Comment from Blue Ribbon Taxi Association Inc.

I fully support the recent clarification in the Federal Register regarding the misapplication of the so-called "taxicab exemption" under the Drug and Alcohol Rule. This exception was never intended to allow transit agencies to “contract away” their obligation to provide safe, reliable, and fully compliant service to their customers. Some TNCs are making the argument that the FTA is changing the rules in a way that will eliminate many valuable transportation programs to individuals. Nothing could be further from the truth. The rules are not changing, the FTA is merely, and rightly so, simply requiring transit agencies to enforce already existing rules and not allow avoiding compliance by relying on a misinterpretation of the 1994 “taxi-exemption”. The FTA is taking the correct steps in requiring compliance with existing regulations for the following reasons: Ensuring the safety of public transit riders should always be the top priority. The FTA’s proposed clarification does not eliminate service—it simply ensures that all transportation providers operating under transit agency contracts meet the same drug and alcohol testing requirements that have been in place for decades. The claim that this rule change will result in a loss of service is misleading. The reality is that numerous local transportation and mobility firms have been complying with FTA policies and requirements while still successfully delivering these services long before TNCs entered the market. These professional operators remain fully capable of continuing to meet mobility needs. Public transit riders, including paratransit users and other vulnerable populations, deserve the same safety protections no matter whether their ride is provided by a bus, taxi, or TNC. The proposed correction does not remove options—it simply holds all contracted providers to the same federal safety standards that have always been in place, although misapplied in some cases, and ensures a safer experience for all. The focus should not be on maintaining incorrectly applied or granted exemptions but rather on ensuring every passenger receives safe, reliable, and fully compliant service. If a provider is unwilling or unable to meet these long-standing federal requirements, they should not be eligible to benefit or receive funds from programs designed to operate under such requirements. There always have been and will continue to be many transportation providers willing to comply with requirements and ready and able to step up.