Comment from Pinellas Suncoast Transit Authority (PSTA)

On behalf of the Pinellas Suncoast Transit Authority (PSTA) I am writing to oppose the proposed changes/clarifications to the “taxicab exemption” for rule 49 U.S.C. 5331 and Federal Transportation Administration (FTA) Drug and Alcohol rule at 49 CFR part 655. The PSTA Board’s adopted mission is “safely connecting people to places” and we strongly believe the contracted services we provide using TNCs are safe and provide a unique mobility option for our transit customers that is greatly improving their quality of life. We are grateful for the partnership the Federal Transit Administration has been to provide us the resources needed for our award-winning transit agency. Ever since 2016 when PSTA was the first agency in the United States to execute a contract with Uber, we have worked hard to ensure the safety of our customers and carefully follow all the federal guidance and requirements as we worked to improve mobility of our community. Then in 2017 we were honored to be one of the original FTA Sandbox grant recipients to expand the use of TNCs to provide mobility to our paratransit customers. While always ensuring the rider chose their service provider, including tested and non-tested options, and continuously monitoring the safety of these new innovative modes, what we witnessed was truly remarkable. Customers, especially people with disabilities loved the increased mobility that Uber and Lyft offered them. Rather than relying on the traditional paratransit model of pre-scheduled rides 24 hours in advance, now customers were choosing to ride to lunch with a friend, or the movies or to a baseball game. For the first time, many of our paratransit riders praised our agency for “treating them the same” as our regular transit riders. These mobility options, with safety records that are better than or mimic our traditional services are now a cornerstone of our service offerings. PSTA utilizes TNCs for several key programs that serve our most vulnerable populations: individuals with disabilities, senior citizens, veterans, and low-income workers. Without our programs, these riders will lose critical access to jobs, medical appointments, and activities that let them live their lives to the fullest. While we have explored what other options we might implement under the revised exemption, we believe we will be forced to cut all these programs and fall back on traditional, more expensive, pre-scheduled paratransit rides. Increased paratransit costs will force our agency to make further cuts to our fixed route transit options as well. The existing regulation is sufficient to ensure the safety of our riders, as our safety records indicate our TNC trips compare favorably with our traditional services’ safety. The current FTA guidance providing for customer choice is appreciated by our customers, provides for better understanding by our customers on the trade-offs of using this new technology, and is how our whole system is set up so disruption of hundreds of thousands of annual trips can be avoided. We urge the Federal Transit Administration to keep the current exemption in place to allow our existing partnerships with TNCs to continue providing life-changing mobility options in our community here in the Tampa Bay region of Florida. Sincerely, Brad Miller CEO, Pinellas Suncoast Transit Authority