Comment from The Transportation Alliance

The Transportation Alliance (TTA) respectfully submits these comments in response to the Federal Transit Administration’s (FTA) request for public input regarding the taxi exemption and associated drug and alcohol testing requirements for passenger transportation providers. Passenger safety must remain the central objective of federal transportation policy. Drug and alcohol testing requirements—consistent with the standards established under 49 CFR Part 382 governing controlled substances and alcohol testing for commercial motor vehicle drivers—provide a critical safeguard for passengers, drivers, and the public. Drug and alcohol testing programs deter impaired driving, reinforce accountability for drivers responsible for transporting the public, and strengthen confidence in passenger transportation services. The Transportation Alliance respectfully urges FTA to: • Maintain drug and alcohol testing requirements for passenger transportation drivers. • Recognize that passenger safety protections must operate as part of a comprehensive regulatory framework. • Reject unsupported claims that safety standards will reduce transportation access. • Rely on operational data and industry experience when evaluating regulatory changes. Millions of Americans rely on passenger transportation services every day and expect to be transported safely by professional drivers. Drug and alcohol testing requirements represent one of the most effective safeguards available to prevent impaired driving. Programs established under 49 CFR Part 382 require pre-employment testing, random testing, post-accident testing, and reasonable suspicion testing. These safeguards deter impaired driving, establish accountability standards for drivers, and reinforce professionalism across the industry. Weakening these protections would undermine a safety framework that has contributed significantly to transportation safety for decades. Some commenters have suggested that maintaining drug and alcohol testing requirements could reduce transportation availability. The Transportation Alliance believes these claims are not supported by available evidence. Passenger transportation capacity in the United States has expanded significantly in recent years. Communities today are served by taxi fleets, NEMT providers, paratransit services, limousine companies, microtransit providers, and transportation network companies. Professional operators have implemented drug and alcohol testing programs for many years without reducing service availability. These programs are a routine component of responsible transportation operations. The Transportation Alliance respectfully urges FTA to: 1.Maintain drug and alcohol testing requirements for passenger transportation drivers consistent with 49 CFR Part 382. 2.Recognize drug and alcohol testing as a core passenger safety safeguard. 3.Reject unsupported claims that safety standards will reduce transportation access. 4.Ensure regulatory consistency across federal passenger safety initiatives. 5.Prioritize passenger safety and public trust when evaluating potential changes to longstanding safety requirements. Passenger transportation services play a vital role in the daily lives of millions of Americans. Ensuring the safety of those services must remain a central objective of federal transportation policy. Drug and alcohol testing requirements represent a common-sense safeguard that protects passengers, drivers, and the public. The Transportation Alliance appreciates the opportunity to provide these comments and stands ready to work with federal policymakers to ensure passenger transportation services remain safe, reliable, and accessible for all Americans.