regarding custom vehicles and street rods are inconsistent as stated by TxDMV staff. Therefore, if custom vehicles that are defined similar to assembled vehicle, which identifies a variety of kit cars, and are deemed legal to title and registration then the result would be for my vehicle to be treated likewise. This fits into “one” of the categories that was stated at the December board meeting.

4. TxDMV staff stated that the decision to revoke titles and registration was done at the local level by clerks at county tax-assessor collectors. It was stated that there are thousands of title clerks across the state that struggle with making these determinations at their offices on a daily basis. This struggle to make these determinations have caused titles and registrations to be incorrectly revoked.

5. According to department staff, there is not a consistent or clear determination by the National Highway Transportation Safety Administration (NHTSA) regarding vehicles that are subject to the department’s review.

The assembled vehicles are being improperly evaluated and the department is relying on either local tax assessor rulings that the department admits is inconsistent or the department is not following its own policies regarding the types of vehicles they claim are street legal.

Due to the rulings and decisions by the department, private citizens are being denied the right to own and operate a privately owned vehicle resulting in loss of personal freedoms, loss of private sector investment, supply chain disruption; lost jobs and wages; and; loss of state and local revenues to the TxDMV from title and registration fees.

Given these incorrect rulings and inconsistencies with federal and state law, the department should immediately reinstate and provide future title and registration to those assembled vehicles that have passed the department mandated vehicle inspection and title and registration process.

Thank you for your time and attention in this important matter.
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Well-Known Member
Tomorrow is a big step in getting this problem solved once and for all. Our DMV working group convenes over the next two days to hash out all the problems and solutions we can think of. 25 people from the industry and government will attend. Everyone keep your fingers crossed.


Well-Known Member
Well as my friend Willie Nelson said, I just couldn’t wait to be on the road again.

My battle with TXDMV is not over. I will continue fighting until this is resolved. And I can assure you it will be resolved. But until then I just am not willing to be walked all over by a bunch of bureaucrats who’ve never had a real job in their life.

Where there’s a will, there’s a way.