Public comments for: Amendment of Rules Governing Special Inspectors and Special Inspection Agencies

Comments

Comment:
NICET will no longer offer testing in Geotechnical Certification after December 31, 2017. Are there going to be other provisions for qualifications of for Supplemental Inspector-2 where the NICET certification is currently required?
Agency: DOB

Public comments for: Pet Shops Rule (New Chapter 5 in Title 24 of the RCNY)

Comments

Comment:
Please see attached letter of support from Best Friends Animal Society. Thank you, Elizabeth Oreck National Manager, Puppy Mill Initiatives
Agency: DOHMH
Comment:
Please see attachment comment from the Humane Society of the United States in support of the proposed rule.
Supporting Document:
Agency: DOHMH

Public comments for: Performance Summary Cards and Penalties for Child Care Programs Rule (New Chapter 3 in Title 24 of the RCNY)

Comments

Comment:
I am submitting a comment to Performance Summary Cards and Penalties for Child Care Programs Rule (24 RCNY Chapter 3): Proposed Section 3-04(a) Posting. Proposed Section 3-04(a) states: (a) Upon receipt of a performance summary card, a child care program shall post it in a conspicuous location within two feet of the front door or other main entrance to the site, between four and six feet above the ground or floor. The performance summary card shall not be defaced, marred, camouflaged, or hidden from public view, or posted in a manner that permits it to be damaged by exposure to weather. This language is too proscriptive and not necessarily achievable given the layout of building and program entrances. I would suggest the following type of language be substituted, similar to that found in New York State Department of Labor requirements for required workplace postings: (a) Upon receipt of a performance summary card, a child care program shall conspicuously post it on the program site in a location where the public can see and access it.
Agency: DOHMH
Comment:
The following are my comments regarding this proposal: 1. Who, what agencies or depts, will be giving the grade? 2. What criteria will be used? 3. How will it be communicated? 4. To whom will it be be communicated? 5. How often will the grade be evaluated? 6. How can a grade be upgraded? My biggest concern is that we are treating child care centers like restaurants. Unless the entire NYC public system adopts such a regulation (which I am certain they will NOT) then the notion of relegating day care and child care centers to receive a letter grade diminishes the multi-faceted purpose and services that we provide. There are already an enormous number of checks and balances and agency reviews for day cares. A letter grade moves closer to what we aim to eliminate - which is a competitive environment. We need to build collaboration and remove the stigma of yet another evaluation that ultimately will be subjective.
Agency: DOHMH

Public comments for: DOT Staten Island Container Truck Rule

Comments

Comment:
Please see attached letter of support.
Agency: DOT

Public comments for: Implementation of the Fair Workweek Law

Comments

Comment:
Comment located in supporting document.
Supporting Document:
Agency: DCA
Comment:
Comments from A Better Balance on Fair Work Week Regulations Attached word document.
Supporting Document:
Agency: DCA

Public comments for: West Chelsea Affordable Housing Fund Contribution Rate

Comments

Comment:
While I support the proposal to sell new air rights for contributions to the Affordable Housing Fund, there are three problems with the current proposed text. First, the price does not appear to be adjusted for inflation. Any proposal should, at a minimum, provide that the price should be annually adjusted by the standard means that the city uses to adjust for inflation. Second, $500 appears to be an arbitrary and low number. The City should value air rights based on a formula tied to the average price per square foot of land in West Chelsea. I would suggest valuing air rights at 40% of the mean price per square foot of residential space. In Chelsea, land is worth approximately $1800 per square foot according to Trulia. Based on the proposed formula, that would lead to a price of $720 per square foot for air rights. This would raise additional funds for affordable housing. Third, given that the goal of the sale mechanism is to raise funds for affordable housing, the City should sell air rights at a deeply discounted rate to buildings that provide more permanently affordable housing than is otherwise required. I would suggest the following formula: - For 121-165% AMI, 25% discount per square foot of permanent affordable housing - For 81-120% AMI, 50% discount per square foot of permanent affordable housing - For below 80% AMI, 100% discount per square foot of permanent affordable housing (i.e., free air rights for deeply affordable housing) Sincerely, Joseph M. Sanderson
Agency: DCP

Public comments for: Proposed Amendment to Reportable Deceases and Conditions and Laboratories (Articles 11 and 13 of the NYC Health Code)

Comments

Comment:
With respect to the proposed rule to require laboratories to report carbapenem-resistant Enterobacteriaceae (CRE), we would ask that the definition of CRE be unambiguous and that the rule clearly indicate which results are expected. This comment is offered in response to ambiguity that has been noted in some definitions provided by other agencies.
Agency: DOHMH

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