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-Caveat Lector-

The following was just sent to all NYC Councilmembers and NY State
legislators

2/9/04
Dear Councilmember,

There are now four new proposed laws aimed at NYC vendors, all of which you
will soon be asked to vote on. You'll hear from the Mayor, DCA Commissioner
Dykstra, Parks Commissioner Benepe and the BIDs about the "urgent" need for
them.

Here's a very different perspective on these proposed laws from someone who
has spent 41 years as a NYC vendor and won four Federal lawsuits in regard
to free speech on public property.

These proposed laws are:
A.  Intro # 48 (formerly known as Intro # 160) now before the Parks
Committee, authorizing the Parks Commissioner to impose a permit system on
First Amendment-protected artists and written matter vendors;

B. Intro # 104 before the Sanitation Committee which allows the police to
issue vendors summonses for any nearby litter, including litter that did not
come from their stand;

C. Intro # 109 before the Consumer Affairs Committees which severely
increases the existing penalties for vending; and

D. A proposed bill before the NY State legislature A09054 concerning
disabled veteran vendors and First Amendment-protected vendors in Midtown
and around the WTC area. According to our sources in Albany this State law
will direct the City to create arbitrary vendor-free zones around various
areas of NYC, including most of Midtown, and to create a completely new
regulatory system on the street for First Amendment-protected vendors which
will involve a lottery, assigned spaces, an arbitrary numerical limit and/or
a permit.

What's Behind The Anti-Vending Agenda

I will comment on these proposed laws separately below alongside the text of
each, but first, here's the supposed rational for these laws as described by
those who have proposed them.

You are being asked to believe that due to the rulings in the street artist
lawsuits and the expiration of the disabled veteran vendor law restricting
certain streets in Midtown, that the City of NY no longer has ANY ability to
regulate vending or to regulate any vendors. You are also being asked to
believe that vending by street artists and disabled veteran vendors has
become a serious threat to public safety; that the already severe penalties
for vending are somehow too mild; that NYC Parks are overrun with street
artists whose vending activities are not consistent with the proper use of
Parks and that the Parks Department has no ability whatsoever to regulate
street artists without resorting to a permit system.

I respect the Mayor, his commissioners and the BIDs right to express their
own opinions about vending, opinions which are obviously quite different
from mine. What I can't support is City Council members and NY State
legislators being asked to vote for laws based on outright deception and
fraud.

Recently the NY City Council voted to oppose the Patriot Act and many
Councilmembers have made their opposition to the war in Iraq well-known.
Allow me to draw a parallel between these national issues and our local
issue.

The justifications being offered for these new vending laws are very like
the justifications President Bush offered for the war in Iraq. An
exaggerated threat is being created for the purpose of rushing you to vote
for laws you would not otherwise be inclined to support.

These justifications are knowingly false, culturally and racially biased and
they are motivated by a corporate agenda which itself is far more of a
threat to public safety than anything even the most imaginative critic of
ours would claim to be caused by vendors. Like the war in Iraq and the
Patriot Act, once one understands what those pushing you to pass these new
laws really have in mind, it's impossible to see them as anything but a
cynical exercise in privatization and a blatant attempt to violate the
Constitutional protections of this State and this nation.

Shortly you will find yourself in a similar position to that which the US
Congress found itself when they were asked to vote in the dark for a Patriot
Act which strips Americans of their rights then asked to authorize a war
that is both needless and damaging to the genuine interests of the American
public. In hindsight many of these US legislators have expressed serious
misgivings. The War on Vendors is a similarly misguided effort, designed not
to protect the public but to benefit the wealthiest corporate interests.

The Big Lie Exposed

The most blatantly false aspect of this anti-vendor propaganda is the notion
that the City has no ability to regulate vending due to the rulings in the
street artist lawsuits and the expiration of the disabled veteran vendor
street restrictions.

Here's an excerpt from a typical example of this anti-vendor propaganda, out
of more than forty such that have recently appeared in the NY media:

NY Post 12/31/03 NYERS GET FED UP WITH HAWKER CLOG
"When the law expired and state lawmakers were unable to reach a deal to
renew it, the floodgates were opened, vendor chaos was born, and pretty much
anyone interested in selling on a city street could...BID President Tim
Tompkins said, "Having this many vendors, totally unregulated, is not only
unsafe but it also contributes to a sense of disorder." He said the NYPD
doesn't "have the legal tools to do anything about it."
"Pandemonium" is how Police Commissioner Ray Kelly described the street
vending situation. "We are evoking our emergency powers" when the streets
become too congested, he said. And, he added, "Obviously, we need the state
to pass a new law."

 Aside from scores of newspaper articles and editorials making this absurd
claim about the City being unable to regulate vendors, it has been
repeatedly made by the Mayor, the BIDs, Commissioner Benepe and Commissioner
Dykstra at various Council hearings and in the press. Is there even a shred
of truth to it?

In reality, the NYPD Commissioner has issued internal directives to all
police precincts ordering police officers NOT to enforce the existing and
still valid size and placement vending restrictions, based on the
knowingly-false concept that the expiration of midtown street restrictions
on disabled veteran vendors means that NO vending laws can be enforced
against them or any other vendors. [See Operations Order #33 issued on
7/15/03]
 Optically scanned excerpt:

"1. On February 28th, 2003, FINEST Message Serial # 018236 was published
 to inform members of the service that on March 1St Section 35-a of the
New York State General Business Law would expire. This section of law
regulated the activities of Disabled Veteran Vendors. The State
Legislature recently adjourned its legislative session without
renewing the above section of law.

2.   Therefore, members of the service are reminded NOT to enforce
the provisions of the above section of law or the provisions of
Section 20-465 of the New York City Administrative Code
relating to the size and placement of general vendors' displays
or any of the restricted street provisions against Disabled
Veteran Vendors."  END QUOTE

However, this very same NYPD directive then goes on to list numerous
circumstances that allow the police to summons, confiscate and arrest
disabled vets, artists and all other types of vendors, and even to clear
entire blocks where vending is perfectly legal DESPITE the disabled veteran
vendor law expiring. In other words directly confirming that the City still
has numerous means at its disposal to regulate vending and to deal with
congestion without a single new law being passed.

Let me state for the record that I do not blame Commissioner Kelly or the
NYPD legal division for misleading the media and the City Council about this
issue. Like the CIA intelligence analysts, Secretary Powell and other Bush
administration officials who were apparently pressured to falsify data,
these are good soldiers obeying their orders. In NYC those orders come from
the Mayor and the Business Improvement Districts or BIDs.

BIDs are corporate interests which as you surely know have a very incestuous
relationship with the NYPD. BIDs are where many high-ranking NYPD officials
go to work after they retire and some BIDs, such as the Alliance for
Downtown NY BID, actually provide the NYPD with precinct houses, vehicles
and other equipment as well as employing them as security guards when they
are off-duty.  It's hardly surprising that police officials feel pressured
to do the BIDs anti-vendor dirty work.

Contrary to these obviously false claims about there being no enforceable
vending rules, neither the Kaswan decision concerning disabled veteran
vendors nor the various Federal rulings concerning street artists [Bery et
al v City of NY /Lederman et al v City of NY; Lederman et al v Giuliani /
Bach et al v City of NY] ever suggested that the City could not continue to
enforce most of the Vending Ordinance's 60 pages of existing time, place and
manner vending regulations against such vendors in Parks and on the streets.
All the disabled veteran vending law expiring in 2003 actually meant was
that disabled veteran vendors could now vend (exactly as the original Civil
War era law stated) on any street, including those midtown streets the BIDs
had pressured Mayor Giuliani to arbitrarily restrict.

After the law expired, disabled war veteran vendors have remained subject to
all other existing laws about the time, place and manner of their vending
activity. In reality, they are frequently summonsed or arrested for
violating these vending restrictions, a fact which City officials and the
media have conveniently hidden from the public but which is known firsthand
to every NYC vendor. Likewise, street artists and written matter vendors
remain subject to numerous restrictions on the size and placement of their
displays on City streets and in Parks and are routinely summonsed,
confiscated or arrested if they violate them.

Additionally, the rulings in our lawsuits specifically stated that the Parks
Department retains its right to impose any new rules it needs about size and
placement of art vending displays, so long as it does not impose a permit
and/or lottery system. All our rulings mean is that we are fully protected
by the First Amendment and cannot be subject to a license or a permit.

Why the Need For Deception in The War Against Vendors?

You might ask, why are BIDs and some City officials falsifying the real
vending situation, going so far as to direct the police not to enforce the
existing vending laws? Their idea is to make the vending situation seem as
chaotic as possible in order to stir up City Councilmembers and the public
against vendors. This, they hope, will pressure you to blindly vote in favor
of these proposed new laws.

An analogy to this would be a police directive ordering officers not to
enforce the existing laws against prostitution, drunken driving or drug
dealing so as to agitate the public against these activities and prepare the
way for drastic legislation that might not otherwise seem acceptable.

Exactly as in the Iraq analogy, corporate interests in NYC exemplified by
the BIDS are the hidden force behind this misguided War on Vendors.
Ironically, in some instances the exact same corporate interests are pulling
the strings behind both issues. In Iraq, seizing control of the oil is the
motivation while here in NYC these interests have a very clear agenda aimed
at seizing control of the City's public streets and Parks so as to use them
to advance their own financial, political and media interests.

Can We Prove They Are Lying about Vending?

The real question should be, how can anyone miss it? One has only to compare
the Parks Commissioner's many statements in which he claims that a handful
of street artists are "commercializing" Central Park to his daily actions,
in which he aggressively and very publicly seeks out corporate interests to
take over entire parks for fashion shows, food promotions, fast food
restaurants, sneaker companies promotions, bars, movie premieres, film
shootings and corporate ads of every imaginable variety [See: Newsday
1/22/03 Putting Burgers Before Art Parks Commissioner Wants Artists Out, Fas
t Food In]. On a weekly basis the Parks Department puts ads in newspapers
and sends out email announcements soliciting corporate vendors to submit
bids to set up new Park vending concessions all over the City. If
Commissioner Benepe thinks street artists are incompatible with the intended
use of Parks can he explain promoting hundreds of such absurdly
Park-incompatible events as a Boloney Festival, a Wendys and a bar built
right alongside a playground?

Mayor Bloomberg is the real sponsor of intro # 48. If he thinks there are
too many street artists taking up too much space in Central Park, can he
explain his own media company and the Central Park Conservancy (a group he
is a very prominent member of) arranging for hundreds of giant works of art
to be set up throughout the exact same Park - at the exact same time he is
proposing this bill? [SEE: NY Times 1/29/04 "The Whitney Biennial Will Be
Playing in the Park" Quote: "There will be art from one end of Central Park
to the other, including grotesque sculptures of werewolf heads, a ferocious
life-size tiger, a bronze bust of Michael Jackson and a 50-foot-tall
inflatable pink rubber ketchup bottle topped with a snowmanlike head."]

 The answer is that this is all elite corporate-sponsored art, in some
instances by artists such as Christo and Jeanne Claude whose works our
billionaire Mayor collects. The Mayor and the Central Park Conservancy
(financed in large part by JC Morgan Chase Bank) think it's reasonable to
allow a twenty three mile long art display for Christo, then eliminate
street artists from the same Park via Intro # 48.

I note here for the record that Christo and Jeanne Claude have written to
their good friend and patron the Mayor and publicly opposed his attempts to
impose a permit on NYC street artists [See Village Voice 3/12/03 Christo
Challenges Bloomberg on Art in the Parks; Closing 'The Gates' to Intro
#160]. Are we to accept as plausible that the Mayor and the Central Park
Conservancy sincerely believe a 23 mile construction of banners, a giant
statue of accused child molester Michael Jackson, a huge Ketchup bottle and
a huge arrangement of "werewolf heads" among other gigantic constructions
are a good use for Central Park, but a few 6 foot art displays by the
members of ARTIST are not?

This is corporate-sponsored elitism on an almost comical level. It is also
censorship, with government officials and their corporate pals choosing
which forms of expression, which artists and which works of art they will
allow to be shown on public property. For an example you might find even
closer to home, take a look at the bizarre giant sculptures that the Mayor,
and JP MorganChase bank have been installing inside City Hall Park, a park
where political artists such as myself were repeatedly arrested for daring
to sell so much as a 4 X 6 inch political postcard criticizing JP
MorganChase Bank's connection to Mayor Giuliani.

Please don't misconstrue my meaning here; I am not opposed to controversial
works being shown in Parks or to the artists showing them, only to the City
picking and choosing which artists have access to public property.

Public Safety is A Cover Story

This pattern of deception about the vending issue is remarkably consistent
because it's all part of one well-orchestrated plan by the BIDs and similar
groups such as the Central Park Conservancy, which both runs and financially
profits from all the vending concessions in Central Park. On the sidewalks,
you are being asked to believe that a moderate increase in the number of
vendors in Midtown (which the Times Sq. BID itself has admitted is only a
slight increase) justifies a ban or drastic limitation on all vendors in
Midtown.

[NY Times 12/2/03 At Crossroads of World, Gridlock on the Sidewalks
"The Times Square improvement district has surveyed vendors three times
since the law lapsed. It found 208 vendors on the Times Square sidewalks on
Oct. 15 - 66 more than were there on April 23."] Is that the "emergency"
justifying these drastic new restrictions on disabled veterans and free
speech, an additional 66 vendors in a 40 block area that routinely holds
millions of tourists? Can you blame me for saying these people have a
sinister and deceptive agenda?

You are being asked to accept that these proposed laws are intended to
protect public safety - but is there the slightest shred of evidence to back
this up? The real issue here is that the BIDs want to use the exact same
space vendors are in for advertising - and that advertising is itself the
real threat to public safety.

Compare the safety rational for the proposed vendor ban to the fact that the
Times Sq. BID has recently installed 400 four-sided ad-covered trash cans in
the same area, all of which are bolted to the sidewalk near crosswalks. On
these garbage can ad kiosks they are charging $500 a month for each ad
[Daily News 12/2/03 City Trashes Sponsors - For A Fee "A single panel on a
four-sided Times Square bin is already fetching $500 per month, Cranston
added...Some 400 large, square trash cans were installed there over the
summer, and 80% of the cans have been sold to advertisers by the Times
Square Business Improvement District. The ads are due to appear next
 month."] This money goes to the BID not the City.

Soon, every BID in the City will follow suit. There are 40 or so BIDs.
Multiply that times 400 and you will have a mere 16,000 of these new
BID-owned trash can ad-kiosk obstructions sprouting up near every crosswalk
in NYC.

Need one mention the thousands of knee-high concrete planters the BIDs have
(in most cases illegally) installed in the exact locations where vending is
legal so as to displace vendors? Can we have a statistic for how many
thousands of pedestrians have been injured bumping into them? Some blocks
within the Midtown BIDs have a planter every two or three feet. Now these
same BIDs are applying for permits to install thousands of concrete
"security" boxes, also aimed for the most part at displacing vendors. Can
any City official explain how a temporary vendor causes congestion but a
permanently installed forest of concrete planters with BID logos do not?

The Media Is The Message

You've likely seen many of the 40 or so recent mainstream news stories and
lead editorials hysterically declaring this to be a City under siege from
street artists and disabled veteran vendors. Might the handful of media
conglomerates that now control virtually all news reporting have an agenda
in this as well?

Compare this proposed ban on vendors to Mayor Bloomberg's misguided Street
Furniture Initiative in which 3,000 very large ad-covered sidewalk kiosks
disguised as bus shelters, pay toilets and benches will be set up on the
exact same spots where vendors now legally sell their wares. These digital
ad kiosks, which the Council was tricked into voting for under the deception
that the initiative was about 20 pay toilets, will damage business for
stores by distracting customers from looking in their windows, obstruct the
sidewalks 24 hours a day seven days a week and will get in the way of
emergency responders whenever there is a fire, an injury or anything else
they must react to. These kiosks cannot be moved in an emergency  - short of
using heavy equipment to rip them out of the street. Need one mention the
effect on pedestrians of these 3,000 permanently-installed new sidewalk
obstructions displaying disorienting lights, video and audio advertising to
pedestrians and drivers? Just imagine how many car accidents will result
from drivers watching these ads.

According to industry press releases, it appears this Street Furniture will
also house cell phone transmitters and repeaters, which many scientists and
health advocacy groups worldwide consider a likely source of cancer-causing
radiation. So far, not even the most rabidly anti-vendor organization has
gotten around to claiming vendors cause cancer.

Clearly, there is an agenda here in which public safety, like weapons of
mass destruction, nation building and encouraging so-called democracy, is
merely the cover story. Media conglomerates, many of which started the BIDs
or sit on their boards of directors, are trying to displace vendors with
advertising on public property. To accomplish this they want to take away
not only vendors rights but the free speech rights of the entire public. As
City officials sworn to protect the interests of all New Yorkers and to
uphold the Constitutions of both NY State and the US, you cannot responsibly
ignore these facts.

Unlike the BIDs, we seek no exclusive right to this property, only that it
continue to be kept accessible for every New Yorkers' speech, association
and reasonable commerce as ordered by various Federal and State courts and
by both the NY State and US Constitutions.

Corporate interests surely have more than enough venues in which to
advertise and promote their mind-numbing propaganda messages on private
property and on the publicly-owned airwaves without them seizing the last
remaining public spaces in NYC for their exclusive private use.

If anything, Midtown, Times Square and SoHo are already inundated with a
virtual orgy of advertising, and now Commissioner Benepe has stated that he
wants to bring this same proliferation of advertising right into our public
parks. Mayor Bloomberg has even brought this commercial advertising into all
the public schools via his controversial deal with Snapple - and now he
wants it in every NYC hospital.

[See: NY Post 2/8/04 City Hospitals Get in Bed With Advertisers "As if New
Yorkers weren't bombarded with enough ads on subways, buses, bus stops,
billboards, garbage cans, television and phone booths, now they're getting
hit at hospitals. Beginning this summer, in what the city calls a first in
the nation, 20 public hospitals will be festooned with 2,500 indoor
electronic ad banners and an unspecified number of outdoor advertising
kiosks."]

We're not against the free speech rights of these corporate interests.
Unfortunately, they are apparently very much against and very envious of
ours.

We are asking you for a fair and reasonable balance; to defend First
Amendment-protected street artists and disabled war veterans instead of
one-sidedly favoring the interests of BIDs and of these corporations, most
notable among them the notorious right wing conglomerate, Clear Channel
Communications, which is poised to get the lucrative Street Furniture
Initiative contract. We are asking you to defend the interests of the vast
majority of your constituency, who will lose their own rights on public
property simultaneously with these bills passing. We are asking you to do
the right thing and vote no on all of these proposed new vending
restrictions.

Robert Lederman, President of A.R.T.I.S.T.
(Artists' Response To Illegal State Tactics)
[EMAIL PROTECTED]

[ARTIST has a large archive of newspaper articles about the Parks
Department, The Street Furniture Initiative and vending proving these
allegations. The rulings from our lawsuits are available at in the links
section and in the archives of our website
http://groups.yahoo.com/group/NYCStreetArtists/  as are hundreds of news
articles on vending. ]

>From the City Council website
http://www.council.nyc.ny.us/

Intro # 0048 (See the address below for the entire text)
http://www.council.nyc.ny.us/textfiles/Int%200048-2004.htm
Int. No. 48
[IMPORTANT NOTE: Because of the history of vending law in NYC "vending of
written matter" always means books, newspapers, art, sculpture, paintings,
photos etc...anything protected by the First Amendment]

By Council Member Foster (by request of the Mayor)

..Title

A Local Law to amend the administrative code of the city of New York, in
order to clarify the express authority of the commissioner of parks and
recreation to regulate the vending of written matter within the geographical
areas under the jurisdiction of parks and recreation.

..Body

Be it enacted by the Council as follows:

Section 1.         Declaration of legislative findings and intent.  The
Council finds and declares that the vending of written matter should be free
of unnecessary restrictions as long as such activity is not a threat to the
public health, safety or welfare.  The Council also finds that geographical
areas under the jurisdiction of the department of parks and recreation are
integral in preserving the welfare of the public.  As such, the commissioner
of parks and recreation has the responsibility of balancing the interest of
the public to enjoy the resources of parks with the rights of the vendors of
written matter.  Permitting unbridled and unregulated vending of written
matter in parks seriously undermines the ability of the commissioner of
parks and recreation to provide public recreational activity and to preserve
the character of parks for the benefit of the public.  Moreover, parks and
parks facilities should not be overrun with commercial activity.  The
Council further finds that there is a specific need for reasonable measures
to regulate the time, place and manner for the vending of written materials
in parks consistent with the First Amendment.  Accordingly, the commissioner
of parks and recreation shall be authorized to regulate, through a
permitting system, the vending of written matter in areas under the
commissioner's jurisdiction.

--------Sanitation Committee Intro # 104----------

[NOTE on Intro # 104 - This law is an open invitation for harassment.
There's no way any vendor in NYC can stop litter from ending up in front of
their display, even if they clean the area every few minutes. The wind will
blow new litter there continuously. Stores already get tens of thousands of
these unfair summonses for litter that has no relation to their business
activity. The penalties for vending summonses double each time you get one.
A $25 fine becomes $50, then $100, then $200 and so on. The police could
give a vendor a sanitation summons every day and put them out of business in
no time. I have no problem with requiring vendors to clean up their own
garbage and most already do so in the interests of making their stand
presentable, but that's not what this is about. "General vendors" in this
context means all vendors including artists and disabled vets. ]

Intro # 104
Vendors to keep the area free from litter.
A Local Law to amend the administrative code of the
city of New York, in relation to requiring food
vendors and general vendors to keep the area in which
they vend free from litter.
------------------------------

----------INTRO # 109 Consumer Affairs Committee--------
[Note on Intro # 109 - Are the penalties for vending too lax, as
Commissioner Dykstra has testified before the Consumer Affairs Committee?
So-called illegal vendors as well as any other vendors who get arrested are
already subject to confiscation, arrest, a $1,000 fine and imprisonment for
up to a year. What's lax about that? Contrary to the claims of Commissioner
Dykstra and the Mayor's Criminal Justice Coordinator, Mr. Feinblatt, every
single vendor who is arrested is already photographed, ink fingerprinted and
in most cases, also digitally fingerprinted as well. If they go through the
system, as I have, they are also digitally face scanned. None of these
records are ever discarded or truly sealed, contrary to popular myth.

What this bill proposes is vague and is likely to be an opening to even
further penalties, but we can surmise what it's sponsors really have in
mind. Last year Commissioner Dykstra and Mr. Feinblatt were advocating a
plan in which three misdemeanor convictions for vending violations would
become an automatic felony with a mandatory year in prison. The judge would
then be forced to give a convicted vendor this sentence even if they think
it is completely unwarranted. Once there is a permit system in Parks and on
the street (Intro # 48 and the new proposed disabled veteran vendor and
street artist restrictions) any legal vendor who violates those laws will
then also be subject to this new law, Intro # 109. In other words, artists
and vets who violate these new laws will be considered illegal vendors.
Please note that Commissioner Dykstra is the former head of the Times Sq BID
and that Mr. Feinblatt ran the BIDs 54th Street Community Court for many
years. That court assigns vendors to work for the very BIDs that had them
arrested. ]

Intro # 109
Increasing penalties for illegal general vendors and
food vendors.
A Local Law to amend the administrative code of the
city of New York, in relation to increasing penalties
for illegal general vendors and food vendors.

Please address your comments or questions to:
Robert Lederman, President of A.R.T.I.S.T.
(Artists' Response To Illegal State Tactics)
[EMAIL PROTECTED]

Street artist information
http://groups.yahoo.com/group/NYCStreetArtists/
http://www.openair.org/alerts/artist/nyc.html



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