I cannot agree with you more that there needs to be some basic barrier to entry for someone entering the FHV industry in relation to the 5 year old vehicle rule for High Volume FHV and driver lockouts. While I do think mandating a 5 year old vehicle max for High Volume FHV is unrealistic, prohibiting any Yellow Cab, Green Cab and FHV over 11 years of age seems realistic and attainable. I see plenty of FHVs and Green Cabs older than 11 years old, with some being almost 20 years of age. I also believe that you shouldn't allow someone to drive a Yellow/Green/FHV with a pedestrian/cyclist/DUI/DWI/School bus incident as it relates to safety; though American Transit does not allow these vehicular incidents, I believe other TLC insurance companies allow. I see this as similar to issuing Medical Doctoral licenses; would you issue unlimited Medical Doctoral licenses, even to those who cannot perform the services in a safe manner? Probably not. I know what I am saying regarding vehicle age and driving history isn't the main point you are trying to address here, but some TLC drivers responded to Uber's vehicular mandate as smart. I think the TLC should look up how many FHV and Taxis are older than 11 years of age, as well as how many drivers have serious vehicular incidents before mandating high volume FHV are at max 5 years old.
Interesting comment! Just to be clear, the TLC is not mandating HV FHVs (Uber, Lyft) to be 5 years or newer, TLC / Parrott's proposed per mile rate calc is essentially fully depreciating a vehicle over 5 years and that, in Uber's opinion, is inflating the per mile rate - Uber is then using that and saying okay if you force this on us, that'll be grounds for us to deactivate drivers with 2019 and older vehicles - those drivers freak out and tell the TLC to change the per mile rate calc.
Like your idea about there being let's say a 10 year model year limit (yellow cabs have 7 years right now, although with WAVs think they got rid of that and said as long as it passes TLC inspection). Given it's primarily American Transit and Hereford now in the TLC insurance market, can tell you both have stricter underwriting standards. However, what you're saying is interesting and perhaps can be tied to whether someone is allowed to keep an active TLC driver's license (akin to your medical doctor license point and safety). The TLC is making the determination of safe through its licensing authority, if you will.
Quickly looked up the number of FHVs that are 2014 and older (11 years+). You're right there are quite a few still - about 7% of the entire TLC-plated fleet.
I cannot agree with you more that there needs to be some basic barrier to entry for someone entering the FHV industry in relation to the 5 year old vehicle rule for High Volume FHV and driver lockouts. While I do think mandating a 5 year old vehicle max for High Volume FHV is unrealistic, prohibiting any Yellow Cab, Green Cab and FHV over 11 years of age seems realistic and attainable. I see plenty of FHVs and Green Cabs older than 11 years old, with some being almost 20 years of age. I also believe that you shouldn't allow someone to drive a Yellow/Green/FHV with a pedestrian/cyclist/DUI/DWI/School bus incident as it relates to safety; though American Transit does not allow these vehicular incidents, I believe other TLC insurance companies allow. I see this as similar to issuing Medical Doctoral licenses; would you issue unlimited Medical Doctoral licenses, even to those who cannot perform the services in a safe manner? Probably not. I know what I am saying regarding vehicle age and driving history isn't the main point you are trying to address here, but some TLC drivers responded to Uber's vehicular mandate as smart. I think the TLC should look up how many FHV and Taxis are older than 11 years of age, as well as how many drivers have serious vehicular incidents before mandating high volume FHV are at max 5 years old.
Interesting comment! Just to be clear, the TLC is not mandating HV FHVs (Uber, Lyft) to be 5 years or newer, TLC / Parrott's proposed per mile rate calc is essentially fully depreciating a vehicle over 5 years and that, in Uber's opinion, is inflating the per mile rate - Uber is then using that and saying okay if you force this on us, that'll be grounds for us to deactivate drivers with 2019 and older vehicles - those drivers freak out and tell the TLC to change the per mile rate calc.
Like your idea about there being let's say a 10 year model year limit (yellow cabs have 7 years right now, although with WAVs think they got rid of that and said as long as it passes TLC inspection). Given it's primarily American Transit and Hereford now in the TLC insurance market, can tell you both have stricter underwriting standards. However, what you're saying is interesting and perhaps can be tied to whether someone is allowed to keep an active TLC driver's license (akin to your medical doctor license point and safety). The TLC is making the determination of safe through its licensing authority, if you will.
Quickly looked up the number of FHVs that are 2014 and older (11 years+). You're right there are quite a few still - about 7% of the entire TLC-plated fleet.