Metropolitican Taxicab Bd. of Trade v. New York City Taxi & Limousine Comm. (Motion for leave granted on Dec. 14, 2010) 71 A.D.3d 508 (1st Dep’t 2010)

Although this appeal addresses the New York City Taxi & Limousine Commission’s authority to amend its rules, the resolution of the appeal might have a broader impact regarding amendments to administrative regulations and the interpretation of the promulgating statutes.  In this appeal, the TLC amended its rules to provide that the statutory cap imposed on the amount charged by taxicab fleet owners when leasing vehicles to taxi drivers.  The First Department noted that the TLC is vested with a broad grant of authority to promulgate and implement a regulatory program for the taxicab industry, including standards and conditions for service, safety, design, comfort, convenience, noise and air pollution control, and efficiency in the operation of vehicles.

The Court held that the TLC was authorized to amend its rules on the issue under the broad grant of authority promulgated to it.  The TLC amended its rules establishing the amount of vehicle lease caps by raising the lease amount for hybrid and fuel efficient vehicles and lowering the lease amount for non-fuel efficient vehicles.  The Court also concluded that the amendments are rationally related to the legitimate governmental goals of providing incentives for fleet owners to purchase fuel efficient vehicles that are designed to reduce harmful emissions, and to require fleet owners to bear some of the additional fuel costs associated with the operation of non-fuel efficient vehicles.