Wednesday, October 5, 2011 |
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Taxis For All Campaign For wheelchair-accessible taxis and liveries in New York City, based upon universal design principles Members include: Bronx Independent Living Services & Disabilities Network of NYC • Brooklyn Center for Independence of the Disabled • Center for Independence of the Disabled, New York • Disabled in Action of Metropolitan New York • Harlem Independent Living Center • National Multiple Sclerosis Society, NYC-Southern New York Chapter • United Spinal Association • VetsFirst • 504 Dems-North Star • 504 Democratic Club July 29, 2011 Hon. Andrew Cuomo Governor, State of New York Executive Chamber, State Capitol Albany, New York 12224 Re: Opposition to A.8496/S.5825 – focus on liveries Dear Governor Cuomo: We are writing to reiterate in greater depth our opposition to A.8496/S.5825 as it concerns the livery system’s expansion into legal street hails. In addition, we write to ask to meet with you to discuss how this legislation should be amended before it becomes law. In our June 12, 2011 letter to you, we urged you not to sign this bill without major revisions, since as written it would continue to shut wheelchair users out of using New York City’s vast taxi system. Only one in 18 yellow taxis would be accessible, and virtually no livery cabs would be useable by those who use wheelchairs. It is particularly striking and distressing that a bill purportedly intended to expand taxi service to underserved neighborhoods actually does the opposite when it comes to New York City’s wheelchair users. This represents a step backwards, not forward, in a state in which equitable access for all to transportation should be a basic goal. As many as 30,000 street hail permits -- but not one new additional accessible vehicle For those wheelchair users who live in neighborhoods now served primarily by liveries, A.8496/S.5825 is particularly onerous. The bill’s writers didn’t even make a token effort, as they did for the yellow taxi system, to improve taxi service for wheelchair users: there is no attempt to add accessible liveries whatsoever. In our original letter, we mistakenly referred to a system in which only 1,500 street-hail permits would be allowed. Actually, the legislation would permit up to 30,000 street-hail permits, a vast transformation of the livery and taxi system. That means that a livery system already known by wheelchair users to offer little to no service would expand that service extensively to street hails. Wheelchair users, already at a disadvantage in finding service in neighborhoods like Washington Heights, Flushing and Bay Ridge through the current radio dispatch system, would now find their neighbors able to hail taxis while they continue to have few options for wheelchair-accessible transport. Coupled with a yellow taxi system with only one in 18 accessible vehicles (under the legislation), this is a classic illustration of the phrase “adding insult to injury.” Accessible livery service today and the City’s lack of enforcement While the City advocates for more livery service outside of the central business, it has a very sorry record of ensuring that accessible livery service in provided in those same neighborhoods. This is in spite of the City’s own legal commitment to accessible livery service. Since 2001, the Taxi and Limousine Commission has had a regulation that requires equivalent service for wheelchair users (Taxi and Limousine Commission Rulebook, Section 59B-17), stating: “Whether the Base dispatches its own Accessible Vehicles or contracts with another Base, the Base Owner must provide ‘equivalent service’ to persons with disabilities.” The TLC then defines equivalent service, which includes comparable “response time to requests for service,” hours and days of service availability” and the “ability to accept reservations” for those who request a wheelchair-accessible vehicle. Unfortunately, this regulation is routinely ignored by livery operators, and the TLC has rarely enforced it. Our members typically are told by livery operators that there is no accessible vehicle available, or they are told to call another number to reach a separate livery company, which is on contract with the base to provide accessible service. Service often is not available from the contracted company either, which can be very far away. For example, one individual in our group found that her local livery operator in Bay Ridge has contracted with a company in Astoria, Queens – about a 90-minute trip just for the pick-up. Since other livery taxi users can call for a ride and get one in a matter of minutes, this surely does not meet the TLC’s own rules. The City has long known of the lack of accessible service for livery users. Over the past 15 years, we have met repeatedly with Taxi and Limousine Commission officials, mayoral representatives, city council members and taxi industry representatives to advocate for increased livery (and yellow taxi) service for wheelchair users. In fact, the lack of livery service is one of the reasons our groups – composed of the region’s largest disability groups – formed the Taxis For All Campaign in 1996. Our members had observed in their travels that cities like Boston and Las Vegas offered a substantial number of accessible hail and radio-call taxis. We also talked with colleagues in London, where every single taxi is accessible, a transition that started in 1989. We note also that affordable accessible vehicles are readily available (and a new, purpose-built accessible taxi, the MV-1, is expected to come off the factory line later this year). In our earlier letter, we proposed ways of funding the purchase of accessible vehicles if necessary. The city’s failed dispatch program Instead of moving forward so that all New Yorkers have taxi service wherever they live and whether or not they use wheelchairs, the City of New York proposes instead to offer dispatch service, in which wheelchair users would call a central number and a wheelchair-accessible vehicle would be sent their way. Unfortunately, there are serious practical drawbacks to this proposal. Chief among them is that the City has already tried to offer dispatch service in a two-year “pilot” between 2008-2010. In “Stranded,” a 2009 analysis of the dispatch program after its first year of operation, Assembly Member Micah Kellner found that: • callers were often told that no vehicle could be dispatched to them; • callers often waited long periods for pick-ups, if a vehicle was actually dispatched; • the service was generally not available on evenings and weekends; and • the TLC did not advertise the program, leading to minimal demand. In spite of the assembly member’s report, no improvements were made in the final year. We are justifiably doubtful that a new version of the program would work. Beyond that, however, is a fundamental question of fairness. Why should one group of New Yorkers and visitors find themselves unable to use the regular system of livery vehicles, merely because they are in wheelchairs? Why, instead, does the City want to relegate wheelchair users to a separate and unequal system of transportation? The government rightly would reject attempts to restrict fair access to the transportation system to other groups based on their appearance or physical characteristics. Wheelchair users should be treated no differently. A.8496 and S.5825 would make a fundamental change in the taxi system. But it should be done right the first time. As you consider this bill, we request the chance to meet with you to discuss how this legislation can get equal access on New York City’s taxis and liveries for everyone. To arrange a meeting, contact Edith Prentiss at 917-733-3794. We hope to meet with you soon. Yours truly, Edith Prentiss, Chair Taxis For All Campaign c/o 739 West 186th Street, Apt. 4E New York, New York 10033 Cc: Lawrence Schwartz Mylan Denerstein |
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