Commissioner Daus, members of the Commission, thank you for allowing me to testify before you this morning.
I am Sergio A. Sanchez, Executive Vice President of Partners Executive Transportation. We are a licensed luxury base operation and would like to express our support and concerns on the rule changes you will be voting on involving mileage requirements.
We recognize our corporate and personal responsibilities for the environment especially for those of us who work and live in New York City. As such we have begun our own “third party environmental sustainability program.”
The rules you anticipate setting are ones we support and would like you to consider some unique and necessary situations. The rules will affect “black car” bases but as a “luxury base” we see potential problems which you might want to consider for all TLC licensed vehicles and bases. Many of our clients use both “black cars “and luxury bases” in their daily operations. It should not be taken for granted that car manufacturers will simply build the cars to meet New York City’s rule changes.
Our corporate clients do express interest in reducing Greenhouse Gas emissions but are not willing to be driven in the hybrid vehicles currently on the market. They want the larger, Lincoln Town Cars, BMWs, Mercedes 550, and even the larger SUVs. They speak about favoring green cars as long as it doesn’t sacrifice their comfort. It is part of the “not in my backyard syndrome.”
Our clients require a quiet, comfortable trip where they can relax or work on their laptop computers or discuss private business matters. They consider the vehicle as their living room or private office. Keep in mind that chauffeured cars often drive multiple passengers. The hybrids currently on the market are not appropriate for multiple business executives. For this reason alone, multiple passenger vehicles like the Lincoln Town Car are more environmentally sustainable than the two or three hybrids that would be needed to transport the same number of multiple passengers traveling to the same destination.
While there is a hybrid Lexus model available, the cost is too prohibitive for our chauffeurs. Our chauffeurs are independent contractors who buy their own vehicles. Cars like the Prius or the Mercury Mariner are just not acceptable for them or our clients. Just imagine, Jason Giambi and Alex Rodriguez in a Prius – together.
An important factor is the actual rating as to what is 25 miles per gallon for city driving means. This figure of 25 MPG is never tested in cities over 1,000,000 populations. What might be 25 MPG in Phoenix is not the same as New York and especially Manhattan. I am sure you all will agree on this. Consider a gasoline powered car that is rated at 25-30 MPG and stuck in traffic by Wall Street. It is not getting 25 MPG but emitting greenhouse gases as much as a car rated at 15 MPG.
Most discussions postpone the real cost and explain that arrangements have been made with financing firms to enable chauffeurs to afford some of these “hybrid” vehicles. The further claim is that the savings in gasoline will offset any monetary outlay. This does not take into consideration the reality of the current credit markets and our individual chauffeur’s financial situation. Many of our chauffeurs do not have high credit scores and even though some attractive financing plans may be available they cannot qualify which results in higher interest payments.
Another significant aspect is for firms like Partners Executive Transportation which does not own the vehicles. Since our chauffeurs will be the ones actually buying the cars, it will be harder for us. Firms that own their vehicles are in a position to negotiate better deals based on the size of their fleets. We can envision firms like ours being pushed out of the market.
There are technologies which can produce the desired results of lowering Greenhouse Gas emissions. It should not to be based solely on 25 or 30 miles per gallon. Such things as compressed natural gas, propane, and hydrogen are just some of the possibilities already on the market. One of our affiliates in Albany announced at a press conference it is converting to all propane and drew a lot of attention from the New York State Assembly.
At present there is only one known dealership that will convert a Lincoln Town car to compressed natural gas in the New York area. The problem with this is that it will only “lease” out a car for 30 months and will not sell it to a chauffeur. This is not a viable program since most of our chauffeurs would rather purchase a vehicle for the various income tax advantages for depreciation and other related benefits.
To be a viable and significant program we recommend that the TLC look at all options, technologies and develop a program similar to what we are involved with. Our clients are looking to reduce their SCOPE 3 greenhouse gas emissions in their supply and vendor services. It is not a matter of 25-30 MPG but their suppliers’ total emissions measured in tones of CO2.
We participate in a “third party verified, environmental sustainability program,” monitored by Green Ride Global. This is a true method of reducing greenhouse gas emissions and meets all national and international governmental requirements.
Our program is a measured approach to reducing our total greenhouse gas emissions with set deadlines and involves our full operations, including vehicles, utilities, employee transportation, and our own supply chain.
We hope the TLC will consider a broader approach to reducing greenhouse gas emissions and not just consider the 25-30 MPG.
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