New York City Taxi and Limousine Commission
33 Beaver Street
New York, NY 10004
Dear Chairman Yassky:
It has come to my attention that the New York City Taxi and Limousine Commission (TLC), in what appears to be a sudden and vigorous enforcement of section (n) of Chapter 54 of the TLC rules, recently began issuing numerous violations to both drivers and owners of accessible taxis for their alleged failure to participate in the accessible driver training program. While I think it is paramount that drivers be trained in both the operation of accessible vehicles as well as to the unique needs of wheelchair users, I do not believe the rules as written or the current enforcement strategy achieves this goal. Instead, this type of enforcement creates a stigma for drivers against accessible taxis at a time when the City and the State are making accessibility the future of the fleet.
It has been reported that it is increasingly difficult for a driver to complete the accessible training course because it is only offered sporadically, causing a backlog of applications. If the City is to be successful in adding thousands of new accessible vehicles to the yellow fleet, as required in the groundbreaking taxi and livery plan that you struck with the State, we can not allow training to be a roadblock. At the December Taxi and Limousine Commission meeting you spoke about including accessible training as a required part of taxi school. I believe this is the best solution to increase training opportunities for drivers and should be incorporated as soon as possible. If accessible vehicle training is made a part of every driverís curriculum, New York Cityís taxis will become more accessible, more reliable and much safer.
Due to the changing dynamics of the taxi industry, I respectfully request that the TLC suspend its
enforcement of section (n) of Chapter 54 of the TLC Rules until accessible taxi training has been incorporated as a component of taxi school. Thank you for your consideration of this matter. If you would like to discuss this issue further, please do not hesitate to contact me at (212) 860-4906.
Very truly yours,
Micah Z. Kellner