"It costs more to get a license to sell hot dogs on the streets of New York City and Washington D.C., than it does to obtain operating authority to own a motorcoach business that can travel the country."

You may have heard or seen that comparison before, as some in the motorcoach industry have used the colorful statement while trying to make a point about bus safety, suggesting it should be more costly for new operators to get into the business.

In other words, they imply or assert that if it cost more to obtain federal operating authority, safer bus companies would result.

Others in the industry, however, say the comparison is bogus, a non sequitur that perpetuates a myth that might not be the best solution for addressing industry safety issues.

The latest use of the comparison came from the American Bus Association, which highlighted the point in a Washington Times article about federal transportation regulators stepping up efforts to get unsafe carriers off the highways.

"Its too easy for people to get into the industry," ABA Communications Director Dan Ronan emphasized in the article, pointing out the fee comparisons between a hot dog stand and bus operating authority. "Its insane."

In Washington D.C., the fee comparison is correct. Hot dog street vendors there pay a little more than $400 for a license, which is $100 more than the $300 that a new bus operator pays to obtain operating authority from the U.S. Department of Transportation

But in New York City, its a bit different. The city charges $200 for a food-cart permit, which is $100 below the cost of what a new bus operator pays.

However, because the city limits the number of licenses to 3,100 and there are more than 2,000 applicants on a waiting list, current license holders have turned the permits into a hot black market commodity and are leasing them to other vendors for as much as $20,000 for two years.

The ABA and some others in the motorcoach industry also suggest that raising the new-entrant fee for motorcoach companies might discourage noncompliant operators from obtaining multiple USDOT numbers, which they keep handy so they can quickly re-open under a new name if they are shut down by federal regulators for safety violations.

"Some of them have five or six numbers and if they had to pay a higher fee then they might not have as many," said Ronan. "A little more of an entry fee would pinch them in the pocket."

The Federal Motor Carrier Safety Administration views the reincarnation of bad bus companies as a critical safety issue and has aggressively chased down carriers that have resurfaced with new names and USDOT numbers after being ordered out of service because of safety violations.

While the hot dog cart vs. motorcoach company analogy might seem like a spicy analogy to bus travelers, the United Motorcoach Association says it is not one that should be used in the campaign to make the industry safer.

One reason, according to the trade group, is because it is not accurate for New York, which is the city cited most often by those who use the comparison as an argument for higher new-entrant fees, and where vendor charges are skewed by the black market activity.

"Clearly it is not so in New York City," said Ken Presley, UMA vice president and chief operating officer, noting that the selling of vendor permits there reminds him of the days before motorcoach deregulation when bus operators had to pay competitors for the privilege of driving over their routes or passing through their states.

More importantly, though, he said raising the new-entrant fee could drive new operators underground, which was a major problem in the 1980s and is certainly not needed in the industry today.

"We believe the more practical approach is to tie the authorization to operate to an individual, not a company," he said. "There are many professional licenses that use that approach -- as it reduces the likelihood of duplicate authority."

He said UMA also believes start-up carriers should not have to invest their often precious capital with the federal government for operating authority. Rather, it should go into their companies.

"No matter how you look at it, a high entrance fee that discourages entry is economic regulation at its worst," he suggested.

Presley contends, too, that raising the new-entrant fee could be used more as an impediment to entry than anything that resembles a solution, and probably would see a court challenge if adopted.