MARIE THERESE DOMINGUEZ MARK J.F.

SCHROEDER
Commissioner Commissioner

November 15, 2023

The Honorable Kathy Hochul

Governor of New York State
State Capitol Building
Albany, NY 12224

Dear Governor Hochul:

The safety of all New Yorkers has always been our top priority. In the aftermath of the
terrible limousine crashes in Cutchogue and Schoharie, which changed the lives of
families and the communities around them forever, it was clear that direct action had to
be taken to protect passengers. Immediately, New York began adopting reforms to
widen and enhance authority, oversight, and operating requirements that have improved
roadway and stretch limousine safety for all New Yorkers. We are grateful that the
Legislature worked with us quickly to pass those laws. Since 2019, more than 20
statutory measures have been adopted, including:

• Enhancing seatbelt requirements in limousines to require each seat to have a

seatbelt installed;
• Establishing statutory authority for the DOT to impound unsafe limousines;
• Prohibiting U-turns by limousines;
• Increasing civil penalties for illegal U-turns;
• Mandating commercial GPS be used in limousines;
• Establishing a hotline for filing safety related complaints;
• Establishing an annual review of motor carrier drivers’ records by the DMV;
• Requiring individuals who operate limousines to possess a commercial driver’s
license with a passenger (P) endorsement;
• Establishing the Stretch Limousine Passenger Safety Task Force;
• Requiring that all drivers of any for-hire vehicle transporting nine or more
passengers are subject to drug and alcohol testing;
• Expanding mandatory seatbelt use to the backseat for those 16 and over;
• Increasing civil penalties for any person found operating a limousine in violation
of state law;
• Authorizing the seizure of license plates for vehicles operating in violation of state
law;
• Establishing a misdemeanor for tampering with a federal motor carrier safety
certification label;
 • Providing authority to suspend or revoke the operating license of an inspection
station that illegally inspects an altered vehicle;
• Prohibiting the registration of altered motor vehicles that do not comply with
federal safety standards;
• Increasing insurance requirements for limousine operators;
• Establishing a class E Felony for persons found operating a vehicle in violation of
or without requisite state authority in a manner that causes the death of another
person;
• Increasing fines for inspection stations that operate in violation of state law;
• Requiring that valid limousine operating authority, inspection information, and
driver qualifications be displayed to the public;
• Requiring that inspection stations report if someone seeks a stretch limousine
inspection without an exemption letter issued by the DOT;
• Requiring DOT to maintain and update its website regarding bus operators and
provide for designated carrier information;
• Establishing an inspection fee for inspections performed by the DOT.

It was clear, however, that more had to be done to protect passengers. At your
direction, the New York State Stretch Limousine Passenger Safety Task Force was
accelerated in Fall 2021, with the group commencing its work soon thereafter. The Task
Force established an aggressive timeline to complete its mandatory review of matters
influencing the safety, adequacy, efficiency, and reliability of the stretch limousine
transportation industry, including holding six meetings and one public hearing. Based
on the in-depth discussions at those meetings, the feedback from the public hearing and
the tireless work of the task force members and associated staff, the final report was
issued in September of 2022 with 16 recommendations of additional actions and
reforms for consideration by the Legislature and the Governor.

Many of the Task Force’s recommendations require legislation, including bills that would
establish increased penalties for operating a suspended vehicle, require that vehicles
have new safety equipment including window break tools, and mandate that older or
heavily used vehicles be taken out of service. The recommendations also include
statutory changes aimed at improved data availability and requiring pre-trip safety
briefings for passengers. Recognizing the need for those reforms to keep New Yorkers
safe, the Senate developed and passed a number of legislative proposals during the
2023 legislative session.

Our agencies have taken action. Beyond the statutory measures enacted in the wake
of the limousine tragedies and recommended in the Task Force report, you made it
clear that we must continue to use our administrative and enforcement powers to
combat unsafe and improper limousines, strengthen partnerships with law enforcement
to enhance roadside enforcement, and establish robust internal working groups
between agencies dedicated to the continued oversight of stretch limousines and
altered vehicles.
At your direction, we have implemented a series of reforms, including:

• Adding a computerized check to the vehicle inspection system (NYVIP) to

preclude a public inspection station from wrongly inspecting stretch limousines,
which may only be inspected by DOT;
• Adding multiple questions to the vehicle registration form to elicit accurate vehicle
seating numbers and to determine if the vehicle had been altered to carry more
passengers;
• Utilizing VIN-based controls to prevent the inappropriate registration or
ownership transfer of altered vehicles in New York State, allowing an additional
level of review of all documentation submitted when registering or renewing a
registration for an altered vehicle;
• Holding bi-weekly meetings between DMV and DOT to coordinate on emerging
and ongoing limousine issues. This includes sharing enforcement data,
enhancing coordination processes and procedures, and taking steps to remove
non-compliant limousines from the road;
• Conducting routine reviews of all vehicles assigned passenger plates with “Limo”
as the body type to ensure such vehicles are appropriately registered;
• Notifying all law enforcement agencies to report any observation of a vehicle that
has been stretched or widened to increase passenger capacity;
• Providing regular communication to limousine operators with reminders on
licensing requirements;
• Coordinating with other states and national partners to identify limousines which
may operate in New York;
• Conducting enforcement operations with State and local law enforcement to
identify improperly operating limousines and removing them from the road;
• Increasing administrative, criminal and civil enforcement actions against those
who fraudulently register and operate limousines in New York. The registrations
of 77 altered vehicles have been revoked, 50 of which occurred in 2023.
Additionally, DMV has taken administrative action, seeking suspension or
revocation of the driver’s license of individuals who circumvent proper registration
requirements and operate unsafe vehicles in a for-hire capacity in New York. In
2023, DMV pursued 13 license actions related to cases of improperly registered
limousines. The registrants of those vehicles have all been penalized with, at a
minimum, a one-year license suspension; and in one case, DMV secured a 7-
year revocation of the registrant’s driver license;
• Notifying insurance carriers of improperly registered limousines;
• Creating and amplifying a public awareness campaign centered on the promotion
of safety steps New Yorkers can take to protect themselves when hiring or riding
in a limousine;
• Coordinating between DMV and DOT in real-time to identify illegal and unsafe
limousines and take the steps necessary to remove them from the road;
 • Intensifying regulation of vehicle inspection facilities to ensure limousines obtain
the proper safety inspections. Since 2020, 39 Inspection Stations and 42
Certified Inspectors have been charged with various violations regarding
inappropriate limousine inspections. Of these, 21 Inspection Station and 20
inspector charges occurred since December 2022;
• Pursuing criminal charges and administrative actions against individuals who
intentionally take actions to put unsafe or improper limousines on the road. Since
2021, 18 individuals have been arrested and charged with various misdemeanors
and felonies associated with fraudulently registering and operating limousines.
These changes reflect our commitment to protect all New Yorkers who want to safely
use limousines throughout the State, but more must be done in statute to fulfill the
recommendations of the Task Force Report.

A continued focus on limousine and roadway safety is of the utmost importance. We

commend you for your leadership and unwavering dedication to this issue by
committing to address the outstanding statutory Task Force recommendations, in
partnership with the Legislature.

We are truly grateful to have played roles developing and implementing significant and
critical reforms, and we remain steadfast in our resolve to see these remaining
proposals enacted into law.

___________________________ ___________________________
Marie Therese Dominguez Mark J.F. Schroeder
Commissioner Commissioner
NYS Department of Transportation NYS Department of Motor Vehicles