NOV. LCT: What operators can learn about building a steady client base from a leading fleet vehicle seller.
New York City is home to some 30,000 limousines, sedans, black cars, and miscellaneous for-hire vehicles. This number includes an estimated 1,200 luxury limousines according to the New York City Taxi & Limousine Commission which licenses these vehicles. Nearly 12,000 medallion taxicabs are also licensed by the T&LC.
In 1988, Jack Lusk was appointed chairman of the T&LC by Mayor Ed Koch. Lusk heads a nine-member commission on which there are currently three vacancies. The T&LC is one of the largest agencies in New York City with 600 employees. Of these employees, 220 are T&LC inspectors, and the 195 inspectors who issue summonses average a total of about 200 every day.
In the following interview, Lusk outlines what the T&LC requires in order to operate legally in New York City.
L&C: What is required in order to do business legally as a for-hire vehicle operator in New York City?
Lusk: In NYC now, you need to be affiliated with a base licensed with the city. The vehicle has to pass three Department of Motor Vehicle inspections a year, and have proper insurance. The owner of the vehicle has to be legally qualified to license which means that he can’t owe a variety of people money (i.e. the parking violations bureau in NY or the state DMV.) And, on top of that, he can’t have a criminal background.
L&C: How large a base... is it still a minimum of 10 cars?
Lusk: Yes, but I expect that could change. The agency has been looking at it and I expect we are going to either eliminate that requirement or greatly reduce it.
L&C: How do you define “doing business” in New York City?
Lusk: The definition is currently in litigation. The agency has taken the position that anybody who does anything in the city other than drop-off should be licensed by the T&LC. We’ve been sued by some people from New Jersey and outside the city saying that that’s an unreasonable burden on them.
L&C: What are the concerns of the Livery Advisory Board?
Lusk: The Livery Advisory Board is very involved in how this agency regulates their industry. They generally take the position that the minimum regulation is appropriate. We talk about dozens of specific issues with them. We talk about renewals, we talk about street enforcement, we talk about out-of-city vehicles.
L&C: Does it boil down to making things more convenient?
Lusk: I think the tension there is that I have to represent the people (i.e. the passengers), and the board is representing business interests. And I think the important thing for every regulator to remember is that these people are in business. I have a public charter to be concerned about the quality of that service vis-à-vis the health and safety issues that the public’s concerned about. It’s never been a problem and I feel I’ve worked very well with these people, but there’s certainly tension.
L&C: What other limousine organizations have you met with?
Lusk: I think I’ve met with pretty much everybody from New Jersey, Connecticut, Westchester, and Long Island. I think they share my concerns which are... problems at the airports with hustlers and problems at the theater district in New York City. There are people in New York City who are clearly operating dangerously and illegally and that’s a concern to anyone who’s a legitimate operator.
L&C: What is your feeling about the bill by New York State Senator Levy?
Lusk: That is something we have worked closely with the Senator’s office on and we hope to bring that legislation to a successful conclusion. It would provide criteria and standards for any operator who wanted to come in or go out of the city and I think it’s very healthy. Let me put it this way... I certainly think it will have a positive result in regional regulation, and I expect to see some kind of legislative conclusion. It’s only in draft now.
L&C: It was reported in the Black Car News that the T&LC wrote about 6,000 tickets during a two-month period last fall. That’s about 100 per day. Is that right?
Lusk: We write about 5,000-6,000 summonses a month.
L&C: So that’s 200 a day. Who’s primarily being ticketed now?
Lusk: Vehicles that are passenger-plated doing business in New York City. That’s the great majority of vehicles that get summonses.
L&C: Do you have any idea what percentage of the for-hire industry is operating in that illegal category?
Lusk: I’d say it’s 25 percent to one-third. There are certain places in New York City where large groups of people operate without being licensed.
L&C: Are T&LC inspectors ticketing at Kennedy and LaGuardia?
Lusk: We’re ticketing heavily there, but we’re trying to work with the out-of-state vehicles to make sure that they’re properly there. We would still ticket somebody who’s hustling.
L&C: What’s the criteria there? Does an operator need a trip ticket?
Lusk: No, it’s not so much that. Our people would see somebody soliciting passengers to go into the city who is not licensed. It’s the guy standing around the baggage area saying, ‘Hey, do you want to go into the city?’
L&C: So if somebody has livery plates from Connecticut or some other area, they’re okay?
Lusk: Yes. That’s not to say they couldn’t potentially get a summons for something inadvertently but, in general, they’re okay. I make disclaimers because we have a lot of inspectors, there are a lot of Port Authority Police, and people get summonses that may not have anything to do with the general licensing issue.
L&C: What is the status of New York City law 957-A which gives the T&LC authority to seize unlicensed for-hire vehicles.
Lusk: The City Council passed a law that needs to have implementing regulations. Those regulations should be in effect around April 1st.
L&C: What is the intent of that law?
Lusk: To do just what it says. To impound the vehicles of operators who are not licensed by the city. Is it directed at the out-of-staters...? Absolutely not.
L&C: Is it directed at the private plate people?
Lusk: Yes, and people who solicit. And people who operate in an illegal fashion.
L&C: I’m wondering about your enforcement plans. Would it be implemented against an out-of-state operator who was licensed in their own area and has insurance?
Lusk: If that person was hustling at the airport, that person could very well have his vehicle seized. Let me put it this way... if one of our people at the airport was approached by someone who said, ‘Do you want to go into the city?’ And they made an agreement and they went to the car and it turned out the car was not registered in the city but was licensed out of the city, that vehicle could very well be impounded.
L&C: We were told about a situation where an operator called a T&LC office and tried to get a license for a vehicle registered in the State of Connecticut. He was told that he needed to register the vehicle in New York in order to be licensed by the T&LC. Is dual registration actually required?
Lusk: It depends on how you ask somebody a question. If you said to one of our clericals that you have a Connecticut plate and you want to register with this agency, they would tell you that you need to be registered in New York. If you told them that you were an out-of-state operator who didn’t go point-to-point in New York City, they would tell you that you didn’t need to be registered. It’s how you ask the question. New York State traffic law says that if you go between two points in New York State, for hire, you must register your vehicle in New York. In order to do that, you do not need a New York address, you simply need to register with the state and you need to have the proper insurance. This agency recognizes that some people who come in from outside the state may want to be registered with us.... They can do that.
L&C: Is it desirable to have the T&LC handle issues as a political agency rather than an executive agency?
Lusk: Well, the commission members serve for seven years. That crosscuts more than one term of an individual mayor even though the mayor may be a two-term mayor or a three-term mayor as Ed Koch was. I think it’s appropriate that the chairman be picked by the mayor. It’s a city agency, it reports to the mayor, and the budget is set by the city.
L&C: Is there anything important we haven’t mentioned?
Lusk: No. You’ve pretty much covered the big ones. We just started driver licensing. That’s the one thing we didn’t talk about. We’ll be licensing all for-hire vehicle drivers.
L&C: Will there be drug testing?
Lusk: There’s a mandatory physical that does not include drug testing.
L&C: How do you expect to deal with the industry as you look ahead?
Lusk: One thing that has happened — because of the widespread tension that the issue of the out-of-city regulation has caused — is that I’ve really gotten to know the people from around the region very well. I think when you know them and can communicate with them, you can very easily resolve most issues. I have no intention of putting these people out of business. I represent legitimate interests in the City of New York and I think they understand that. Above all else, we strive to be reasonable and fair, which I think is all you can ask for in a regulatory agency.
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