October 23, 2025

Dear Members,


New York City’s idling enforcement program is creating real challenges. Motorcoach companies are being fined even when keeping the engine running is necessary for passenger safety, comfort, or reliable operations. These penalties raise costs and make it harder to serve customers.


ABA has submitted formal comments in support of one of their members' application for a variance request to the New York Idling Enforcement Program. This request seeks reasonable flexibility in the enforcement process to better accommodate the operational realities of motorcoach service providers. Currently, the City’s strict and inconsistently applied idling enforcement framework poses significant challenges for motorcoach operators by penalizing essential vehicle functions needed for passenger comfort, safety, and service reliability.


A win here could set a precedent for fairer enforcement that benefits every company running into or through New York.


Please take a moment to submit comments before October 28th to help ensure fair idling enforcement for all operators serving New York City


Access the public comment portal here.


To assist with your submission, we recommend highlighting the following key points in your comments.


Suggested Talking Points:


Operational Considerations


  • The motorcoach industry supports responsible environmental practices and compliance with idling regulations.
  • The requested variance would ensure enforcement is balanced with the need for passenger safety, comfort, and operational efficiency.
  • Flexibility in idling enforcement helps maintain service reliability, especially during extreme weather, high passenger volumes, or heavy urban congestion.
  • Motorcoaches often operate under conditions—such as traffic delays, scheduled layovers, and passenger boarding—that require limited idling for safety and comfort.


Environmental and Technological Commitment


  • The motorcoach industry continues to invest in cleaner technologies, including newer engines and idle-reduction technologies.
  • The sector is one of the most fuel-efficient and low-emission modes of passenger transport, reducing overall carbon output by taking cars off the road.
  • A variance will allow operators time to implement emerging technologies while maintaining essential service levels.


Passenger and Public Benefits


  • Maintaining safe interior temperatures is critical for passengers, especially for seniors, children, or individuals with medical needs.
  • The variance supports the reliability of scheduled service, tourism operations, group travel, and charter markets vital to New York’s economy.
  • Balanced enforcement avoids disruptions that could impact accessibility, tourism, and community events.


Regulatory Partnership


  • The variance request promotes collaboration between regulators and operators to achieve shared environmental and public service goals.
  • Practical enforcement approaches build trust and compliance, ensuring rules are effective without being unnecessarily punitive.
  • Industry feedback ensures regulations are informed by on-the-ground operational realities.


Economic Impact


  • The motorcoach industry supports jobs, tourism, and regional connectivity — sectors that benefit from fair and consistent regulatory treatment.
  • Overly restrictive enforcement could increase costs, reduce service options, and negatively impact local economies dependent on group travel and tours.


Your participation is vital in demonstrating the collective voice and professionalism of our industry. Thank you for taking a few moments to share your thoughts.

Regards,


Member Services

memberservices@trailways.com

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