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Regulatory Reform Philadelphia’s Taxicab & Limousine Program

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Regulatory Reform Philadelphia’s Taxicab & Limousine Program. Presented by: James R. Ney, Director Taxicab & Limousine Division Philadelphia Parking Authority IATR Conference –Washington D.C. November 17, 2012. Background.

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regulatory reform philadelphia s taxicab limousine program

Regulatory ReformPhiladelphia’s Taxicab & Limousine Program

Presented by:

James R. Ney, Director

Taxicab & Limousine Division

Philadelphia Parking Authority

IATR Conference –Washington D.C.

November 17, 2012

  • PPA assumed regulatory authority for taxicabs and limousine service in the City of Philadelphia in April 2005 as a result of passage of Act 94 of 2004
  • Regulatory program comprehensive in nature.
  • First time regulatory oversight of key components such as Dispatch Companies, Financial Service Providers including brokers, lenders and insurers.
  • In-house state inspection of taxis twice annually with emissions testing.
the industry
The Industry
  • Previously regulated by the Pennsylvania Public Utility Commission, the Philadelphia taxicab and limousine industry includes:
    • 1600 medallion taxicabs owned by 800 companies
    • 1000 limousines owned by 150 companies
    • 5000 drivers most of whom are independent operators
    • 14 dispatch companies to one of which each medallion taxicab must be a member
    • Six partial rights taxicab companies with operating territories straddling sections of the City and the suburbs
locally promulgated regulations
Locally Promulgated Regulations
  • PPA strictly considered a local agency at the time.
  • Numerous meetings held with industry and riding public stakeholders to gain input.
  • Regulations included higher vehicle standards with mileage restrictions, stricter inspection requirements, better driver training, industry financial service provider requirements.
  • Regulations approved by PPA Board in time for transfer of regulatory authority from PA – PUC to PPA in April, 2005.
hospitality initiative
Hospitality Initiative
  • Act 94 of 2004 also included funding for PPA to make taxicab service in Philadelphia “more consumer friendly”
  • PPA, in consultation with stake holders of local taxi service, determined that updated technology should be purchased and implemented
hospitality initiative1
Hospitality Initiative
  • RFP for Philadelphia Taxi Technology issued in October 2004
    • Sought a single vendor to provide a turn-key system that could provide the following:
      • Automated - Coordinated Dispatch System
      • GPS based
      • Navigation assistance for drivers
      • Panic button for driver safety
      • Credit/Debit card processing
      • Consistency
hospitality initiative2
Hospitality Initiative
  • Signed Contract with Taxitronic (VTS) in Feb. 2006
  • Sought and obtained an additional appropriation of funding from the legislature in April 2006 for a now $4 million contract which included:
    • Up to date equipment programmed to work only as an integrated unit in the vehicle in which it was installed
      • Tamper proof meter which provides printed receipts with all trip information
      • MDT’s (MX870) with voice navigation, text messaging, system training and moving map display
      • Passenger compartment payment center
hospitality initiative3
Hospitality Initiative
  • Off the shelf and customized software
    • Trip and driver tracking
    • Remote shut-off of driver
    • Coordinated dispatch
  • Installation, support & maintenance, training
  • Uses cellular rather than radio technology
  • Provides driver non cash payment processing at 5% per transaction. Prior to this, cashiering was handled by Dispatch Companies at 10 – 12 % per transaction.
costs for system
Costs for System
  • Total cost of $4.06 million
  • Per vehicle cost of $2,600 fully paid by appropriation of the legislature from the medallion fund
  • Dispatchers pay $500 per work station for software and purchase their own PCs and other associated hardware
  • Medallion owners pay $18 per month per medallion for air time/communication costs. Collected by PPA and paid to VTS.
  • Drivers pay nothing other than per transaction credit card fee
installation and system integration
Installation and System Integration
  • Began in Spring 2006 with installation of approximately 30 “early adopter” taxis
  • Installation of first four Dispatchers’ affiliated taxis in July 2006
  • All taxis installed by end of 2006
legal challenges
Legal Challenges
  • From 2005 to 2009, lawsuits filed by every segment of industry – either won by PPA or dropped by industry.
  • In Feb. 2009, the PA Supreme Court overruled the PA Commonwealth Court to determine that the PPA was a State rather than local agency for purposes of judicial jurisdiction when acting in its capacity as regulator of Philadelphia taxicabs and limousines.
  • In April, 2010, the Commonwealth Court determined that the PPA’s Taxi & Limo regulations were invalid because they were not promulgated in accordance with the Commonwealth Documents Law.
legal challenges new regulations
Legal Challenges – New Regulations
  • While validity of existing local regulations remained under appeal to PA Supreme Court, PPA Gen. Counsel and TLD drafted new regulations in the format of those issued by all PA State Administrative Agencies.
  • The 156 pages of regulations were released by the Authority in November, 2010 to the PA Independent Regulatory Review Commission to begin the extensive vetting and review process.
new regulations
New Regulations
  • After one full year marked by several comment periods after which modified regulations were released in response, the final form regulations were approved by the IRRC and finally the Attorney General on 11/10/11 and published in the PA Bulletin on 12/3/11.
  • An order was passed by the PPA Board stating that the new regulations would be used henceforth in lieu of the local regulations whatever the outcome of the pending Supreme Court deliberation.
new regulations1
New Regulations
  • Several “wish list” regulations initially included in the proposed regulations, such as lowering the allowable age of taxis to remain in service from eight years down to five and allowable mileage for service entry from 135,000 miles down to 15,000 miles had to be removed in the interest of avoiding protracted conflict in the interest of saving time.
    • Possibility was always present that PPA-TLD would have to shut down if an adverse decision was handed down by the Supreme Court before new Regs. were approved.
stronger regulatory body
Stronger Regulatory Body
  • Lost no ground in terms of what was implemented under the old (local) regulations.
  • Codified once and for all many provisions on which industry continually questioned PPA-TLD authority.
  • Emphasized responsibility of medallion owners over all aspects of taxicab operation.
  • Made some other improvements that industry and TLD were in agreement would benefit everyone such as separate drivers’ certificates for taxi and limo drivers.
  • Established a rock solid base on which future rulemaking endeavors and or initiatives could be confidently launched.
moving forward in 2012 hospitality initiative
Moving Forward in 2012 Hospitality Initiative
  • Replacement of all outdated taxi technology/GPS/credit card equipment with faster, more efficient equipment and software with interactive “Taxi TV” by December, 2012.
  • Negotiated reduction to 5% per transaction fee paid by drivers to 4.35%.
  • Conclusion of single vendor contract and allowing multiple technology vendors to serve the market under strict guidelines set forth by PPA-TLD by June, 2013.
moving forward in 2012 act 119 signed into law july 5 2012
Moving Forward in 2012Act 119 – Signed Into Law July 5, 2012
  • PPA backed legislation authorizing issuance of 15 new wheelchair accessible medallions for sale each year for the next ten years.
  • Requires substantial compensation and incentives for drivers during and after the certification process.
  • Regulations are currently being drafted with the assistance of the IATR with the aim toward submission of proposed regulations to IRRC just after the New Year.
  • Modifies language in our enabling legislation, Act 94, to allow installation of either safety shields OR cameras as crime prevention measures in all taxicabs.
moving forward in 2012 electronic testimony
Moving Forward in 2012Electronic Testimony
  • Nearly concluded promulgation of a new regulation under the IRRC process which allows witnesses who can demonstrate a certain degree of difficulty in attending a hearing at TLD headquarters to participate by skype or telephone.