✅ Livery Pilot Proposed, 2,500 "Restricted" TLC Plates Could Be Issued Soon
TLC will vote on a Street Hail Livery (SHL) Pilot. Creation of new "SHL Permit" seems to be an answer to traditional Livery & Black Car industry calls for more vehicle access. We explain.
The NYC Green Cab 🚕✅ industry, formally known as the Street-Hail Liveries (SHL) sector, is often the forgotten child of the City’s for-hire transportation industry.
That’s about to change though if a newly proposed SHL Pilot is approved at this Wednesdays, May 3rd Taxi & Limousine Commission (TLC) public meeting. Our understanding & analysis of the proposed Pilot indicates it’s actually more about addressing the traditional Black Car & Livery industries repeated calls for more “base-restricted” FHV Licenses (a/k/a TLC Plates).
Before we discuss the details of the new SHL Pilot, let’s provide some high level background on the market, often referred to as NYC green taxis.
NYC Green Taxis (a/k/a SHLs)
“Street Hail Livery vehicles [a/k/a Green Cabs] can pick up passengers by street hail anywhere outside of Manhattan (except for the airports) and in Manhattan north of West 110th street and north of East 96th street. Street Hail Livery vehicles may also accept dispatches in Manhattan north of West 110th street and north of East 96th street and anywhere outside Manhattan, including the airports.”
- NYC TLC
Although this may now sound like an unimaginable past, JUST as Uber/Lyft were arising, NYC’s government created the “green taxi” in 2013. These Apple Green cabs were created in response to an NYC FHV SHORTAGE 👀 (yes, you didn’t read that wrong), especially for residents living in or needing to travel from outside central Manhattan (e.g., outer borough origin trips).
When launched, the City made rules regarding how many new green cab FHV Licenses (known as SHL Permits) could be issued and established a new licensing regime. Near the height of the green taxis popularity in 2014, the Wall Street Journal reported there were 5,200 green taxis making 43,000 trips per day. Based on TLC data it appears the summer of 2015 was the green cab sectors “trip peak” at ~58,000 trips per day across ~6,500 unique vehicles.
“Nelson De La Cruz, 68, said his nearly $6,000 investment—buying a $1,500 permit, painting his sedan green, outfitting it with credit-card processing and other equipment—has yet to pay off. He said his fortunes haven't improved now that he's able to take street hails legally.
Pablo Urena has had more luck. Mr. Urena said [he] doesn't have to work as much and his pay has doubled to about $300 in fares and tips a day since he switched from a traditional livery car.”
- Wall Street Journal, June 19, 2014
Obviously and unfortunately, times have drastically changed for green cabs (SHLs) from the rise of Uber/Lyft to the pandemic 👇.
The NYC TLC held a public hearing about the Green Cab / SHL sector a few months ago on February 8th. The entire meeting lasted less than 25 minutes and only had two, albeit good, speakers testify at length.
SHL Pilot…2,500 NEW “Restricted” TLC Plates?
The TLC frames the Pilot as being mostly about green cabs, but the program really seems to be about using the SHL Permit licensing regime, created for green taxis, to help traditional Black Car & Livery bases access new FHV Licenses (a/k/a TLC Plates).
The TLC’s Pilot allows for the issuance of up to 2,500 new “SHL Permits”(in reality, the TLC is viewing it as a reissuance of retired permits). As you can see from our side-by-side comparison, the Pilot is essentially creating a new sort of outer borough “restricted” Black Car & Livery FHV License.
The Pilot calls for an SHL Permit to be attached to a vehicle that IS NOT green (or yellow), can’t accept street hails, can’t have a taximeter, can’t have taxi top ads and is subject to black car & livery base-affiliated vehicle inspection standards…are we just not creating more traditional TLC-plated black car & livery vehicles, that essentially can’t pick up in Manhattan? Are we missing something here? A question we do wonder about is whether these SHL-permitted vehicle can be cross dispatched to an HV base (Uber, Lyft) if the trip originates outside of core Manhattan? 🤷♀️
For a full description of TLC’s Proposed SHL Pilot click here.
Our Thoughts
A qualm we have with TLC’s Pilot is they don’t seem to be straightforward about what’s going on. If you are going to create/issue new “outer borough-only” Black Car & Livery Base “Restricted” FHV Licenses (“Restricted” TLC Plates), present it as such and have the full industry / community debate. Also, while the Pilot could certainly help current or former green cab drivers leave the industry…we’re having a hard time understanding how this benefits the actual green cab SHL sector?
We believe the TLC must be better. The regulator must not rush policy through, hoping no one notices details or “connect the dots”. It comes off as being not transparent and disingenuous. Perhaps that’s not the intention.
The strict language around transferability of these new Pilot “SHL Permits” (TLC Plates) also seems to unnecessarily complicate established New York State DMV rules, presumably outside of TLC’s regulatory purview. For example, for many in this industry a vehicle’s initial “titled Owner” is often a non-traditional automotive finance entity, friend or family member, which can’t easily appear as a “lienholder” on a New York State DMV Vehicle Title. As one can easily imagine, quite a few NYC TLC drivers can’t easily access auto financing from traditional lenders, especially today!
We also do appreciate this language is meant to protect against the hoarding of these new “restricted” Pilot TLC Plates by corporate entities (e.g., large leasing companies, base owners, etc.) and ensuring the FHV Licenses are permanently retired, if not used.
We try to be balanced at this publication. We definitely don’t want to come off as perpetually critical of the TLC. We do understand they must balance many different policy desires. That being said, and our readers will know, we’ve been pretty consistent on reiterating that the last thing the NYC for-hire transportation industry or City needs is **MORE TLC PLATES**, congesting our roads and dividing a limited driver earnings pie. However, we do also know and have worked with several long time black car & livery base operators who genuinely believe accessing more vehicles (that Uber/Lyft can’t effectively dispatch), is the only path forward and a way to turnaround their businesses.
Time will tell.
As always, let us know your thoughts in the comments section below or by emailing us at info@automarketplace.com.
AutoMarketplace NYC covers the for-hire transportation industry and automotive news. Check out AutoMarketplace on YouTube ▶️
Very interesting 🤔
Let’s see how the pilot goes
how to get a base letter for SHL pilot program application?