RPA supports TLC’s amended fatigued driving rules as they build upon the city’s Vision Zero initiative and will help improve public safety. The bulk of our comments address other benefits that enhanced for-hire vehicle (FHV) trip data would bring to transportation policy.

New York City needs to create a uniform for-hire-vehicle data collection standard that would apply equally to yellow taxis, green cabs and black cars, including both traditional car services and e-hail services such as Uber and Lyft. Having more precise data on the travel patterns of all these vehicles is essential for planning how to best use our finite roadway capacity and to gain a better understanding of congestion and the performance of the city’s dense street network.

In the past, requiring black car operators to provide the same data as the larger yellow taxi fleets (and later green taxis) would have been an excessive financial and administrative burden for many smaller companies. Taxis are more heavily regulated, but are also the only for-hire-vehicles allowed to pick up street hails. Before e-hails/on-demand services, this was a huge competitive advantage and medallions were highly valued. This made investments in GPS technologies an expensive proposition in 2008, requiring the installation of a custom solution at a cost of up to $5,000 per cab, an unaffordable proposition for many livery operators.

Much has changed over the past six years. E-hails or on-demand services have been introduced, allowing the public to request a car in seconds from their smartphones, easier and more convenient than standing on the corner with an arm stretched in the air. Smartphones are now equipped with GPS technology and enough raw processing power to do everything (and more) than the specialized hardware and software required by the TLC, all for a few hundred dollars.

The biggest development, however, has been the surge in for-hire-vehicles to a total of 88,000 vehicles in 2015. This breaks down to 13,600 yellow cabs, 7,700 green cabs and 66,700 black cars. It is estimated that about 40,000 of the black cars are transit network companies (TNC) such as Uber, Lyft and Via. These companies have the capability to provide the data that the TLC is requesting (Driver Fatigue Rule and Enhanced FHV Trip Data), and other black car operators can do so with little additional burden. Combined, these companies represent more than 75% of the for-hire-vehicle fleet. TNC companies have raised concerns that rider privacy could be compromised. However, the TLC proposal would protect the privacy of users, just as it does today with the yellow and green taxi data. No personal data on users would be provided to the TLC, just the pick-up and drop-off locations and times of the vehicle along with a unique identifier. The publicly available data also would be aggregated to larger geographies – TLC taxi zones – and would not include specific addresses.

This request is reasonable and will allow policy makers and planners to better serve the public, the most desirable outcome of any new rule.