TLC Confirms "Plate Cap" Extension & Calls Out Illegality of Selling FHV Licenses
Previously announced September decision regarding FHV License Pause extension sent out in official email blast to TLC drivers. TLC makes clear it's illegal to sell an FHV License
AutoMarketplace.com NYC covers the for-hire transportation industry and automotive news. Check out AutoMarketplace.com on YouTube ▶️
As I highlighted a few weeks ago, the FHV License Pause (aka TLC Plate Cap) was officially extended until (at least) March 2022 by the NYC Taxi & Limousine Commission (i.e., when the next FHV License Determination report is due). Today, an official TLC email ‘blast’ confirming the decision went out to all TLC licensees, so more drivers may have become aware of the decision made one month ago.
“Over 30,000 existing For-Hire Vehicles did not provide passenger service in July 2021, even though they are licensed to do so, representing a large pool of vehicles that could return to the road and provide service” - NYC TLC
Given the underutilized for-hire vehicle supply and ongoing medallion crisis we believe the ‘TLC Plate Cap’ will be in place for several years and have published a few articles laying out our logic (links below if interested).
NYC TLC Votes to Remove EV Exemption, But Drivers Still Want Ability to Own Their Own Car (AutoMarketplace, June 23 , 2021)
NYC TLC Extends Plate Cap As Senator Schumer Wants More For The Medallion Industry (AutoMarketplace, September 16, 2021)
New TLC Office Will Regulate NYC Taxi Medallions. What This May Mean for Medallion Values (& TLC Plates) (AutoMarketplace, September 30, 2021)
The Wheelchair Accessible Vehicle (WAV) exemption still remains, allowing individuals or corporations to add TLC-plated WAVs. However, it’s my belief that similar to the recently removed battery electric vehicle (BEV) exemption to the FHV License Pause, the WAV exemption may be removed if too many cars are added to the TLC fleet. As regulations become clearer (i.e., plate cap here to stay for a while), there could (presumably) be a surge in WAV applications and its something we will keep track of.
TLC Plates Are Not Transferable
For the observant, you may have noticed an interesting callout in the TLC email today, that wasn’t in previous updates about the FHV License Pause.
My best guess is:
The TLC is reminding drivers who have a claim to a FHV License that they do not have a transferable asset (they don’t have a taxi medallion)
That there may be incidences of illegal ‘TLC plate sale’ transactions and the TLC is warning drivers against engaging in them, either as seller or buyer
As we mentioned previously, FHV Licenses (aka TLC plates) acquired via a corporate entity could technically be sold via the sale of a business, but our research indicates a large majority (~75%) of plates belong to individual TLC drivers. Given business sale transactions of corporate-acquired TLC plates require more capital (i.e., purchase of 5, 10, 20, 50 vehicles) the risk of individual operators having the capital to speculate seems low.
That being said, many NYC TLC drivers, especially those that rent a TLC car, aren’t blind to what such a dynamic could lead to and are calling for a “One Driver, One Plate” rule. Their arguments are honestly somewhat valid as you have a few well known mega fleets (i.e., thousands of FHV licenses) that maybe able to wield significant pricing power, leading to price gouging.
While many TLC drivers think current rental rates (i.e., Camry goes for ~$400 per week) constitute price gouging, an honest financial analysis seems to indicate otherwise. However, that doesn’t mean there doesn’t exist a future where price gouging does occur. This is why I believe you’ll see more regulation around corporate-owned TLC plates whether that comes in the form of lease caps or other regulations.
For full disclosure, although it’s no longer our core business, AutoMarketplace parent company HFW has a medium sized TLC fleet. When we started the leasing business in late 2016, we didn’t foresee/bet on the plate cap dynamic that played out and were focused on leasing out UberBlack-qualified cars (i.e., BMWs) at competitive rates. In fact, AutoMarketplace (launching soon) is born from the experience of owning and operating an NYC fleet (i.e., lessons/tips around saving on auto repair & maintenance, tires, etc).
It’s hard to be be completely unbiased as I write about this subject, but at the same time I can understand multiple sides of the story (business, politics, etc. is very rarely black and white). There is definitely a risk of price gouging by certain bad actors in the TLC leasing industry and there should be reasonable (key word) regulations around that. At the same time, unless the TLC wants to completely collapse the medallion market, it cannot in good conscious open up FHV Licenses for quite some time.
As always, let us know your thoughts below!
AutoMarketplace.com NYC covers the for-hire transportation industry and automotive news. Check out AutoMarketplace.com on YouTube ▶️
I wish my sound can be reached to someone can think about what I'm going to say . As hard worker driver as one of many same like me in nyc we become a slaves to limousine company's they don't even give us the legal minimum wage here in NYC which is illegal + also tlc rental company's and other transportation company's. also we can't open our business and be free any more because the nyc tlc decided to stop The tlc license plate numbers after making a mess in nyc given everybody a license plate number with or without experience for any type of car or any color making the market going crazy and people playing with the prices and open the way to the black market to control the prices of 1 or more license plate numbers under corporate or not also there is no limit for 1 person to have more than what he need all of this because big company's and they completely forgot about our freedom As a driver's we don't want to be a slaves to any company's the time for slaves is already gone long time ago. and we can't go any where any more unless just leaving nyc because authorities wrong decision..please try to fix this mess...and this is my thoughts
1-pull back any license plate number without the owner use only.
2- open back the license plate numbers only 1 for each ny family residence for at least 3 years so they can feel free to do business
3- stop the black market by stop the owners of TLC license plate number from paying or selling or registering under someone else's name or a different car not belongs to them.
I think this way NYC TLC can make the Palance in the market getting the control back again and the most important thing is To be FAIR 👌 with the other driver's they cannot see them behind all this mess and make them FREE back again...thanks
One driver one one plate ! Drivers who rent are modern slaves for rental companies! It’s not fair !! This is a call SOS call to the new mayor of newyork ! One driver one plate !!!!