Public comments for: DOT Proposed Pedestrian Plaza Rules

Comments

Comment:
My name is Craig Buckley and I am the owner of Street Meet Promotions, an independently owned small business with an office in Times Square, which provides employment to 35 people. We are one of the agencies Broadway Producers and Theatres hire to promote their shows within Times Square. We provide branded street teams for such currently running shows as Beautiful, An American In Paris, Fun Home, The Phantom of the Opera and Wicked. Our teams do not handle any financial transactions, but instead distribute Broadway show flyers that direct over 4,000 people to theatre box offices and to TKTS. These Broadway shows depend on us distributing informational flyers on the sidewalks of Times Square in order to increase ticket sales. The loss of these ticket sales can be the difference between a Broadway production closing or staying open. Who we are and the service we provide differs greatly from the many costumed characters and others asking for tips. Restricting the areas where we can reach potential theatregoers will drastically impact our ability to promote Broadway shows and to direct people to TKTS. Placing a Phantom of the Opera or Wicked brand ambassador in a zone between two costumed characters will be highly ineffective. . I object to the inclusion of the word “solicitation” in the rules. If the City wants to avoid litigation, it needs to make sure that the bill doesn't infringe on constitutionally-protected free speech. This would be all the worse if the people litigating were the very people the city council is trying to protect - the business and visitor community of Times Square. The Supreme Court, held, in the 1990 case United States v. Kokinda, "Solicitation is a recognized form of speech protected by the First Amendment." The government cannot simply outright ban "solicitation" in any part of a public street or plaza, which is precisely what the current version of the bill says. This is just one more reason the city should remove the word "solicitation" from the bill especially as it relates to the public streets and sidewalks. This would still allow the employees of the businesses around Times Square to be able to inform tourists and visitors about their offerings, and the City would not be risking litigation with its own businesses. Thank you for your thoughtful consideration of the matter and request follow-up from the NYCDOT and City Council on this matter. Craig Buckley Founder/ CEO Street Meet Promotions 264 West 40th Street, Suite 505 New York, NY 10018
Agency: DOT
Comment:
Attached
Supporting Document:
Agency: DOT
Comment:
Attached
Supporting Document:
Agency: DOT