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TLC Testimony – 2/12/2015

Good morning Commissioner Joshi and distinguished Commissioners of
the TLC. My name is Michael Allegretti, speaking on behalf of DanachNY, Grun, Hinter, Schmecken, Unter, and Weiter, LLC for Uber
Thank you for the opportunity to testify, and I want to start by
reiterating our keen interest in collaborating with the TLC and working
When we entered New York almost 4 years ago, we worked with TLC
staff to form our first black car base and place it within the regulated
for-hire vehicle industry. We support the TLC’s regulation of our bases.
There are effective ways the TLC can expand upon its efforts to
regulate FHV bases affiliated with apps
This is also an opportunity to take a look at how our City’s
transportation ecosystem has evolved because of the TLC working
collaboratively through FHV base licensed system to regulate app
companies like Uber.
The results over the last four years have established a new standard of
service for riders and economic opportunity for drivers in New York
City. The TLC now has a unique opportunity to pursue measures that
would lift the entire industry up – including taxis, liveries and black cars
– to meet these new standards.
--Lets first take a look at the results of Uber NYC working collaboratively
with the TLC through our FHV bases:

Over the last four years, Uber NYC has provided comprehensive
outer-borough service with average pickup times of 3 minutes or

We have doubled the average hourly earnings of drivers to $30
per hour.

We have provided riders with an unprecedented level of
transparency about their ride - including providing a driver’s
name, license plate #, base affiliation, all BEFORE a trip starts.

Riders can also share their ETA with loved ones to create a safer

We respond in real time to rider concerns – any complaint
submitted – no matter how big or small - is replied to within 3
hours, but often within minutes.

We have created a new model for providing disabled New Yorkers
with a reliable ride in northern Manhattan and the outerboroughs which are committed to expanding

-We believe our experience in New York is roadmap for the TLC to
create higher standards for the taxi and care service industry. The TLC
can and should pursue progressive measures to make these advances
for riders and drivers the new industry-wide goal:
All companies should be able to demonstrate to the TLC they can
provide fast, reliable service to all New Yorkers in every part of our city.
In addition all companies should be held aggressively accountable for
discriminatory practices, that have historically meant some New
Yorkers can get a ride while others cannot because of where they want
to go, their background or skin color.
Every driver should have a real opportunity to earn a real living – the
current taxi/car service average hourly earnings is $15 – we believe it
should be $30. The taxi industry medallion system has forced drivers
to pay wealthy medallion owners daily exorbitant fees just for the right
to their job. This is on top of the money they already pay to garages for
renting their cabs. The TLC could explore lowering the cap on
medallion lease costs, new rules to require driver ownership of
medallions and audit the city’s garages and make sure that drivers
aren’t getting ripped off.
The TLC should require that every rider who steps into a car gets a
digital communication with their driver’s license and vehicle plate
numbers, along with a way to contact the driver or base.
The TLC should adopt new, tougher price transparency requirements.
Riders deserve to know how much their trip will cost before it starts.
Companies should also clearly post their fare structure on their
websites, within their apps, or on any other communication device
consumers use to request a ride. They should also use easy-tounderstand notifications if prices rise above standard fares, and require
customers to voluntary accept such fares.

The TLC should require all companies to be accountable to riders by
requiring them to respond to rider concerns quickly. All members of the
industry should provide mechanisms for consumers to give real-time
feedback about each trip, regardless of whether they sit in the back of
a black car, a livery car, or a yellow or green cab.
The TLC should require that all cars outfitted to provide rides to
disabled New Yorkers should be able to arrive in 10 minutes or less which is actually double Uber’s average pick-up time today for our
uberWAV product.
-The product of Uber’s collaborative work with the TLC has shown it is
possible to provide this level of service and driver opportunity on a
large scale across the City – lets make it the new standard for the
entire industry.
Uber also wants to continue our partnership with the TLC to provide
real consumer protection, customer service, and safety across all parts
of the industry, including our own. We recognize that fast emerging
technology poses new challenges.
New York City Government has in the last several years prioritized
creating a new tech based economy in our city – supporting companies
like Google, Etsy and Quirky to establish a real presence in New York.
Even today, for example, Mayor Bill de Blasio is meeting with New York
tech leaders at New York CIty's Inaugural Tech Talent Pipeline Advisory
Board meeting. This City government is clearly committed to growing
our tech ecosystem and cultivating more tech industry jobs. We
applaud the Mayor for his efforts on this front.
Figuring out how to balance supporting the benefits of the tech
industry to New York City while ensuring tech companies operate
within the existing regulatory framework is key for Uber and City
Government. The TLC has an opportunity to strike this balance by
building on the existing FHV base license structure and requiring that
all bases that utilize apps be required to obtain a separate license from
the TLC to use these apps for dispatch. This approach matches how 22
other jurisdictions across the country have handled dispatch app
regulation and would fit squarely into the TLC’s existing regulatory
Alternatively, an approach that would put TLC in the driver’s seat of
how apps are run and operating would go against existing precedent
and stifle the progress we’ve made for riders and drivers.

We hope to work with the TLC to continue to build on the progressive
change we have seen to New York City’s transportation system that
has given riders better options and drivers the ability to make a real
living to support themselves and their families. This is what truly
matters and this is what we want to help the TLC achieve.
Thank you.