Rule status: Proposed
Comment by date: September 19, 2023
Rule Full Text
The Taxi and Limousine Commission is proposing the Green Rides Initiative, which aims to increase the number of zero emission vehicles and wheelchair accessible vehicles in the high-volume for-hire fleets.
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- Mail: Taxi and Limousine Commission, Office of Legal Affairs, 33 Beaver Street Room/Floor: 22nd Floor ; New York, New York 10004
September 20, 2023
10:00am - 11:00am EDT
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Comments are now closed.
Online comments: 27
Jose Nolveiro Canon
I think is an excellent idea so I hope some help from the state or federal to buy those zero emission cars
I applaud NYC and the TLC for pushing these rules forward but there is not enough clarity or incentives in this proposed rule around charging infrastructure. The TLC links to one article highlighting Revel’s development plans but was analysis done that shows that Revel’s infrastructure alone will meet these ZEV goals? What is NYC/TLC/NYCEDC doing in terms of working with developers to help them develop city property in convenient locations for drivers? 50% of NYC’s vehicles park on the street which should hold true for TLC drivers. Where will these drivers charge without home charging and how is DOT supporting the development of charging besides the curbside program with FLO? Curbside L2 charging is not suited or reliable enough for high milage TLC drivers.
Additionally, the rule is forcing Uber/Lyft to electrify but they don’t own any vehicles which puts the onus on large fleets to buy electric and for Uber/Lyft to inceltivize them to do so. As someone with close ties to the fleets, I have not seen any solid indication that HVFHS will come out of pocket and the fleets are not interested in electric at this point which leaves us in limbo. The rule assumes developers will build multi-million dollar sites without guarantees (or some reasonable forecast) of vehicle utilzation – this situation is not investible and difficult for the majority of developers to overcome. Utility incentives help with some of this development cost but there is still significant utilization risk.
I have spoken directly to the largest fleets in NYC who have all experimented with EVs and the #1 reason drivers return EVs is because of the lack of charging infrastructure. IMHO, I would focus incentives and rule-making to encourage the build-out of street-level, fast charging in garages, parking fields, gas stations, shopping centers, and city property. The lack of EV growth thus far is a problem that stems from the lack of supply of convenient charging. Building adequate, ubiquitous infrastructure will give drivers comfort to know they can get a fast charge when they want it and get back out on the road.
Founder and CEO
Outpost Energy Development
I like the idea of all EV vehicles
But how is the average driver gonna afford it where are we gonna charge all these EV vehicles the infrastructure
Can’t handle it you have to have a vote among the drivers let the drivers decide it’s not fare if this becomes law without the drivers input
This is a great idea and a way to have the TLC folks focus on transitioning to a greener less costly vehicle.
Great idea; however as an TLC driver I face challengers to replace my vehicle to EV as follows:
– EVs is totally NOT affordable to purchase; govt should provide more incentives than $2000 to encourage TLC drivers to switch
– EVs is high maintenance. While charging is cheaper than gas; however the battery life is gone after 5 years or so then has to replace the battery for over $10,000 is ridicules, which costs more than using the gas of 5 yrs alone.
– While DOT is asking for charging stations recommendations, until the city has charging stations so convenient like the current gas station mapping available, otherwise it’s not feasible as TLC vehicles drive all day, everyday! Also I live in apartment building where I can’t install a charging station at home. Any solutions?
– Should have tax deductible incentive to use as an FHV EV every year as we are making effort to make the whole city green and serve the public; rather than only incentive to purchase (come on, $2000 is nothing comparing the $10,000 to replace battery 5 years later!)
Are you sure in 6 years that the plan is feasible as the charging station mapping and EV pricing gonna be dropped? Gov’t should negotiate the EVs deals with the manufacturers to benefit the TLC drivers and for the city’s green effort sake to ease the pain, speed up the plan, and show that you really want this to happen in actual world. We are only making minimal income already, ask all New Yorkers who can afford an EV right now, then work your way down to find solutions to have the TLC drivers to replace a higher price tag and higher maintenance EV then gas. It’s not only saying to make the world better, it is the actual workable detailed plan to make things happen. TLC drivers should not pay from our own pocket ALONE and sacrifice their family digestible food to make the world better while the government/TLC/riders/passengers/base don’t care and won’t contribute a penny to help.
I suppose there is indeed a kind of chicken & egg situation. No more EVs w/o more charging stations; no more charging stations w/o more EVs So let us either do nothing — or take a chance that more EVs will in turn & in a short time lead to developing more charging stations!
There are complications around expanding an EV fleet, to be sure, but the alternatives seem to be to do nothing — or begin adding more EVs & hope & trust that the market & gov’t persuasion will smooth out some of those complications. At the end of the day, we need more EVs (& fewer gas guzzlers) on city streets.
More wheelchair accessible – good idea. Zero emission – bad idea. Therefore, against the proposal.
This sounds like a great idea. Also, any time the city tries to improve pedestrian or cyclist safety by adding bike lanes, daylighting, etc., (and in the process, removing a small % of parking spaces) or providing NYCers with more ability to bike through the city (i..e, Citibike racks), certain die-hard car-owners – who resent that their selfish, car-centric ways need to change…that the city needs to Take Back more public space for pedestrians and cyclists… these particular ‘car people’ love to say how all of this is ‘unfair’ to the disabled (who apparently have ‘no other way’ to get around but by driving themselves everywhere). So then…these same ‘car people’ should applaud this proposal, since it will help the very same individuals that ‘car people’ profess to care so much about. 😉
Jose R. Polanco
Let us get are own licence plates for e cars. I paid every week a lease to own $675
TLC NEED NEED TO BE MORE REALISTIC. ALL EV BY 2030 IS IMPOSSIBLE.
I think it’s an excellent step taken by TLC. TLC should open up future car licenses to EVs only.
I strongly support the Green Rides Initiative and believe that promoting electric vehicles (EVs) is crucial for a sustainable future. As a driver, I am committed to reducing my carbon footprint and would greatly benefit from an EV plate to facilitate my transition to electric transportation. Please consider my request for an EV plate to support eco-friendly transportation alternatives. Also I renting car $550 if it approve and get a own plate it will help for us.Thank you.
I am a long term rentar in NYC and would like the opportunity to plate my vehicle.
Syed Murtaza Hussain
They should give the TLC license plate electric or WAV to every single person because drivers life is really hard specially at that time when inflation is so high it’s really difficult to pay extra money to the garage MAFIA for no reason thanks
Yes I want green Rides
Looking for green Rides
I write to offer my perspective on the proposed Green Rides Initiative, which aims to increase the presence of zero-emission and wheelchair-accessible vehicles in high-volume for-hire fleets. While I support the environmental goals of this initiative, I believe there are additional measures that could be considered to further facilitate the transition for drivers.
Firstly, I recommend that the TLC explore the possibility of arranging no-interest or low-interest loans for drivers seeking to upgrade their existing vehicles to comply with the proposed regulations. Such financial assistance would alleviate the initial financial burden on drivers, enabling a smoother transition to zero-emission or wheelchair-accessible vehicles.
Secondly, I propose that the government explore potential subsidies for taxes and fees associated with the acquisition of electric vehicles. This incentive would not only make electric vehicles more financially accessible for drivers but also promote the broader adoption of sustainable transportation solutions.
Lastly, I urge the TLC to engage in collaborative discussions with industry stakeholders such as Uber and Lyft to establish comprehensive guidance and resources for drivers navigating the transition process. By leveraging the collective expertise and resources of all involved parties, we can develop effective strategies to assist drivers in affording the costs associated with upgrading their vehicles.
I appreciate the TLC’s commitment to environmental sustainability and accessible transportation services, and I believe that these suggested measures can further enhance the effectiveness and inclusivity of the Green Rides Initiative.
Thank you for considering my comments. I look forward to the continued progress towards a more sustainable and accessible transportation ecosystem.
I started a lease to own dec 2019 where I also payed 665$ a week for two years lease to own and when I finished the supposed freeze was extended and it’s almost 2024 so the company took the plate, Which defeated the purpose of why we choose lease to own to become our own buisness owners. I also applied for the ev lottery within the first minute. And I was put on a waiting list. So I have a payed off vehicle with no plate. So I forced to rent again because now leasing to own is 700$ a week and more. Robbery. And no one is standing in the gap for us drivers. How are there no plates but these companies keep getting more plates and us drivers who have already payed and sacrificed can’t.
I am submitting these comments on the Green Rides Initiative on behalf of my company, It’s Electric Inc.Comment attachment
In the midst of a rapidly increasing climate crisis, we must do all we can to mitigate emissions. The proposed Green Rides Initiative, which will require all 78,000 Ubers and Lyfts to be electric or wheelchair accessible by 2030, is an important step in that direction. While Open Plans does not believe that EVs are the only or the best way to reduce emissions, we support this initiative as one piece of the puzzle.
EVs offer significantly lower maintenance and fueling costs over the lifetime of the vehicle, and they can eliminate many of the fumes rideshare drivers are exposed to during their long shifts behind the wheel. EVs will reduce air pollution from emissions (though it’s important to note that they still produce particulate pollution from heavy tires and additional wear on the street). Yet, mandating the transition and easing drivers through the transition are not the same. Six years is not a long timeline for drivers to make the switch. And with EV prices still higher than an average gas car and charging access lacking citywide, the switch to EVs could be an onerous proposition.
To ease the burden, rideshare drivers deserve to receive additional relief from the City and the companies they work for. The City should equip some private parking garages with fast charging stations.Rideshare drivers should get discounted charging at city-run sites. Additionally, many drivers are locked into seven-year leases. If they entered into one this year with a gas car, that means they are already missing the 2030 deadline. There should be a lease buyout or conversion program established to financially assist drivers in acquiring EV leases.
Drivers also need regulatory incentives. Most rideshare EVs today are the result of special issuances of EV-only licenses by the Taxi & Limousine Commission (TLC). TLC licenses regularly expire as drivers stop using them, including over 3,000 that lapsed last month. The TLC should immediately reissue expiring licenses as EV-only licenses, thereby creating guaranteed pathways for EV adopters to earn fares without raising the total number of rideshare vehicles operating.
Even a widespread switch to EVs will not prevent a climate crisis – only a shift away from cars and toward mass transit and walkability will do that. Which is why it’s essential that our public space – streets, curbs, plazas, sidewalks – not be used for car infrastructure of any kind. This space must remain available for the variety of uses that encourage truly dense, livable streets – traffic calming treatments, pedestrian amenities, bus lanes, micromobility lanes, outdoor dining, greenery, and more.
Fewer cars on New York’s streets is a quality of life victory. Crossing the finish line means ensuring that every car remaining is electric, especially rideshare vehicles.
I have TLC license and purchased EV without any incentives – just because I wanted that and believe it’s better for the city and communities.
But I don’t drive for hire – I don’t have TLC plates and it’s extremely hard to even rent the plates. Only one really available option for drivers like me – leave my EV at home and rent an old gasoline car from a corporation!!!
So isn’t obvious what TLC administration must do about it???
Take TLC plates out from corporations and give it to drivers owners the EVs!!!
Extremely simple solution.
Revel and American Leasing should be DENIED licenses for registering new EV cars. Revel leases their Teslas from American United Transportation inc (AKA American Lease & Management 1165 Ogden Ave. Bronx, American United Transportation INC. 640 S. Conduit BLVD, plus a few othersI found during a corporate search.)
American Leasing and Revel do not have legitimate insurance. Instead of insurance they have a law firm. The name of the law firm is Abrams Fensterman. They maintain a desk and a website which uses the name Affirmative Direct Insurance. The name is registered as an insurance company. However it has no assets or governance like an insurance company. That is so that if one of American Leasing Vehicles gets into a crash, the other side’s insurance company has to deal with a law firm that will drag things out until the injured person gives up. Revel, the company known for using only EVs and which are mostly blue Teslas leases their cars from American Leasing (also known as the entities noted above)
Revel and American Leasing should be denied any other licenses and consideration of any kind until they are proven to have and maintain a legitimate insurance policy not one that is an insurance company only on paper.
I bring this up because my legit insurance company, GEICO has been suing American United et al to recover the cost of fixing my car which was heavily damaged by a ride share driver who was leasing a black Camry from American United Transportation Inc. It is now MORE than two years and the case is still in litigation with the law firm that owns Affirmative Direct, Abrams Fensterman. These are bad people who have no regard for the safety and health of drivers and passengers who are not associated with Abrams Fensterman. They are protecting a company that will not take legal responsibility for their actions.
Please deny them the licenses they seek.
I am writing to express my concerns regarding the proposal to introduce zero-emission for-hire vehicles in New York City, specifically as part of the Green Rides Initiative. While I understand the importance of reducing emissions and promoting sustainability, I believe there are several factors that need to be considered before implementing such a program.
Firstly, I am concerned about the practicality of transitioning to zero-emission vehicles for for-hire services in a city as densely populated as New York. Electric vehicles (EVs) have limitations in terms of range and charging infrastructure, which could potentially lead to service disruptions and inconvenience for both drivers and passengers. This might result in longer waiting times and decreased reliability of for-hire transportation services, which could negatively impact residents and visitors who rely on these services daily. As a result hurting drivers’ earnings.
Furthermore, the cost of transitioning to zero-emission vehicles can be prohibitive for many drivers and fleet operators. EVs are generally more expensive to purchase upfront, and while there may be incentives available, the financial burden of acquiring and maintaining these vehicles could be a barrier for owners/operators in the for-hire industry. It’s crucial to consider the economic implications and potential hardships this may impose on individuals and businesses.
In addition, the current state of EV charging infrastructure in New York City is not sufficiently developed to support a large-scale transition to zero-emission vehicles. Installing charging stations in densely populated urban areas is a complex and costly endeavor that requires careful planning and investment. Without a well-established charging network, the practicality of operating EVs in a for-hire capacity remains a significant challenge.
Lastly, it’s essential to acknowledge that zero-emission vehicles are not a one-size-fits-all solution for all transportation needs. Some for-hire services, such as larger vehicles (I drive minivan) used for group transportation or trips requiring longer distances, may not yet have viable electric alternatives. Rigidly mandating zero-emission vehicles across the board could limit the diversity and flexibility of services available to the public.
In conclusion, I believe that while reducing emissions and promoting sustainability are vital goals, the implementation of zero-emission for-hire vehicles in New York City should be approached cautiously and thoughtfully. It is crucial to consider the practical challenges, economic implications, and the readiness of infrastructure before moving forward with such a significant transition. I hope these concerns can be taken into account during the decision-making process.
Thank you for your attention to this matter, and I look forward to any opportunities for further discussion and dialogue on this issue.
Electric Vehicle price of more than $30,000 is unfair for the TLC drivers.
I have been a long time TLC license holder and been driving rented Tlc plate vehicle. And I’ll appreciate TLC if I have my own talc plate. Thanks
Annexed in a PDF are my comments. If you have any questions, please email me at firstname.lastname@example.org or telephone me at 917-576-0225.
Treasurer & Board Member of
Disabled In Action of Metropolitan New York, Inc.
Email address: email@example.com