Competition is good – fair rules must protect the public and apply the same standards for all vehicles for hire
As a small family-owned and operated business with roots in the St. Louis community that are 80+ years deep, all we want is a fair opportunity to serve customers well and succeed on a daily basis. We exist within a regulatory environment with fair rules that are purposed with protecting the riding public.
At County & Yellow Cab, we strive to exceed our customers expectations every single day with every ride that we provide. We know that we are only as good as the last time that you rode in one of our vehicles. Competition is at the root of what drives us to succeed. As our regulating body, the Metropolitan Taxicab Commission, considers changing their regulations to allow Transportation Network Companies to legally operate in the St. Louis region, they asked for comments from the general public.
As a co-owner and 3rd generation operator of two of our areas ground transportation providers – County & Yellow Cab and Best Transportation, I felt it was my duty and responsibility to provide my comments and suggestions. Below is a copy of the letter that I submitted to the MTC. If you peel away the layers of this “onion”, I have two main points – ensure public safety and fair rules that apply to all providing the same vehicle for hire service.
To all involved at the Metropolitan Taxicab Commission –
I would like to thank you for your strong commitment to the public safety issues related to legalizing any vehicle for hire alternative to the St. Louis Region. I am writing this letter as a co-owner and operator of both a taxicab company and a premium transportation company. As an operator that has experience in both areas of vehicle for hire transportation, I feel that I have a unique perspective that may be valuable when considering what regulation changes are necessary.
In my opinion, transportation network companies (TNC’s) should be subjected to the same rules that we have followed to the letter since the inception of the MTC. A lot of publicity surrounds the possibility of their arrival in St. Louis, but we should all recognize that the technology they offer is already offered to riders by some of the taxi companies operating here. But in the spirit of welcoming competition, customer choice and having many transportation alternatives available to our citizens and visitors, there are certain rules that can and should be changed for all. There are also some rules that I feel very strongly must remain to protect the riding public.
I would like to ask that you please consider the following alternatives when reviewing changes to the regulations for vehicle for hire transportation for transportation network companies. These are in no particular order as I view them all as equally important.
1. FBI Fingerprint background checks for all drivers – regardless of full time or part time status. This is just a no brainer. No other option should be accepted. This is the only form of background check that provides maximum assurance of safety and security for the riding public. The small amount of money and time for this process are well worth it. If TNC’s are so opposed to this process, you have to ask yourself – what are they trying to hide. This is not a process that can be left up to each operator to self-regulate. The MTC came into existence because of public demand for assurances of safety and reliability. All vehicles for hire should be required to provide such assurances, not just some of them. Since when is it considered “onerous” for some ride providers to provide such assurance to protect the public?
2. Drug testing upon licensure and then year round random drug testing for all drivers. I do agree with Uber’s assessment that the drug test is just a snapshot in time. But their assertion that the passengers provide a real time evaluation if their driver is impaired would be comical if it were not so unrealistic and dangerous. Many people seek rides because they, the riders, are impaired by alcohol. How can a drunk person in the backseat be held responsible for knowing if the person behind the wheel is drunk too. The initial drug test is critical to qualify any driver to be safe for the riding public. The year-round random testing would give riders the assurance that all drivers are clean of all controlled substances at all times. If the CCN holder is already conducting an effective random drug testing program, then proof and results could be substituted for the random program to be administered by the MTC.
3. Full time commercial liability insurance for the protection of the driver, passengers and innocent bystanders with proof of insurance provided at annual renewal and upon random request during the remainder of the year. We have seen story after story of TNC drivers working off the platform and as a result, there is a huge gap in insurance. TNC’s will say that these drivers will be deactivated from the platform – but by time they find out – if they find out – it could be too late. If full time commercial liability insurance – which is very expensive – it not required of TNC providers, it would not give riders the protection they need and would give TNC’s a dramatic unfair competitive advantage. The fair and level playing field for all providing the same service are crucial to successful regulations and continuing to provide good viable options for our region. The commercial liability insurance that is required of all vehicle for hire providers should never allow for periods of no coverage, or periods where the coverage amount is different depending on what the driver is doing. Full coverage all the time!
4. Reduction in the premium sedan annual fees – When the MTC began the process of evaluating allowing UberBlack to operate in St. Louis, you made some code changes that had previously inhibited their business model. But during this same process, the MTC more than doubled the annual permit fees for premium sedan operators. It has often felt like the premium sedan operators have been the sacrificial lambs, so to speak, in the process. In addition to increasing our fees, you also issued a total of 52 new black car permits without the benefit a study showing the need for more black cars in our market. The increase in premium sedan permits is now to the point where new premium sedan operators have made a substantial investment in a vehicle but they are struggling to make a good living because of the large disparity in the supply vs. demand for this service. This saturation bundled with the large increase in our fees will continue to put premium sedan operators at an unfair competitive advantage. I would like to ask that you put the premium sedan fees in line with the cab fees and eliminate the huge disparity. Premium sedan operators are faced with extremely high operating costs such as vehicles that are 4 to 5 times the cost of a vehicle for a taxi fleet, full commercial insurance and providing employment and full benefits for our chauffeurs. Requiring us to pay almost 5 times what a taxi operator pays for the annual permit fee is not valid by any means.
5. Vehicle inspections and markings and other vehicle for hire regulations – While making sure that a vehicle is in good working condition and has adequate markings so that potential passengers know that they are utilizing a legally licensed vehicle for hire are extremely important, we need to have a fair and level playing field for all those providing the same service. If the MTC will decide not to require these markings for Uber or other potential TNC’s operators, then they should remove this requirement and other burdensome regulations for all vehicle for hire providers.
6. Permit limits for all vehicle for hire classes – In allowing TNC’s to operate in St. Louis, it is important to balance new customer choice with a fair operating environment for cab drivers and companies that have significant investments and commitments to serving the St. Louis Region. Thousands of St. Louisans and visitors rely on cab service that is available everywhere, all the time to everyone (whether or not they have a smart phone). While TNC’s thrive on part time drivers that can easily abandon this revenue stream on a whim, all other vehicle for hire drivers look at this as a career and profession. If our region is going to give them any chance of continuing to make a good living, support their families, buy homes and put their kids through college and provide this service at a reasonable price, we must also make sure that there are the right number of vehicles available for the potential needs of our citizens and visitors. I highly encourage you to be strong in increasing the number of taxi permits available for compliant taxi operators and limit the number of TNC permits to a conservative number of no more than 400. The MTC has invested a substantial amount of money in the ground transportation study being currently conducted by Dr. Ray Mundy. Let his study begin the conversation regarding how many taxis’ vs. TNC’s are warranted in our region. And for the sake of protecting a TNC’s ability to make a decent wage, the MTC should look at a permit limit as a tool to protect their income making potential as well. TNC drivers all over the country continue to be disgruntled with their inability to make a decent wage in markets where there are no limits and the roads are flooded with TNC’s. Equally important is the need to control road congestion and pollution for our residents. Flooding the streets with an unlimited number of TNC’s would contribute greatly to these problems.
Thank you for your time as a volunteer regulator. I realize that the role that you play in protecting the riding public in our region is thankless and time consuming. But your role is necessary and important so please remain diligent in your efforts.
Deborah L Rudawsky, CPA
Co-Owner and Chief Financial Officer
St. Louis County & Yellow Cab