Speaker of the New York State Assembly Carl E.

Heastie
LOB 932
Albany, NY 12248

March 1, 2017

RE: Transportation Network Company legislation, data transparency, and safety impacts

Dear Speaker Heastie,

A report published this week by acclaimed transportation analyst Bruce Schaller found that
the services of transportation network companies (TNCs) like Uber and Lyft amounted to 600
million extra miles driven on New York City streets in 2016. These car-based services, rather
than mass transit, are contributing to paralyzing congestion and bus speeds that are among
the slowest in the nation both inside and outside the Manhattan Central Business District.
We understand that both the recently-passed Senate bill S4159 (Seward) and the Governors
S2008/A3008 could potentially worsen this trend of increasing congestion, as they contain
inadequate provisions to prevent cars registered outside the city from operating within New
York City.

Furthermore, the conclusions in Mr. Schallers report were obtained through the analysis of
TNC data that, by law, must be provided in New York City --- but that will not be reported to
state and local officials Upstate under the Senate or Governors bills. As a result, jurisdictions
outside of NYC will not be able to complete similar studies, because their data sharing
requirements are so weak as to be near-meaningless. We urge you to not pass any bill that
does not address these issues.

First, we would like to draw attention to the potential for this legislation to have a serious
impact on traffic and congestion not just in the counties outside New York City to which it will
ostensibly apply, but within the five boroughs as well. There are no provisions in the
legislation that would prevent vehicles registered to bases outside New York City from
operating within the city limits. If this bill is passed, there would be no feasible way to stop
vehicles from Westchester or Nassau Counties from traveling into New York City, which
would flood the streets with even more for-hire vehicles on top of the existing high number.
These vehicles would not be required to have Taxi and Limousine Commission plates, merely
window decals, which would make enforcement and regulation a challenge. Not only would
this increase in vehicles worsen traffic and congestion, but it would also undermine recent
New York City legislation that requires TNCs operating within the five boroughs to share
anonymized data with regulators. Your district, along the Westchester County line, would
potentially be among the hardest-impacted.
The legislation, as it stands, does not make adequate provisions for the type of data collection
and analysis necessary to insure a properly regulated system, both inside and outside New
York City. TNC legislation proposed by the Governor and the Senate requires TNCs to collect
important trip and driver data, but does not compel the provision of that data to any state or
local regulators. Instead, regulators are supposed to audit TNC records by visually inspecting
a small sample of what will be millions of rows of data at twice-yearly meetings. This short,
basic inspection is inadequate and will not result in any meaningful conclusions being
reached. In order for this data to be properly analyzed, it must be thoroughly audited and
mapped with geospatial software a process that takes time, but more importantly has the
potential to illuminate the traffic, environmental, and road safety outcomes of this substantial
change in policy.

We believe it would be irresponsible to allow such a drastic change in TNC legislation without
putting in adequate safeguards. It would jeopardize New York Citys progress towards Vision
Zero, weaken the base of data on TNC trips that is so crucial to proper analysis, and endanger
the public through worsening congestion and its associated detriments.

Sincerely,

Paul Steely White

Executive Director
Transportation Alternatives

Veronica Vanterpool
Executive Director
Tri-State Transportation Campaign