New York City’s proposed changes to idling penalties and enforcement could have significant consequences for private motorcoach operators and the passengers they serve. In written testimony prepared for the New York City Council’s October 20, 2026, hearing before the Committee on Environmental Protection and Waterfronts, Transportation Advisors CEO Thomas Holden outlines concerns about higher penalties while supporting reforms that would make enforcement more timely and accountable.
Holden’s perspective comes from his work developing and auditing transportation safety, maintenance and driver-qualification programs. His testimony asks lawmakers to consider how idling enforcement intersects with the daily responsibilities of safely operating a passenger motorcoach, from maintaining air-brake pressure to accommodating passengers who use wheelchair lifts and protecting people during extreme temperatures.
“This industry does not defend unnecessary idling, and I have written the policies that tell drivers to shut down,” Holden states in his testimony.
Higher penalties and exposure across a fleet
Proposed Int. 11-A would increase the maximum civil penalty for an idling violation from $2,000 to $7,500, a 275 percent increase. It would also establish escalating penalty ranges for repeat violations within three years. Those violations would be counted against the same respondent even when different vehicles were involved.
Holden opposes applying the increase to private motorcoaches. He argues that counting violations across an entire company’s fleet could expose operators to higher penalty tiers without adequately distinguishing between individual vehicles or circumstances. His recommendation is to exclude private motorcoaches from the proposed increase or, at minimum, apply the escalation by vehicle rather than by company.
Support for enforcement reforms, with practical amendments
Holden supports several provisions in Proposed Int. 561-A, including replacing percentage-based complainant awards with flat payments, limiting duplicate notices involving the same vehicle within 60 minutes, and establishing standards of conduct for complainants. The proposal would also require DEP to issue a notice within 60 days of receiving a citizen complaint, while retaining a separate process through which complainants may pursue cases.
His concerns center on whether motorcoach operators could realistically qualify for the bill’s proposed $50 reduced penalty. The qualifying remedies involve installing a battery-powered auxiliary power unit or replacing or converting the vehicle to an all-electric vehicle. Holden argues that these options do not adequately account for the equipment, passenger-compartment demands and operating patterns of over-the-road motorcoaches. He proposes an additional qualifying option recognizing a 2010-or-later EPA-certified engine with properly functioning emissions controls.
The testimony also requests clear protections for necessary engine operation associated with safety inspections, air-brake systems, accessibility equipment, passenger and baggage handling, and maintaining safe cabin temperatures in extreme weather. These are proposed changes intended to give operators clearer, workable standards.
Responsibility for leased vehicles
Holden also supports Int. 562, which would establish a program allowing vehicle lessors to transfer liability for certain idling violations to lessees. His position is that responsibility should follow the party operating the vehicle, with notice and an opportunity to be heard.
Across these proposals, Holden urges the Council to consider passenger safety, operators’ investments in cleaner equipment and the practical requirements of providing group transportation. His testimony offers specific amendments intended to support fair enforcement while preserving safe, reliable motorcoach service.
Read Tom Holden’s full written testimony: CLICK HERE
For questions about the testimony or Transportation Advisors’ safety and compliance services, contact Tom Holden at Tom@TheAdvisors.org
