For-Hire Vehicle

Transportation
Study

January, 2016

City of New York

Bill de Blasio, Mayor
Office of the Mayor

I. INTRODUCTION
In the last several years, the ubiquity of mobile phones,
and the rise of new platforms for getting and giving
rides have increased the complexity of New Yorks
transportation system. With the arrival and rapid growth
of new types of on-demand for-hire vehicle services,
the City has sought to answer fundamental questions
about the potential impact of these changes on key
priorities: managing the efficient movement of goods
and services across the City, particularly in Manhattans
congested Central Business District (CBD), supporting a
comprehensive and sustainable transportation system,
promoting equitable growth, and ensuring safety for
drivers and passengers.
New York City is committed to offering a reliable, safe,
accessible, and comprehensive transportation system
that promotes the public good and meets the needs
of all New Yorkers across all five boroughs. The City
must make sure that residents and visitors have a
range of appealing transportation options, that the
streets are safe, that passengers are protected from
fraud and abuse, and that those who work to provide
transportation have fair and sustainable working
conditions and income opportunities. While doing so,
the City must take steps to ensure that its transportation
system is accessible to all, regardless of individual ability.

For-Hire Vehicles are a Vital Part of New

York Citys Transportation Mix
For-hire vehicles (FHVs) -- yellow and green taxis,
livery cars, traditional black car services, and the fastgrowing app-based car services like Uber and Lyft -are an important part of the Citys transportation mix.
Paid transportation market snapshot
Annual paid trips by mode
Millions of trips, 2014

Most New Yorkers get around using subways or

buses. Public transit makes up the largest part of our
transportation system by ridership, but taxi and livery
services have long played a significant role. New York
City has the lowest rate of private car ownership in the
nation and the highest utilization of for-hire services.
Every day hundreds of thousands of New Yorkers and
tourists take trips in for-hire vehicles, relying on them to
get to work, school, medical appointments, to and from
the airports, and other destinations.
From the iconic yellow medallion taxis clustered in
central Manhattan, to neighborhood car services found
in communities across the Bronx, Brooklyn, Queens, and
Staten Island, the industry has grown and changed to
meet a wide range of customer needs. At the high
end, there are limousines and premium black car services
that largely work for corporate accounts. In the midrange value are yellow and green cabs, hailed on the
street throughout the five boroughs. There are also small
neighborhood livery companies, whose costs are often
lowest and conduct many of their transactions in cash.
In the last three years, the landscape of for-hire service
has changed considerably due to the rise of app-based
electronic dispatch (or e-dispatch) services, such as Uber
and Lyft, that allow customers to request vehicles on
their smartphones.

The Citys Regulation of For-Hire Vehicles

For-hire
services
235

Bus
793

Although subway and bus trips significantly outnumber

for-hire vehicle trips, for-hire vehicles provide some
services that the mass transit system cannot. Many
New Yorkers use for-hire vehicles when subway or bus
lines are too far away from their home or destination or
when mass transit is perceived as too slow or requires
too long a wait. In addition to convenience and speed,
passengers may also select for-hire vehicles for comfort,
privacy, and the relative ease of transporting bulk items
and packages.

Subway
1,750

SOURCE: TLC 2014 data; MTA annual reports

The City regulates for-hire vehicle services through the

Taxi and Limousine Commission (TLC) to promote the
public interest. The rise of e-dispatch services have
blurred the traditional line between medallion cabs,
which can offer street-hail service, and non-taxi for-hire
vehicles that offer pre-arranged service. With the quick
arrival of a car at the tap of a button, the distinctions
that yielded differential regulatory treatment across
black and yellow cars are less relevant, and the City
must adapt its traditional frameworks to support the
new entrants that do not squarely fit into traditional
categories. E-dispatch providers have worked with the
TLC to meet requirements for existing categories, but

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 1

Due to technological advances, once-distinct regulatory categories are blurring

FHV Ecosystem, pre-electronic dispatch FHV growth

High

FHV Ecosystem, 2015

High

Black cars

Yellow cabs
Yellow and
green cabs

Green cabs
Low

Price point

Price point

Black car1
Yellow cabs
Green cabs
Low

Livery

Livery

Traditional

E-hail / e-dispatch

Street hail

Pre-arranged
Access type

Traditional

E-hail / e-dispatch

Street hail

Pre-arranged
Access type

In NYC, Uber and Lyft are categorized as black cars, not as a separate category
Interviews with industry players, experts, consumers, and TLC, and review of TLC regulations

their rapid growth has stressed the regulatory framework

and is upending traditional categories, prompting the
City to review the for-hire vehicle industry and lay out
four priority areas for study and reform:
1. Supporting a comprehensive transportation
system (including the provision of transit choices,
geographic coverage, accessibility, and the financial
health of the system as a whole);
2. Promoting equitable growth (including consumer
protections around pricing and other issues, labor
market impact and job quality);
3. Managing mobility impacts in the Central
Business District of Manhattan (assessing the
ability of people and goods to travel into, out of,
and around Manhattan, the volume of vehicle traffic
on the roads, the capacity of the roads themselves,
and assessing any environmental impact); and
4. Ensuring safety (for drivers, passengers, and other
users of New York City streets).
In the FHV industry, as in other economic sectors, when
sudden changes in market activity produce outcomes
that might be counter to the public interest, government
must evaluate the rapid changes and take strategic
steps to promote a vibrant marketplace while crafting
reasonable regulations to promote the public good. In

PAGE 2 OFFICE OF THE MAYOR

this report, we set forth facts and findings that provide

a basis for the future regulation of New York Citys forhire vehicle market.
This report is a product of months of analysis and
evaluation, drawing upon the Citys internal agency
expertise, along with the assistance of outside
consultants, to provide the fact basis on the current
baseline conditions in the Manhattan core. Data
provided in this report was collected during the study
period (August through October, 2015).

II. THE REGULATION OF

APP-BASED E-DISPATCH
SERVICES
New York City has a long tradition of adapting its rules
and regulatory structures to the changing needs of
the for-hire vehicle industry and its passengers. These
regulations have generally occurred in reaction to
market behavior and conditions rather than as part of a
proactive vision for the transportation industry. The Citys
regulation of the industry has adapted with changing
times from the cap on taxi medallions imposed during
the Great Depression, to the creation of the Taxi and
Limousine Commission in the early 1970s.
Jurisdictions across the U.S. and the world have adapted
different models of regulation for e-dispatch operators

Regulation has evolved to recognize four types of FHVs

Haas Act caps the
taxicab industry
at 13,595 in
response to
oversupply during
the Great
Depression

City establishes
TLC to regulate
medallion taxis and
investigate the
increasing problem
of gypsy cabs

1937

1960

Radio calls make up

an increasingly
large part of yellow
taxi dispatches as
business accounts
grow, frustrating
street hailers

1971

Unregulated
neighborhood car
services become the
primary means of
for-hire transport in
underserved areas,
particularly outer
boroughs

TLC requires
medallion owners
to transfer their
radios to nonmedallion vehicles,
creating the
"black car"
industry

1980 1982

TLC gains
jurisdiction over all
"for-hire vehicles,
legitimizing
neighborhood car
services for the
first time

Uber debuts in
NYC, initiating
rapid growth in
number of FHVs

1987

Yellow cabs pilot

e-hail app to
better compete
with e-dispatch
companies

2011 2012

2015

To bring more
transport options to
outer boroughs,
City debuts
green cab
licenses allowing
FHV drivers to
accept street hails

SOURCE: TLC interviews; NYC FHV Fact Book; Schaller Consulting

like Uber and Lyft. In many jurisdictions, like San

Francisco and Washington, D.C., e-dispatch services
operate on a decentralized peer-to-peer model.1 Under
this model, these companies provide the software to link
passengers to drivers of vehicles who give rides. The
platform bears the regulatory responsibility for safety,
including training and background checks. In these
jurisdictions, drivers without a commercial license may
offer rides in their personal cars using the platform.

yellow taxi drivers has declined five percent.2 Over the

same two-year period, new for-hire vehicle registrations
by former yellow taxi drivers have increased many times
over.

In New York City, these companies face added

requirements under the TLCs for-hire vehicle legal and
regulatory framework; drivers are professionals and must
hold a commercial license, as well as undergo more
rigorous background checks and training. Though drivers
may operate their personal vehicles, those vehicles must
submit to City inspection.

Managing Mobility in the Central Business

District

E-dispatch services are growing rapidly. In New York City,

the rise of e-dispatch services has created noticeable
shifts in driver and consumer behavior. Many drivers are
moving from yellow cabs to drive primarily for e-dispatch
companies. In the past two years, the number of active
1

Press clippings; City regulatory agencies

III. KEY CHALLENGES &

FINDINGS
One of the key transportation challenges in New
York City is the movement of people and goods in
Manhattans Central Business District south of 60th
Street. The CBD drives the regional economy, houses
over two million workers, and attracts tens of millions
more tourists each year.3 It is home to the greatest
concentration of economic and social activity in the
country and the most intensive vehicle traffic congestion
in the City. Most people who enter the CBD do so via
subways or buses, but a substantial number arrive by
vehicle.
2
TLC data
3 NYC&Co.

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 3

Findings:
Traffic speeds show a stable pattern of peak concentration over time
Traffic speeds by origin and destination over time
Average MPH AM/PM Peak, Midday, and 24hr average for an average day from 09 to 15
Traffic speeds show a stable pattern of peak concentration over time
Traffic speeds by origin and destination over time
Average MPH AM/PM Peak, Midday, and 24hr average for an average day from 09 to 15

Vehicle congestion in the CBD is related to a variety of

factors, which can be broken into those that affect the
volume (demand) of travel and those that affect the
capacity (supply) of the roadway. The volume of vehicle
traffic in a given area is frequently measured by the
total number of vehicle miles traveled (VMT). This will
vary based on the total demand for travel (the number
of vehicle trips of all types that people take) and the
mode of travel by which trips are undertaken. In the
Manhattan CBD, the vast majority and a growing share
of trips are by foot, rail, bus, and bike; an important but
minority share of trips are by car or truck.
4
5
6

TTI Urban Mobility report, Texas A&M and INRIX, 2015 Urban Mobility Scorecard
TTI Urban Mobility report, Texas A&M and INRIX, 2015 Urban Mobility Scorecard
TLC TPEP data on taxi speeds

PAGE 4 OFFICE OF THE MAYOR

All to all

20
10
0
CBD to
CBD

20
10
0

Zone 2A to
Zone 2A

20
10

Traffic Engineering Book (4th Edition)

2014

2015

Hour-range estimate1

1 AM peak is2009
6A-10A, Midday
period is 10A-4P,
Peak is 4P-8P2013
2010
2011 and PM2012
SOURCE: TLC database
7

AM Peak
Midday
Pm Peak

24 hour average

AM Peak
Midday
Pm Peak

AM Peak
Midday
Pm Peak

AM Peak
Midday
Pm Peak

Nevertheless, based on several key indicators,

vehicle congestion has been increasing in severity
in the Manhattan CBD over the past five years, with
consequences for people in buses and cars, and
businesses and institutions that rely on goods delivered
in trucks. Peak hour vehicle commuters in NYC faced
an average annual delay of 74 hours in 20144. The
annual cost of lost time due to congestion delays was
approximately $14.7 billion.5 Average vehicle speeds
have fallen nearly 10% over the last two years.6

AM Peak
Midday
Pm Peak

Road
network
with
capacity
reducing
factors

AM Peak
Midday
Pm Peak

Road
network
at full
capacity

Permanently or temporarily reducing the capacity of

roadways generally increases motor vehicle congestion,
shifts vehicle travel to other routes or times of day, or
causes some traffic to disappear as travelers shift to
other modes or otherwise change their pattern of travel.
Changes like opening and closing lanes and setting
traffic light timing systems alter the baseline vehicle
capacity of the roadway producing similar changes
to travel behavior. Blocking lanes for construction of
buildings, subways, underground utility infrastructure,
or road repairs can also reduce road vehicular capacity
by anywhere from 25-100%7 depending on how many
lanes are blocked. A large number of people arriving by
subway or bus increases pedestrian volumes, which can
reduce motor vehicle road capacity by as much as a third
as turning vehicles must wait for pedestrians crossing
at intersections. Motor vehicle traffic congestion is also
significantly affected by how curb space is managed.
When there is inadequate space at the curb for trucks
and delivery vehicles and those vehicles double park,
they can remove a full lane or more from traffic service.
Vehicles circulating in a search for parking and engaged
in parking maneuvers can also have a significant impact
on congestion. In an important respect, many of these
contributors to congestion are signs of prosperity and
the efficient use of street space vehicle congestion
would be far worse if people on foot drove instead,
and the growth of new buildings, tourism, infrastructure
investment and economic activity are signs of a healthy
city.

AM Peak
Midday
Pm Peak

As the Citys population and tourism have grown, the

New York City Department of Transportation has worked
to improve the safety, efficiency, and livability of the
streets by supporting travel options that require less
space such as walking, riding the bus, and bicycling,
while maintaining appropriate traffic flow for cars and
trucks. These steps, including pedestrian safety projects,
bus lanes, bicycle lanes, and plazas, are core to the Citys
safety and sustainability goals, and fundamentally allow
more people to access and enjoy the Central Business
District without adding more cars on the road.

Reductions in vehicular speeds are driven primarily

by increased freight movement, construction
activity, and population growth. According to the
Citys analysis, several factors have contributed to
the recently observed drop in Manhattan CBD travel
speeds by taxis and buses, affecting practical vehicular
roadway capacity and how it is used. Population and
job growth, increased construction activity, growth in
the number of deliveries, and record levels of tourism
have all contributed to the reductions in vehicle speeds.
Construction permits in the CBD are up 6-7% since
20098 and pedestrian counts in the CBD are also up
18-24% since 2009.9
E-dispatch is a contributor to overall congestion,
but did not drive the recent increase in congestion
in the CBD. Vehicles of all types play a role in congestion
in the CBD. The number of trips by all vehicle types
in the CBD remained flat between 2014 and 2015
as increases in transit ridership offset increases in trip
deman driven by growth. Increases in e-dispatch trips
are largely substituting for yellow taxi trips10 in the CBD.
Because these e-dispatch trips are substitutions and not
new trips, they are not increasing VMT. Additionally,
there is no clear evidence to suggest decisive capacity
effects driven specifically by e-dispatch pick-up, dropoff, and parking behaviors in the period. Therefore,
e-dispatch does not appear to be driving the additional
congestion experienced in the CBD.

likely to be modest declines in vehicle speed. However,

small macro-level changes may drive significant delays
at discrete points. For example, if the growth in the
FHV sector is due to net new car trips, then high-traffic
intersections could see significant increases in vehicular
congestion.

Finding:
E-dispatch could drive modest growth in congestion
in the future. The impact of e-dispatch vehicles on
congestion in the CBD may change in the future. If rapid
e-dispatch growth were to reduce public transit trips,
there would be additional modest growth in congestion
across the CBD due to for-hire vehicles. Given that much
of the growth seems to be growth in e-dispatch, these
scenarios show modest growth in the CBD as a whole,
even with significant growth in other car modes.

Yellow utilization, for sample day

Percent of yellow VMTs travelled where meter is running, city wide
60

50

52

55

54
56

40

55

54

20
0

2009

10

11

12

13

14

2015

Introduction of e-dispatch players

In addition to looking at congestion in the CBD as a

whole, the study also briefly examined the impact
changes in the FHV sector could have at the micro level.
Within the CBD, over the next five years, there are

The number of vehiclemiles-traveled (VMTs),

a measure of traffic
volume, is flat overall
in the CBD from 2014
to 2015, even with the
growth of e-dispatch

Based on a sample mid-week day in April for each year 2009-2015, annual average of 21.5 trips per shift
likely higher and number of yellow shifts per day lower due to shifts that contain hours in consecutive
24-hour days

SOURCE: TLC database analysis of a sample mid-week day in April for each year 2009-2015

For-hire services were a relatively small portion

of VMT in 2014

and while e-dispatch grew in 2015, total VMTs

are essentially flat

Total 2014 VMTs originating in CBD2

VMTs by mode, millions

Total 2015 VMTs originating in CBD2

VMTs by mode, millions (+ or since 2014)

1,000
800
600
400
200
0

1,000
800
600
400
200
0
2014

Private Car
1
2

2015

Truck

Taxi and Traditional FHV1

e-dispatch

Taxi corresponds to BPM Taxi category and contains Yellow, Black, Livery, and Limo; in CBD pickups are 95.9% taxi
All data is centered on VMTs located wholly within the CBD regardless of origination and/or destination. BPM projections for 2010 and 2020 are interpolated linearly to arrive at 2014 and 2015 values for Private Car and Truck,
and Private Car is adjusted by diversion to e-dispatch based on primary research on NYC residents. 2014 and 2015 TPEP data analyzed to determine Taxi trip origins/destinations and lengths; assignments to TAZ based on
shortest path through road-network via BPM assignment functionality. No data exists on traditional FHV in 2014, and BPM growth rates are applied in reverse to arrive at 2014 FHV levels. Cruising VMTs incorporated into Taxi
/ traditional FHV / e-dispatch breadcrumb data estimates from Yellow adjusted to other modes via driver survey. VMT of revenue trips for e-dispatch is taken directly from Uber submitted data; given lack of data on traditional
FHVs this information is assumed to apply to those as well. Uber data scaled to total e-dispatch market based on Uber proportion of e-dispatch pickups in 1H15; measured at 99.5%

SOURCE: NYMTC BPM projections, TLC databases

8
9
10

DOT roadway construction permits

DOT pedestrian count during one week in Spring, 2009-2015
NYMTC BPM Projections, DOT, TLC

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 5

Yellow cab utilization remains steady despite

decline in trips, with little change in congestion
impact. While yellow taxi trips have declined over the
study period, patterns of yellow taxi utilization have
not changed. Since the arrival of e-dispatch apps, the
ratio of yellow taxi vehicle miles traveled with the meter
engaged to yellow taxi vehicle miles traveled without a
passenger has remained constant, with metered travel
representing approximately 54% of taxi vehicle miles
traveled.

Ride-sharing may have inadvertent, detrimental

impacts on congestion. Ride-sharing a carpool
service operated by e-dispatch and other providers
- is gaining momentum in New York City as well as
cities around the country. More and more e-dispatch
providers are adding this feature to their menu of
services for their customers convenience, as ridesharing works the same as other e-dispatch services,
but offers cheaper individual rides. Though this service
may provide some benefit for consumers individually,
the effects on congestion vary depending on which
pool of consumers ride-sharing pulls from. Ride-sharing
could have a substantial impact in reducing vehicle miles
traveled, but only if many consumers change from other
car-based modes and few riders switch from public
transit. NYC buses typically use scarce urban street
space much more efficiently than FHVs, even if there are
several passengers sharing an e-dispatched ride-share
service. The congestion mitigation of an 11-13% switch
in yellow taxi and e-dispatch trips over to ride-sharing
would be completely offset if less than 1% of public
transit riders also switched to ride-sharing.11
Air Quality improves over time. Even in light of
potential congestion increases, modeling done for this
study shows that air quality levels from mobile sources
are expected to improve in the future -- in large part
due to substantial increases in automotive emissions
standards. In addition, the Citys new Air Code and new
State and Federal requirements mean that any increases
in air pollution caused by the addition of vehicles would
not be sufficient to alter the overall downward trend.
Given the relatively small percentage the FHV industry
represents of vehicles in the CBD, and the substitution
effect between yellow and FHVs, under the current
standard for taxis and for-hire vehicle usage and
retirement, changes in the FHV sector are not likely to
affect New York City air quality in a significant manner.
11
HDR/KLD for-hire services projection model, Bandwagon ridesharing data; NYC
Consumer survey September 2015

PAGE 6 OFFICE OF THE MAYOR

Supporting a Comprehensive
Transportation System
Meeting Accessibility Commitments
Another continuing challenge the City faces is providing
sufficient and reliable accessible transportation.
Wheelchair users are about 10%12 of the total population
of people with disabilities.
New Yorkers with physical disabilities have sought equal
access to every part of the City, including the taxi fleet,
for years. The City is committed to making the yellow
cab fleet 50% accessible by 2020 and the green cab
fleet 50% accessible by 2024. All black car and livery
car services, including e-dispatch providers, are required
by TLC rules to provide equivalent service to all users
regardless of disability, but a 2014 enforcement action
found widespread failure to meet the requirement.
Finding:
As e-dispatch continues to grow, the percentage
of for-hire vehicles that are accessible will drop.
Yellow and green taxi fleets, which are subject to
accessible vehicle requirements, are losing their supply
of willing drivers to e-dispatch services, which are subject
to the equivalent service rule, but which are not subject
to the judicial and statutory mandates affecting yellow
and greens cabs. E-dispatched cars are not accessible
to many people with disabilities including vision and
hearing loss, or people using non-folding wheelchairs.
As more e-dispatch vehicles are added to the road, the
number of accessible yellow and green taxis becomes a
smaller and smaller percentage of all for-hire vehicles
even without the drop in supply of yellow and green taxi
drivers that the City is beginning to experience. If the
system were fully accessible and people with disabilities
were to take as many trips per day as New Yorkers on
average, the New York City transit system would see
almost 920,000 trips per day13 taken by people with
disabilities out of a population of roughly 1,000,000
disabled individuals. Wheelchair users would generate
approximately 83,000 trips per day14 through the New
York City transit system.

Supporting Mass Transit

One of the Citys core interests is maintaining adequate
revenue to support mass transit and other transportation
needs. As an intensive user of City streets, it is
appropriate that for-hire vehicle companies participate in
funding these needs, and it is appropriate that e-dispatch
companies pay their fair share. The blurring between
12
13
14

Mayors Office for People with Disabilities

Assuming same trip intensity as overall NYC population across all modalities
Assuming same trip intensity as overall NYC population across all modalities

The chart below demonstrates how taxes and fees figure into the fare paid by passengers:
Medallion

For-hire

Yellow cab

Green cab

Livery

Black car

None

None

None

8.875% total
8.875%
(inc. 4.5% for NYC) (inc. 4.5% for NYC)

$0.50 / trip

$0.50 / trip

None

0.375% (part of
total sales tax)

0.375% (part of
total sales tax)

$1000 / vehicle

$400 / vehicle

$400 / vehicle

$400 / vehicle

$400 / vehicle

Medallion
transfer

5% of sales price

N/A

N/A

N/A

N/A

Accessibility
surcharge

$0.30 / trip

$0.30 / metered trip None

None

None

CMVT

Cost-based
fees

Commercial vehicles
contribute differently to
public revenues

MTA tax

Driver lic.

New driver: $84

New driver: $84
New driver: $84
New driver: $84
New driver: $84
2-yr renewal: $168 2-yr renewal: $168 2-yr renewal: $168 2-yr renewal: $168 2-yr renewal: $168

Vehicle lic.

Renewal: $550

Renewal: $300

Renewal: $275

Renewal: $275

Renewal: $275

Inspections

$90

$90

$75

$75

$75

Other revenue
sources

Industry taxes

Trip sales tax

Limo

Vehicle sales

N/A

N/A

N/A

8.875% sales tax paid on vehicle sales but contribution to City revenues difficult to measure

Driver
income tax

Driver lease
sales tax

8.875% on vehicle N/A

lease

State income taxes for NYC resident drivers contribute to City revenues but difficult to measure

SOURCE: TLC, OMB

the yellow cab and e-dispatch market has eroded an

important source of transit funding, since taxes and fees
are applied differently between these two sectors even
though passengers now readily move between them.
The City and the Metropolitan Transportation Authority
(MTA) receive significant amounts of revenue from
yellow and green cabs. There is a $0.50 MTA surcharge
for every trip in those vehicles that goes to support mass
transit. Taxi passengers also pay a 30-cent per ride fee
that goes towards an accessibility fund to help the City
achieve its fleet accessibility goals. Non-taxi for-hire
vehicles, including e-dispatch vehicles, do not pay an
MTA surcharge or an accessibility fee. However, they
do pay a per trip sales tax of 8.875%, with 0.375%
devoted to the MTA, 4.5% going to the City, and the
balance directed to the State. Yellow and green cabs
do not pay sales tax.15
Finding:
The shift to e-dispatch will create a revenue
shortfall for key transportation priorities. Every
e-dispatch trip taken in place of a yellow or green taxi
diverts revenue from measures to fund an accessible
fleet and support New York Citys subway and bus
system. Without regulatory intervention, the growth
of e-dispatch services will have lasting impact on this
important source of support for public transit and
accessible vehicles.
15

New York City Office of Management and Budget, TLC

IV. PROMOTING EQUITABLE

GROWTH
As a result of the technological advances that have
occurred in the for-hire vehicle sector, once-distinct
regulatory categories are now blurring, and causing
more direct competition for drivers and passengers.
Where there were once yellow and green cabs that took
on passengers through street hails, and black cars and
livery that did not, these lines are no longer so clear.
Through the use of apps that let customers e-hail and
summon e-dispatches yellow and green cabs, black
cars, and livery cars are now in direct competition for the
same passengers. All for-hire vehicle sectors are under
pressure from illegal street hails which leave passengers
without the consumer protections offered through
regulated services.
This new FHV landscape has had a wide array of
ramifications. The market segmentation that once
existed has substantially eroded. Yellow cabs once
obtained passengers almost exclusively through street
hails and taxi stands, including at airports. Livery
services worked primarily in neighborhoods that were
not well served by yellow cabs. Black cars mainly
served corporate clients through advanced bookings,
primarily in Manhattan. With the advent of app-based
dispatching, Ubers share of the FHV market has risen
sharply. Despite the introduction of e-hail apps, yellow
cabs have seen their passenger volume decline.16
16

TLC database

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 7

While the categories of FHV vehicles have blurred,

the regulatory framework has remained remarkably
fixed. Yellow and green cabs have fleets whose sizes
are restricted by law 15,23717 and 18,000 vehicles,
respectively. Livery, black car, and limousines including
e-dispatch cars have no such restrictions.

The survey was the first of its kind for the for-hire vehicle
industry in New York City.

Choice factors for trips when passengers considered

taking multiple for-hire services options
E-dispatch is chosen for short
wait times, easy payment, and safety

Fare information is disseminated differently by sector.

Yellow or green cab prices are fixed and clearly
displayed for the customer. A livery passenger can get
a price quote from the dispatcher or driver. E-dispatch
customers do not receive a firm fare quote in advance,
an information asymmetry that can be exacerbated with
so-called surge pricing.

Yellow

Yellow taxi is chosen for

comfort and when late

E-dispatch

Both are chosen

for speed of travel

% riders

26
16

Short wait

32
23

22

28

31

27
19

34

23
8

Easy to pay

Safety

Comfort

I was late

Fastest

There are over 148,000 licensed for-hire vehicle drivers

in New York City. All of these drivers must interact with
TLC at some point throughout the year: getting a car
inspected, dealing with a violation, or renewing a license.
Until recently, licensing by itself presented a challenge as
different sectors have different classifications of licensing.
A recent change allows medallion and FHV drivers, who
once had separate licenses, to operate vehicles in either
sector. Drivers of yellow and green taxis are required to
attend taxi school, which provides important training
in safety and customer service. This requirement has
recently been extended to drivers of non-taxi for-hire
vehicles. There are also significant differences in fares,
the frequency of TLC inspections, and other regulations.

The survey showed that both financial and non-financial

considerations play important roles in customer and
driver behavior, and that e-dispatch services are viewed
favorably for an array of service attributes, including
convenience, comfort, and value.

Data collection is inconsistent across for-hire vehicle

classes. Yellow and green taxis have far more stringent
data requirements than non-taxi for-hire vehicles,
which have, for years, only been required to report
manually. This is in contrast to the steady stream of
data collected by the Taxi Passenger Enhancements
Project (TPEP) system in the yellow sector and Street
Hail Livery Passenger Enhancements Project (LPEP)
system in the green sectors. E-dispatchs app-based
technology provides an opportunity to even out the
data requirements and to better understand the needs
of all for-hire vehicle customers. It should be noted that
e-dispatch providers collect personal information from
their customers and it is the duty of the City to ensure
that providers protect the customers privacy from data
breaches.

Passengers were more mixed on e-dispatch providers

surge pricing, the practice of raising prices when
demand for rides exceeds available vehicles in an area
for some period of time. The idea behind surge pricing
is to incentivize additional drivers to serve an area
experiencing high demand, and to reduce demand at
least temporarily and bring it into alignment with current
supply. The survey results show that customers generally
understand how surge pricing works, but 44% feel like
that practice is unfair.19 Despite this finding, overall,
people surveyed felt positively about e-dispatchs value
for the money.

18

Understanding Customer Choice

To better understand what is driving both consumer and
driver decision-making, the City conducted an in-depth
survey as part of its study of the for-hire vehicle industry.
17
Note: the current number of medallions is capped at 13,237. An additional 2,000
have been authorized yet not auctioned.
18 TLC

PAGE 8 OFFICE OF THE MAYOR

Restricted to trips where the respondent stated they also considered another FHS type, such as taxi,
e-dispatch, black car or livery company

Among consumer survey respondents who had used a

for-hire vehicle service at least once in the past three
months, riders chose both taxis and e-dispatch for speed.
Riders who chose e-dispatch services chose them for
short waits, ease of payment and safety. Riders chose
taxis for comfort, or when in a hurry.

Understanding Driver Choice

To companies providing for-hire service, competition
for drivers is often as important as competition for
passengers. E-dispatch companies have recruited heavily
for drivers and have offered financial incentives and
earnings guarantees to attract drivers.
19
Independent survey of 1,000 transportation consumers in New York City conducted
in September 2015, weighted based on American Community Survey 2013 age, income, and
gender distributions. Based on 231 trip-level responses from Uber riders

Some drivers have moved from yellow cabs to e-dispatch

-- over 1,200 drivers in the first half of 2015.20 They
have made this move for a range of reasons, both
financial and non-financial. Among e-dispatch drivers
who previously drove for other for-hire service sectors,
the most frequently mentioned reasons for switching are
convenience of hours, income, and quality of passengers.

simplicity, or ensuring the system is easy to

understand and work within;

The survey results show that flexibility in working hours

and income are both important to drivers choices. On
the financial side, a slight majority of e-dispatch drivers
believe that driver earnings are higher in e-dispatch
than other for-hire service sectors, while one-third view
earnings as similar and 11 percent view e-dispatch
earnings as lower. However, only 27 percent of drivers
who have switched sectors report income was the
primary reason for switching. Broadly consistent with
these driver survey results, published estimates of
possible income by sector support the conclusion that
driver earnings are an important part of many, but not
all, drivers decisions to move to e-dispatch.21

enforcement, or minimizing the likelihood of

informal or illicit activity; and

Drivers across sectors share many of the same

characteristics. About three quarters of all drivers say
that driving a taxi or other for-hire vehicle is their fulltime job. Another common factor amongst all drivers is
that they are, for the most part, independent contractors
lacking any form of healthcare or disability coverage.

(iii) cultivating a competitive and innovative market in

for-hire service;

While there are important advantages for drivers and

customers in the shift toward e-dispatch services, the
City has an important stake in maintaining a vibrant and
financially healthy taxi industry given the importance of
street hail and taxi stand service in the densest parts
of the City as well as the importance of serving cash
customers (which e-dispatch companies do not currently
do) and wheelchair users. Differential regulations for
taxis compared to other categories of for-hire vehicles
limit traditional yellow taxis ability to compete effectively
with e-dispatch services, and encourage a vibrant and
competitive market for passengers and drivers alike.

V. RECOMMENDATIONS
Based on the findings of the study, the City believes
theres a need for further regulatory measures in order
to continue to meet the needs of New Yorkers. There
are five guiding principles that inform these proposed
reforms:
20
21

TLC Data and Analysis

Online survey of 2,540 TLC-licensed drivers in September, 2015

flexibility, or maintaining the ability to adapt as

technology and business models change;
balance, or providing necessary protections with
minimum friction;

evenness, or treating all sectors as close to equally

as possible, except where differences are driven by
policy goals.
New York needs a level playing field among yellow,
green, black and e-dispatch services, with differences
in regulations or standard driven by clear policy goals:
(i) a quality passenger experience;
(ii) new income opportunities and good jobs;

(iv) ensuring accessible for-hire transportation options;

(v) safe and efficient NYC streets; and
(vi) maintaining a regulatory structure with integrity.

Ensure a Quality Passenger Experience

The study recommends reforms to protect the riding
public. These reforms build on steps that the TLC has
taken over the last two years to specifically address rider
safety and consumer protections.
Protect consumers from unexpected or opaque
pricing. The study recognizes that the growth of
e-dispatch means a growth in passengers traveling
without the benefit of a fixed metered fare. The City
should continue efforts to protect passengers from
unclear or predatory pricing, and continue efforts to
innovate additional protections as providers innovate in
their pricing mechanisms. Through rulemaking, the City
has taken strong measures to ensure transparency and
consumer protection in the use of differential pricing
in the e-dispatch market, and these efforts should
continue.
Coordinated shift changes. Shift changes in the Citys
taxi fleet lead to regular periods with dramatic drops in
taxi availability, often at times where there is substantial
demand for for-hire service. The City recently launched
two pilot programs to allow more flexible shift times

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 9

and has been encouraging fleet managers to better

coordinate these shift changes and moderate their
impact on taxi availability during peak hours.

Create Opportunity and Good Driving Jobs

The City should pursue a regulatory framework that
allows for the maximum flexibility for drivers to choose
between driving opportunities, while ensuring a uniform
floor of standards to protect consumers and minimize
safety risks to drivers, passengers, and other street users.
Differences between the different for-hire sectors should
not prevent good and qualified drivers from getting on
the road.
Equalize worker protections in the for-hire market.
To the extent allowable by law, the City should seek
to enhance the benefits and protections available to all
drivers. To the extent that the law is a barrier to ensuring
provision of benefits desired by drivers like health care or
disability insurance, the law should be changed.
An extended license period and faster driver
licensing processing. The speed with which a person
can become a licensed for-hire driver is of major
concern to aspiring drivers and companies providing
for-hire service. To improve processing times and
license acquisition, the TLC will continue efforts to
transition to online licensing processes wherever possible
and continue to develop a system that offers fuller
transparency to applicants about their license status and
the ability to perform more of the activities necessary
to gain a license without in-person appearances. In
addition, the City has published proposed rules to
extend the licensing cycle beyond the current two year
cycle. With improvements in licensing requirements
and better training, licensee renewals can be extended
without undermining driver standards or protections
for the public. A longer license period will also allow
for quicker processing for all current and prospective
licensees by reducing processing volume.

Cultivate a Competitive and Innovative

Market in For-Hire Service
The City and State can work together in order to create
a level playing field that encourages new entrants, while
also giving current operators an opportunity to compete
by offering quality and responsive for-hire trips.
Offer more flexibility for medallion-owners.
Recently, the City announced plans to reform ownermust-drive restrictions. Allowing medallion owners more
flexibility to put their vehicles to work will provide broad

PAGE 10 OFFICE OF THE MAYOR

benefits to the riding public, ensuring the maximum

availability of the taxi fleet.
Equalize transit-contribution and workers
compensation fees across the for-hire sector. The
State tax code and State Insurance Law set a basic
framework for the responsibilities of for-hire providers.
In the same way that we seek to provide for evenness in
Citys oversight of the industry, the relevant State laws
ought to reflect evenness in the mandates facing for-hire
vehicles. In New York City, support for mass transit and
accessibility has dropped as e-dispatch has grown. State
reforms should ensure that all for-hire services providing
on-demand service contribute to supporting mass transit
in the localities in which they operate. Further, as there
is convergence in the different classes of for-hire service,
workers compensation requirements among the vehicle
classes should be unified.

Ensure Accessible For-Hire Transportation

Options
The study recognizes the growth of e-dispatch forhire services without proper provision for accessibility
as a challenge to the Citys ability to fairly provide
transportation options to all who need them.
Increase and Enforce accessibility requirements in
for-hire service. All riders, regardless of accessibility
needs, should enjoy the same ability to use for-hire
transportation. Under the Citys existing regulations
each for-hire vehicle sector has a responsibility to provide
accessible service. The City should ensure that these
responsibilities are met through enforcement action.
Ensure accessibility in all categories of for-hire
service. Over the next several years, the yellow taxi
fleet will phase in additional accessible vehicles until
it is 50% accessible. Similarly, TLC rules require that
33% of the green fleet be accessible by 2024, with 50%
as the ultimate goal. Both accessibility models include
incentive funds to encourage vehicle conversion. In the
absence of a dramatic improvement in service provision
in the coming years, the City should pursue a similar
path to ensuring accessibility in the non-taxi for-hire
vehicle sector.
Improve coordination with Access-a-Ride to expand
on-demand accessible transportation options. The
City can expand the reach of accessible for-hire service
by identifying ways to improve coordination between
the TLCs growing accessible taxi program and the MTAs
current Access-A-Ride system. The Citys accessible
yellow and green taxis can help to provide greatly
enhanced and more efficient service for Access-A-Ride

users. The City and the MTA should continue to work

together towards that end.

Further Safe and Efficient Use of New York

City Streets
The study does not recommend a cap on for hire
vehicles at this time. While for-hire vehicles contribute
to congestion, they have not driven the decline in
Central Business District speeds that the City has recently
experienced.
Reduce congestion through targeted enforcement
of congestion-causing violations. The City should
continuously evaluate traffic-causing activities by forhire vehicles and other vehicles, particularly in the
Central Business District, with appropriate enforcement
responses. Even at current congestion levels, some forhire vehicle activities associated with passenger pickups like idling, double-parking, and blocking the
box have particular additional congestion impacts,
and should be a particular focus of enforcement in the
most congested parts of the City.
Support efforts to improve bus speeds. The City
should take steps to reverse the alarming recent decline
in bus travel speeds, which is pushing riders out of public
transportation and into other modes. It will require
strengthening incentives to fill empty seats in vehicles
consuming scarce street space in the core and shifting
low occupancy vehicles out of the core during times of
peak demand.
Better airport connections. At both La Guardia and
Kennedy Airports, the City and the Port Authority have
worked to provide better and more seamless rider
experiences for users of taxi or e-dispatch services. There
is still more opportunity to improve service at the airports
that the City should pursue in concert with the Port
Authority, particularly in facilitating ride-sharing.

Protect the Integrity of the Regulatory

System
With more for-hire vehicles on the road, there is more
opportunity for illegal or illicit activity, and the City needs
more tools to address that activity. At the same time, the
City must gain additional information from all sectors
on the activities of licensed providers to ensure proper
regulation of the system.
Crack down on illegal street hails. Illegal street hails
subject both driver and passenger to potentially unsafe
and unaccountable rides, open for-hire bases to liability

for rides that they did not arrange or mediate, and

exploit information asymmetries between driver and
passenger that can result in predatory pricing or fraud.
The right to accept street hails has historically been
limited to yellow taxis and green hail vehicles in order
to reduce congestion. This right requires the purchase
of a medallion and is subject to heightened regulatory
scrutiny. The City should pursue higher penalties for
illegal street hails, and options for criminal prosecution
against those who flout the law.
Ensure full access to for-hire data. The City works
hard to regulate the taxi and for-hire markets, but this
oversight could be more effective with fuller access to
data about the activities of market participants which
drive and inform analysis of the impact of market
activity. The City should pursue a broader set of data
reporting requirements for all FHV sectors. In addition
to the benefits such information would provide for
enforcement and the protection of public safety, more
comprehensive data would enable continuing analysis of
congestion and other impacts from the for-hire system,
allowing for informed policy making.

METHODOLOGY
CONGESTION IN THE CENTRAL BUSINESS DISTRICT:
To better understand congestion in the CBD the City
used a widely accepted model called the Best Practice
Model (BPM). The BPM model was developed to
determine the overall 2010 and 2020 vehicle miles
traveled, or VMT (private, trucks, taxi) on a 24-hour
basis. The VMT were derived from a complex traffic and
regression modeling analysis approved by the New York
City Department of Transportation. Existing and future
demand volume over time by transportation mode
was determined using BPM projections, New York City
Taxi and Limousine Commission breadcrumb data, and
e-dispatch trip records which were less complete for
the FHV sector than for the yellow and green sectors.
The future VMT projection was mapped out against the
24-hour speed profiles including the capacity reduction
factor applied to the number of roadway lane miles.
Speed depends on a combination of the facility type, the
free-flow speed, and the ratio of volume to capacity (i.e.,
the ratio of vehicular traffic demand to the supply of road
capacity to accommodate traffic) along the roadway at a
given time. The capacity of the road to serve the demand
is a function of the number of lanes, number and type of
intersections, traffic signal controls, temporary closures,
parking and double-parking. The effective capacity of

FOR-HIRE VEHICLE TRANSPORTATION STUDY PAGE 11

a road is affected by the composition of the traffic

whether private cars, buses, taxis, trucks, pedestrians,
bikes, or other modes.
Generally, when traffic volume is lower, the traffic
speed is higher; as volume increases, the speed drops
in a non-linear way. Since the CBD is near saturation
capacity during the Peak Hours (AM, Midday, and PM),
any increase in vehicle miles traveled will not show a
linear correlation to a decrease in capacity or increase
in VMT with respect to speeds. For this study, a set
of macro level curves were developed to analyze these
relationships at a zonal level. The model was used as
a directional indicator of the change not the absolute
change. A higher resolution model with more spatial and
temporal detail would yield results with more detailed
variation.
If all things were to be held constant, except for changes
in the FHV market, a comparable condition to current
congestion levels observed in the City can be anticipated
for the year 2020.
CUSTOMER/DRIVER SURVEY: The study undertook
primary research to build an understanding of the forhire vehicle market, including a survey of consumers,
a survey of drivers, and focus groups with drivers. The
consumer survey focused on mode choice decisions and
was anonymously administered by a professional market
research firm. The survey included 1,850 people in New
York City, including 1,000 consumers of for-hire services
(defined as having used a for-hire vehicle service within
the last three months). The survey results were weighted
to ensure representation of the broader New York City
population as defined by U.S. Census demographic data.
To better understand the labor market and decision
factors for drivers of for-hire services, a survey was sent
anonymously to 45,000 TLC-licensed drivers, resulting
in 2,540 complete responses (response rate of ~5%).
Finally, the study held four focus groups, reaching 26
drivers, including drivers of traditional black cars, liveries,
yellow taxis, and e-dispatch for-hire vehicles. The focus
group participants were recruited by a professional firm
and were moderated by a professional moderator not
involved in the study.
POSSIBLE FUTURE SCENARIOS: Scenarios were
developed to help the City think through the future
implications of any policy changes for the FHS market.
Scenarios were developed to address what the FHS
sector would look like by the year 2020 if the City were
to do nothing, and how those changes would impact
congestion, accessibility and revenue. Three scenarios
were developed to understand the impacts of high- and

PAGE 12 OFFICE OF THE MAYOR

low-growth of e-dispatch as well as the source of that

growth by 2020:
1. if e-dispatch growth has already peaked;
2. if the e-dispatch sector continues to grow, resulting
in net new car trips that is to say, if the growth
that occurs pulls new trips from places like public
transit, walking and biking, and other transportation
modes; and
3. if the e-dispatch sector continues to grow, but only
as a result of a displacement of taxis.
AIR QUALITY: As part of the For-Hire Vehicle Congestion
Study, macro-level air quality and traffic analyses
were conducted to estimate the existing and future
FHV impacts over the next five to ten years assuming
no changes are made to existing TLC regulations.
Additionally, two future scenarios were evaluated for
the year 2020. Case A assumes that the FHV growth
generates net new trips and Case B assumes that FHV
growth will substitute for other car-based modes, which
would not result in net new trips. As part of the analysis,
the following procedure was undertaken:
1. a regression model was developed to estimate the
future trips;
2. the future trips were then converted to vehicle miles
traveled; and
3. hourly VMTs were assigned an associated speed
based upon existing and projected future speeds.