Testimony submitted to the NYC Taxi and Limousine Commission September 27, 2018 by Kate Slevin, Senior Vice President for State Programs and Advocacy

Thank you for the opportunity to submit comments on proposed rules regarding driver income and vehicle lease transparency. Regional Plan Association has the following comments on the proposal.

RPA supported many of the provisions in Intro 890-B and Intro 144-B which were signed into law by Mayor de Blasio in August 2018. Intro 890-B reiterates the Agency’s authority to establish a driver pay floor and Intro 144-B provides the same support for the Taxi and Limousine Commission’s (TLC) authority to require the provision of certain data from for-hire vehicle (FHV) service providers.

As we note in our testimony on the legislation, we support the overall goals of the rules to establish a baseline pay for drivers and to require for-hire companies to share data that will help the city better manage congestion on city streets. We applaud the City Council and TLC for taking these steps, and believe the City’s ability to better track so-called utilization rates of vehicles, so fewer cars are driving around without serving passengers.

However, we believe the ​“shared ride bonus” runs counter to the goals of encouraging shared rides in for-hire vehicles. This will disproportionately raise the cost of providing pooled rides and runs contrary to the goals of reducing congestion and limiting greenhouse gas emissions. This new fee would be the first in the nation to explicitly penalize pooled rides. It runs counter to RPA’s belief that public policy should encourage multi passenger trips to the largest extent possible. Similarly, city and state goals including New York State’s congestion surcharge bill provide incentives for shared rides over trips with only one passenger.

While we support this rule overall, we urge you to eliminate the ​“shared ride bonus” before the final proposal is adopted. Thank you.