Open Letter to the Natural Resource Defense Council

Are you aware that the San Francisco branch of the Natural Resource Defense Council (NRDC) is backing a plan by the venture capitalized corporations Uber and Lyft to put thousands of their private vehicles on that city’s streets without an environmental impact study, regulatory oversight or emission controls?

         The new services called, Uber Pool and Lyft Line, designate the same vehicle  (owned by a private individual) to pick up at multiple locations in the same area and take the passengers to different places where the vehicles drop them off.

Uber and Lyft market this strategy by claiming,

• “Shared ride platforms … reduce the number of private vehicles on the road” …” decreasing emissions of greenhouse gases and criteria pollutants, particularly in urban areas.”

This is a textbook example of Orwellian doublethink. They may or may not be motivating private citizens to take their cars off the road but they are certainly putting huge clusters of their own privately owned vehicles on the streets to do the job.

But it sounds good, yes? In fact, it sounded so good to Amanda Eaken, Deputy Director of the NRDC’s Urban Solutions Program, that she wrote in her comments to the California Public Utilities Commission that despite the fact that,

• “… these services are novel” <and> “have not yet been the subject of independent research to verify their broader social and environmental impacts…,” <and> While important research questions remain to be answered, this is not the time to make changes that would prevent ridesplitting (her word for Uber Pool & Lyft Line) from further evolving, particularly in light of… California’s ambitious climate goals.”

         Would Ms. Eaken and the NRDC take the same attitude if Exxon said that it was evolving a new, environmentally friendly method of fracking? Would the NRDC wait to see what the effects would be before calling for an inquiry? I think not.

The CPUC's Confused Ideas On Reducing Greenhouse Gases

President Michael R. Peevey of the California Public Utilities Commission (in his Proposed Decision of 9/19/2013) upheld the laudable goal of reducing greenhouse gases in the transportation sector in keeping with The Global Warnings Solutions act.

Unfortunately, he also accepts TranForm's belief that "ridesharing services have the potential to advance" these goals. If Transform had been talking about real rideshare services, their idea might well be true. However, what they meant was Lyft, Sidecar and Uberx – services that transport passengers for a fee.

The difference?

The model of a real rideshare would be people who share a vehicle to or from work. If you have four people riding together, this takes three vehicles off the roads.

Lyft, Sidecar and Uberx, on the other hand, use an app to drive over and pick people up at one location and drive them to another. This was recognized by President Peevey in his proposed decision.

What he appears to have missed is the fact that the TNC's increase rather than decrease greenhouse gases. They do so in two ways: One – the distance separating a TNC from the customer adds to the length of the trip thus emitting gases over and above what the customer would have emitted by using his or her own car; and Two - instead taking cars off the streets, the TNCs add vehicles.

For example: Lyft, Sidecar and Uberx are currently operating over 2,000 vehicles in San Francisco alone. This more than doubles the number of taxis operating in the same areas. On surface, this would seem to only only double the amount of greenhouse gases being emitted.

However, 97% of San Francisco's taxicabs are hybrids or low emission vehicles and only 17% of the TNC vehicles are. This means that the amount of gases being emitted by the TNC's is far more than just double  that of a S.F. taxi – and this doesn't even include the pollution caused by the number of of town cars and limos being put on the roads by Uber.

The CPUC's proposal , instead of helping to reduce emissions, would exacerbate the problem.

The proposal would do this in two ways:

One – it states that,

"TNCs may only use street-legal coupes, sedans, or light-duty vehicles including vans, minivans, sport utility vehicles (SUVs) and pickup trucks. Hatchbacks and convertibles are acceptable."

Minivans, sport utility vehicles (SUVs) and pickup trucks? Gas guzzlers all! But no mention of low emission vehicles.

Two - more importantly the proposal says,

"TNCs need not apply for a certificate of public convenience and necessity pursuant to PU Code § 5371. TNCs are exempted from this requirement, as are many charter-party carriers regulated by the Commission, pursuant to PU Code § 5384(b)." 

This means that the TNC's can put out as many vehicles they like of any kind for any reason whatsoever.

Actually this has been a major flaw in the rules covering TCP vehicles. The state of California has been putting far too many limos out for years. 

If the CPUC really wants to reduce greenhouse gases, what they should be doing is requiring environmental impact reports before putting out more limos or the TNC's, not adding to the problem by applying the same absence of regulations to the TNC's.

As it is, the CPUC proposes to open the floodgates for an environmental disaster.