a lower east side block association
P.O. Box 59, NYC 10002

Sent via Certified Mail, November 7, 2015

Mayor Bill de Blasio,
NYC DOT Commissioner Polly Trottenberg,
NYC Police Commissioner William J. Bratton,
NY State Senator Daniel Squadron,
Council Member Margaret Chin,
Assemblyman Sheldon Silver,
Manhattan Borough President Gale Brewer,
NY State Governor Andrew Cuomo,
US Senator Chuck Schumer,
US Senator Kirsten Gillibrand,
US Congresswoman Carolyn Maloney,
US Congresswoman Nydia Velázquez,
FMCSA Acting Administrator T.F. Scott Darling,
FMCSA Chief Safety Officer and Assistant Administrator Jack Van Steenburg

Re: Intercity Buses on Manhattan’s Lower East Side

By way of introduction, my name is Emma Culbert and I am writing on behalf of a Lower East Side block association in Manhattan called SPaCE (Seward Park around Canal East).

Approximately three years ago, Chinatown and the Lower East Side endured a rapid increase in housing intercity bus operations in small store fronts and on the streets. A small number of the buses have acquired permits. Many more are operating without authorization. Our neighborhood has become the de facto dumping ground for private bus permits as well as the destination of choice for an overwhelming number of bus companies operating illegally (without permits). There are approximately 4000 pick-up and drop-offs per week. The intercity bus industry has literally rolled in to and over our community in the past few years.

The operations of transportation organizations are extremely dangerous. That is why transportation industries have strict policies, procedures, governance and enforcement that keeps the injury, illegal activities, and death toll to a minimum. The private intercity bus industry (commonly referred to as “Chinatown Buses”) has grown without controls, infrastructure, a focus on passenger safety and with no regard for residents and other business owners’ quality of life and concerns.

A solid first step was made when the intercity bus permit system officially went in to effect on April 10, 2013. However, the law did not begin to be enforced until August 15, 2014 after the flags were raised by the affected community. This past spring, members from the NYC 5th and 7th police precincts spoke at a monthly Community Board 3 Transportation Committee meeting declaring that they are overwhelmed and unable to effectively police intercity buses. Enforcement of the law has since made it very apparent that the illegal operations of the intercity bus industry far surpasses the ability to control it.

Based on our data, the current situation has two major arms. The forward facing challenge is the responsible and reasonable granting and revocation of permits in locations which have been properly vetted by the DOT. However, the backward facing challenge of this debacle is reigning in the wild west, illegal operations of 80+ buses that are doing business in our neighborhood.

Our Complaints and Grievances are genuine:
• Endangering the welfare of children and the elderly via impassable sidewalks due to waiting patrons and their cargo
• Lack of infrastructure to adequately provide patrons with bathrooms and shelter
• Lack of infrastructure to quickly and economically move the patrons on to their final destination
• Increased noise pollution
• Increased air pollution
• Increased general refuse

• the lack of effective policies, procedures, governance and enforcement to protect the community,
• the inability to effectively enforce existing stipulations,
• the illegal operations that occur on intercity buses, namely transporting of illegal arms,
• that Canal Street east of the Manhattan Bridge and the adjoining streets are narrow one lane roads that do not have the capacity to accommodate buses

…It is only a very short matter of time before one of our children or seniors is injured or killed. Any statistical model would show that as a cold, hard fact.

Our ask:
• Establish a saturation point (no permits granted if the applicant is seeking a permit at a location that has exceeded X number of picks-ups and drop-offs within Y number of feet of another permitted stop).
• Place a freeze on issuing more permits on Canal Street, East Broadway, Allen/Pike Street until the number of pick-ups and drop-offs has reduced to below the established saturation point.
• Create a form of governance (policy and procedure) for the de facto bus station that has been created in our neighborhood.
• Create a stipulation that requires bus operators to establish routes, have them publicly vetted and then enforce them.
• Increase the current fines to make the tickets an effective deterrent.
• Enforce revoking permits based on fine accumulation.
• Make 311 a viable tool for filing a complaint against intercity buses.
• Publish the stipulations that coincide with granted permits.
• Increase traffic enforcement to support the 7th and 5th Precinct’s ability to effectively police the industry.
• Partner with other states who issue licenses and the federal government who grants the right to operate to highlight and target bus companies operating illegally.
• Require permitted buses to post their licensed location on their windshields.
• Authorize the study on the impact on local businesses, traffic flow patterns and environmental impact.

We recognize and respect the tradition of the Chinatown bus service that has developed in our neighborhood, however, additional permits would not be servicing the community. In fact, the bus operations now stand in direct opposition to the benefit of our residential neighborhood. For the sake of our children, our seniors, and our community, SPaCE, along with other block associations and the Lower East Side and Chinatown residents and business owners will continue to fight any future intercity bus applications in our neighborhood.

Our elected officials have the power to prevent a tragedy rather than to remediate one in court, e.g. Leandra’s Law: http://en.wikipedia.org/wiki/Leandra%27s_Law. Please, we are pleading with you to embrace the path of prevention. This letter is meant to reiterate the position of the SPaCE Block Association and its’ over 350 (and growing) signers of the Chinatown Bus Industry petition to deny further permits in our immediate neighborhood.

We would very much appreciate a follow up conversation to further discuss our concerns and next course of action. We look forward to working with you on this very serious and timely issue.

Most Sincerely,

The SPaCE Block Association

Emma Culbert, President
Linda Jones, Secretary

NYC 7th Precinct, Captain Steven Hellman
NYC 5th Precinct, Deputy Inspector Fernando Burgos
Manhattan Community Board 3, Susan Stetzer