🤔 400 New EV Plates Reserved For Business Are Open To "Anyone"
🤔 400 New EV Plates Reserved For Business Are Open To "Anyone"
NYC TLC has begun to reveal more details about its plans to distribute 1,000 NEW EV-Only FHV Licenses (a/k/a TLC Plates). The 600:400 (driver:business entity) allocation is now marketed differently
Yesterday, the NYC Taxi & Limousine Commission (TLC) sent an email update (see below) on the release of 1,000 NEW EV-only FHV Licenses (a/k/a TLC Plates). The previously guided mid-March timeline of when applications would open was reiterated.
However, one thing that particularly stuck out to us was the wording around the 400 business entity or “unrestricted” allocation as:
Being open to ANYONE 🤔
Its application opening in the “following weeks” after the 600 TLC plate allocation specifically reserved for individual drivers
This is departure from how the 600:400 TLC plate allocation was previously communicated by TLC Chair David Do, which implied 400 (of the 1,000) would be allocated to business entities only (or at least our perception of the communication).
Obviously, an individual driver could have always applied for TLC Plate(s) in the 400 allocation via their own business entity, but the wording now seems to clearly stress & indicate “anyone” can apply for the 400 “unrestricted” allocation.
Are All 1,000 Plates Open To Drivers?
The short answer is YES ✅.
The more complicated answer is TLC drivers interested in applying for an allocation in effectively the “second ‘business entity’ round” should make sure they have a business entity they can apply with.
Although the TLC says a business tax ID (EIN) or Social Security Number (SSN) can be used to apply for the 400 TLC Plates allocated for “anyone”, it would be confusing why anyone would attach an SSN to that application vs. an EIN.
Why do we say this?
Liability protection: The ability to have claim to a TLC Plate (a/k/a FHV License) via a corporate entity can more effectively allow one to protect against claims directed at a specific individual.
Transferability: In its proposed rule language that allowed for the issuance of new EV-only TLC Plates, the regulator literally says the 600 driver-only TLC Plate allocation are “non-transferable” licenses, while the 400 are “unrestricted”. If an individual driver has the ability to acquire an “unrestricted” TLC plate(s) via attaching a business tax ID (EIN) to his/her/their application then it would essentially make no sense to attach an SSN (vs an EIN) to their TLC Plate application. You can also more effectively transfer the claim to TLC Plate(s) via selling a business entity, while you can’t sell a TLC Plate attached to an individual’s SSN.
“400 of these battery electric vehicle licenses will be distributed on a first come, first served basis to anyone who meets the licensing criteria, including but not limited to the purchase of an electric vehicle, submitting proof of insurance and payment of application fees, as set forth in subchapter 59A of chapter 59 of Title 35 of the Rules of the City of New York. Applicants for these 400 unrestricted licenses may obtain more than one license, up to 400 [Note: since changed to a limit of 25 per EIN or SSN).
Of these 1,000 new licenses, the TLC will restrict 600 battery electric vehicle licenses to individual drivers to allow drivers who have been leasing a vehicle the opportunity to own instead of lease a licensed TLC vehicle. These individual, non-transferable licenses will provide drivers currently stuck leasing their vehicles with an opportunity to own their own vehicles. Reserving a number of the new available licenses for individual, non-transferable licenses is meant to balance the opportunities for individual drivers to purchase with the current realities of the market.”
Business Entity Allocation Limits
As we reported recently, there was one surprising (& welcome) announcement related to putting limits on the 400 (of 1,000 business entity (“unrestricted”) allocation) to 25 per entity (defined as an EIN tax ID or Social Security Number (SSN)). Previously, a single business entity could technically apply for the entire 400 allocation on a “first come, first serve” basis.
Details On When & How To Apply
It’s also worth remembering that TLC Chair & Commissioner David Do previously stated that further (specific) details on how to apply for the new EV-only TLC Plates would be made public in the weeks before the official mid-March application, reiterating that drivers SHOULD NOT buy an electric vehicle (EV) until that guidance is given. Do indicated, and the TLC continues to guide, that the online “statement of interest” and overall application would open in “mid-March”, first to individual drivers and then to business entities.
Click here for a link to full meeting recording.
An Auction Should Be Held For “Unrestricted” Allocation
We continue to believe that the 400 NEW “unrestricted” FHV Licenses (a/k/a TLC Plates) should be auctioned off. This will also help raise money for the City & TLC to fund electrification goals.
As we previously wrote:
“To allocate 400 EV-only TLC Plates to corporate entities on a “first come, first serve” basis(!) and no limit per entity(!) [since changed to TLC’s credit 👏], in our view, is not good policy and will likely be subject to claims of unfair dealings. For example, if it is revealed (via publicly available NYC Open Data) that Revel managed to acquire a large chunk of these new EV-only TLC Plates, there will likely be a lot of driver backlash, whether fair or unfair. It may not seem obvious, but we know this market. To be clear, we aren’t accusing Revel of backroom dealings and we think they have every right to expand their business within the TLC’s given regulatory framework.
We also think the TLC can use the current unique backdrop to partially reclaim a financial mechanism it once had with taxi medallions. A mechanism that historically helped the City raise hundreds of millions of dollars. In turn the money raised, as mentioned, can further promote TLC’s overall electrification goals.
Finally, an auction will make clear that the regulator very carefully considers ANY & ALL future FHV License issuances of any kind, until taxi medallion values and driver earnings recover to a healthy level. Remember, any issuance of more TLC Plates will impact medallion values. Although medallions aren’t being auctioned, they will want to see some mechanism to prevent further FHV License issuances.”
As always, let us know your thoughts in the comments section below or by emailing us at info@automarketplace.com.
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What does it mean by statement of interest. Is it something like u state why you want the tlc plate.
And then based on the answer they either let you apply or not apply for the application.
I don’t like to (EV) but I could Apply for my car . TLC plate. I need that. I want to do my Own Bussness. I have TLC Linncess and Car. How I could I do Apply for my Car TLC plates. Thanks