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Require Uber & Lyft to provide wheelchair access!
October 2, 2019
Here’s your opportunity to make Uber & Lyft more wheelchair-accessible!
ATTEND an October 10 workshop OR SEND written comments on The TNC Access for All Act, a California law to provide wheelchair-accessible rides from Uber and Lyft (and similar companies), and to charge a small fee on every TNC ride to create a fund to pay for on-demand transportation using WAVs (wheelchair accessible vehicles).
This San Diego workshop is being held by the California Public Utilities Commission (CPUC), the agency with authority over TNCs like Uber and Lyft. (“TNCs” are Transportation Network Companies.)
Key info from the CPUC notices below and attached:
Workshop on TNC Access for All Act
CPUC proceeding R.19-02-012
Thursday, October 10, 9:30 - 5
San Diego Association of Governments (SANDAG)
401 B. Street, Suite 700, San Diego, CA 92101
Local access number: 1-415-655-0002 (US)
Access code: 960 951 628
On the Internet: (for the slides only — audio is by phone)
Join Webex Meeting
https://cpuc.webex.com/cpuc/j.php?MTID=mfc781b09b7ddf7d2e8afde53b80daf7b or https://cpuc.webex.com and enter the meeting number
Meeting number: 960 951 628
Meeting password: SB1376
To submit written comments: Send them to the CPUC Public Advisor’s Office at email@example.com by the workshop date, October 10. You must include the proceeding number, R.19-02-012; ideally, in the subject line.
To people willing to make spoken comments, either in person or by phone:
Disability Rights Education & Defense Fund (DREDF) contacted the CPUC to clarify who needs to provide advance notice by Oct. 4 that you wish to speak at the workshop. CPUC staff replied that the morning "presentation" portions are primarily for Parties to present their proposals that were due last Fri 9/27—those presenters should give advance notice—but that all attendees will be able to ask questions after each presentation. [DREDF comment: It is useful to hear these presentations to learn the important issues.] In the afternoon, all attendees, with or without advance notice, whether in-person or by phone, will have the opportunity to provide input during the "open discussions” on the agenda. [DREDF comment: whether or not you’re available in the morning, we hope you will go, or call in, in the afternoon, and state one of more of the Talking Points listed below. There will likely be a time limit on public comments.]
Talking Points to convey to the CPUC about the TNC Access for All Act (referred to below as the TNC Access Act, for short):
- It’s urgent that the CPUC establish crucial benchmarks before allowing TNCs such as Uber and Lyft to take “offsets” and “exemptions.” Offsets and exemptions allow TNCs to utilize the funding generated under the TNC Access Act to provide WAV service by charging a 10-cent fee on every TNC ride. If these benchmarks, which are standards required of TNCs by the CPUC, aren’t defined FIRST, then there’s nothing to keep TNCs from using up available funds without providing high-quality on-demand service to wheelchair users.
- When drivers cancel a ride, this must be taken into account when calculating response time. If a rider is trying to reach a destination, the TNC response time begins when the rider made their first request!
- In establishing response times, the CPUC should add a new benchmark: that TNCs must provide 90% of WAV trips within an appropriate time, based on the response times non-disabled riders receive in each California county. The response-time requirement that's already in the TNC Act, which is for only 80% of WAV trips, is not strong enough to require the quality of service in the TNC Access Act’s goals: a continuously improved, reliable, and available level of service. At 80%, one in five rides can take far longer for the car to arrive than it would for anyone else. For example, in some localities, it will be important to require 80% of trips to begin within 10 minutes or less from when the vehicle is requested, and 90% of trips to begin within 20 minutes or less. Such a benchmark is inadequate with only the “80%” provision; it’s critical that a “90%” provision be added. Other transportation systems have benchmarks up to 95% of all rides, and higher.
- One key measure of acceptable service that the CPUC must address: a rider must never be stranded at their destination. The rider must be able to return home when they wish, just like anyone else.
- When offsets are taken, TNCs may only count costs that exceed what it costs to provide the same trip in a non-WAV vehicle.
- TNCs must be required to provide thorough driver training and vehicle access safety features such as effective wheelchair securements. These things are necessary for effective WAV service.
- TNCs must be required to provide detailed documentation to the CPUC, and all reported data must be available to the general public.
- The TNC Access Act also allows other access providers to obtain funding generated by the Act, if TNCs don’t meet the Act’s standards. It's important for the CPUC to clarify that these access providers are not limited to TNCs alone, which would be a nonsensical interpretation of the Act, and would limit the scope of providers needed by the disability community.
California disability advocates may remember that last year, California state Senator Jerry Hill sponsored the TNC Access for All Act, which became law on September 22, 2018. (Read the law at https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1376).
Now the CPUC is working on how to regulate this law, and things are moving fast. Please become involved!
Note that programs along somewhat similar lines are being implemented in Seattle, Portland, Chicago, and New York City. Each program takes a different approach. California’s is the first known statewide effort.
Disability groups that are working together to pressure the CPUC to issue strong, effective rules are: Disability Rights California (DRC), Center for Accessible Technology (CforAT), Disability Rights Education & Defense Fund (DREDF), and other groups committed to fully accessible TNC service, including supportive transit agencies.