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High-Volume For-Hire Service Provider Congestion Rules Testimony

Today, the Partnership for New York City submitted testimony to the Taxi and Limousine Commission Hearing on High-Volume For-Hire Service Provider Congestion Rules

Thank you Chair Heinzen and members of the Taxi and Limousine Commission (TLC) for the opportunity to submit written comments on the proposed high-volume for-hire service provider (HVFHSP) rules. The Partnership for New York City represents the city’s business leaders and largest private sector employers. We work together with government, labor and the nonprofit sector to maintain the city’s position as a global center for commerce and innovation.

We urge the TLC to hold off on adopting proposed regulations that would prevent the issuance of new for-hire vehicle (FHV) licenses and limit FHV travel without passengers in Manhattan below 96th street. In the past year, the FHV industry has had to absorb many new rules and charges including the congestion surcharge and new formulas for paying drivers. The TLC should allow time to assess the impact of these rules on the industry, its customers and mobility throughout the city before taking further action.

For-hire vehicles have become a significant and valued part of transportation services in New York. As this industry matures, we should be seeking to ensure that it is competitive and responsive to needs of our very diverse communities. Over-regulation at this early stage in development of the industry risks market distortion and inadvertent bias for or against a business model or company.

FHVs are particularly important in transit deserts that are not well-served by public transit, where FHVs may be the only good option. To ensure adequate service to these areas, it is important that companies can license sufficient cars and drivers. The proposed cap on new licenses and driver pay rules may not support that objective. It is important to study how these rules affect citywide services before further regulating the industry.

Furthermore, high-occupancy FHVs should not be subject to the license cap or per capita charges that discourage shared rides. The TLC should exempt these vehicles in order to reduce congestion and advance environmental goals. The Partnership was an early supporter of congestion pricing and we are inaugural members of the OneNYC Advisory Board which has assisted in developing city initiatives that promote reduction in carbon emissions. Encouraging more shared rides in multi-passenger vehicles is part of these goals.

Thank you.