Rasier-CA, LLC

1455 Market Street, 4th Floor

San Francisco, CA 94103

December 24, 2014

Via Email
Denise Tyrrell
Acting Director
Safety and Enforcement Division
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102-3298
tyr@cpuc.ca.gov
Re: Clarification of TNC Vehicle Inspection Requirement
Dear Director Tyrrell:
We write to request that the Commissions Safety and Enforcement Division (SED)
clarify the manner in which inspections are conducted on vehicles used by Transportation
Network Company (TNC) drivers who accept trip requests from the Uber smartphone
application. Decision 13-09-045, entitled Adopting Rules and Regulations on TNCs, sets
forth, in Section 2.24, that vehicles used by TNC drivers must be inspected annually:
Prior to allowing each TNC driver to operate a vehicle, and annually
thereafter, a TNC must inspect the drivers vehicle, or have the vehicle
inspected at a facility licensed by the California Bureau of Automotive
Repair, and maintain complete documentation of such inspections. A TNC
drivers vehicle must, at a minimum, pass a 19 point inspection prior to
allowing the driver to operate the vehicle under the TNCs platform.
It is our understanding that Section 2.24 requires vehicles to be inspected by a certified third
party (i.e., a licensed California auto repair facility), or, an employee-representative of the TNC
itself, and Rasier-CA, LLCs (Rasiers) policies continue to reflect that understanding.
Interpreted differently, however, this requirement may appear to allow a TNC to rely on
contracted driver partners, who are not certified mechanics, to conduct inspections on other TNC
drivers vehicles. Given that this TNC driver peer-inspection practice exists today in the
California TNC industry, we are writing to ask for clarification on whether the SED believes that
vehicle inspections conducted by TNC drivers who are not certified mechanics is consistent with
the letter and intent of Section 2.24.

Beginning on February 2, 2015, Rasier will explore the possibility of using its own driver
peer-inspection program, similar to current practices of others in the TNC industry, unless
otherwise notified by SED that TNC driver peer-inspections are not permitted under Section
2.24.
Clarification from the SED on this issue would assist Rasier in ensuring driver partners
receive the most accurate information. We look forward to your response to our request for
clarification, and thank you for your consideration.

Sincerely,

K. Juvvadi
Krishna K. Juvvadi
Senior Counsel