On September 10, 2018 NYTWA submitted a letter to the Taxi and Limousine Commission Chair Meera Joshi regarding the TLC’s decision to not seek enforcement of TLC rules governing vehicle owner or agent conduct. The letter outlines how the TLC maintains disparate prosecutorial procedures for complaints made about driver conduct, and corporate licensee conduct, respectively. Moreover, the TLC has declined to enforce its rules where there are prima facie violations, punishing drivers for having “unclean hands” for conduct that falls outside TLC’s purview, all the while protecting corporate licensees’ financial interests.
As the TLC will soon be responsible for regulating the terms of For-Hire-Vehicle (FHV) leases and financing FHV driver pay, NYTWA hopes that complaints against corporate licensees will be enforced by the TLC’s Driver Protection Unit (DPU). Especially as mandatory arbitration is nearly universal in the app-based FHV sector, it is even more critical that the TLC develop a robust culture and practice of enforcement against wrongdoing by corporate licensees as the stakes for drivers will soon be much higher.