As for a moving violation or not, the whole thing got challenged early on while they were still only on DC roads. The decision was that they couldn't prove beyond reasonable doubt who was the person driving. Maybe the car was a loaner, a company pool-car, or being driven by a brother. So you get a piece of paper with a photo of your vehicle's front, the back, and a zoom-in shot of the license plate. If I were in an area that assigned points based on one of these, I'd check into the background of why MD and DC are not going after the operator and challenge your local law.
The District and our county own the equipment. The thing that burns me is that the whole damn deal (at least downtown) is run by a division of Lockheed and they get something like a THIRD of every fine that is paid!
SecuLaw - I'm amazed that they leave the Windstars out overnight in your area. Officers I know have said that the county knows better than to do that here.