Comment from Community Transportation Association of America (CTAA)

On behalf of its nearly 1,300 members, the Community Transportation Association of America (CTAA) is pleased to offer the following comments to the Federal Transit Administration (FTA) on its Notice of Proposed Policy Statement Regarding the Applicability of FTA's Drug and Alcohol Testing Program to Transportation Network Companies (TNCs). After considerable discussion on the proposal with member transit agencies of various sizes providing rural, paratransit and urban transit services, CTAA urges FTA to withdraw the proposed policy statement entirely and allow the important issue of the applicability of FTA’s drug and alcohol testing program to TNCs to be fully addressed through the reauthorization process for the IIJA/BIL. The wide variety and growth of technology arrangements and deployments allowing the traveling public to book, pay for, and take trips; the expansion and variety of the TNC-public transit marketplace; and the confusion created by the proposed change in answer to a Frequently Asked Question (FAQ), we believe, requires a more thorough and thoughtful approach that a surface transportation reauthorization process will allow. Further, CTAA and its members strongly recommend that FTA cease the use of FAQs in lieu of more clear and comprehensive guidance on all of its programs moving forward. Finally, CTAA is aware of TNC providers working directly with public transit agencies that currently meet the provisions of the drug and alcohol testing rules. Our request for withdrawal does not indicate support for reducing the safety of public transit passengers. CTAA and its members regard all forms of TNCs as transportation entities/providers and that whenever a TNC receives federal public transit funding it must be subject to current safety and accessibility regulations.