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THE COUNCIL OF THE CITY OF NEW YORK
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October 30, 2014 Meera Joshi Commissioner Taxi and Limousine Commission 33 Beaver Street New York, NY 10004
Dear Commissioner Joshi,
Thank you for hosting the informative and comprehensive hearings on the Taxi & Limousine Commission's (TLC) plans to incorporate Local Laws 27 (Coopers Law), 28, and 30 of the Vision Zero initiative into the TLC rules. We appreciate the work that you and your staff are doing to make these laws a reality on our streets. However, in light of comments made by some TLC commissioners during the hearing, we write today to clarify some key points: Several commissioners referred to accidents. This term contradicts a core principle of Vision Zero: death and injury on our citys streets is preventable and unacceptable. Therefore the term, crash is more appropriate. As stated in the 2014 Vision Zero Action Plan: The City of New York must no longer regard traffic crashes as mere accidents, but rather as preventable incidents that can be systematically addressed. No level of fatality on City streets is inevitable or acceptable. (Vision Zero Action Plan of 2014, page 7) Rather than accepting traffic fatalities as accidents, Vision Zero allows usgovernment agencies, industry groups, key transportation stakeholders and the public aliketo understand traffic crashes as the result of a series of actions that can be changed or prevented through enforcement, education and design. (Vision Zero Action Plan of 2014, page 9) One commissioner expressed hesitation, citing the hypothetical scenario of a historically safe driver who one day picks up the phone and kills someone. As every Commissioner must be aware, TLC rules prohibit use of cell phones or any communication device, hands-free or otherwise, while operating a cab. A historically safe driver who kills someone is no longer a safe driver. Several commissioners expressed concern that these rules would imperil the ability of drivers to earn their livelihood. We counter that it is the drivers dangerous behavior, not the rules that govern them, that have imperiled his or her ability to earn a livelihood. Public safety must be the TLCs highest priority, above protecting the economic interests of unsafe drivers or any other stakeholder that would put the public at risk. Furthermore, these rules apply only in the case of critical injury or fatal crashes. Fewer than one percent of drivers are involved in crashes this serious; more than 99 percent of drivers will not be affected by these laws. We are sympathetic to the challenging work environments and economic situations that many drivers confront as they seek economic opportunity for themselves and their families. We also appreciate that you are aware of the comments that were made and that you are working to sensitize the other commissioners. It is our hope that the other commissioners will be willing to consider these linguistic and cultural shifts as they move forward with enforcement of these important rules. We look forward to our continued work together toward our common Vision Zero goal of preventing death and injury on our citys streets. Thank you.
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