Office of Administrative Trials and Hearings - Public Hearing - Proposed Rule May 16, 2016 NYCLA TESTIMONY Publications1794_0

Office of Administrative Trials and Hearings – Public Hearing – Proposed Rule

May 16, 2016

TRANSCRIPT OF THE

CITY OF NEW YORK

OFFICE OF ADMINISTRATIVE TRIALS AND HEARINGS

PUBLIC HEARING

ON PROPOSED RULE REGARDING PENALTIES

FOR OFFENSES ADJUDICATED BY

ENVIRONMENTAL CONTROL BOARD

MONDAY, MAY 16, 2 016

66 JOHN STREET

10TH FLOOR, CONFERENCE ROOM

BOROUGH OF MANHATTAN

10:33 a.m.

Reported By:

Jennifer Cassella

HEARING CONVENED AT 10:33 a.m.

PRESENT:

Simone Salloum, OATH

Mark H. Leeds, ECB, OATH

Elizabeth Nolan, OATH

Denis Brogan, OATH

Diana Haines, OATH

Amy Slifka, OATH

Helaine Balsam, OATH

Tynia Richard, OATH

Peter Schulman, OATH

Peter M. Mazer, Metropolitan Taxicab Board of Trade

Elana Soleimani, Jack Jaffa & Associates

Dawn Falco, Jack Jaffa & Associates

Gabrielle Klein, Jack Jaffa & Associates

Carol Sigmond, NYCLA

TESTIMONY GIVEN BY THE FOLLOWING INDIVIDUALS:

Peter M. Mazer, Metropolitan Taxicab Board of Trade

Carol Sigmond, NYCLA

Proceedings

SALLOUM: Good morning. I’m
Simone Salloum, Assistant General Counsel
of the New York City Office of
Administrative Trials and Hearings, OATH.
Thank you for attending OATH’s hearing this
morning.

OATH is conducting this hearing in
accordance with the requirements of the
City Administrative Procedure Act. It’s
purpose is to receive comments from you on
OATH’s two proposed rules that would, one,
modify various adjudication procedures at
OATH and allow the OATH Hearings Division
to adjudicate summonses formerly heard at
the Environmental Control Board and the
Taxi and Limousine Tribunal; and two,
repeal the OATH Environmental Control Board
Air Penalty Schedule.

The proposed rules were published in
the City Record on April 15, 2 016. OATH
e-mailed the rules to the Speaker of the
Council, each Member of the Council, all
Community Board Managers, news media and
civic organizations. OATH posted the
proposed rules on its website and also
e-mailed the rules to New York City Rules
for posting on its website.

You may present an oral statement or
submit written comments concerning the
proposed rules. Please sign in at the
entrance of the room if you wish to present
an oral statement this morning. We have
been accepting written comments on the
proposed rules since its publication in the
City Record and will continue do so through
the end of this hearing.

When you speak, please state your
name and affiliation, and speak slowly and
clearly so that your statement can be
accurately recorded. We also ask that you
limit your statement to three minutes, and
if you could also just let us know which
rule you’re commenting on, that would also
be appreciated.

OATH will make available a copy of
all written comments received, together
with the hearing transcript, during normal
business hours at the 10th Floor Conference
Room, located at 66 John Street, New York,
New York on May 26, 2 016. OATH will
carefully consider all of the comments that
it receives today and all written comments
received through May 16, 2016. OATH will
issue final rules following that
consideration. Thank you.

I think first we have Peter Mazer.

Feel free to come up.

MAZER: Good morning. My name
is Peter Mazer and I am General Counsel to
the Metropolitan Taxicab Board of Trade. I
represent taxicab drivers and owners before
the OATH Hearings Division, both the Taxi
Tribunal and ECB, and I also represent
respondents at the OATH Trials Division.

I commend OATH for the proposed
rules that are the subject of today’s
hearings and urge their immediate passage.
These proposed changes will professionalize
the Tribunal and will help to ensure that
respondents receive fair hearings.

This morning I would like to address
two issues that may be unique to the Taxi
Tribunal and which I believe require some
attention. Certain Taxi and Limousine
Commission rule violations carry penalties
which include discretionary license
suspension or revocation. Such penalties
are immediately imposed upon a default.
Two that come to mind are suspensions for
failure to inspect a taxicab or failure to
answer a notice to correct a defect, but
there are others that affect both taxicab
owners and drivers.

Because the TLC has the ability to
immediately prevent a medallion taxicab or
street hail livery vehicle but not a black
car or a car service vehicle from operating
when a suspension is imposed, a suspension
upon a default results in the taxicab
medallion owner or driver immediately being
prevented from working, even if the
suspension or revocation is imposed in
error. Not a day goes by where a driver or
owner is not suspended in error. As for an
example, where the TLC and respondent enter
into a settlement and yet the OATH Hearing
Officer defaults the summons. Since OATH
Hearing Officers are instructed to impose
the maximum permitted penalty, a suspension
or revocation is imposed even in cases
where the vehicle was inspected, the notice
was answered, or the underlying violation
has been cured. I do not believe this
occurs in context of health or ECB cases.
Restaurants are not shut down upon an ECB
default, however, taxicabs are put out of
service every day.

The solution is simple. A default
suspension or revocation can be stayed for
a few days so that if it is imposed in
error, the matter can be rectified. Most
errors are corrected in a day or two, but
the driver or owner is typically deprived
of his or her livelihood until the error is
corrected. This is not acceptable. These
are not isolated instances, but daily.
occurrences, costing the industry millions
of dollars annually. I urge OATH to adopt
this relatively easy fix of simply staying
suspension or revocation default penalties
for a few days in order that errors can be
fixed.

A second point I would like raise
concerns consumer complaints. OATH rules,
indeed the Administrative Code, permit a
complainant at the Taxi Tribunal to appear
by telephone or even by affidavit.
However, at a recent public TLC Commission
meeting, the TLC Chair acknowledged that
due process mandates that a complainant be
present at the hearing upon the request of
the respondent. I strongly recommend that
OATH enact changes which reflect the
intention of the agency head, that a
respondent be permitted to request the
complainant be present at the hearing and
that a Hearing Officer be permitted to
direct such attendance, where the facts and
circumstance warrant. While the
Administrative Code permits a hearing to go
forward by telephone conference or
affidavit, the TLC and OATH can agree to
follow the direction of the TLC Chair and
mandate the appearance of a witness at a
hearing where the facts and circumstances
warrant.

Well, I thank you. If have you any
questions, I’d be happy to answer them.

SALLOUM: Thank you.

I think next up we have Dawn Falco.
Do you wish to testify?

FALCO: Actually, at this time I
would like to withdraw my request. Do I

still have an opportunity to submit
anything via writing?

SALLOUM: I think by the end of
close of business today.
FALCO: The end of today. Okay.
Thank you so much.
SALLOUM: Elana Soleimeni.
SOLEIMENI: I’m going to also
waive it and submit something by writing by the end of the day.
SALLOUM: And then
Gabrielle Klein.
KLEIN: The same.
SALLOUM: Does anyone else wish
to testify?

(Ne response.)

(Whereupon, a recess is taken.)

SALLOUM: Ms. Sigmond, are you
ready to testify?
SIGMOND: Yes.
SALLOUM: If you could, just
state your name and affiliation.
SIGMOND: Good morning. I’m
Carol Sigmond. I’m the President of New
York County Lawyers Association and I’m
here to testify on behalf of the
Association. I am also a partner at Cohen,
Seglias, Pallas, Greenhall & Furman,
4 5 Broadway, New York, New York. I’m here
today to address OATH on behalf of the
Association and our task force on
administrative law reform.

NYCLA has been studying these issues
since 2 006 and we have issued approximately
six reports, the most comprehensive being
dated December 22, 2009 and available at
our website, nycla.org. Our task force
Chaired by the Honorable
Margaret J. Finerty and Susan B. Lindenauer
has focused on preparing reports and making
recommendations to improve the
administration of justice in what is often
called the fourth branch of government, and
I thank you for giving me a few minutes of
your time.

We support unequivocally, OATH’s
adoption of the proposed modifications to
the various adjudication procedures and to
allow the OATH Hearings Division to
adjudicate summonses formerly heard at the
Environmental Control Board and the Taxi
and Limousine Tribunal. These changes
reflect the New York County Lawyers
Association policies to facilitate and
further create meaningful due process and
reforms in the law which we believe are in
the public interest, and we applaud and
support OATH’s efforts.

The OATH proposed changes, which
include clarifying the powers and duties of
hearing officers, a single summons process,
homogenized panels and generally uniformed
rules to govern hearings at the
Environmental Control Board, is a big step
in the right direction. We note that
future improvements, some of which are
outside the scope of OATH’s rule-making
authority, should include the creation of
uniformed appeals process, among other
things.

In the meantime, our task force will
continue to study this area of the law and
explore new solutions. We look forward to
a continued dialogue with OATH on these
issues and welcome engagement with other
government agencies and stakeholders
essential to this process. Thank you.

SALLOUM: Thank you,
Ms. Sigmond.
SIGMOND: Do you have any
questions?
SALLOUM: No.
SIGMOND: Thank you.

(Whereupon, a recess is taken.)

SALLOUM: It’s 12:00 p.m., and
this concludes the public hearing.

(Time noted: 12:00 p.m.)

C E R T I F I C A T E

STATE OF NEW YORK )

) ss.:

COUNTY OF RICHMOND )

I, JENNIFER CASSELLA, a Notary Public within and for the State of New York, do hereby certify:

I reported the proceedings in the within-entitled matter, and that the within transcript is a true record of such proceedings to the best of my ability.

I further certify that I am not related to any of the parties to this action by blood or marriage; and that I am in no way interested in the outcome of this matter.

IN WITNESS WHEREOF, I have hereunto set my hand this 17th day of May, 2016.

JENNIFER CASSELLA

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three (1) 5:18

time (3) 10:9 12:7 13:25

TLC (6) 7:13,24 9:9,10,23,24

today (4) 6:5 10:14,15 11:16

today’s (1) 6:19

Trade (3) 2:14 3:3 6:13

transcript (3) 1:2 5:24 14:12

Trials (3) 1:4 4:5 6:17

Tribunal (6) 4:17 6:16,22 7:2 9:7

12:14

true (1) 14:12

two (5) 4:12,17 6:25 7:8 8:17

Tynia (1) 2:11

typically (1) 8:18

underlying (1) 8:7

unequivocally (1) 12:8

uniformed (2) 12:24 13:7

unique (1) 6:25

urge (2) 6:20 8:23

various (2) 4:13 12:10

vehicle (3) 7:15,16 8:6

violation (1) 8:7

violations (1) 7:4

waive (1) 10:19

warrant (2) 9:20 10:3

way (1) 14:16

website (3) 5:2,4 11:23

welcome (1) 13:13

WHEREOF (1) 14:18

wish (3) 5:8 10:8,24

withdraw (1) 10:10

within-entitled (1) 14:11

witness (2) 9:25 14:18

working (1) 7:20

writing (2) 10:12,19

written (4) 5:6,10,23 6:5

York (11) 1:3 4:4 5:3 6:2,3 11:11:11:15,15 12:15 14:4,8

10:33 (2) 1:15 2:2

10th (2) 1:13 5:25

12:00 (2) 13:23,25

15 (1) 4:21

16 (2) 1:11 6:6

17th (1) 14:19

2006 (1) 11:20

2009 (1) 11:22

2016 (5) 1:11 4:21 6:3,6 14:19

22 (1) 11:22

26 (1) 6:3

45 (1) 11:15

66 (2) 1:12 6:2

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Office of Administrative Trials and Hearings – Public Hearing – Proposed Rule May 16, 2016 NYCLA TESTIMONY Publications1794_0

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