⚡ NYC TLC Publishes EV Roadmap, Ahead Of New EV-Only Plates
Yesterday, the TLC released a 45 page report regarding its plans to electrify NYC's for-hire transport fleet. The report comes ahead of January 11th meeting discussing new EV-only FHV Licenses
Although the NYC Taxi & Limousine Commission (TLC) held a meeting yesterday, it was pretty odd. Only 2 TLC Commissioners, including TLC Chair David Do, of the 9 member TLC Commission Board even attended! In addition, only two people spoke about the proposed agenda, that we overviewed a few days ago. The meeting lasted 12 minutes 👀. We believe the TLC (1) needed to publicize this meeting better and/or (2) held it too close to the holiday season, when many are not as inclined to attend, including 7 TLC Commissioners!
As we’ve stated in the past, we aren’t going to hold back on criticizing the TLC when appropriate. Since being appointed Chair, David Do has achieved a lot and in a short time frame, which he should be commended for. While Chair Do attended and led yesterday’s meeting, for 7 of the 9 other TLC Commissioners not to be present, in our mind, should have basically prevented the meeting from proceeding.
To access a recording of yesterday’s TLC Commission meeting click here 📹.
Quorum & Driver Commissioners
In the future, we believe the TLC needs to have a quorum, or minimum number of Commissioners present, in order to proceed with a public Commission meeting. We also think, yesterday’s showing gives further merit to the idea that additional “Driver / Industry” Commissioners, should be added to the TLC Commission Board.
“This bill would increase the size of the Taxi and Limousine Commission (TLC) board from nine to eleven commissioners. The two additional commissioners would be required to hold a valid TLC driver license and would be appointed by the Mayor, with the advice and consent of the Council.”
- NYC Council Bill (Int 2247-2021)
⚡ TLC EV Roadmap Report
Although yesterday’s TLC Commission meeting proved to be underwhelming, the publication of a 45 page report on the regulator’s electrification strategy was definitely not! Given TLC Chair David Do’s NYC Council testimony (see below) in October, we knew more information on the regulator’s electric vehicle (EV) plans were coming soon. To his and his team’s credit, they put together a good report, with nice data and details, in a fairly short time frame.
Given the importance of the report and its length, we thought we would break up our coverage over a few pieces or it may prove to be TMI.
In today’s piece, we’ll overview the the sections bolded:
Executive Summary
Why Electrification?
EV-Centric Regulations (partial overview)
Given the recent announcement that 1,000 new EV-only FHV Licenses (a/k/a TLC Plates), the EV-Centric Regulations section will probably be of immediate interest to many TLC drivers, bases, fleets and other industry participants.
Click here to access the full TLC EV Roadmap report 📘.
TLC’s EV Roadmap Executive Summary
“This report is the beginning of a roadmap, with a goal nothing short of electrifying the vast majority of TLC vehicles by the end of this decade”
- David Do, Chair, NYC Taxi & Limousine Commission
The TLC identifies three major barriers to entry that’s preventing more EV adoption among TLC drivers and fleets: Cost, Charging Coverage, Regulations.
TLC Answers: Why Electrification?
The TLC references the unique, over 120 year old history, of EV taxis in NYC. They are correct, NYC EV taxi history goes all the way back to 1895!
One of TLC’s core argument for electrifying the for-hire transport fleet relates to reducing emissions. This argument likely needs to be more refined as the mining of rare earth commodities used in producing batteries, needs to be considered. Remember, ESG stands for Environmental, Social and Governance. The mining of rare earth commodities, that are a core part of current EV battery chemistry, might help facilitate the E part of the ESG acronym, but some serious questions remain around whether they abide by the SG parts of the acronym.
Net-net though, the overall point that EVs will reduce emissions is valid when viewed over a long term horizon. We think it’s important to be as intellectually honest about how EVs meet ESG goals though. Perhaps, the TLC will further refine its requirements for EVs, to ensure overall ESG standards are met (i.e., child labor isn’t used in mining commodities for batteries in EVs). Most of us understand reducing emissions is a valid priority, but there are also social & political complexities that need to be considered.
Finally, the TLC also argues that maintaining an EV is cheaper than a gas (ICE) vehicle, but that argument once again needs to be further researched and quantified. From battery replacement costs to the lack of third party maintenance providers, TLC drivers and fleets are also hesitant to adopt EVs related to fear of unknown costs and lack of third party auto repair shops.
Again, any new technological adoption process is complex and that, by itself, shouldn’t stop adoption of EVs. We should also be hesitant of over skepticism that results in perpetually "kicking the can down the road” 🥫.
TLC Is Creating EV-Centric Regulations
This section of the TLC report covers several topics, but we thought the language around regulations related to lifting the FHV License Pause (a/k/a TLC Plate Cap) to issue new TLC Plates, was noteworthy. As we’ve reported, many were surprised, including the recently debt restructured yellow taxi medallion industry and City traffic congestion voices, by the recent announcement that 1,000 new EV-only TLC Plates would be issued. Based on the language in the report, perhaps we should expect future EV-only TLC plate issuance announcements, a strategy that may not sit well with many vs. incentivizing converting the existing TLC fleet 🤔.