Battery Electric Vehicles – New Hearing Start/End Time (same date)
Rule status: Adopted
Agency: TLC
Effective date: June 25, 2021
Proposed Rule Full Text
TLC-Proposed-Amendment-of-Rules-Governing-Issuance-of-For-Hire-Vehicle-Licenses-Preliminarily-Certified-5.11.21-002-1.pdf
Adopted Rule Full Text
Promulgated-Amendment-of-Rules-Governing-Issuance-of-For-Hire-Vehicle-Licenses.pdf
Adopted rule summary:
The Taxi and Limousine Commission promulgates amendments to its rules regarding the battery electric vehicle exception to the for-hire vehicle license issuance pause. The promulgated rules eliminate the exception and require the TLC to consider issues surrounding battery electric vehicles when determining how many for-hire vehicle licenses to issue every six months.
Comments are now closed.
Online comments: 60
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Joseph Chow
Comment added June 1, 2021 11:19amI would like to share some thoughts on this issue. I’m a researcher at NYU working in the area of urban transportation systems, in particular on electric mobility systems. I understand that the recent exemption for electric taxis has led to a rapid growth of e-taxi licenses, but I would also caution a full reversal of the exemption. E-taxis align well with the sustainability goals of NYC and they need all the help they can get in competing in this competitive market. For example, a recent study of ours (Jung and Chow, 2019) shows that, due to the current limited charging infrastructure and longer charging time than ICE vehicles, e-taxis make only $0.95 for every $1 that ICE taxis make, and this gap widens to $0.86 per e-taxi for each $1 earned by ICE taxi (when there are up to 5000 e-taxis) as more e-taxis fill the market because of the congestion from charging at the limited number of stations. Especially at a vulnerable time where NYC is looking to grow EV usage, e-taxi investment can provide synergies by boosting the value of charging hub investments which in turn would create more value for other passenger EV investments and other e-mobility options. These positive externalities must also be considered alongside the discussion of the trade-offs between GHG emissions reductions and congestion costs that e-taxis pose to the road traffic. Disregarding them and treating them completely the same as ICE taxis may derail the momentum that has been gained in this growth so far.
A more measured response may be to have a regulated allowance on the e-taxi cap separate from the ICE taxi cap. I’d be happy to share further comments and thoughts and participate in this process if you would like; my contact information is below.
Reference:
Jung, J. and Chow, J.Y., 2019. Effects of charging infrastructure and non-electric taxi competition on electric taxi adoption incentives in New York City. Transportation Research Record, 2673(4), pp.262-274.—
Joseph Chow, PhD, PE
Assistant Professor, Department of Civil & Urban Engineering
BUILT @ NYU Laboratory
Deputy Director, C2SMART University Transportation Center
NYU Tandon School of Engineering
6 Metro Tech Center
Brooklyn, NY 11201, USA
Tel: +1 646 997 4030 -
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John Olsen
Comment added June 16, 2021 10:46amInternet Association (IA) is the only trade association that exclusively represents leading global internet companies on matters of public policy. Our mission is to foster innovation, promote economic growth, and empower people through the free and open internet. We believe the internet creates unprecedented benefits for society, and as the voice of the world’s leading internet companies, IA works to ensure legislators, consumers, and other stakeholders understand these benefits.
Our attached letter details our concerns with the proposed rule.
Comment attachment
IA-Letter-NYC-TLC-Proposed-BEV-Rule.pdf -
Stephen Cortes
Comment added June 16, 2021 10:58amI am deeply concerned that removing the BEV exemption as proposed in your rule posting does not reduce congestion or greenhouse gas emissions as listed as your purpose for making this change.
New York City needs to be making every effort to add electric vehicles to our streets, not cap them, and the evidence presented is severely lacking.
In your statement, the Commission says 400 BEVs have been added in the last two years with this exemption in place. Out of more than 100,000 FHV licenses, that represents less than 0.5% of all vehicles.
That’s simply not good enough, and even if that number grew to 10,000 (10%), it would not be enough.
Every effort to add more charging infrastructure and more EVs to the road, as FHVs, personal, and city-owned vehicles, should be the direction NYC needs to go!
This is shameful for the most-populous city in the nation with tremendous sickness, cost, and death that comes from air pollution every year.
Please VOTE NO!
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Javier Santana
Comment added June 16, 2021 11:02amAs a native New Yorker, who’s father drove for the TLC for 30+ years, who founded UhSpot, Inc (https://uhspot.com) to improve the lives of new yorker’s who depend on vehicle ownership to maintain a living, and who cares about protecting our city’s environment and sustaining jobs, I’m for the TLC’s proposal to eliminate BEV’s exemption to the for-hire vehicle license cap and ask that the Commission VOTE YES on this rule change on June 22.
BEV’s (with the use of autonomous vehicle technology) are projected to eliminate the majority of human powered for-hire vehicles through an autonomous vehicle service called transportation-as-a-service. By setting a cap on BEV’s now, New York City will be well positioned to protect its workers when the market shift occurs. New York city has many other ways to achieve its carbon neutral goal by 2050, congestion pricing being one of them.
If this rule change passes, we can rest assured that our TLC workers will be able to provide for their families, the same way my father provided for his family of 5. BEV’s are projected to reach ~30% of all new car sales by 2030. With market adoption of BEV’s increasing and the implementation of congestion pricing, New York City will be well positioned to reach the carbon neutral goal.
For the good of TLC drivers, New Yorkers, and our city’s future, please VOTE YES on this proposed rule. Thank you.
Javier Santana, Co-Founder, President, UhSpot, Inc.
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Devin Viss
Comment added June 16, 2021 12:31pmI am concerned that a full repeal of the BEV exemption will force drivers to continue using existing gas vehicles, even if there is a desire to switch to an electric vehicle for environmental benefit.
I also understand that there is a concern for using the BEV exemption as a loophole for exponentially increasing new BEV licenses instead of converting existing licenses.
As a NYC resident who cares both about the environment and traffic congestion, I strongly urge this committee to consider an alternative pathway for existing FHV license holders to convert their license to a BEV license, or consider an additional but reasonable yearly cap for BEV FHV licenses that allows for moderate BEV vehicle growth, instead of removing the exemption entirely.
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Michael Eydman
Comment added June 16, 2021 3:21pmThis is a perfect case of various parties with unique agendas using this for their benefit, please read the rule text in full so you understand what is being done. I have received emails from rideshare companies saying that TLC is trying to block them from adding new electric rideshare vehicles, which is not true. Here are the facts:
TLC has ruled to limit the issuance of new FHV licenses to ALL vehicles to reduce congestion. Later on they made an exception to allow electric (BEV) vehicles to get new FHV licenses. However, the requests for these unexpectedly increased and they want to lock it down again to prevent more congestion, their original intent.
This is not meant to prevent BEV from being used. If new owners or rideshare companies want to invest into NYC and reduce climate impact, they can buy up existing FHV and convert them to electric, which shouldn’t cost anything.
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Valeska
Comment added June 16, 2021 3:29pmWe all need to adapt. I am sorry to those who’s income depends on industries which clearly now have a time stamp attached.
NYC’s public wants to move forward, allow for way more options, bikes, electric vehicles of all sorts, less cars altogether.
Voting yes allows the TLC to artificially uphold old ways to serve special interests.
The right way is to adapt. Get ready, move with the times, not against it.
For those who’s income dependents on old ways the task is not to throw force against progress, but to find new I come within progress.VOTE NO. Let’s do the right thing.
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Boubacar
Comment added June 16, 2021 6:43pmCommissioners of the TLC:
My name is Boubacar Mohamed and I drive with Uber in New York City and I have been renting a vehicle, which costs me $400 per week.
I want to have my own plate and car. I would like to pay weekly or monthly until I have my own but I am unable to do that with the strict regulations.
I recently heard that you are considering changing the rule that would allow me to plate my own Electric Vehicle in the future, and I am writing to ask you to reconsider. Right now there are only two options for me to ever plate my own vehicle, and stop paying hundreds of dollars a week to rent a car.
By taking away the EV exemption, it means my only option would be a vehicle equipped to move wheelchairs, which doesn’t make sense for me to also use as my personal car.
Right now I can only earn on the platform if I fork over a substantial amount of my earnings to rental car companies. I want to be able to own my own car, and generate more earnings so that I can bring more support to my family.
Thank you.
Boubacar Mohamed
Bronx, New York -
Delpeche Miguel
Comment added June 16, 2021 8:23pmTlc trying to exclude minority driver and block potential driver to own a plate by ruling now you can’t own a plate after 2years tlc and mayor and governor cuomo .corporations can have plate and but minority can’t
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Delpeche Miguel
Comment added June 16, 2021 8:38pmIt’s very disgraceful to see tlc want to put a stop
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Edgar Sal
Comment added June 17, 2021 5:57amWE DONT NEED ANOTHER COMPANY. The commissioners must be Racist, they considering allowing another white rich person to get richer on minorities. Is enough give us the opportunity to transition into electric vehicles
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Gurjeet Singh
Comment added June 17, 2021 10:33amEvery day People are buying and selling their corporation on the other hand people who’s trying best to save money to get the electric vehicle and are now out of options. Now they want to put a stop on this to but they can’t put stop on corporations. This mean TLC is always been against normal people. They are loyal to rich people to make them even more richer by passing this rule.
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Anil Chandra Pradhan
Comment added June 17, 2021 11:41amNeed to issue TLC plates to both BEV and regular gas vehicles as soon as possible.
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Richard Khuzami
Comment added June 17, 2021 12:08pmFrom:
Richard Khuzami
Old Astoria Neighborhood Association (OANA)Dear Commissioners,
New York City is facing a climate emergency, with the health impacts of harmful traffic emissions taking more than 1,400 lives every year. As a New Yorker who cares about protecting our city’s environment and creating green jobs, I’m against the TLC’s proposal to eliminate the BEV exemption to the for-hire vehicle license cap and ask that the Commission VOTE NO on this rule change on June 22.
If this rule change passes, it will prevent our city’s progress towards electrification, ensuring that gas-guzzling cars continue to dominate and public health continues to suffer. Two years after the EV exemption was originally passed, less than 0.5% of New York City’s more than 100,000 FHVs are electric. This just isn’t good enough. New York City can’t afford to lose any more time in the battle against climate change, and companies like Revel are ready to help now with an all-electric fleet.
Revel is also creating 170 green jobs, giving TLC drivers the option to choose a company that will guarantee them a stable wage and benefits. This is an opportunity that your drivers deserve and that they need. For the good of TLC drivers, New Yorkers, and our city’s future, please vote NO on this proposed rule.Best,
Comment attachment
Richard Khuzami
President, Old Astoria Neighborhood Association
OANA-Revel-Support-Letter.docx -
Lyudmila M.
Comment added June 17, 2021 2:10pmVOTE YES !!! ☝ IT’S USELESS !!!
CHARGING STATIONS ARE NOT CHEAP TO INSTALL !!!
WHO CAN AFFORD THEM…??? !!!
I’m TLC Driver, MOST OF US – DRIVERS LIVE IN APARTMENTS, there’s ABSOLUTELY NO WAY TO charge electric vehicles. Landlords don’t allow to install charging stations in the building’s garage ! Drivers MUST receive landlord’s permit for installation of charging station in the building’s garage + HIRE CERTIFIED Engineer from Electric company ConEdison to install properly charging station AND PAY OUT of OUR OWN POCKET !!!
I live in NYCHA apartment’s building and considered to buy electric vehicle in the first place (2015 year). My Manager of NYCHA Amsterdam Houses Mr. C. Gordon PERSONALLY DID NOT ALLOWED ME to install electric charging station on my Reserved outside Parking Spot NYCHA Parking Lot in Manhattan !!!
I was WILLING TO PAY OUT OF MY OWN POCKET to hire ConEdison Certified Electric Engineer, they told me price estimate would be around $7,000 +
ConEdison procedures also require all paperwork, permits etc. for installation of charging station on my NYCHA Parking spot… and i wasn’t able to receive such permit from my NYCHA Manager… as a result I HAD TO GO with traditional gas vehicle.
All of us TLC Drivers suffer without option to be able to charge our TLC license plate vehicles on OUR NYCHA LEGAL Parking spots while we rest at home AFTER WORK !!! SHAME NYCHA !!!
1) As a TLC Driver I can’t afford to just idle every 30 minutes while WAIT to charge electric vehicle anywhere in the City, TIME MUST BE USED EFFICIENTLY !!!
2) Uber App hours MUST BE RESERVED and once you go off line to charge 30 minutes vehicle THAT’S IT… YOU CAN’T GO BACK ON line !!! SO YOU OUT OF WORK !!! ☝
3) Lyft App the same practice, can’t go online… App companies suspended time reservations TEMPORARILY due to Pandemia !
It’s even WORSE to deal with privately own building’s landlords/companies etc. to get permits for installation of charging stations in the garage… THEY aren’t willing to PAY for it either !!!
What average apartment’s resident can afford to pay $7,000 to install charging station…?!
MOST TLC Driver’s CAN’T AFFORD to buy private HOUSE… to charge electric vehicle… DiD YOU SEE how much we get paid…??!
Sorry FOR NOT SUGAR COVERING !!!
06/17/2021 Time 14:10 -
Ibrahim Toure, P.E., LEED AP
Comment added June 17, 2021 2:19pmI am a lifelong NYC resident, concerned citizen, and professional engineer who has worked for 19 years in NYC public transportation.
I write this comment as the droughts increase and the heat waves rage on our west coast, the glaciers melt at our north and south poles, the oceans slowly rise all around us, and the looming storms swell in magnitude, frequency, and ferocity, awaiting their next opportunity to overwhelm our shores and surge to devastate our city once again.
Per a joint study the National Aeronautics and Space Administration (NASA) and the National Oceanic and Atmospheric Administration (NOAA) published June 15, 2021 in Geophysical Research Letters, the energy imbalance between the rate at which the Earth is absorbing energy from the Sun and the rate at which the Earth is releasing energy to space has risen from about half a watt per square meter in 2005 to about a full watt per square meter in 2019. As the Earth’s surface area is slightly more than 510 trillion square meters, this means Earth is currently receiving at least 510 terawatts (TW) of global warming energy or “equivalent to four detonations per second of the atomic bomb dropped on Hiroshima, or every person on Earth using 20 electric tea kettles at once”. (https://www.nasa.gov/feature/langley/joint-nasa-noaa-study-finds-earths-energy-imbalance-has-doubled)
Those that deny that human activities significantly contribute to this massive destructive imbalance forfeit the opportunity to alter forecasted eventual global human extinction level outcomes by changing the way we do things now.
Ride-share vehicles inherently reduce the number of private passenger cars on the road, thus reducing transportation energy expenditure and pollution. If one car owning person chooses to take a taxi instead of driving, then one less car is on the road for that trip. Ride-sharing vehicles improve upon this by hosting multiple passengers. The more ride-sharing vehicles on the road at reasonable competitive prices, the fewer private passenger car trips are needed or incentivised. Thus ride-sharing vehicles reduce traffic congestion by removing private passenger cars from our roads and streets. Comparisons can be made between traffic congestion in New York City (NYC) with its many taxi and ride-share services (in addition to mass transit and alternative modes such as bicycles) and Los Angeles, California with its predominantly private passenger car transportation mode.
Internal combustion engine (ICE) vehicles are typically designed to operate most efficiently at highway speeds, and least efficiently (burning more gas and emitting more pollution) at slower city speeds, with frequent stopping and starting, while moving slowly through stalled traffic, and while idling (at red lights at stop signs, stuck in traffic jams, and during passenger pickups and drop offs). Sadly these lower efficiency operating conditions are exactly the conditions under which taxi and ride-share vehicles operating in NYC, with our maximum speed limit of 25-MPH on city streets, must abide. Thus ICE vehicles operate at lower than optimal design efficiency, and produce more pollution per mile, when used for taxi and rideshare services.
Battery electric vehicles (BEV) do not emit tailpipe pollution during their trips. Energy is expended, pollution emitted, and negative environmental impacts generated during the manufacture of BEVs and their batteries. Additionally BEVs may indirectly contribute to pollution if they cause significant increase in energy demand and production at local fossil fuel burning power plants. However, over the life of the vehicle, BEVs on average generate much less pollution than (ICE) vehicles. (https://fas.org/sgp/crs/misc/R46420.pdf, https://www.nytimes.com/2021/03/02/climate/electric-vehicles-environment.html)
BEVs are also well suited for NYC taxi and ride-share services because they have zero tailpipe emissions, perform efficiently at low speeds, recover energy via regenerative braking during frequent stops and starts, operate much more quietly than ICE vehicles, typically have driver assistance features to automatically recognize and avoid collisions, and may have higher crash safety ratings as determined by the National Highway Traffic Safety Administration (NHTSA) and the Insurance Institute for Highway Safety (IIHS). Ride-sharing BEVs thus provide the public benefits of indirectly reducing traffic congestion pollution by removing private passenger cars from the roads, as well as directly reducing toxic exhaust, greenhouse gas, and noise pollution by operating quietly with zero tailpipe emissions.
BEVs should be permitted to provide ride-share and taxi services within NYC for the reasons stated above. The current established NYC Taxi and Limousine Commision (TLC) policy of allowing BEVs to provide ride-share and taxi services without a TLC medallion or certificate is environmentally prudent, socially responsible, and economically encouraging as it allows for increased competition, innovative business models, and new job opportunities. These potential economic benefits are of great importance as NYC seeks to recover from the lingering effects of the global pandemic with additional flexibility, resilience, and innovation in our business sectors. The equity and transportation access provided by ride-share and taxi services are important not only to the single mother traveling to work in the early morning rain, the person trying to return safely home from a bar in the late evening, the senior or disabled person trying to get to their doctor’s appointment on time, but to us all.
The current established policy permitting BEVs to be used for taxi and ride-share services should remain in effect and should not be altered or amended to reduce its effectiveness, limit its scope, ban, reduce, or cap new BEV taxi and ride-share vehicles, limit public access to BEV taxi or ride-share vehicles, stifle market competition, reduce NYC’s ability to provide more hopeful long term outcomes for our residents and commuters, or reduce NYC’s historic ability to set a shining example of foresight and wisdom for the cities and governments of the world.
Please Vote NO for this proposed amendment.
Sincerely,
Ibrahim Toure, P.E., LEED AP
Comment attachment
NYC Resident
NYS Licensed Professional Engineer
Letter-to-TLC-regarding-EVs.pdf -
Alvaro
Comment added June 17, 2021 3:19pmGreetings TLC , my name is Alvaro , the reason when I applied for TLC license is to drive a car, Means every person that gets a TLC license would drive a car on the road , if you think you have enough cars on the road , Stop Giving TLC License , because stoping for new electric cars , will not work with congestion problem because drivers will rent cars any way , if TLC stop allowing for individual to register an electric vehicle , TLC will be making business to rentals companies and the congestion problem will not be solved , Please STOP , VOTE NO
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Jessica Enzmann
Comment added June 17, 2021 4:49pmJune 17, 2021
Taxi and Limousine Commission
33 Beaver Street, 22nd Floor
New York, New York 10004Re: Sierra Club Formal Comments – Battery Electric Vehicles exemption
Dear Commissioners:
Sierra Club is writing to respectfully express concerns over the proposed rule change to the Taxi and Limousine Commision’s (TLC) Local Law 147. Removing the waiver for Battery Electric Vehicles (BEV) to obtain For-Hire Vehicle (FHV) licenses would not align with local, state, or federal goals for greenhouse gas (GHG) emissions reductions and would delay the City’s progress on clean transportation.
The transportation sector is currently the largest source of greenhouse gas emissions in New York contributing more than a third of the state’s emissions. This pollution has been shown to increase the risk of asthma, heart attacks, cancer, and premature death. Transportation pollution impacts communities of color the most, making it crucial to prioritize zero emission vehicles in these communities. New York has set some ambitious climate goals through the Climate Leadership and Community Protection Act (CLCPA) including 85% reduction in ghg emissions by 2050. Eliminating the FHV license waiver for BEV is a step backwards in meeting local, state, and federal goals for GHG emission reductions.
The current BEV exemption has been positive for electric vehicle adoption, and the new proposed rule stands to stifle the purchasing of BEVs and in turn negatively impact the build-out of electric vehicle charging infrastructure. BEVs are one of the best tools to improve our air quality. Eliminating tailpipe emissions will benefit everyone, especially those that live near busy highways. Disallowing BEVs to obtain FHVs would set New York back in terms of incentivizing new BEVs entering the ridesharing market.
With over 2 million passenger vehicles in total on the road in New York City the claim that 400 new BEVs approved for FHV licenses between 2019 and 2021 significantly contributes to congestion or GHG emissions through congestion is questionable. . Cutting down on rideshare/pool vehicle services that utilize BEVs would only increase the amount of trips New Yorkers take in gas combustion rideshare/pool vehicle services passenger vehicles and increase greenhouse gas emissions.
For these reasons, Sierra Club urges the Commission to reconsider implementing the proposed rule. I welcome any questions you may have regarding Sierra Club’s position and can be reached at [email protected].
Sincerely,
Comment attachment
Jessica Enzmann
Organizing Representative, Sierra Club Clean Transportation for All
Sierra-Club-Comments-for-NYC-TLC-proposed-rule-change-to-BEV-license-waiver.pdf -
Kwaku Anyemedu
Comment added June 17, 2021 6:31pmI’m a driver for Revel’s electric rideshare program. I took this job because I have been a rideshare driver for years. I enjoy the work, however as an independent contractor, there are so many downsides and disadvantages to rideshare work. There is no PTO, there are no health benefits, there is no opportunity to take part in a retirement plan. There is no sense that you are part of a supportive team that has your back 24/7. It feels like you are all on your own, having to deal with everything yourself.
Drivers deserve a job that is the best fit for them. This means working at a company like Revel, where I’m an employee with benefits. Working at Revel means I have a guaranteed salary not based on the number of trips I complete. I have more peace of mind, knowing that I am getting paid regardless of the number of trips I actually complete. I love feeling like being part of a company and a family, where I have a supportive team I can turn to whenever I have any issues or struggles.
Having the backing of a company is very important to me. It also is a good feeling knowing that by driving an electric vehicle, I’m helping the environment and to prevent climate change. I and other fellow Revel riders are ready to start driving and making a major change in our city, but the city is saying they want to change the rules so Revel won’t be able to operate.
Please VOTE NO on the proposed amendment.
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Anwar syed
Comment added June 17, 2021 6:43pmGive each TLC driver a plate so they can get raid of renting a TLC car
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Esther Castillo
Comment added June 17, 2021 7:23pmRequest to testify during the hearing on June 22: Battery electric Vehicles.
Good Evening,
I’m a recently hired driver for Revel’s electric rideshare program. I have been a rideshare driver since 2018. I’ve worked as an independent contractor for Uber, Lyft and a liberty taxi base without any benefits such as medical insurance. I have worked long hours just to cover the expense of renting a car, gas, and personal living expenses, plus high taxes each year. I enjoy driving because of the flexibility that it offers me, during this time I have earned an Associate degree in Human Services and Mental Health and a Bachelor’s in social work, I will continue my studies in the fall to pursue my Master’s in Social work (MSW). Working for Revel means a guaranteed salary, healthcare, and paid time off, and a flexible schedule that will allow me to continue my education, that gives me peace of mind, something I do not have as an independent contractor making close to poverty wages while working for a company like Uber, who offers zero benefits or peace of mind. Me and the other Revel drivers are ready to start driving and making a change for our city, but the city is saying they want to change the rules so Revel can’t operate rideshare.
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xiongchen
Comment added June 17, 2021 9:38pmAs a very environmentally friendly means of transportation, electric vehicles have made an outstanding contribution to reducing carbon emissions around the world. Therefore, it is really unwise for TLC to cancel the licensing of electric vehicles.
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Desmond Armah-Hammond
Comment added June 17, 2021 11:34pmI will like to testify at the hearing on June 22 re: Battery Electric Vehicles.Good morning, my name is Desmond, and I have been a New York City yellow cab driver for the past 30 years. I’m very proud of my service. But I think it’s time for a change. I am very excited to be driving for Revel Electric because with this company I’m an employee, which means I receive a steady salary every time, which is an assurance that the family will be taken care of. It also means that I will receive healthcare benefits which are huge as almost all of you will agree with me. I will also receive paid vacation like I’m sure all of you do receive and paid time off. I think we should all agree that we leave this earth for our grandchildren (our children are already here) better than we came into it. And that is why Electric Vehicle is the way going forward to save our environment and planet. I and fellow Revel Rideshare drivers are standing ready to hit the streets to do what we love and enjoy doing best, to serve our people. Revel Electric Rideshare is leading the way. I strongly urge my good councilmen and women to support Electric Vehicles in this the most famous and beloved city that we all cherish.
Thank you.
Let’s go Yankees !!!!!” -
Darryl Johnson
Comment added June 18, 2021 1:45amI don’t support TLC changing the order to issue new plates to electric vehicles. It can be edited to only allow tlc drivers to get EVs and not big companies.
Don’t do away with the law, just make things right
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Fiz
Comment added June 18, 2021 9:50amI would like to said tlc should open up new licences or plates only for the independent drivers bot for companies. According to my research it seems like drivers are working to pay their car rents which nothing less then between $370 to $400 a week. Drivers running on the road in stress to keep the city moving so they should have chance have their hands on their own property. Stop these rental Mafia and open up TLC plates for independent drivers
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Farhan Haider
Comment added June 18, 2021 9:54amTLC must allow individual drivers to acquire electric vehicle plates. The big companies must not be allowed to monopolize the industry again! Will tlc finally do something for the drivers who are the backbone of this industry?
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imran saleem
Comment added June 18, 2021 10:05amTlc has first priority to tlc drivers for plates
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Daniel Anghelache
Comment added June 18, 2021 10:47amTLC drivers should be allowed to license there own electric vehicles.
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Md Hossain
Comment added June 18, 2021 10:59amWe should deserve own a electric vehicle.
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Albert Betemit
Comment added June 18, 2021 11:20amHello.
This rule should be approved to insure and incentivize the independent fhv operators to expand their operations. There should also be a cap for us independent operators of 2 to 5 combined of either of these wheelchairs and electric vehicles. As such this would not allow the independent operators to become a big company with a monopoly themselves. If and when approved the tlc should advertise through e-mail to the drivers already vehicle licensed of this opportunity.
Sincerely
Albert Betemit -
Mouhamadou Aliyu
Comment added June 18, 2021 12:20pmRespectfully, I urge the commission to vote on this issue, no more plate, no more vehicles, keep the cap. Electric or not the city and the industry can not afford more cars on the street of New York.
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Tobias Lescht
Comment added June 18, 2021 12:22pmCommissioners, thank you for the opportunity to testify today on this important issue.
Fast-charging infrastructure is required to drive EV adoption by all transportation sectors in the city including, for-hire vehicles, personal vehicles, and fleets — both owned by the city and private parties. Without sufficient access to public fast-charging, it will never make financial or practical sense to convert from gas to electric.
Currently, there are only two publicly accessible, free to park, fast chargers in NYC, aside from the JFK cell phone lot. To electrify New York’s two million cars and one million daily taxi and rideshare trips, we need to build more fast charging infrastructure.
Studies from the Green Mountain Institute, EVGo, and Lyft have all found that demand from rideshare is essential to making EV fast-charging stations financially viable. In one example from Denver, the rollout of 100 electric rideshare vehicles doubled the utilization of EVGo’s public charging stations in the city. Without the utilization that rideshare provides, it is prohibitively expensive for private companies and city governments to fund, operate, and scale EV charging infrastructure at a level that will truly change market behavior towards EVs. We must do all we can to encourage rideshare drivers to go electric. The cascading effect of building more public fast charging will encourage private car owners and other fleets to electrify as well, helping to meet the city’s environmental goals.
Currently, rideshare vehicles pollute our air at an alarming rate. Each gas-powered rideshare trip causes about 70% more greenhouse gases than the trips they displace.
The TLC’s Yellow Taxi EV pilot is a step in the right direction, but it will not solve NYC’s EV infrastructure or environmental problems. Because Manhattan is the main service area for Yellow Taxis, publicly funded charging infrastructure to serve them will be focused there, which will cause inequities across other boroughs and slow the rate of EV adoption outside of Manhattan.
The number of daily rideshare vehicles and rides outnumbers that of Yellow Taxis by nearly five to one. The goal needs to be electrifying both Yellow Taxi and rideshare fleets across the entire city.
Any new government-run initiative to get Yellow Taxis or rideshare fleets to electrify will take years to construct and implement and will have high taxpayer costs. The EV exemption is a $0 cost incentive that is putting EVs on the road today and encouraging fast charger development. While we support new incentives, they should not come at the cost of the EV exemption.
If the EV exemption is removed, there will be no incentive for rideshare drivers to buy EVs and very few drivers will make the transition. In turn, less charging infrastructure will be built perpetuating the city’s reliance on fossil fuels.
I urge the Commission to VOTE NO on this rule change and not to remove the best tool the TLC has to help electrify transportation in the City.
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Leslie Stevens, for the 350NYC.org Steering Committee
Comment added June 18, 2021 2:03pmWritten testimony from 350NYC.org Steering Committee:
Since 2018, there has been a “pause” on issuing new TLC licenses to operate for-hire vehicles, with an exemption only for those that are wheel-chair accessible or battery electric vehicles (EV). We at 350NYC are opposed to the current proposal that would revoke this exemption. Please VOTE NO.
We strongly believe that NYC must quickly transition to electric FHVs as a necessary and critical step towards achieving the important goal of electrifying the transportation sector.
In NYC, transportation contributes about 30% of greenhouse gas emissions, and is the second largest sector. A significant percentage of these emissions can be attributed to for-hire vehicles (FHV). A study by the NYC Mayor’s Office of Sustainability, between 2010 and 2018, showed greenhouse gas emissions from FHVs and taxis increased 66% as a result of the exponential growth of app-based FHV services like Lyft and Uber. Even today the FHV’s in NYC are basically all gas-combustion engine based, with less than .5% of FHVs electric in 2020. The gas-combustion engine problems: GHG’s, toxic pollutants from exhaust – are still here.
California has passed legislation mandating that all for-hire vehicles be electric by 2030, and New York should do this same. The Uber/Lyft “commitment” (non-binding) of all Electric Vehicles by 2030, should imply a gas-FHV ramp-down by a minimum of 10,000 vehicles/year to begin cleaning up the air and reducing the major GHG impacts. As of mid-2020 there were only about 250 fully electric FHVs in NYC. Getting to zero gasoline-FHVs must be significantly accelerated.
The City Council’s decision in 2018 to cap the number of new FHV licenses was a step in the right direction, but we strongly recommend that the City Council and TLC include specific caps which reduce gas-powered FHV’s, especially the gigantic SUVs. Gas-powered vehicles pose a huge threat to the health of our planet and endanger the health of our local communities. Exhaust emissions contain a range of toxic pollutants like carbon monoxide, nitrogen oxide, and particulate matter, which have been linked to high rates of asthma, heart disease, chronic bronchitis, and cancer. In Manhattan, FHVs, over 99% of which are gas-powered, spend roughly 42% of the time cruising without a passenger or idling while waiting for a customer. Idling engines can produce up to twice the amount of exhaust emissions as when the car is in motion. Unfortunately, the TLCs efforts to curtail the amount of time an FHV can spend cruising without a passenger failed in court.
We are running out of time to take action to prevent a Climate Catastrophe, and to bring down Greenhouse Gas (GHG) emissions from transportation in NYC.
It makes NO sense to revoke the exemption for electric vehicles now. It is incompatible with the City’s climate goals. It should not matter which FHV company is increasing the number of EV’s in the FHV market as long as the total FHV/taxi market has a heavily declining cap. We recommend that the TLC reduce drastically and quickly, the total number of gas-powered FHVs to improve sustainability, to reduce pollution quickly and to reduce congestion. We also request that the TLC create a separate cap for gas-powered FHVs and a cap for electric vehicles. This would allow the TLC to ensure a strong increase in EVs while quickly reducing gas-powered vehicles.
Although not the topic of this ruling, the biggest barrier to Electric Vehicles in NYC is the lack of public charging or fast-charging infrastructure. We hope the TLC and City Council will work to create a network of universal, economical, fast-charging stations.
We, the 350NYC.org Steering Committee are writing this testimony on behalf of our NYC members. 350NYC is a group of environmental activists focusing on local NYC climate issues. We are a grassroots organization of all-volunteers who advocate for political and social solutions. Our overall purpose is to drastically reduce greenhouse gas emissions and move towards a just transition in a renewable economy.
Signed
Leslie Stevens for the Steering Committee of 350NYC.org
Email: [email protected] -
Innocent independent contractors
Comment added June 18, 2021 2:23pmHey tlc it’s time to stop acting like fools and being smart behind the doors with these ride hailing’s companies and give plates to only full times drivers and take back all the extra plates they r sitting or they working part time
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mohamed elhoubba
Comment added June 18, 2021 2:53pmHello, my name is Mohamed Elhoubba,
I am now with team Revel. I took this job because I like the rules and the benefits for the employees, plus we can see the future close to us, and I want to say thank you to revel for this chance to work with them.
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Ngawang lama
Comment added June 18, 2021 4:45pmit’s drivers who deserve first and sole access to the right to own an electric or wheelchair accessible vehicle — not large fleets companies — as the TLC promised.AT last working class people are the once’s that sufferers. Have to rent from this big company and pay so much per week 350$to 600 $ plus gas. how does it sound if TLC collect 40 percent of plates from the big TLC rental company and distribute it to individual with electric and wav THAT WILL ALSO HELP IMPROVE THE AIR in NYC AND ALSO HELP LOT OF FAMILIES and also the number of car stay the same. Now that’s not gona happen because working people are the once’s who has to pay the price So my vote is NO. Drivers are suffering a lot from this rental company let’s keep this simple does it sound fear where a person can own a 100 of TLC PLATES IN A NAME OF COMPANY and a Harding working tax payer can’t even have once this is so called freedom AMERICA
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Frank Cicero
Comment added June 18, 2021 4:52pmDon’t you think it would be a good idea the first fix the yellow taxi problem before you start jumping around adding more cars and more congestion ?
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Chris Richardson
Comment added June 18, 2021 5:25pmDear Commissioners –
Attached are detailed public comments from Chris Richardson and Nigel Carr of ADL Ventures. A summary of those comments is below.
The TLC should consider the foundational role BEVs play in cleaning the air and improving health outcomes in New York City instead of eliminating BEV-based FHV exemptions that will be central to increasing the penetration of BEVs in the FHV fleet beyond today’s negligible share of <1%.
Because of the City’s higher baseline levels of pollution, the social cost of emissions in New York City is nearly twice as high as the national average, which means that each marginal pollutant impacts the health of New York City residents more than elsewhere in the state and elsewhere in the country. As such, BEVs (Battery Electric Vehicles) are a critical tool in protecting local health outcomes in New York City and the only way to rectify the City’s emissions problem.
While we agree with the argument that increased congestion leads to higher emissions today, this is only the case if NYC streets are populated with ICE (internal combustion engine) vehicles. If the City enacts policies to incentivize BEV adoption across the FHV fleet, the argument that congestion drives pollution weakens.
Further, media reports (NYTimes) suggest that the risk of having too many FHVs on the streets of NYC may be at a historic low, as less than half of the yellow cabs are on the road currently and rideshare drivers are down 32% from the beginning of the pandemic. Given the shortfall of FHVs due to the pandemic, summer 2021 may be the least effective moment to argue that too many for-hire vehicles are on the road. If the City currently needs more FHVs today to meet rider demand, why not encourage a portion of those vehicles to be fully electric?
Maintaining an incentive for BEVs to participate in the market will help New York City demonstrate 1) that it values the health outcomes of its residents and 2) that it intends to follow through on its GHG reduction and transportation electrification commitments.
Thank you,
Chris Richardson, Partner
Nigel Carr, PrincipalADL Ventures
Comment attachment
http://www.adlventures.com
ADL-Ventures-Public-Comment-on-BEV-Exemption-for-FHVs-June-18-2021.pdf -
Daniel A Costello
Comment added June 18, 2021 6:00pm“My name is Daniel Costello.
I have been working as a rideshare chauffeur for the past 5 years. I utilized the Uber and Lyft apps had my own private clients and started working for a medical transport company.
When I saw that the company Revel was looking for drivers. I knew I couldn’t pass up the opportunity to work for a progressive forward-thinking company that puts emphasis on bettering the environment by utilizing EVs. First successfully distributing mopeds throughout the NYC area to reduce the congestion issues NYC suffers from. Second monthly rentals for e-bikes. Which they offer door-to-door service, and Third to have the ambition and know-how on creating rideshare that will benefit the drivers with full-time positions including full medical benefits, retirement options, and paid time off. This is a big deal considering if a rideshare person needs to take time off they have to double their workload to compensate. Earning a steady income no matter the number of rides I complete reduces congestion because I’m driving less without a customer.
So in closing: Please allow EV vehicles to join the rideshare TLC of NYC. It will benefit us environmentally, This is the step forward all metropolitan cities need for a cleaner future. Plus Revel offers consistent work so I personally don’t have to juggle 3 different sources of income. You are also giving us a great opportunity to grow with a company that cares about the drivers.
I feel like this company has my back.
Please vote NO on removing the EV exemption. Thank you.”
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Naquan jacobs
Comment added June 18, 2021 6:15pmI’m a driver for Revel’s electric rideshare program and was very excited to get started as an employee earning a salary that comes with benefits and support staff. Something I haven’t had for the past 3 1/2 years being a rideshare driver. I’m a bit confused as to why the TLC is trying to pause us from serving the citizens of the city. To me it seems this is what the TLC waned. And that’s All-electric vehicles!”
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Muhammad Bilal
Comment added June 18, 2021 7:49pmKindly allow us to drive electric vehicles. Don’t pause on electric vehicles.
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Asif Riaz
Comment added June 18, 2021 7:55pmThat’s not fair pause on electric vehicles. I don’t think so tlc have concerns about traffic congestion. If you have concerns why you allow to corporations to renting non electric vehicles. Non electric vehicles are not suitable for atmosphere. Please don’t pause on electric vehicles.
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Amir Ilyas
Comment added June 18, 2021 8:01pmPlease don’t pause on electric vehicles. Otherwise drivers renting non electric vehicles from corporations. And non electric vehicles not good for atmosphere .and please mercy on drivers they can’t afford $400 or $500 rent for week. So kindly don’t pause electric vehicles.
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Eddie Terry
Comment added June 18, 2021 9:25pmmmissioners of the TLC:
My name is Eddie Terry and I drive with Uber in New York City. I’ve been a TLC-licensed driver since 2017, and I have been renting a vehicle, which costs me $365 per week. For the last 3 years I have been saving money to purchase an EV vehicle.
I am a substitute teacher and I earn supplemental income on Uber during the summer months. I recently applied for a Battery Electric Vehicle and am expecting it in less than a month! I was planning to get plates for it so I no longer have to rent to earn supplemental income.
I recently heard that you are considering changing the rule that would allow me to plate my own Electric Vehicle in the future, and I am writing to ask you to reconsider. If you remove the EV exemption, it would completely derail my plans to be financially independent and earn income to help make ends meet.
Right now, I can only earn on the platform if I fork over a substantial amount of my earnings to rental car companies. I want to be able to own my own car, and generate more earnings so that I can bring more support to my family.
Thank you.
Eddie Terry
New York City -
Leroy K Davis Jr
Comment added June 19, 2021 1:51amMy name is Leroy Davis and I drive with Uber in New York City. I’ve been a TLC-licensed driver for over 6 years, and for the past few years I have been renting a vehicle with the goal to save up enough money to own my own vehicle and plates one day. I feel as if I am being robbed each week by the rental companies.
I pay over $500 each week for my TLC rental car. I DONT have the option to own this vehicle. I am choosing to do so because I have hopes to one day own my on electric TLC plated vehicle. Having my own vehicle will allow myself and other driver’s the opportunity to truly become a self employed business owner.
I am highly motivated and invested in my goals but this law would hurt drivers like me who are seeking to pursue their dreams as a small business owner. By owning my own vehicle and plates, I’d have my own business where I can position myself for longevity but this rule change by the TLC is disempowering drivers like me by limiting me from doing that.
I am writing to ask you to reconsider because right now there are only two options for me to ever plate my own vehicle, and stop paying hundreds of dollars a week to rent a car.
By taking away the EV exemption, it means my only option would be a vehicle equipped to move wheelchairs, which doesn’t make sense for me to also use as my personal car. I have a family of 4! I need my own vehicle for work and for personal use. Thats why an electric vehicle would be ideal!
Right now I can only earn on the platform if I fork over a substantial amount of my earnings to rental cat companies. Please do not pass this rule so that I can continue to focus on saving for small business and eventually own my fleet one day.
Thank you.
Leroy K Davis Jr.
Bronx -
diego cordora
Comment added June 19, 2021 11:58amFirst I would like to say that it’s a shame that you want to take way the ability for individual drivers to continue to have the opportunity to own the own plates through the EV program. That system as you claimed was to decrease carbon emissions in the air. Now you are closing it for us because you want to block big business. Stop trying to make us rent rather than own our vehicles. I am opposed to your choices, you are repeating what you did with the yellow cabs owners. We want you to do the right thing and allow us the opportunity to own our plates. US not BIG BUSINESS>
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Toudonou
Comment added June 19, 2021 1:17pmI am an independent contractor asking for us to have the option to get EV plates, please don’t punish us, we should have the right to have a plate and EV’s are one of the only ways for us to continue to be free of rental companies high charges.
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Sarin Rimal
Comment added June 19, 2021 2:24pmallow drivers to get ev plates. no plate of any type for rental companies or revel!
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Islam
Comment added June 19, 2021 2:59pmI am asking you TLC to not punish me by taking away the ability for me to get a EV vehicle plate. It isn’t fair, why will you take away the only chance I have to get my own plate. Big Business will win, not the independent contractor. Pay attention to the your failures of the pass with Yellow cab. Now you are trying to do it to us. Please stop and pay attention to what independent contractors really need is to stay independent and have the ability to get our own plates not RENT>
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Michele
Comment added June 19, 2021 3:43pmI’m a proud Independent Contractor serving the riders with pride. I am disappointed in the new rule you are trying to pass by taking away the ability for FHV drivers to get EV plates. This is one of the few options we have to be independent in order of RENTAL Companies who cheat us and with their high fees. Why not keep the plates available for only individual owners NOT Leasing Companies or Big corporations. Do what you said you made EV an options for the environment. Put Drivers FIRST>>>>>>
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Michele Dottin
Comment added June 19, 2021 3:47pmI am asking you TLC to put the FHV driver first. We deserve the right to get plates and EV’s are one of the only two choices we have. Why punish us by taking away the right to be free of Rental and Leasing companies who charge use huge fees. Put the DRIVERS first not corporations. Give the EV options only to INDIVIDUAL DRIVERS not corporations who use loopholes to bet the system. You missed it with Yellow’s nor correct it with FHV drivers.
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Mousa
Comment added June 19, 2021 3:51pmI am asking for EV plates to be available to individual drivers, we need the option to have our own plates and EV’s is one the only real options as the future will be Electric Vehicle as independent contractors we need to have this open to us. Close the corporation option NOT the FHV Drivers. We need to be free of RENTAL and LEASING companies exploits…
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Daniel
Comment added June 19, 2021 3:55pmIt’s a shame that you are planning on taking away my right to get an EV plate. We work hard to save money in order to get a plate of our now. You made the plate more valuable than the driver, now we need you to make us more valuable by having the ability to get an EV plate and be free of Rental and Leasing companies. DRIVERS FIRST…..
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TUK
Comment added June 19, 2021 3:58pmI need the ability to get plates and EV’s is one of the only reasonable option I have to get independence from Rental and Leasing Companies. Please allow us FHV drivers only to get EV plates not big corporations. Put us first…
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Malik Zafar
Comment added June 19, 2021 5:09pmHi. Please allow ev plates for drivers not corps.
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Rashid
Comment added June 19, 2021 5:11pmYou idiots. Allow ev plates for drivers not corps it’s that simple. Drivers have been telling u this since day one
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Benjamin Mandel
Comment added June 19, 2021 6:07pmChair Heredia Jarmoszuk and Commissioners:
Thank you for the opportunity to comment on the proposed amendment of rules governing issuance of for-hire vehicle (FHV) licenses by the Taxi & Limousine Commission (TLC). CALSTART opposes the proposed amendment to remove the electric vehicle (EV) exemption for FHV license issuance. While we agree that roadway congestion is a paramount policy issue for New Yorkers’ air quality and standard of living, we urge the TLC to address this imperative through other means than by foreclosing opportunities for the EV ecosystem to develop. The persistently low EV adoption rate in New York City is a problem that demands more—not less—policy support and directed investment at this critical inflection point.
CALSTART is an internationally recognized nonprofit clean transportation technology consortium, with more than 280 members all dedicated to the growth of the clean transportation industry. CALSTART works with the public and private sectors to drive innovation in clean vehicles and mobility. Our membership includes vehicle manufacturers, suppliers, infrastructure providers, fleets, low-carbon fuel producers, utilities, investors, and more. CALSTART has seven offices across the country, including our Northeast Regional Office in Brooklyn, NY.
CALSTART ran a NYSERDA-sponsored workplace charging incentive campaign from 2017-2020 in recognition of the structural impediments to EV adoption in and around New York City—namely the heavy reliance on either on-street parking or shared garages that are not configured to support dedicated chargers. Despite the installation of 130 plugs in lower New York through this program, the same structural issues persist and more high-throughput infrastructure support is urgently needed.
We applaud the TLC for its efforts in recent years to advance two major policy priorities for New York City, reining in roadway congestion by freezing FHV license issuance while encouraging a shift in the FHV fleet toward electric vehicles (EVs) by exempting EVs from this freeze. While this exemption has not been widely utilized—currently less than 0.5% of FHV on New York City roads are electric—the need to transition more of the on-road fleet to EVs grows more pressing by the day. And recognizing that FHVs drive more miles than do typical passenger vehicles, focusing efforts on incenting and supporting FHV electrification will deliver the greatest benefits to New Yorkers by maximizing electric miles as well as avoided emissions from on-road cars.
Despite Mayor de Blasio’s announcement in September 2017 that the City would build fast charging hubs in each borough to catalyze uptake of EVs citywide, the City has moved slowly to put in place the infrastructure necessary to support meaningful adoption of EVs. Nearly four years after that announcement, the City has yet to open any of the proposed fast charging sites in DOT-operated lots and garages. Moreover, the private sector has not adequately filled the gap on its own; there are currently only nine fast charging sites throughout the five boroughs, including three that are part of a DCAS pilot and one site built by the New York Power Authority (NYPA), and several of the nine feature only one or two plugs.
The all-EV rideshare service recently announced by Revel provides precisely the sort of investment the City has been lacking, providing a credible pathway to make the benefits of electric vehicles more accessible to drivers and FHV customers alike. Revel’s first Superhub in Brooklyn will be the largest fast charging installation in New York City and can scale to be even larger, accommodating not just Revel ride-hail vehicles but also private cars and potentially freight uses. Alongside the NYPA fast charging site at JFK Airport intended for FHV drivers, these well-situated and large-scale fast charging sites can make FHV electrification not just viable, but more economic than using conventional cars in FHV service. With convenient locations, reliable access to a plug, and a quick charging experience, FHV drivers could begin to transition their millions of miles each year in NYC from polluting gasoline to clean electricity.
We urge the TLC to reject this proposed rule and to retain the EV exemption indefinitely. Doing so will send the strong signal to the private market that New York City is open for EV investment and innovation. We do understand and support the City’s emphasis on congestion mitigation, but submit that this burden should fall not on low-impact, high-performance EVs but rather on non-electric FHV service.
Thank you for the opportunity to comment on this important matter.
Sincerely,
Benjamin Mandel
Comment attachment
Northeast Regional Director
CALSTART
67 35th Street
3rd Floor, Suite C356
Brooklyn, NY 11232
CALSTART_Comments-on-TLC-proposed-BEV-amendment.pdf -
Raghu Sudhakara
Comment added June 19, 2021 9:11pmJune 18, 2021
Taxi and Limousine Commission
33 Beaver Street
New York, NY 11201Re: Comments to the TLC’s Proposal to Amend Rules Related to Battery Electric Vehicles
Dear Commissioners:
Consolidated Edison Company of New York, Inc. (Con Edison) submits these comments to the Taxi and Limousine Commission’s (TLC) proposal to amend its rules relating to the issuance of for-hire vehicle (FHV) licenses to battery electric vehicles. As part of our Clean Energy Commitment, Con Edison is committed to leading and delivering the transition to the clean energy future in support of the ambitious climate goals of New York City and New York State. In support of these carbon reduction goals we have developed the country’s second largest electric vehicle (EV) charging infrastructure program to reduce infrastructure costs of EV chargers and have also partnered with the New York City Department of Transportation to develop and pilot curbside EV chargers across all five boroughs.
Large scale adoption of EVs is essential for New York City to achieve its climate goals, reiterated in a recent study published by the City of New York and its utility partners1. A clean transportation system also brings additional benefits including improved health outcomes from reduction of localized air pollution and noise levels. Access to clean and efficient transportation, which can include transit, EVs, and improved biking and pedestrian infrastructure, will be key to realizing such benefits.
Range anxiety due to insufficient access to EV charging has been widely recognized as a leading barrier to EV adoption, and it is a particularly acute challenge in our dense urban environment. The development of easily accessible, geographically diverse, and visible charging infrastructure across the city will be critical to driving EV adoption. In order for such charging infrastructure buildout to be economically viable, costs need to be spread over a minimum predictable baseline usage of the chargers. This baseline use of chargers is possible when they serve EVs who have consistent and significant charging needs on an ongoing basis, such as taxis and FHVs. And in a virtuous loop, an increase in the number of chargers supported by such higher use vehicles that are also open to the public can enhance confidence among the public, a majority of which are renters without access to in-home charging, to adopt EVs and thus facilitate a faster transition needed to meet our climate goals.
Con Edison kindly requests that the TLC reconsider the potential impacts of this rule change from an environmental perspective. Meeting the goals of a low carbon future entails using all the policy tools and levers available to facilitate an electrified transportation system. We stand ready to assist the TLC and the City as it continues to transition internal combustion engine vehicles to EVs to reach our climate
goals.Thank you for your consideration.
Sincerely,
Raghu Sudhakara
Comment attachment
Director, Demonstration Projects
Con-Edison-Comments-to-TLC-Proposed-Rule-Change-for-EVs_June-18-2021.pdf -
Raghu Sudhakara
Comment added June 19, 2021 9:13pmJune 18, 2021
Comment attachment
Taxi and Limousine Commission
33 Beaver Street
New York, NY 11201
Re: Comments to the TLC’s Proposal to Amend Rules Related to Battery Electric Vehicles
Dear Commissioners:
Consolidated Edison Company of New York, Inc. (Con Edison) submits these comments to the Taxi and Limousine Commission’s (TLC) proposal to amend its rules relating to the issuance of for-hire vehicle (FHV) licenses to battery electric vehicles. As part of our Clean Energy Commitment, Con Edison is committed to leading and delivering the transition to the clean energy future in support of the ambitious climate goals of New York City and New York State. In support of these carbon reduction goals we have developed the country’s second largest electric vehicle (EV) charging infrastructure program to reduce infrastructure costs of EV chargers and have also partnered with the New York City Department of Transportation to develop and pilot curbside EV chargers across all five boroughs.
Large scale adoption of EVs is essential for New York City to achieve its climate goals, reiterated in a recent study published by the City of New York and its utility partners1. A clean transportation system also brings additional benefits including improved health outcomes from reduction of localized air pollution and noise levels. Access to clean and efficient transportation, which can include transit, EVs, and improved biking and pedestrian infrastructure, will be key to realizing such benefits.
Range anxiety due to insufficient access to EV charging has been widely recognized as a leading barrier to EV adoption, and it is a particularly acute challenge in our dense urban environment. The development of easily accessible, geographically diverse, and visible charging infrastructure across the city will be critical to driving EV adoption. In order for such charging infrastructure buildout to be economically viable, costs need to be spread over a minimum predictable baseline usage of the chargers. This baseline use of chargers is possible when they serve EVs who have consistent and significant charging needs on an ongoing basis, such as taxis and FHVs. And in a virtuous loop, an increase in the number of chargers supported by such higher use vehicles that are also open to the public can enhance confidence among the public, a majority of which are renters without access to in-home charging, to adopt EVs and thus facilitate a faster transition needed to meet our climate goals.
Con Edison kindly requests that the TLC reconsider the potential impacts of this rule change from an environmental perspective. Meeting the goals of a low carbon future entails using all the policy tools and levers available to facilitate an electrified transportation system. We stand ready to assist the TLC and the City as it continues to transition internal combustion engine vehicles to EVs to reach our climate goals.
Thank you for your consideration.
Sincerely,
Raghu Sudhakara
Director, Demonstration Projects
Con-Edison-Comments-to-TLC-Proposed-Rule-Change-for-EVs_June-18-2021-1.pdf