I have a hard time imagining anyone arguing against any reasonable attempt to ensure better, fairer transportation services for disabled riders – an issue that has always seemed just out of reach in NYC, despite the fact that there have been many attempts, and quite a few very smart people seeking solutions over the years.

Of course, the key word here is “reasonable.” An unreasonable plan would be one that would put the companies attempting to provide those services out of business – not just for the financial damage it would do to the transportation companies themselves, but logic would dictate that service for disabled riders would not be improved if there weren’t companies left to provide that service. Keeping those critical points in mind, I would consider the NYC Taxi and Limousine Commission’s (TLC’s) current plan – which is scheduled to be discussed at their September 28 meeting – to be un-reasonable.

There are a few ways to look at the TLC’s proposed new rules: Perhaps the commission introduced its EXTREME plan as a negotiating tactic, thinking the industry would panic, roll over and agree to some far-less-devastating version… or maybe the TLC threw it out there hoping they could shock the industry into coming up with a totally different plan, and if that plan didn’t work out, the TLC could say, “Hey, it wasn’t our idea.” Or maybe, just maybe, their intention all along was to get the industry to band together in an unprecedented show of unity, and work together toward a real solution for providing better Wheelchair-Accessible Vehicle (WAV) services for disabled riders, without shuttering countless businesses and putting thousands upon thousands of people out of work.

For the sake of argument, let’s just assume the TLC’s plan all along was that last thing… because, honestly, it doesn’t matter how we got here, but it definitely worked. I have talked before about inroads made toward uniting the industry, but no one has ever seen a situation quite like this one before. The Black Car Assistance Corp. (BCAC), Limousine Association of New York (LANY), Livery Base Operators, Inc., Livery Round Table, Carmel, Lyft, Uber, Via and the New York State Federation of Taxi Drivers have not only joined forces, representatives from each group have been meeting on a weekly basis for over two months now, seeking a reasonable solution to ensure disabled riders receive better, more convenient access to WAVs without crushing the entire industry. Combined, the “Coalition” represents more than 100,000 vehicles – an enormous number by any standard.

Ever since the proposed new rules were announced, Coalition representatives began meeting with several TLC commissioners, including Chairwoman Meera Joshi, and they plan to meet with the remaining commissioners in advance of the September 28 meeting. According to Ira Goldstein, who not only represents the BCAC, but is serving as the spokesperson for the Coalition, a number of commissioners have been receptive, while others are keeping their cards close to the chest.

It should be noted that, after a meeting between the Coalition, Ms. Joshi and her top staff, Mr. Goldstein received a letter from Ms. Joshi congratulating and commending him on his success in getting such a diverse group on the same page.

From the outset, the Coalition has made it clear that building a program based on dispatching a certain percentage of rides in WAVs, and punishing those that don’t, is unworkable from top to bottom, and must be scrapped – even if the top number was only 10%, rather than 25%. The Coalition pointed out that you can’t reasonably dictate to the customer the type of vehicle they MUST ride in – and in fact, many Black Car bases have multi-year contracts with corporations specifically outlining vehicles they deem acceptable. Even on the Livery side, Livery Base Operators spokeswoman, Cira Angeles, noted that some percentage of customers would likely refuse transportation in a WAV – for example, if an environmentally-conscious rider booked a vehicle, and wanted a high-MPG hybrid.

Instead of a percentage-based system, the Coalition formally proposed a Centralized Dispatching system that includes Black Car, Livery, Luxury and TNC bases that aggregates demand and supply. Although it will require some time and effort, the Coalition feels strongly that this type of system provides a framework that will satisfy everyone’s needs.

In a letter addressed to Ms. Joshi, the Coalition made the following points:

The proposal is not realistic. Acquiring the number of vehicles necessary to comply with an arbitrary trip mandate of 25% would cost at least $500 million. Simply put, this expense will drive many of our members out of business, especially the smaller operations, as we seek to comply with a WAV mandate that is not set at actual WAV demand.

 The industry is committed to a real solution. We agree that the industry must have a WAV solution that works for drivers and passengers. To that end, we support a reliable dispatch solution and we stand ready to work with the TLC to establish it. We believe that this “passenger-first” model would more effectively and efficiently enhance accessibility.

We firmly believe that a WAV solution is within our grasp, if we work together towards a solution. If we do not, then our concern is that the City will promise accessibility that it cannot deliver and will leave the industry in a worse position to provide service to all New Yorkers.

Ms. Joshi expressly agreed to address the Coalition’s letter and proposal, but as we went to press on September issue of Black Car News, no response had yet been received. For this, and a number of other reasons, I would urge the TLC to postpone their hearing on the subject of WAVs – at least until Ms. Joshi has the chance to respond, the Coalition has time to digest Ms. Joshi’s comments, and everyone can move forward together with a REAL solution – one that doesn’t do more damage than good.


Article by Neil Weiss

Neil Weiss is the Editor/Publisher/Owner of Black Car News and Livery Times. He has been involved in the ground transportation industry since 1991, writing thousands of articles on a wide variety of subjects.

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