May 26th, 2015

Commissioner Meera Joshi

Taxi and Livery Commission
33 Beaver Street
New York, NY 10004
Re: Proposed Regulations Regarding Ride-hailing Applications
Dear Commissioner Joshi:
We write today regarding the Taxi and Limousine Commissions proposed regulations
concerning ride-hailing applications and to advocate in the interest of tens of thousands
of businesses throughout New York City. As prime representatives of the citys small
business community, we are dedicated to fostering economic development and job
creation throughout the City and within the diverse communities we serve. We believe
that creating a business environment that embraces innovation is an essential
component to the continued success of the citys economy and the quality of life enjoyed
by its residents.
As you may know, New York Citys digital economy has developed extensively
throughout the past decade. A 2014 study released by HR&A Advisors noted that the
NYC tech ecosystem now accounts for approximately 291,000 jobs both technical and
non-technical in nature. The positive impact of these jobs, however, extends far beyond
those workers paychecks.
Innovative mobile and internet-based technologies are constantly expanding
opportunities to participate in the citys economy whether its a part-time working
mother in Manhattan being able to sell homemade products through a digital artisan
marketplace or an independent filmmaker in Brooklyn financing her next documentary on
a crowd-funding platform. This economic activity is enabled by New York Citys
innovation economy. However, when the city begins to stifle innovation, it risks dispelling
those that innovate. If this occurs, everyone loses: employees, customers and the
taxpayers.
The for-hire vehicle industry is a prime example of a sector that has benefitted greatly
from innovation. New market entrants in the for-hire vehicle industry have dramatically
improved options and access for passengers by putting more drivers on the road and
providing viable transportation options in previously underserved communities. This, in
turn, has allowed other businesses to benefit a Manhattanite can now visit a pizza
parlor in Southern Brooklyn or Staten Island without having to worry about being

stranded in a transit desert. Further, thousands of drivers themselves have benefitted

economically from this innovation-based growth.
Regulations that could potentially impede this type of progress would not only hurt
consumers, but also would send a dangerous message that reaches far beyond the forhire vehicle industry. It is a message that will resonate with innovators and
entrepreneurs across all sectors: New York City is not the place for your disruptive
ideas.
It is within this context, then, that we want to express our concern with the TLCs
proposed new app-licensing requirements. While we support the concept of maintaining
a regulatory level playing field for the wide range of participants in the Citys for-hire
vehicle industry, overregulating certain technology-based solutions will create a double
standard and unfortunately lead to a very un-level playing field for these innovators.
Further, the proposed regulations as drafted would substantially impede the operation of
technology-enabled FHV applications to service the citys airports, which have witnessed
significant improvements as a result of these new transportation options.
At the end of the day, we simply want to ensure that these regulations, while clearly wellintentioned in theory, do not in practice unduly and unequally burden technologicallydriven participants in the industry, simply because these services utilize innovative
technology to engage the marketplace.
In a city that thrives on creativity and entrepreneurialism, such a precedent could have
serious ramifications for the future of the city's economy. Therefore, as you continue to
develop a regulatory framework for digital dispatch apps, we urge you to develop a
solution that protects public safety, yet also encourages innovative competition in the
marketplace.
Very Truly Yours,

Carlo A. Scissura, Esq.

President and CEO, Brooklyn Chamber of Commerce

Nancy Ploeger
President, Manhattan Chamber of Commerce

CAS/mc