Testimony Before the New York City Council Committee on Transportation Hearing on Clean Air Taxis
Tuesday, June 3, 2008

My name is Micah Z. Kellner and I represent the 65th Assembly District in Manhattan, including parts of the Upper Ease Side, Yorkville, and Roosevelt Island. Thank you to Chairman Liu and Council Speaker Christine Quinn for the opportunity to testify today.

I strongly support the goal of making New York City's taxi fleet greener. Given the realities of global climate change and the clear links between auto emissions and asthma, lung disease, and other serious threats to public health, there is no question that we should be taking steps to mitigat ethe environmental impact of taxi traffic in New York. But it is critical that we go about this in the right way, and for the right reasons. Unfortunately, it has become apparent to me that, in the name of a worthy goal, the Taxi and Limousine Commission is using flawed metrics and a rushed timetable to provide a public relations victory for the outgoing mayoral administration - even if it means sacrificing other important priorites in the process.

The TLC's deadline of October 1, 2008, for achieving the 25 miles-per-gallon standard is simply not realistic. Vehicle manufacturers and the vast majority of the taxi industry have made this clear: there will not be enough vehicles available. The production of hybrid vehicles cannot currently meet demand and there are not enough parts to make more vehicles to meet the TLC's deadline. Yet the TLC insists on maintaining the deadline regardless of this information. In doing so it is pursuing an arbitrary timeline based on a single metric, miles per gallon, and risks sacrificing the broader interests of taxi riders.

As you are aware, I have been urging the TLC to move toward a taxi fleet that is fully accessible for riders with disabilities. In a New York Post op-ed last December, I noted the serious shortcomings of the taxi models that currently qualify for "wheelchair" medallions, and called on the TLC to approve new models that are genuinely safe and accessible. As it stands, all three vehicles that qualify for "wheelchair" medallions - two versions of the Chevrolet Uplander and one of the Dodge Caravan - are side-loading, which means that most motorized wheelchairs do no fit into the passenger section, and wheelchairs that do fit cannot be properly secured.

The industry has long argued that better models were not available, but this situation has changed and the industry is genuinely excited about the prospect of developing taxis that are both environmentally friendly and fully accessible - but only if there is adequate time allowed to do so.

There is absolutely no reason why there should be any conflict between developing clean air taxis and taxis that are fully accessible. Indeed, we have a unique opportunity to achieve both goals at the same time. But by rushing the process, the TLC is inexcusably pitting people with disabilities against the environment and public health concerns.

The TLC has put the cart before the horse, developing regulations before properly assessing what might be possible for the next generation of taxis. The first priority should have been the development of the Taxi of Tomorrow, not the arbitrary imposition of a standard based on a single metric, on an industry that cannot possibly meet that standard in this economic climate with so few hybrid vehicles and replacement parts available. Fuel efficiency is an important factr, but it is not the only one.

This is all the more ironic because the TLC's own "Taxi of Tomorrow" initiative has stimulated manufacturers to find solutions that combine clean air goals with accessibility. For instance, Ford's Transit Connect, a vehicle that has been operating in Europe as a taxi for years, would be fully wheelchair accessible, twice as fuel efficient as the Crown Victoria, and have ultra-clean tailpipe emissions. Ford anticipates mass productions and roll out the Transit Connect in September 2009, nine months after the TLC's deadline. But by pushing medallion owners to invest in new vehicles this fall - for the sake of meeting an arbitrary October 1 deadline - the TLC is undermining its own efforts to encourage owners to adopt more promising vehicles that will be available within the next year or two.

The TLC should slow down. Nobody is asking for a prolonged delay in implementing stronger fuel efficiency standards. We are only asking the Commission take the time to ensure that improved fuel efficiency in the short term does not come at the expense of the opportunity to solve other problems with the taxi fleet.

Unfortunately, the TLC's timetable suggests that political imperatives are taking precedence over the needs of taxi riders and the general public. I cannot help but think that, in rushing toward an unrealistic but public relations-friendly fuel efficiency goal, the Commission is more intent on providing the Mayor with a legacy project than on taking the opportunity to develop a genuinely well-rounded taxi. Ironically, if the TLC would simply postpone the deadline until the Fall of 2009, when accessible purpose-built taxis start coming off the production line, the Mayor would have a more complete legacy of providing public vehicles that are both environmentally friendly and accessible. From a publicity standpoint, accessible taxis may not be as attractive as green taxis - but they are no less important.

Again, there is no reason for these two goals to be in conflict. Our taxis should be accessible and green. Rather than sacrifice everything else for the sake of meeting a miles-per-gallon standard, we should be working on a complete solution to developing the taxi of tomorrow. But this means operating on a reality-based timetable, not a political timetable.

I urge the TLC to reconsider the October 1 deadline. We must not squander the progress that has been made by the Taxi of Tomorrow initiative. The ultimate goal is within reach: taxis for all, both accessible and environmentally friendly. It is critical that we take advantage of the opportunity, rather than letting it slip away in the name of political expediency.

Thank you again for the opportunity to testify today.

834 Legislative Office Building
Albany, NY 12248
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315 East 65th Street
New York, NY 10065
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E-mail: KellnerM @ assembly.state.ny.us

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Jean Ryan, Taxis For ALL Campaign's vice-chair, testified at a City Council transportation committee oversight hearing, "Clean Air Taxis: How Realistic Are the City's Miles Per Gallon Mandate?" on June 3, 2008. Here's a transcript of her testimony:

I am Jean Ryan, a VP of Disabled In Action and Vice-Chair of Taxis for ALL Campaign. The Taxis for ALL Campaign is a coalition of groups and individuals devoted to promoting taxis and for-hire services that are fully accessible to people with disabilities in New York City. We are by far the broadest-based, longest-established and most knowledgeable group in the City on this topic.

We are pleased that the City is taking steps to promote manufacture of a new "iconic taxi," which we hope will meet the goals of being less polluting, more comfortable for passengers and drivers, and accessible to passengers with disabilities. We are also pleased that the City has passed a regulation requiring black cars to have better gas mileage. However, without also mandating accessibility at the same time, the City is doing the thousands and thousands of City residents and tourists and businesspeople in our city a disservice.

We love clean air. Who doesn't? Many people with disabilities already have breathing problems. We care about the air we breather and we care about the environment and about the depletion of natural resources. But we also need to get places. But if vehicles can be developed that are cleaner, the can also be developed and are being developed as we speak that are also accessible, too! Why not mandate both? Green and accessible – Perfect together.

When Sam Sullivan, the mayor of Vancouver, British Columbia, Canada, recently came to New York City on a fact-finding trip, he had a horrible experience because he uses a wheelchair. He talked about it on his radio show and his blog and we have it on our website, www.taxisforall.org. He said, and I quote: "It was very difficult arriving at the airport. There were no wheelchair accessible taxis available. I had to be carried into a van by four people and my wheelchair had to be manhandled into a van as well, only to get into Manhattan to get to my hotel." He was lucky he got there. Many people can't get where they want to go because we don't have accessible taxis and car services to speak of in this City.

Up to now, the TLC, the Mayor, and the City Council seem to have lacked the will to do anything meaningful about it. We don't need anything special and separate! We need something universal that everyone can use!

As it stands now, the iconic taxi RFI does not require accessibility at all according to ADA standards! For example, the ADA height specifications for the passenger door opening are 56 inches and the passenger area is 56 inches, and there are requirements for a wheelchair restraint system and a ramp. The RFI's Vehicle Technical Specifications do not include any of these requirements and only specify that the doorframe has to be 38 inches high (VTS 2.8.6). No one in a wheelchair could get into a doorframe that low.

Furthermore, the Vehicle Technical Specifications 2.8.6 permit the passenger doorsill to be 13-16 inches above the ground, and that is far too high for many people with mobility disabilities.

Additionally, there is no provision in the Vehicle Technical Specifications for audio output for the meter or other technology for the benefit of people who are visually impaired, (VTS 2.4.1) or for any accommodation for people with hearing impairments such as an induction "loop" to help people with hearing aids to understand the driver-passenger intercom or audio systems, (VTS 2.10.18 and 2.10.21).

Despite our numerous requests, the iconic taxi committee which drew up the RFI refused to include anyone from the Taxis for ALL Campaign. Why not? Why don't they want to make the iconic taxi accessible? Or was this a huge oversight? We wouldn't know. We weren't on the committee and couldn't have input.

As it stands now, people who use wheelchairs and have major mobility problems in this City and who need accessible taxis cannot reliably get them. We cannot get accessible car services because they hardly exist. We usually have to call days in advance and pay exorbitant rates by credit card. For car service! Last year when my wheelchair wheel broke, I was going to gave to pay 45 dollars and wait 2 hours to go 7 blocks instead of waiting 10 minutes and paying 5 dollars if I were ambulatory. Is that equivalent service like the regulations call for? The TLC knows what is happening and does nothing about it.

In short, we care about clean air and we also want accessibility. To have vehicles with both will benefit everyone. It will mean that people will be able to transport their children in strollers easily. They will be able to haul their bulky packages easily and bring their suitcases and golf clubs into the car with them instead of putting them in the trunk, if they want to. It will mean that they will have room to transport their pets. They will have leg room if they are tall.

We encourage the City Council to think about the aging population in this City, to think about the rising costs of Access-A-Ride, to think about the tourist business and how the lack of accessible taxis and car services is hurting this City, is making life very stressful and costly in many ways, driving up Medicaid costs and Access-A-Ride costs because people can't get an accessible car services or taxis. We encourage the City Council to require all taxis to be green and accessible.

Respectfully submitted,

Jean Ryan, Vice Chair, Taxis for ALL Campaign
VP Public Affairs, Disabled In Action


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The Taxis For All Campaign urged Mayor Bloomberg and the Taxi & Limousine Commission to mandate a transition to wheelchair-accessible taxis and other for-hire taxis, similar to the forward thinking that made higher mileage vehicles a requirement.

The Taxis For All Campaign – which is made up of the largest disability organizations in New York City – has called for a gradual adoption of accessible vehicles, particularly in the yellow-taxi fleet, and more accessible service in the livery and black car industries.

"We support greener, less-polluting vehicles – who wouldn't? – but wonder why the city would mandate this innovation and reject another," said Anne Davis, the group's chair and a representative of the New York City Chapter of the National Multiple Sclerosis Society.

Holding signs reading "Green + accessible cabs: Perfect TOGETHER" and "We like green cabs – We'd LOVE it if we could ride in them!" at the TLC's April 17th meeting, the group urged commissioners to heed the interests of all New Yorkers, including the tens of thousands who cannot use for-hire cars because they are not designed to accommodate wheelchair users.

At the meeting, the TLC was expected to vote to require black cars to meet higher gas mileage standards starting in 2009. It approved a similar mandate for yellow taxis last year. Taxi fleet owners say it will take technological innovation to meet the TLC's miles-per-gallon requirements and that the ideal vehicle is not yet available – the same objection they and the TLC have been requiring wheelchair-accessible taxis. However, accessible taxis are now widely used across the U.S. and one company, Standard Taxi, is developing a new, factory-built accessible taxi.

The Taxis For All also released a letter to TLC Chairman Matthew Daus, urging him to include a representative from its group on the Iconic Taxi project.

"Unfortunately, the RFI does not declare that accessibility to people with disabilities, including those who use wheelchairs, is a bedrock requirement for a successful iconic taxi design... On the other hand, the City has taken the position that high gas mileage is a bedrock requirement for most future yellow cabs,and it is about to do the same with respect to black cars."

"By choosing to move forward with one innovation rather than both at the same time, the City is missing an historical opportunity to transform the taxi fleet," said Edith Prentiss of the 504 Democratic Club. "It's clear that if it's possible to produce a green taxi, you also can produce a green and accessible taxi." Currently, only about one percent of the city's more than 13,000 yellow cabs are accessible; very few livery or black cars are accessible.