I'm posting Director Hayashi's letter for two reasons:
1. It's one of the best summaries of the problem that I've seen.
2. It was instrumental in Seattle's decision to limit the numbers of TNCs. Before Hayashi sent her letter the Seattle Council was split on the vote. After they read it, they
voted unanimously to regulate.
A third reason is that the Director hasn't gotten her props for helping keep the bogus taxis out of numerous cities including Austen, San Antonio and Philadelphia – where the
TNC's get towed if they show up.
March 12, 2014
Dear Seattle City Council Members:
I am writing this letter in the hopes of helping to inform your upcoming
decision about appropriate regulation of companies that provide smartphone
access to individuals using personal vehicles to provide for-hire transportation
to the public. Please notice that I did
not call it “ridesharing.” That is a false
characterization of this type of for-hire vehicle service that was adopted in the
hope that by characterizing these services as “carpools” they would not be
required to carry commercial insurance under California law. What we now call Transportation Network
Companies (TNCs) in California asserted that position before the California
Public Utilities Commission (CPUC), but the CPUC rejected it, finding that the
TNCs are commercial, for-hire vehicles that are operating for profit.