Public comments for: Amendment to Impose a One-Year Moratorium on New Events

Comments

Comment:
The proposed amendment of 50 RCNY 1-05(d) will not only mandate denial in 2015 of applications for street activity permits for street activities not held in 2014, but will actually mandate denial in 2015 of applications for street activity permits for street activities not held in 2013, since the proposed amendment does not relax any provision in the rule as currently amended. Therefore, the proposed amendment is a patently oppressive, tyrannical, and un-American affront to the planning of new or revived neighborhood events that are intended to be safe, peaceful. entertaining, and educational--unless street activity permits were approved for same before 2013. again in 2013, and again in 2014. The proposed amendment unnecessarily curbs the vast authority to approve, deny, and otherwise control the statuses of street activity permits that is already explicitly vested in the Street Activity Permit Office ("SAPO") by 50 RCNY 1-05(a) through 1-05(c) and 1-05(e). Moreover, the "Statement of Basis and Purpose of Proposed Rule" states, in pertinent part, "...the New York City Police Department has requested that SAPO exercise its discretion temporarily to deny permits for additional events scheduled for calendar year 2015." That discretion already exists under the current rules. The "Statement of Basis and Purpose of Proposed Rule" states further, "The proposed rules will authorize SAPO to deny permits to these events only if the event was not held in calendar year 2014 (sic)." That representation is just mendacious mumbo-jumbo, given that the proposed amendment does not authorize SAPO to exercise its discretion, as evidently requested by the New York City Police Department, but gives SAPO no choice but to deny automatically in 2015 applications for street activity permits for street activities not held in 2014. Hence, the proposed amendment of 50 RCNY 1-05(d) and its presentation to the public are but costly exercises in regulatory superfluity and should be withdrawn.
Agency: SAPO