Regional Plan Association Testimony to the Taxi and Limousine Commission on For-Hire Vehicles

Thank you for the opportunity to submit testimony on the Taxi and Limousine Commission proposed amendments to its rules to limit the amount of time For-Hire Vehicles dispatched by High-Volume For-Hire Service Providers spend cruising in the Congestion Zone. Regional Plan Association is a non-profit civic organization that conducts research, advocacy and planning to improve mobility, economic opportunity and sustainability in the New York metropolitan region.

FHV trips often account for 600,000-700,000 trips per day, and some TLC traffic counts indicate that For Hire Vehicles account for upwards of 30% of traffic in the Manhattan core. Regulating the industry will be vital to reduce traffic congestion in Manhattan and throughout the five boroughs. 

RPA strongly supports the goal of this legislation -- to reduce traffic congestion and improve travel times by decreasing the amount of time that FHVs are cruising for fares. According to the TLC, drivers currently spend 41% of time cruising. This proposal has the goal of bringing that number down to 35% by February 2020 and 31% by August 2020. We hope these numbers can be pushed down even further in the years that follow. 

We are concerned, however, that these policies will be implemented without giving time to assess the cumulative impacts of each new regulation, including the cap on FHV drivers and congestion fee surcharges implemented earlier this year and the congestion pricing cordon charge to be implemented in early 2021. 

For example, the for-hire industry offered incentives to FHV passengers this spring to offset the impact of new congestion fees authorized by the State Legislature in 2018 and implemented a few months ago. It is possible that the full impact of congestion fees, $2.75 for TNCs, $2.50 for taxis, and $0.75 for pooled trips, might not yet be visible in the data. 

Additionally, in less than 18 months, New York City will begin to benefit from the implementation of congestion pricing, which will reduce the number of vehicles in Manhattan south of 60th Street. But until the policy is implemented, we do not know how much congestion will drop or how it will change travel patterns. If drivers are now cruising in areas right outside the 96th street congestion fee boundary, for example, it could eliminate and mask traffic reduction gains from a congestion pricing cordon toll at 60th Street,

As such, RPA recommends consideration of a more phased-in implementation to collect more TLC data on how current and anticipated regulations are working.

We also suggest TLC analyze the effect of these policies on drivers. The industry has publicly stated that there may be an incentive to simply freeze drivers out of the apps as a reaction to restrictions on utilization rates. This could reduce drivers earnings. Either the agency should protect against this through regulation, or phase in the regulations over time so drivers have time to adjust.  

We also want more data on the cap and whether the cap helps reinforce utilization goals, or whether it is simply redundant. There is not much evidence yet that the cap on new licenses is working, and it seems that increasing utilization rate and reducing cruising times is a more efficient and flexible approach than a strict cap on licenses. One way to possibly reduce the effect on drivers is to exempt existing long-term TLC drivers from the FHV driver cap, so they have the option of opting in if they would like.

Thank you for the opportunity to submit written testimony, and we applaud your proactive approach in attempting to manage congestion through FHV regulations.