Revised Final Opening Comments to the CPUC's Ridesharing Rulemaking II

This is the second part of the revised comments that I sent into the California Public Utilities Commission hearings on ridessharing. Like my most recent post, it is a summary of my ideas on the subject and contains links to other posts of mine. 

In the photo I make up for past omissions by finally giving Sidecar drivers their due.

Lyft, Sidecar, Tickengo and Uberx are not Ridesharing Services

As for a detailed analysis on this subject, I don’t think I can do better than refer you to a few of my own blog posts on The Phantom Cab Driver Phites Back. For an analysis of marketing by double-talk see:

100,000 Uninsured Rides and Counting: If it looks like a duck and walks like a duck, will it bark if you call it a dog? 

For a look at further perversions of the English tongue, as well as a critique of the idea that a driver isn’t a professional until he or she makes more than $8,776 a year, see:

My Reply Comments to the CPUC on Lyft, Sidecar & Willie Brown

It does appear that Tickengo belongs in a different category than Lyft and Sidecar. However, as far as I can tell it’s not a nonprofit, and they still advertise that their drivers will make money. For a look at the difference between Tickengo and a true ridesharing service like Avego, let’s look at the websites:

You have to go to the driver’s page on their website to find it, but Tickengo’s drivers do get paid.

https://tickengo.com/

Unlike the fake rideshares, Avego’s goal is to have “fewer cars on the road” not more.

https://rtr.avego.com/rtr-desktop-web/

Then to compare them both to massively bogus “ridesharing” services, see:

Become A Lyft Driver - Lyft Drivers Make up to $35/hr - lyft.me and

http://www.side.cr/drivers

But for the best evidence that Lyft et al are not ridesharing services, why not look in the horse’s mouth? Journalist Justine Sherrock Life Behind the Wheel in the New Rideshare Economy writes:

“When a driver posed a question about taxes, Lyft directed the poster to a fellow driver who is also a tax accountant. ‘Calling a voluntary payment for service received a ‘donation’ does not affect whether it’s taxable unless the receiver is a tax-exempt organization,’ she posted. ‘So all of your Lyft income is taxable since you are not a tax-exempt organization. Hope this helps guys. This is considered self employment income, not a hobby.’”

Later in the article Sharrock says:

“Toward the end of my shift, I was about to sign out when I figured I may as well accept one last request for my drive home across the city. But then I remembered that there was no way for me to tell if someone was going in my direction or, say, to the airport.”

To refer to hosting a Lyft ride as carpooling is most assuredly wrong, according to any known definition of the word….”

“I later confronted Zimmer (John Zimmer CEO of Lyft) about this. ‘Ridesharing is where we are heading. Right now we are at page one of a 100-page book,” he says. “You have to build up a base service that is reliable, be careful about the math of the supply and demand, and get people used to riding with each other, and then add incidental trips. Without that peer-to-peer base, real-time ridesharing has no chance.’”

In sum, Lyft, Sidecar and the rest all fail both true ridesharing tests: their  drivers don’t exclusively pick up riders that are going in the same direction as they are; and both the companies and their drivers work for money.

Congestion and Pollution

John Zimmer’s fantasy of having one hundred thousand vehicles transporting passengers with his mustached cars may not be possible, but it appears to be a goal he’s striving toward. San Francisco is already over-saturated with bogus taxis, and both Lyft and Sidecar are still putting them out at a frenetic rate.

Dr. Dan Hara of Hara Associates (2) has estimated that San Francisco needs 800 more cab to handle the business. However, Lyft and Sidecar have already put somewhere between 2,000 to 2,500 illegal taxis on the street. According to classic deregulation theory, this would mean that a balance between the need for cabs and the number of cabs (legal and otherwise) available has not been reached.

But classic theory assumes that the owners of the vehicles would have to purchase the cars, maintain and pay for insurance along with the other expenses that it takes to run and work a cab. Lyft and Sidecar don’t have most of those costs, so they can keep on increasing their fleets without the same natural balance that deregulation theory projects. It’s sort of like a Ponzi scheme where individual drivers may make less but the overall number of rides is more so Zimmer, Sunil Paul (CEO of Sidecar) and their investors make more money. Easy enough to do in a down economy with a lot of people willing to work part time.

What evidence do I have for this?

1. According to most drivers I've talked with as well as my own experience, the taxicab business in San Francisco is down by at least twenty-five percent.  Our taxi customers are being stolen by Uber, Lyft, Sidecar and the host of other illegal vehicles.

2.   This means that the fake rideshares, rather than fulfilling the need of picking up new customers as  they claim to be, are picking up business that would be picked up by taxis anyway.

•    This is especially true at SFO, where Lyft justifies its right to go by claiming that there aren’t enough taxis when a couple of hundred of them are waiting for flights to arrive almost every hour of every day.

3. Sidecar has a rule that a driver only has 20 seconds to respond to a dispatch or the hail will be given out to the five next closest cars. If there were a balance between the number of Sidecars and the number of orders, there wouldn’t be five empty cars hanging around for a race.

4. Both Lyft and Sidecar are sending their drivers to the same areas that are already overpopulated with taxis and away from the neighborhoods that cabs currently underserve. Justine Sharrock:

“We were given strategies on how to maximize our ‘Lyft Loot,’ i.e., make more money, by driving during peak hours and waiting in optimal locations. We were shown a map of the city with Outer and Inner Richmond areas labeled as ‘No,’ and downtown, SOMA and the Marina as ‘Yes.’ In other words, follow the tech money. In the mornings, being closer to the edges of town works as well, since people take Lyft to work.

Hunters Point and the Bayview, low-income minority communities, didn’t even make it onto the map. Since the app connects drivers with rides nearest them, Lyft is essentially not available for people in those communities.”

5. I can add the anecdotal experiences of myself and numerous other drivers who have frequently turned up on dispatched orders only to find that a Lyft or a Sidecar has been hailed as well. I’ve also seen Lyft or Sidecar drivers picking up passengers in places like Market Street that I would have gotten on a flag if the fake rideshares hadn’t been there.

What you have then is a duplication or triplication of effort that is already seriously congesting and polluting San Francisco, the negative effect of which will increase geometrically if the CPUC shows the bad judgment to legalize these bogus ridesharing services.

BTW - Zimmer's fantasy doesn't really work on any level. If he did put his 100,000 faux taxis on the street, the real taxi business would cease to exist. All that would be left would be "community drivers." What would happen if a person needed to go to a hospital at 4 am? Where would he or she find the "community driver" who was going to the same hospital at the same time?

Revises Opening Final Comments to CPUC's Ridesharing Rulemaking

My opening final comments to the CPUC hearing are something of a summary of my thoughts on ridesharing. Although I repeat ideas that I've written and said before, I've hopefully phrasing them more concisely than I did in earlier versions.

Because of the length of my comments I'm going to put them into two post. The first one will deal with deregulation. The next will be about Lyft and Sidecar's spurious claims to being ridesharing services.

The End notes, surprisingly, can be found at the end.

The photo is of Kristen Sverchek,  the General Council of Zimride incorporated, who personifies (for me) the true Lyft and Sidecar sense of community.

Revised Opening Final Comments 

The so-called “ridesharing” businesses of Lyft, Sidecar, Uber and others are not legitimate and should not be legalized. To do otherwise, to legalize them, would lead to an extensive and destructive deregulation. It would create congestion, pollution and endanger the people who drive and ride in the vehicles as well as the general public.

Deregulation

If the CPUC allows the use of personal vehicles for transporting passengers (i.e. as taxicab or livery services), It would be impossible to tell whether or not any car was a legal rideshare.  There would be no way to control the number of illegal taxis. In fact, this is already happening.

Ever since the CPUC gave Lyft, Sidecar and Uber free passes to grossly expand their businesses a plethora of illegal cars and taxis (including cars with fake pink mustaches) have hit the streets. Instant Cab, Ur Cab Service, Uberx, Tickengo, Rickshaw and Jitney are either operating here or on the way. There’s a Sarah’s Taxi Service with a limo body and a taxi top, a phone number that doesn’t work and no online listing. A cab driver I know has developed his own app and just can’t wait for ridesharing to be given the official thumbs up so he can buy a junk car and start making some extra money.

And why not?

Deregulation is one of those ideas that sounds good but doesn’t work out so well in practice. It’s got that Social Darwinism thing going for it that’s ingrained in the American psyche. You know. Competition necessarily improves everything. Yes, sometimes. But don’t forget that for the fittest to survival often means wasting everybody else.

Taxicab services have been deregulated almost everywhere in the world at one time or another. And they’ve been re-regulated almost everywhere a short time later. (1), (2).

Lyft and the other bogus ridesharing companies criticize city regulators for protecting taxicab companies. Well, protecting business is a natural function of government agencies – just like the CPUC appears to be protecting investors from Silicon Valley (3). However, City regulators are also protecting the earnings of drivers and the safety of the public. It’s not clear, on the other hand, how the CPUC’s refusal to allow people to see whether or not they are riding in insured vehicles protects the public’s interest.

Indeed, the major reason that deregulation fails is that it does not protect the public’s interest. According to Bruce Schaller: (4)

“As the competition increases, the amount of money for each driver declines. Drivers thus tend to congregate in the places that are busy already instead of going to the outlying area where they are less likely to get a ride."

The quality of the vehicles also declines because less money is available to buy new ones. And, as income levels decline, experienced drivers leave the business to untrained drivers, thus endangering the public. More from Schaller: (5)

"There appears to be a strong relationship between taxicab crash rates and driver incomes. Higher driver incomes are associated with lower crash rates."

Negative Effects of “Community” Deregulation

Lyft, Sidecar and the other fake “community” taxis are already deregulating the business with the predicted results.

1. The income of cab drivers has declined about twenty-five percent over the last year, causing many experienced professions leave the business.  

Keeping the 25% decline in mind, Cab, Lyft and Sidecar drivers all make about $20 per hour. (6), (7), (8)

• ·      Cab drivers are entitled to Workers Compensation benefits and if they work enough years, have a chance to become the one taxi driver in five who owns a medallion worth $250,000, which brings in $2,500 a month on top of what the owner makes from driving. This is down from $300,000 a year ago. 
•    In addition, there is a driver’s fund created primarily from a 5% fee on the sale of medallions currently worth 3.1 million dollars that might be used to help reduce medical insurance payments for cab drivers.
•    If Lyft, Sidecar and the other pseudo rideshares are legalized and not restrained, the medallion would be worth little or nothing in a few years. If this happens, the quality and professionalism of drivers would take a nosedive.
•       If Lyft and Sidecar drivers use their own cars, which AAA says, costs them $0.596 per mile to run. At 100 miles = $59.60. If they work 10 hours, they make $200-$59.60 = $141.40 or $14.40 per hour. The minimum wage in San Francisco is $10.55
•     Cab and limo drivers are carefully vetted and trained. There is a 28 hour course for cab drivers which includes: geography (maps/ routes/locations), defensive driving, vehicle and pedestrian safety as well as vehicle codes and traffic safety. Drivers have to pass a test on the materials before they start working. I understand that limo drivers take a 70 hours course.
•        Lyft and Sidecar drivers are minimally vetted and trained mostly by rumor. (9), (10)

2. Lyft and Sidecar are putting vehicles on the street that are inferior to taxicabs.

• ·      Over 95% of the cabs in San Francisco are hybrids that undergo a though mechanical inspection at the Airport before they are put into use. Furthermore, they are checked at the end of every shift.
•     Less than 20% of Lyft and Sidecar’s vehicles are hybrids, and the companies do not mechanically inspect the cars. (9) (11)
•     A San Francisco taxicab cannot be older than 2006. Lyft and Sidecar accept vehicles as old as 2000.

3. It’s way too early to tell what the accident rates for the “fake ridesharing” companies will be. As a former insurance underwriter, I can tell you that Lyft and Sidecar haven’t been in business long enough to generate meaningful statistics. Sidecar claims to have stats showing that their drivers are safer than cab drivers, but they also claim to train their drivers and mechanically inspect their fake cabs, and they don’t do either one. 

Come now. Cab driver bigotry aside, does it really make sense for untrained drivers to be safer than ones that are trained? As much as I hate to say something nice about Uber, they at least are smart enough to hire experienced taxi and limo drivers who have been the subjects of driving studies. Once again, from Schaller:

"The lower crash rates for cabbies are not so surprising given that taxi drivers are far more experienced than other drivers. They are behind the wheel up to 3,000 hours a year. Their driving records are scrutinized by the Taxi and Limousine Commissions and auto insurance carriers. They risk losing their livelihood if they have too many crashes or get too many tickets."(12)

(Click Below for End Notes.)

Corrections to Yesterday's Post and an Apology

I was proud of myself yesterday for getting a post out in less than three hours. 

Unfortunately, much of the information in it was not correct. I later had a conversation with Director Chris Hayashi who noted the changes below.

          1.  Dan Hara will not have his report finished by the end of the week so the MTA Board won’t discuss it until the July 16th.

2.    The most important proposal for the June 18, 2013 Board meeting will concern the legalities for the sale of medallions to drivers on the Waiting List.

Electronic Taxi Access

The anonymous commenter to yesterday’s post was partially right but Director Hayashi actually had a couple of meeting on Friday and Monday that included not only managers from Desoto, Luxor and Yellow but reps from Flywheel and Taxi Magic as well. Changes in how ETA will function will result from these meetings but these revisions will not necessarily be as nefarious as anonymous thinks.

The final formulation is still a long way off but here are some of the features or principles that ETA will include or follow:

• ·      The orders will be offered through the PIM monitors instead of separate smart phones.
•     Only apps like Flywheel or Taxi Magic with at least a 1,000 customers will be accepted by the system. 
•     Yellow Cab will probably sign up with Taxi Magic.
•      Dispatching services like City Wide Dispatch with a large number of customers will be included in the system.
•     Dispatching services with less than 100 customers will probably be dropped.
•     The orders from the individual apps will be integrated so that two different taxis won’t be sent to the same address.
•     The same app company cannot dispatch both limos and taxis so the Uber’s taxi app will probably bite the dust. I’m adding the bold assumption that companies dispatching bogus “ridesharing services” will likewise not be allowed to dispatch taxis in SF. Goodbye Instant Cab. May you take your Georgia Tech degrees and do something useful (not to mention legal) with them in the future.
• 
  

  A guiding principle for Flywheel and Taxi Magic is that they want “quality” drivers rather than a sheer numbers. In short, they want people who will pick up orders instead of taking a dispatched hail and then blowing it off to grab the first flag they see.

I’m also in favor of this principle. The execution, however, leaves something to be desired – at least with Flywheel. They are much too draconian. I’m being held off their service right now because their app didn’t work properly and I was forced to take cash. I was held off earlier because their GPS gave me the wrong location and I cancelled the order after I took it. When I call them up, I usually get some twenty-two year old techie who cheerfully tells me something like, “Yea – lots of you guys complain about that.”

I would hope that Director Hayashi would use the June 11^th Town Hall Meeting (since it won’t covering Hara et al) for a face to face between Flywheel and Taxi Magic and their drivers. I think it’s time they re-design their software with the end users in mind.

 Finally, I'd like to apologize to President and General Manager of Luxor Cab, John Lazar, for calling him a dinosaur yesterday. He's clearly more in tune with the future than I gave him credit for. Indeed, he's making it. Sorry Mr. Lazar.

Meter Increase??? Gate Increase??? No-Go Fee. Technology Fee. ETA.

All the above and more were discussed at a recent Town Hall meeting.

On May 31, 2013 Dan Hara will be handing in his final recommendations, which will include whether or not there should be gate and/or meter increases. There will be Town Hall meetings to discuss the issues on June 11th and the MTA Board will look at and possibly vote on the proposals on June 18, 2013.

Not to editorialize but:

 1. No businesspeople in their right minds would raise their rates when they are being successfully underpriced by their competition.

2. It's time to get rid of gate fees and replace them with a split of the meter. I've been saying this ever since I was first hired by Yellow Cab and saw the corruption and incompetence that the gates & gas system caused. And I repeated my ideas to the MTA the moment they took over. The bottom line is that a gate system makes leasing to drivers the business of cab companies - not picking up customers.

There are companies like Desoto, Luxor and Green who consciously try to give good service but they are in the minority. I won't rant about the details. I've already done this enough. The primary problem is simply that the profits and losses of the companies are not directly linked to the amount of business that they do. If the meter were split, the MTA wouldn't have to conduct arcane studies to find out which companies were good and which were bad. All that would take care of itself - and service to the public would drastically improve.

I've said this so often that I sound like a crank but the future lies with me. (See Uber. It might also be a good idea to take a Business 101 course along with a double dose of common sense.)

Electronic Taxi Access (ETA) et al.

I didn’t catch the entire meeting and Director Chris Hayashi (photo, hand) was still presenting the proposals when I left so I can’t give definitive summary. The final plan won’t be presented until May 31^st but the following covers what little I do understand of the system.

1. All available taxis will appear on the map of a customer’s smartphone.
2. The MTA itself will create no app but rather will co-ordinate hails from Flywheel, Uber's taxi app and other legal apps.

3. All the information from the individual apps will be routed through a central system in order to appear on the smartphone.

3. The exception will be calls to dispatch services and e-hails from single company apps like Luxor or Desoto’s.

     A. However, these calls and e-hails will be integrated with the ETA system so that only one cab will be sent to each order.

In other words, this will be the centralized dispatch system that drivers have spent thirty years lobbying for.

In addition:

1. The App Fees will be paid by the customer.

2. There will be a Technology Fee to be paid by the customer instead of credit card processing fees paid by the drivers.

3. A $10 No Go fee also will be automatically deducted from customers’ credit card if they aren’t there.

4. The “Response Time Fee” listed on the white board above is being renamed a “Premier Service Fee.” It will be paid to a driver if his or her taxi gets to a customer within a promised time like under ten or fifteen minutes. Yes this does mean that a driver will get a bonus picking up a ride in time.

Needless to say there are criticisms:

1. ETA won’t improve service because taxi drivers will take a flag before they will take a dispatched call. As the saying goes, a bird in the hand is worth two in the bush.

Well, that depends upon the birds in question doesn't it? Seriously, if you think about it, you are often closer to dispatched calls - unless you spend all your time in Union Square.

Take my situation for instance. I start driving from the inner Bayview at 4 pm. It takes me five minutes to get to the area around Zynga and Adobe where I can pick up flags, and another three to five minutes to get to either Market Street or the cabstand at Cal Trans. All that time I'm within five minute or less of dozens of businesses where people might want taxis.

The unwritten rule is that a driver shouldn't take dispatched calls during rush hour because most of them will be No Go's. The reasons for this are that you don't how old the orders are and the people have probably called three or four companies.

With ETA both these problems disappear. Your cab will be the only one sent to the order and you'll get the No Go fee if the party isn't there. In addition, with all hails going through one dispatch system, you'll have at a minimum of three times more orders to choose from.

2. This will discriminate against people without smart phones or with Paratransit cards.

The orders will be dispatched in such a way that a driver can’t tell what type of order it is.

3. If so, drivers won't take the hails because they might not get a No Go fee.

This comes from the meeting. Cab drivers, man. So many of us look only at the empty side of the hourglass. Eighty per cent of the people in S.F. have smart phones and people who don't have them don't take as many taxis as people who do. Furthermore, No Go's on Paratransit rides are rare. 

The percentage of No Go's will be extremely rare on with ETA and the odds of getting the fee if the customer isn't there are better than 90%.

The Age of the Dinosaurs...

... reputedly passed over 65 million years ago but a few survivors are hanging on in the taxicab business in the personas of John Lazar and the management of Yellow Cab.

Mr. Lazar reputedly killed Open Taxi Access a few years back and is out to waste ETA as well. The problem for him is that it's not as easy to buy politicians as it was back in the day. With Lyft and Uber on the scene the price of corruption has sky rocketed.

On the other hand, maybe Lazar is getting a kickback from Uber and Lyft. The balkanization of the dispatching services in this town is what opened the floodgates for the illegal apps in the first place. The adoption of an ETA system would be the best weapon we could possibly use against them.

But the President and General Manager of Luxor Cab is still living back in the Jurassic Age when the companies with the most medallions necessarily made the biggest profit. If he succeeds, all he's likely to win today is a large cut of a dying industry.

BALL PARK WORKSHOP

A taxi Workshop was held last week as part of the Waterfront Transportation Assessment Project. The meeting was aimed at improving taxicab access and service at AT&T Park before, during and after ball games as well as other events.

The SFMTA was represented by Peter Albert (standing to my right in the last photo) who is heading the project, Project Manager Erin Miller (standing along with PCO Supervisor Gregory Sedlock in the lead photo), Taxi Services Director Chris Hayashi and Project Manager Carli Paine.

Taxicab drivers were represented by the usual suspects plus a few others.

Erin Miller suggested that we break up into three groups and that each team come up with five ideas to improve drop-offs and pick-ups.

We were encouraged to write or draw our recommended changes on maps of the area around AT&T.

Then a spokesperson for each group presented their proposals.

There appeared to be general agreement on the following ideas:

1. There should be better signage directing customers to cab stands. Colim Marcoux (third photo – white hair) suggested that flashing signs inside (or outside?) the ball park could be used for this purpose.

2. There should be a Taxi Only lane on 2nd street from Bryant to King streets.

• The cab stand on 2nd & King should be extended from Townsend to Brannan.
• U-turns should be allowed for taxis on 2nd and, in order the make the turns safer, there should be no parking on the East side of 2nd up to Townsend or, possibly, Brannan.
• Taxis should be allowed to make left turns onto the Embarcadero from 2nd after the games.

3. The cab stand on 3rd & King should be moved to the East side of the street and extended from King up to Brannan (expect for the bus stop).

4. Since the Cal Tran station at 4th & Townsend functions as a cab stand, taxis should be allowed to make legal U-turns there.

• Let me add that it would be a good idea to put a PCO at Cal Tans to help taxis safely make U-turns, not only after AT&T events, but during rush hour.

5. Traffic (except for taxis) should be turned from the Embarcadero onto Brannen after the games.

Mark Gruberg of the UTW said that a cab strand should be placed on the south side of King directly in front of the ball park.

Other drivers thought that limos should have a separate staging area. Trevor Johnson of the SFCDA suggested that the 3rd street side of the park would make a good place for limos so they could form a line "all the way out to the Bayview."

Most drivers where also in favor of having a non-enforcement rule for taxis dropping off and picking up for an hour after the game. This idea appeared to meet with something less than enthusiasm by PCO Sedlock and the project managers. I think the concept needs clarification.

None of us are suggesting that we make a cinéma-vérité version of The Purge with PCO's desperately fleeing avenging cab drivers. By all means ticket red-light running or any other dangerous moves.

However, the reality at these events is that there is going to be a great deal of chaos. Traffic is usually heavy and regularly gridlocked before the games, making it difficult or impossible to drop-off in a cab stand. And, after a game,  people run and flag the first taxi they see whether it's in a cab stand or not. It's not reasonable or efficient to expect them to walk a block when there is a cab right in front of them. Double-parking (typically for less than half a minute) is often the only realistic option.

Drivers should be allowed to drop-off or pick-up customers wherever it can be done safely without fear of being ticketed for minor, frequently imaginary infractions. So many drivers have been hit with bogus tickets after games that many of them won't go near the ball park. If the city really wants taxi drivers to do a better job at AT&T, the PCO's are going to have to change their mind-sets from one of "busting violators" to one of helping customers get to and from ballgames.

Fortunately, it sounded as if Peter Albert, Erin Miller and the other city representatives in the room enthusiastically embraced this point of view. Director Hayashi also promised that taxi drivers would no longer be harassed and that the eight newly hired investigators of Taxi Services would help out at the ball park.

Ever the skeptic, I said to Hayashi after the meeting,

"Well, they really listened. Do you think they'll actually make the changes?

"Of course," she replied. "Everybody knows things aren't working now."

Photos by Chris Hayashi

Chris Hayashi at the CPUC

Director of Taxi Services Christiane Hayashi (photo) gave two powerful speeches at the recent CPUC hearing on Order Instituting Rulemaking on Regulations Relating to Passenger Carriers, Ridesharing, and New Online-Enabled Transportation Services.

Hayashi illuminated issues obscured by the rhetoric of both the so-called NOETS and the CPUC spokespersons. She also explained the negative consequences for the public of legalizing these bogus taxicab services.


The first talk begins with a comment on sharing the podium with Uber. The joke is that Uber had held court for over forty minutes before Director Hayashi was given the opportunity to speak. And, of course, Uber and Hayashi don't like each other very much.

The second talk is brilliant and impassioned. It's ending also points out the varying levels of respect given by the CPUC to the spokenperson for the City of San Francisco and the one for Uber.

A CPUC "facilitator" rudely shut down Director Hayashi before she had a chance to finish by claiming that Illya Abyzov, a manager for Uber, had only been given two minutes to talk before his Q & A. Actually Uber attorney Ed O'Neil's introduction of Mr. Abyzov took two minutes by itself and, as I mentioned before, the entire performance took up over forty minutes with Illya neither saying much nor answering any question he didn't like. The kicker is that Illya Abyzov is not listed as a "Party" to the Rulemaking. That is to say - he should not have been allowed to speak at all.

You might also have noticed that Hayashi was cut off precisely when she was about to give the "specific" ideas for change that the "facilitator" claimed to be asking for.