From: Carol SchachterTo: SAPOrulesSubject: Comments Regarding Rule Change: for December 2 hearingDate: Wednesday, November 30, 2016 1:16:10 PM

I am writing this letter in support of keeping the street fairmoratorium item as is and thank you from the followingorganizations:Stuyvesant Park Neighborhood AssociationGramercy Neighborhood Associates13th Precinct Community Council

We are delighted that we can continue to have our street fairsunder the present moratorium policy. Thank you again for thisruling.

Carol Schachter (for the organizations listed above).

December 2, 2016 Michael Paul Carey Director Mayor's Street Activity Permit Office 100 Gold Street, 2nd Floor New York, New York 10038 Re: Proposed changes to the Rules of New York concerning Street Activity permits. Dear Mr. Carey: Manhattan Community Board 4 (CB4) appreciates the opportunity to comment on proposed changes to the Rules of New York concerning Street Activity permits. CB4 has a good working relationship with the Street Activity Permit Office (SAPO). CB4 understands the need to incorporate new processes and to provide for better planning. However, the previous proposed changes were significant and CB4 believes that SAPO needs to take more time and opportunity to adequately engage with event sponsors, operators and community organizations. CB4 would like to recommend that SAPO provide the various stakeholders the opportunity to engage in meaningful negotiations with SAPO and to be conducted in their local environments. CB4 is on record for supporting the extension of the moratorium on new street fairs and recommends to extend the existing moratorium on street fair applications to Calendar Year 2017. During which time SAPO continue engaging all stakeholders with the goal of formulating a effective and balanced set of new rules. We appreciate your consideration and look forward to working with your office to address the above issues. Sincerely yours, Delores Rubin Chair Manhattan Community Board 4 cc: Hon. Corey Johnson, City Council

CITY OF NEW YORK

MANHATTAN COMMUNITY BOARD FOUR

330 West 42nd Street, 26th floor New York, NY 10036 tel: 212-736-4536 fax: 212-947-9512

www.nyc.gov/mcb4 Delores Rubin Chair Jesse R. Bodine District Manager

11/28/2016 NYC Rules

https://rules.cityofnewyork.us/comments­view/26396 1/1

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Public comments for: Street Fair MoratoriumComments

Michael Tisi

Barbara Gerber­...

Carol Schachter

Comment:My name is Arthur J. Tisi. My Grandfather was issued the first permit to conduct a street festival in New York City in 1926. This wasfor the San Gennaro Festival. In those days the Irish (God bless them) controlled the Catholic Church and would not allow the“WOPS” to display the statue of San Gennaro in a street procession and therefore refused to allow the statue of San Gennaro out ofthe church. My Grandfather told the clergy he understood and quickly put together a committee of Neapolitans who stole the statue ofSan Gennaro when the church closed. The rest is history. My Grandfather knew that a street festival was not about church rules butwould be an excellent way for the hard working poor immigrants in the community to earn money to feed their families while perfectingtheir talents. So too today’s street fairs are about giving minorities, women, people of color and immigrants a venue to enter the retailworld by utilizing their talents to support their families. There are no problems with street festivals which financially support thousandsof fair vendors and provide a day of free entertainment for New Yorkers and tourists alike. The only problem here is a handful of naySayers who only think of themselves. We know our great Mayor will not be conned into destroying so many lives by these negativeself­serving meddlers.Was my Grandfather correct? Because of street fairs in which my parents worked, I graduated FordhamUniversity with a degree in Pharmacy and my late brother, Dr. G.M. Tisi was the Dean of the University of San Diego Medical School.Let’s talk about “self­serving meddlers.” We were there and assisted with the late, great Mayor Edward I. Koch in the early seventieswhen S.A.P.O. was first developed. The purpose of S.A.P.O. was and still is to help not­for­profit organizations and the like to raisemuch needed funds and was not to create a high end or chic event. We knew then that along with helping the not­for­profits, S.A.P.O.would also help the poor and jobless in New York to stay off public assistance or welfare and earn much needed money to supporttheir families. In those days the street vendors were mostly Italian Americans and Jewish Americans. In fact, Mayor Koch oftenproudly referred to his father as a shlepper. (Yiddish = a sales person who walked from house to house) Today street festivals areabout the not­for­profits, immigrants, women, people of color and African American Americans who deserve their chance at theAmerican dream. That’s all. SELF SERVING MEDDLER # 1 Who are these meddlers? Let’s start with Dan Garodnick who says streetfairs should be about local merchants and that people new to retail should apologize to him for not vending more chic & high­endproducts. Sorry Dan but all the vendors could not go to Dartmouth College like you and your rich friends did. Download to readmore……….Supporting Document:

 mor_2017.pdfAgency: SAPO

Comment:Thank you very much for the moratorium regarding the closing of Manhattan street fairs or of changing the fee structure. I hopethat you will extend the moratorium beyond 2017. These street fairs, as attested to by so many vendors and by the sponsorsproduce revenue necessary to all.Agency: SAPO

Comment:We continue to support present street fair moratorium rulings and oppose any SAPO rule changes. Thank you. Carol Schachterfor the 13th Precinct Community Council, GNA and SPNA (three community organizations).Agency: SAPO

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Mardi Gras Productions

225 Broadway, Suite 1202 New York, NY 10007

Tel: (212) 809-4900 Fax: (212) 809-7345

My name is Arthur J. Tisi. My Grandfather was issued the first permit to conduct a street festival in New York City in 1926. This was for the San Gennaro Festival.

In those days the Irish (God bless them) controlled the Catholic Church and would not allow the “WOPS” to display the statue of San Gennaro in a street procession and therefore refused to allow the statue of San Gennaro out of the church. My Grandfather told the clergy he understood and quickly put together a committee of Neapolitans who stole the statue of San Gennaro when the church closed. The rest is history.

My Grandfather knew that a street festival was not about church rules but would be an excellent way for the hard working poor immigrants in the community to earn money to feed their families while perfecting their talents.

So too today’s street fairs are about giving minorities, women, people of color and immigrants a venue to enter the retail world by utilizing their talents to support their families.

There are no problems with street festivals which financially support thousands of fair vendors and provide a day of free entertainment for New Yorkers and tourists alike. The only problem here is a handful of nay Sayers who only think of themselves.

We know our great Mayor will not be conned into destroying so many lives by these negative self-serving meddlers.

Was my Grandfather correct?

Because of street fairs in which my parents worked, I graduated Fordham University with a degree in Pharmacy and my late brother, Dr. G.M. Tisi was the Dean of the University of San Diego Medical School.

Let’s talk about “self-serving meddlers.”

We were there and assisted with the late, great Mayor Edward I. Koch in the early seventies when S.A.P.O. was first developed. The purpose of S.A.P.O. was and still is to help not-for-profit organizations and the like to raise much needed funds and was not to create a high end or chic event. We knew then that along with helping the not-for-profits, S.A.P.O. would also help the poor and jobless in New York to stay off public assistance or welfare and earn much needed money to support their families. In those days the street vendors were mostly Italian Americans and Jewish Americans. In fact, Mayor Koch often proudly referred to his father as a shlepper. (Yiddish = a sales person who walked from house to house)

Today street festivals are about the not-for-profits, immigrants, women, people of color and African American Americans who deserve their chance at the American dream. That’s all.

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SELF SERVING MEDDLER # 1

Who are these meddlers?

Let’s start with Dan Garodnick who says street fairs should be about local merchants and that people new to retail should apologize to him for not vending more chic & high-end products. Sorry Dan but all the vendors could not go to Dartmouth College like you and your rich friends did.

Local merchants 50% he says. Maybe if he bothered walking through his Congressional District he would see who the locals are: Staples, Citibank, Starbucks, Chase bank, Duane Read Pharmacy, Sprint cell phone stores, CVS and others who can afford the high rents.

Sorry Dan, no more local candy stores, all gone.

What exactly did 50% local merchants per festival or no permit really mean?

It means people of color, women and immigrants, all New Yorkers, stay out of Manhattan and work only in the outer boroughs where you live. Even though Manhattan is where the tourists are and retail sales are better, STAY OUT.

Did he forget that when he was campaigning to be elected, he and his father pitched a tent in 20 or more street festivals? They knew then that street festivals also “got out political messages.” Their tent was at all Second & Third Avenue Festivals including:

The Tilden Democrats Festival

17 Precinct Community Council Festival

Bellevue South Community Association Festival

Stuyvesant Park Neighborhood Association Festival

Turtle Bay Association Festival

13 Precinct Community Council Festival

Manhattan East Community Association Festival

Church of the Good Shepard Festival

Gustavus Adolphus Church Festival

All of these groups supported his election. As of today, some of these groups who lost their festivals because of his headline grabbing rhetoric, no longer exist. Thanks Dan.

SELF SERVING MEDDLER # 2

The non-elected head of the TIMES SQUARE ALLIANCE, Tim Tompkins, who feeds at the public trough and commands a salary of over $400,000.00 a year. Almost twice the amount our elected Mayor, a humanitarian genius, is paid. Lest we forget, Mr. Tomkins must be thanked for giving us costumed comic book characters who hit the Police, bare breasted ladies of questionable repute and The Hug Guy to mention a few. All of whom extort tourists for cash.

He accepts noncompetitive bid food vendors and lines the BID area with them. Not being satisfied with all this, he and his puppet, Wally Rubin, the District Manager of Community Board #5, claim the Broadway theaters are burdened by street festivals which cause traffic problems. Saying this, they promote and possibly authored the new rules prohibiting street festivals between 42nd and 50th Street, between 6th & 8th Avenue.

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This means nothing and traffic to a theater is not a problem since all side streets are open to traffic, providing easy access to theaters. The imaginary traffic problem is so severe that you can’t get a ticket for Hamilton for 10 years and the Broadway theaters are having their best year ever.

Just what does this false rhetoric mean?

It means this is my area, I own it, SO STAY OUT!

At a brief hallway meeting I had with Tim Tompkins at 100 Church Street on Oct. 13th. 2016, I tried my best to explain to him that if these “New Rules” passed, thousands of lives would be destroyed and how would he feel in 5 years knowing he was part of this treachery? But it fell on deaf ears.

Yes, I work for Mardi Gras Festival Productions and we resent the claims of Wally Rubin Community Board # 5 that “not-for-profits who make small amounts of money by sponsoring these fairs and the producers who make the bulk of the money.” We will produce upon request the number of festivals where Mardi Gras lost money or broke even. We continue to produce some of these events so that our vendor members and the not-for-profits could earn some desperately needed funds. We may be wrong, but we consider helping those in need to be good business.

We at Mardi Gras always knew that our great Mayor Bill de Blasio was not doing this. He said “it was not something that I initiated.”

He also was quoted as saying “the proposed changes were the work of others in the administration and were already going forward when I heard about them.” ...” honestly, this is not one of my priorities.” (NY Times Nov. 8, 2016)

That is why Mardi Gras has always encouraged our 2500 vendor members and their families to support Mayor de Blasio, who is one of the few in Government that has devoted his entire life to helping women, minorities, new citizens, people of color and African American Americans. Mardi Gras Productions, in addition to festival productions, it also is a membership organization counting 2500 vendors among its members.

Just where did these treacherous “NEW RULES” come from?

During a meeting at the office of Mardi Gras Productions on Sept. 23rd, 2016

with Mr. Emil Lissauer a Bloomberg administration appointee and former Director of SAPO, he confessed “I wrote these rules.” Did he write them at the behest of the Times Square Alliance? He continued to tell us “We were prevented from implementing these rules in 2015 by Corp. Council because they said they were Punitive.”

The above was verified during a phone call with Gabe Taussig an attorney at Corp. Council (now retired) who was assigned to advise SAPO.

When these rules were first proposed we noticed the following: after the City collects a permit fee for any special event or displays, on Broadway btw 41st and 47th Street. The Times Square Alliance Collects an additional concession fee as high as $28,000.00 a day.

(See exhibit A)

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Although all the Rules were not implemented, this was and special event organizers have been compelled to pay this fee.

We hope Mr. Tompkins understands Malcolm Gladwell’s Theory

“Bad things mount up, then suddenly, at a dramatic moment everything comes crashing down.”

We have given our opinion and understanding of why these NEW RULES are Treacherous.

Now you decide.

From: CLRATo: SAPOrulesSubject: NYC Street Fair RulesDate: Thursday, November 03, 2016 8:59:55 AM

To Whom It May Concern, Children’s Leukemia Research Association would like to thank all concerned for keeping thecurrent moratorium for NYC Street Fairs in place. We are a small Charitable Organization and these events are very important to us. We support Research to find cures for Leukemiaand provide Patient Aid to individuals with leukemia for their medical bills and prescriptionmedications. We hope these same rules continue for the future. We would also like to specifically thank Michael Carey for understanding all the community’sconcerns and leaving the rules as is. Aileen T. Sullivan Children's Leukemia Research Association Inc.244 Fifth Avenue, Suite 2969New York, NY 10001 Email: info@childrensleukemia.org

From: Lisa GomesTo: SAPOrulesSubject: SAPO"s New Proposed 2017 Moratorium & RulesDate: Thursday, November 03, 2016 12:25:09 PM

Dear Mr. Carey, Thanks you for identifying and understanding the Community Boards concernsand leaving the rules as is. Sincerely,Lisa GomesDistrict Manager, CB9Q718-286-2686  

From: John MuddTo: SAPOrulesSubject: Thank youDate: Thursday, December 01, 2016 10:51:05 PM

Dear Michael,

Thank you for continuing the tradition of our street fairs. It is a great helpto our community and the continuance of our quest for a better quality of lifein the midtown of Manhattan.

We're moving so many projects along to better our community.

We are certainly in support of keeping things operating as they have. It helpsso many independent vendors as it does us tremendous good.

Warm regards, a very merry holidays, and more!

John Mudd, PresidentMidtown South Community Councilwww.midtownsouthcc.org331 W 38TH Street #5NY NY 10018

917-520-3009 cell

"Never doubt that a small group of thoughtful, committed people can change theworld. Indeed, it is the only thing that ever has." - Margaret Mead

Comments by The Times Square Alliance to The Mayor’s Office of City Wide Event Coordination and Management

Street Activity Permit Office December 2, 2016

Thank you for allowing the Times Square Alliance the opportunity to comment on the Street Activity Permit Office (SAPO)’s proposed extension of the moratorium on street fair applications to 2017. We would like to thank Michael Paul Carey and the de Blasio Administration for beginning a dialogue to address longstanding concerns about the impact of street fairs on neighborhoods, while balancing the benefits to local non-profits, street fair vendors and other groups. We feel strongly that there is great value in continuing to examine ways to make the distribution of street fairs more equitable, data-driven and sensitive to neighborhood concerns, even though the initial proposals put forth by the administration were deemed not to be practicable. With respect to the current proposed rule changes, we support extending the existing moratorium. As we have stated before, we continue to believe that Times Square has a unique set of facts that necessitate a neighborhood-specific solution: Street fairs in Times Square create an excessive burden on an already overburdened neighborhood. Near-weekly street closures have caused extreme congestion, hurt local businesses and overwhelmed the area. The part of the City which is the busiest and among the most traffic-congested on weekends has more street fairs than any other. Times Square is already extremely dense and congested. The neighborhood represents just 0.1% of New York City’s total area, yet it has 21% of the city’s hotel rooms, 95% of the Broadway theaters, and a greater concentration of subway stations than any other neighborhood. An average of 480,000 pedestrians visit Times Square daily—this figure does not drastically fluctuate between weekdays and weekends. Unlike other business districts and much of Manhattan, Times Square is busier, not slower, on weekends. 54% of weekly Broadway attendance is crammed into the two days street fairs occur -- Saturday and Sunday. At the same time, multiple data sources indicate that weekend vehicular traffic in Times Square often exceeds weekday traffic, unlike other parts of Midtown. Despite the intensity of weekend activity, Times Square has a disproportionate number of street fairs. Community Board 5 has 30% of all Manhattan street fairs. Times Square is 11.8% of Community Board 5, but has 51% of CB5’s multi-block street fairs. Times Square represents one-tenth of one percent (.1%) of the city’s land area, yet has ten percent (10%) of all street fairs citywide. Making visitors to the city needlessly exasperated threatens thousands of jobs and millions in net new spending. The very people inconvenienced by street closures who come to NYC to visit Times Square’s hotels, theaters and restaurants on weekends brings net new dollars – and tens of thousands of jobs -- to NYC’s economy. Times Square’s actors, stagehands, musicians, hotel workers, and restaurant

employees all depend on Times Square’s thriving tourist economy supports 354,000 jobs and $5.5 billion in state and city tax revenues.

In light of the above facts, we feel two principles should guide the Administration in permitting street fairs. One is that every neighborhood and every community is different. The second is that objective data about vehicular and traffic congestion, as well as the distribution of fairs by neighborhood, should be used as a filter for deciding not so much if a given street fair should occur, but rather where it should occur. With respect to the first point, there should not be a "one size fits all” solution to this issue. In some areas of the city, street fairs are important economic drivers, drawing additional foot traffic and activating commercial centers. In Times Square, however, the excessive number of street fairs in an already excessively congested neighborhood at peak times exacerbates existing congestion and blocks access to local businesses and entertainment venues. In some instances, they can even create a safety hazard. New York City is a collection of diverse, unique communities; the characteristics that define our neighborhoods must be considered when drafting rules that govern the location and frequency of street fairs. With respect to the second point, data should drive decisions. CECM should use the Department of Transportation, the Taxi and Limousine Commission and land use and destination venue data to see which streets at which times have the greatest congestion and traffic pressures, even without street fairs. That should be put together with information about the relative number of fairs on those streets, compared to other streets and neighborhoods, to make decisions about whether or not to deny a particular location or time for a particular street fair. We strongly encourage the City to either use existing data or undertake an independent study to determine the impact of near-constant street fairs on the Times Square area, and to engage in a serious discussion with us and other stakeholders about comprehensive reform. The Alliance recognizes that street fairs play an important role in the fabric of New York City, that street fair vendors are a hard-working part of the city’s economy and that non-profit organizations often receive essential revenue from these events. In no way do we seek to prevent such organizations from raising funds through street fairs, or to limit vendors’ capacity to earn money from a multitude of fairs. Indeed, we know that many neighborhoods and fellow bids want more street fairs and we support them in that. However, we ask that the city also keep in mind the hundreds of thousands of New Yorkers employed in and because of times square when it considers the equitable distribution of street fairs. Thank you.