September 1, 2025 Letter Re Failure of SLA To Provide Method of Operation Data

Coalition of Musicians and Dancers to Eliminate Regulations Against Music and Dancing

September 1, 2025

The Honorable Brad Hoylman-Sigal
Legislative Office Building, Room 310
Albany, NY 12247
Email: hoylman@nysenate
The Honorable Deborah J. Glick
Legislative Office Building, Room 621
Albany, NY 12248
Email: GlickD@nyassembly.gov

The Honorable James Skoufis
New York State Senator
Chair, Senate Investigations & Government Operations Committee
Legislative Office Building, Room 612
188 State Street
Albany, NY 12247
Email: skoufis@nysenate.gov
The Honorable Al Stirpe
Chair, Assembly Committee on Economic Development, Job Creation, Commerce & Industry
Legislative Office Building, Room 847
Albany, NY 12248
Email: stirpea@nyassembly.gov
The Honorable Lily M. Fan
Chair and Commissioner
New York State Liquor Authority
Alfred E. Smith Building
80 S. Swan St, Suite 900
Albany, NY 12210
Email: press.office@sla.ny.gov
James Katz
Deputy Secretary for Economic Development & Workforce
NY Governor’s Office
State Capitol
Albany, NY
(Contact via Nicole Migliore)
Email: nicole.migliore@exec.ny.gov

Re: SLA Noncompliance with ABC §110-c — Method of Operation Data

Dear New York State Officials:

I am writing to call your attention to the New York State Liquor Authority’s (SLA) failure to comply with Alcoholic Beverage Control Law §110-c, enacted in 2019 and sponsored by Assembly Member Deborah Glick and Senator Brad Hoylman-Sigal. This statute requires SLA to make Method of Operation data, including stipulations, publicly available. For a short period, SLA complied, but in 2023–24 the Authority abruptly ceased providing Method of Operation information in its online database.

This omission has significantly undermined transparency and oversight. With SLA’s previously available Method of Operation data, we were able to document how many New York City establishments were prohibited from providing live music, DJs, and patron dancing. Without this data, policymakers and the public cannot evaluate SLA’s licensing practices, understand conditions imposed on licensees, or consider changes in the law to prevent SLA from continuing to prohibit live music and patron dancing.

I raised these concerns directly with SLA:

Dec. 7, 2024 — I wrote to SLA Chair Lily Fan urging restoration of Method of Operation data (see attached letter), with no response.
Mar. 1, 2025 — I submitted a FOIL request asking SLA to provide its license file including Method of Operation fields.
Aug. 29, 2025 — Despite reminders, SLA delayed until recently, when its FOIL office responded that it “hopes” to make the data publicly available by Dec. 19, 2025.

This response is unacceptable. SLA clearly retains Method of Operation data internally—otherwise it could not conduct its own license reviews. It is implausible that the Authority would need to manually examine 12,000 NYC licenses to recreate what previously existed in its database and in all likelihood still exists in an internal database. The requested information could easily be exported to a spreadsheet and released. Nor is there reason to believe SLA will meet its new December deadline. This is not an IT issue; it is a matter of transparency and statutory compliance.

Moreover, another FOIL request revealed that SLA’s internal Method of Operation records are disorganized and unsystematic. Approved Methods of Operation often appear only as handwritten notes on application forms. In response to FOIL, SLA was unable to produce complete files even for a few modification applications. There does not appear to be a standard form issued to licensees confirming their approved Method of Operation. This undermines both SLA’s operations and the Legislature’s explicit directive in §110-c.

I respectfully urge you, as an overseer of SLA, to press the Authority to:

  • Immediately restore Method of Operation data online, in compliance with §110-c.
  • Explain why Method of Operation fields were removed in 2023–24.
  • Clarify how SLA internally tracks Method of Operation terms for its licensees.
  • Justify why compliance is being delayed until December 2025 with a law enacted in 2019.

Thank you for your attention to this matter. Our coalition of musicians, dancers, and community members stands ready to provide further information or testimony as needed.

http://dance-music-regulation.com/wp-content/uploads/2025-09-01-Transparency-Letter-Final.pdf

2025-09-01-Transparency Letter Final
Filename: 2025-09-01-Transparency-Letter-Final.pdf