Taxi-Transit Integration in the Atlanta Region

Taxi-Transit Integration in the Atlanta Region Analysis of Taxi Regulations across 40 Jurisdictions in the Atlanta Metropolitan Area June 2001 Prepared Under Contract for Georgia Regional Transportation Authority Randall Guensler Trans/AQ, Inc. Atlanta, GA

Trans/AQ, Inc. INTRODUCTION Taxicabs serve as a vital link in the regional transportation system by providing on-demand service to and from many locations in the region. Business travelers and tourists use taxis extensively to travel from the airport into Atlanta and within the downtown convention corridor. Taxicabs also serve as a critical support system for transit operations, providing service from transit stations to final destinations. Commuters require a guarantee that a reliable, on-demand, after-hours transportation service will be available before they will commit to traveling by transit or carpool. Taxis also provide back-up transportation service for Atlanta residents when their primary transportation mode is unavailable. The 13-County Atlanta Metropolitan planning area consists of 80 distinct government jurisdictions with potential regulatory authority over the operation of taxicabs (13 counties and 67 cities). The Hartsfield Atlanta Airport Authority has also adopted various requirements that affect taxi operations. The State of Georgia, through the Public Service Commission, requires that limousine drivers obtain a chauffeur's license from the State, but does not exercise direct permitting oversight on taxicab operations. The City of Atlanta (through the Bureau of Taxicabs and Vehicles for Hire) regulates the majority of taxicabs operated in the region. However, all 80 of these government bodies have the authority to adopt specific regulations governing the operation of taxicabs within their city/county boundaries. Half of the 80 jurisdictions have implemented regulations that specifically govern the operation of taxicabs. Hence, companies that choose to operate in the Atlanta region must be familiar with the requirements of any regulations that apply in the 40 areas where they may choose to operate. To perform this regulatory analysis, each jurisdiction was contacted by telephone in July 2000 to request a fax/e-mail copy of any specific zoning and operations regulations applicable to taxi operations. 1 By the beginning of September 2000, all 80 jurisdictions had provided documentation on the requested information (except for the City of Lovejoy, whose staff refused to participate in the study). Dr. Guensler of Trans/AQ cursorily reviewed each regulation to identify basic regulatory requirement consistencies and inconsistencies across regulatory jurisdiction. After performing this review, Trans/AQ created a basic operational requirements checklist containing the majority of requirements that appeared in more than one jurisdiction. Each regulation was evaluated in detail using the checklist to determine which requirements applied in each jurisdiction. Appendix 1 summarizes the analytical results. This report first summarizes the regulatory requirements across the 40 jurisdictions that have implemented taxicab regulations. Based upon the results of this regulatory analysis, the author argues for the implementation of uniform regional policies for regulating taxicab operations. The final report section proposes the method for adopting proposed regulations and provides some guidelines for developing uniform regulations for obtaining business licenses, taxicab permits, and driver permits. 1 Surprisingly, the State Law Library does not currently maintain copies of city and County ordinances, so each jurisdiction had to be contacted for copies of their regulations. The Legislature passed a law in 2000 that will require local governments to submit copies of their ordinances to the State in 2002. 1

Trans/AQ, Inc. SUMMARY OF REQUIREMENTS AND ISSUES ACROSS JURISDICTIONS Exclusionary Zoning All 80 of the county and city governments have the authority to implement zoning regulations that either allow or prohibit siting of taxicab businesses within their jurisdictional boundaries. Seven jurisdictions have essentially prohibited the siting of taxicab companies within their jurisdictions through exclusionary zoning (or failure to specifically allow taxi operations to locate within the jurisdiction). Reasonable limits on where taxicab companies can locate and reasonable restrictions on site design and operation seem logical. However, given the importance of taxi operations to regional mobility, the state should probably examine whether such exclusionary zoning should be discouraged. Company Requirements All but three of the 40 jurisdictions that regulate taxi operations require that the company obtain a business license and permit to operate a taxi facility. An annual regulatory fee accompanies permit renewal in 29 of the 37 jurisdictions. In Hapeville, companies must renew business permits every 6 months. In 14 or 15 of the jurisdictions, the local City Council must approve the business license application. Fourteen of the 40 jurisdictions require that taxi companies maintain permanent office space and 12 require the company to staff the office with a dispatcher. Fayetteville requires companies to file a drug free workplace certification. Nine regulations require that companies demonstrate that they have sufficient parking for every taxi in their fleet. Other zoning requirements in other jurisdictions may enforce similar parking requirements. The City of Clarkston requires each company to provide a restroom to drivers (which should probably be required in other areas as well). In 25 of the 40 areas, the company must maintain an updated list of vehicles and drivers, and the companies are usually required to submit list updates to the governing body within a day or two of the change. In Canton, companies must provide name changes on the vehicle and driver list to the regulatory agency within 24 hours. The City of Atlanta requires that every taxicab company maintain a minimum fleet of 25 vehicles. The intent of the requirement was presumably to ensure that only larger, more reputable companies would provide service in the Atlanta area. The supply of Atlanta taxi permits (Certificates of Public Necessity and Convenience) is limited to 1582 taxis by the Atlanta Bureau of Taxis and Vehicles for Hire. Because new companies must procure a minimum of 25 of these existing CPNCs on the open market before they qualify for a business license, the fleet size requirement serves as a significant barrier to marketplace entry. Given the regulation of taxi fares, the impact of the barrier to entry and reduced competition will not increase market prices, but can significantly reduce service quality. other jurisdictions require a minimum fleet size. The City of Atlanta, through the Mayor and City Council, regulates the rates that cab operators may charge for trips made into or out of the city. Nine other jurisdictions stipulate in their regulations that the City Council has the authority to regulate taxicab rates. The rates are not contained within the regulations, so it is not immediately clear how these cities have implemented rate restrictions. In their regulations, the city of Duluth prohibits baggage charges and the cities of College Park and Union City set the maximum flag pull rate of $1.50. Fare structures were not reviewed as part of this study, so it is not clear at this time whether the 2

Trans/AQ, Inc. allowed rates are significantly different across jurisdictions. However, from a regional transportation perspective, it would make sense to establish a reasonable rate structure that applies throughout the region. Four of the jurisdictions stipulate that the governing body has the authority to audit company financial records. Violations of the local taxi regulations in 27 jurisdictions can result in the revocation of the business license, taxi license, or both. Some cities can also impose fines for violations of taxicab regulations (e.g., up to a $1000 fine in Duluth). The general clarity of most regulations provides an unambiguous basis for determining whether a violation has occurred, and almost all of the regulations offer a hearing and/or appeals process. For example, in College Park and Union City, operators may appeal permit denials or suspensions directly to the City Council. However, in Morrow, Smyrna, and the unincorporated areas of Cobb County, the simple filing of a safety complaint by a passenger appears to be sufficient grounds for the agency to suspend the taxi operator's license (until the safety issue can be resolved by a vehicle inspection). In five areas, the governing body appears to have the discretionary authority to revoke any permits in their jurisdiction if the agency deems it in the 'interest of public safety.' The lack of specific standards in discretionary permit revocation in these areas is disconcerting and may run afoul of legal standards for avoiding arbitrary and capricious implementation of regulations. Owner Requirements In 22 of the 40 jurisdictions that have implemented taxi regulations, regulators undertake background checks of company owners before the company may obtain a business license. The main purpose of the background check appears to be to identify individuals with previous felony convictions. In Fayetteville, applicants must actually submit fingerprints and pay for a GBI background investigation. Seventeen regulations provide some kind of restriction associated with previous felony convictions. Some regulations stipulate specific felonies that prevent company ownership (typically 'morals' felonies, alcohol felonies, and traffic felonies) while others ensure that owners have never been convicted of any felony (e.g. Lawrenceville and Duluth). The felony convictions language in these regulations is concise and not subject to judgement or opinion. However, four jurisdictions impose a general morals clause, which requires that company owners be of 'good moral character.' The authorities of Canton, Lake City, Duluth, and Stockbridge must determine whether the owner is of 'good moral character' before granting the business license. However, officials have no standards against which they can consistently judge the moral standing of the owner. In Fayetteville, a person that previously operated a business that required "unusual police observation" or inspection in order to prevent violation of any law or regulation can be denied a permit. Again, discretion on the part of regulators has to be employed to determine whether "unusual police observation" had occurred. Again, the discretionary permit denial in these areas can run into problems under arbitrary and capricious legal standards. Additional ownership restrictions have been included in 18 of the 40 areas. For example, to obtain a business license, 18 jurisdictions establish a minimum owner age requirement (two require owners to be 18 years or older and sixteen require owners to be 21 years old or older). Fayetteville limits company ownership to United States citizens while 12 other jurisdictions limit ownership to US Citizens or legal residents. The city of Canton requires the company owner to post a $500 bond (however, the bond purpose is unclear). 3

Trans/AQ, Inc. Insurance Requirements The majority of jurisdictions that have implemented taxicab regulations require operators to carry minimum levels of vehicle insurance coverage. The State of Georgia requires that its citizens provide $25,000.00 coverage for individual bodily injury or death ($50,000.00 coverage per incident) and $25,000.00 per event in property damage coverage (OCGA 33-7-11). Because taxicabs are common carriers, local jurisdictions can require operators to provide higher insurance coverage limits than those minimum general driver requirements of the state. The cities of Atlanta and Conyers allow self-insurance through the posting of a bond (under detailed state regulations). The City of Atlanta requires operators to post an insurance sticker on the exterior of the vehicle indicating that the vehicle complies with the regulations. Of the 40 jurisdictions with specific taxicab regulations, 34 stipulate minimum insurance coverage limits that must be met by operators, one does not stipulate any requirements, and five are vague. The vague taxicab regulations (Conyers, East Point, Fairburn, Hapeville, and Lilburn) all require the company to carry 'adequate' insurance, but no limits are specified in the regulations. Because State insurance limits apply in these five jurisdictions, adequate insurance may simply mean meeting the state limits. Eleven of the 34 jurisdictions that prescribe minimum insurance requirements also require operators to increase their coverage to comply with any future increase in required state coverage that may exceed the locally prescribed levels. At this time, 12 of the 34 local regulations specify coverage limits that are below the minimum state limits (Austell, DeKalb County, Avondale Estates, Chamblee, Decatur, Lithonia, Douglasville, College Park, Hapeville, Union City, and Dallas). Similarly, 19 of the 34 local regulations specify property damage coverage limits below the minimum state limits (however six of these regulations stipulate that operators must meet State requirements, so their regulations actually do require a higher level). When regulations specify coverage that is below the minimum state levels, there is a possibility that an operator will not provide sufficient coverage (although it is unlikely since insurance companies are aware of the required state limits). Bodily injury insurance requirements are much higher than the $25,000 state minimum limits in 12 of the 34 jurisdictions (two at $50,000, seven at $100,000, two at $300,000, and Acworth sets the minimum limit at $1,000,000). Similarly, per event bodily injury insurance requirements are much higher than the $50,000 state minimum limits in 11 of the 34 jurisdictions (three at $100,000, six at $300,000, one at $500,000, and Acworth sets the minimum limit at $2,000,000). While higher bodily injury coverage requirements may provide residents and passengers with better peace of mind, the higher levels constitute a significant increase in the cost of taxi transportation that must be passed on to the consumer. The high insurance coverage limits was an important and significant issue raised by the taxi representatives in the July 21, 2000 GRTA taxi industry forum. It should not be surprising that there are no taxi companies located in Acworth, Lake City, Morrow, Powder Springs, and Stone Mountain, given the $300,000 or greater liability limits prescribed in their regulations. Only one taxi operation is located in Riverdale, which prescribes bodily injury coverage six times greater than the state requirement, despite the fact that Riverdale is very close to the airport. Given the regional nature of taxicab transportation, and because the state-required insurance levels have been deemed adequate by both the City of Atlanta and State of Georgia, it can be reasonably argued that these limits should apply throughout the region. Additional research and policy discussions should ascertain the 4

Trans/AQ, Inc. appropriate level of insurance coverage that should be required of all taxicab operators throughout the region. Personal injury (medical) liability coverage is not required in Georgia, although some jurisdictions do require such coverage for taxi operations. Four of these jurisdictions stipulate that operators shall provide $5,000.00 in personal injury coverage and Hapeville requires $10,000.00 in coverage. Additional research and policy discussions should also determine whether personal injury (medical) insurance coverage should be required of all taxicab operators throughout the region. Taxicab Operating Permits Aside from a business license requirement, most of the 40 jurisdictions that have implemented taxicab regulations require operators to obtain a license to operate each taxicab within the jurisdictional boundaries. All 40 of these jurisdictions (except perhaps for Riverdale, depending upon how the regulation is interpreted) require operators to obtain a taxicab permit before they can pick up passengers within the jurisdiction's limits. Trips originating within the jurisdiction clearly constitute doing business within the area. On the other hand, 16 of the jurisdictions clearly do not require taxicabs based outside of the jurisdiction to obtain a local permit to operate if they are only dropping off passengers within the jurisdiction. From a regional mobility perspective, it makes sense from an economic and mobility standpoint to ensure that taxicabs have the ability to drop passengers off at any desired location. Nevertheless, based upon a strict reading of the regulations, taxicab drivers would be in violation of taxicab operating regulations in 21 of the 40 jurisdictions if they entered to drop off a passenger without obtaining a local permit. In four of the regulations, it is not always clear whether a permit to drop off is required. For example, the term "engage in business" in the Dallas, GA rule is unclear; making it uncertain whether you need a permit to drop off passengers in the city. Most of the jurisdictions appear to require an annual permit fee for each taxicab (and some of the others may require a fee payment under separate administrative requirements). As discussed earlier, the Bureau of Taxicabs and Vehicles for Hire limits the number of taxicab permits to 1582. In Union City, the City Council can also deny permits if they deem that enough taxis are in service. Vehicle Specifications The City of Atlanta is the only jurisdiction that specifies a minimum vehicle weight for taxicabs. While the intent is probably to improve the safety of passengers by forcing companies to purchase larger vehicles, this requirement may need to be revisited in light of the potential to improve fuel economy and minimize vehicle emissions. A large number of vehicles that are lighter than the specified requirements may provide comparable crash protection. At the time of this study, The Atlanta Bureau of Taxicabs and Vehicles for Hire ordinances required that taxi vehicle age not exceed 5 years, but this regulation was not being enforced pending litigation. During the course of this study, the Atlanta City Council adopted a new ordinance stating that the age of all taxicabs must not exceed eight years. The city of Forest Park limits the vehicle age to 15 years. other jurisdictions currently specify vehicle age limits. Because the taxi fleet is often the first and last transportation experience that convention visitors to Atlanta will have, regional or statewide requirements paralleling those of the City of Atlanta are probably desirable. 5

Trans/AQ, Inc. Taxicab Mechanical Inspections Most jurisdictions that require a permit for each taxi also require routine safety inspections for these vehicles. The basic requirements can include initial certification inspections before the taxi receives a permit to operate, routine certification inspections (annual, semi-annual, or quarterly), and periodic surprise inspections in the field (Table 1). Vehicles that fail certification and routine inspections do not receive a permit to operate. Roswell requires certification that the vehicle is safe, but provides no specific inspection requirements. Under most regulations, taxi companies must immediately remove from service any vehicles that fail periodic surprise inspections conducted by the local police department. Table 1 Summary of Vehicle Inspection Requirements for 40 Atlanta Regional Jurisdictions Inspection Type Required t Required Certification 17 23 Annual 11 29 Semi-Annual 7 33 Quarterly 1 39 Periodic 21 19 Most regulations specify what vehicle components must be examined in the safety inspection (brakes, lights, windshield wipers, working door latches and windows, seatbelts, etc.). Stockbridge, Morrow, and Forest Park all stipulates tire tread requirements or a minimum tire tread depth. Sixteen of these jurisdictions stipulate that a certification sticker or inspection certificate must be posted on either the exterior or interior of the vehicle (requirements vary widely). Implementation of statewide inspection criteria for vehicles for hire and transferability/reciprocity of inspection certificates would make good common sense. Taxicab Exterior Requirements Some cities, such as Doraville 2, require that all taxis in the same company be of uniform color scheme. Roof dome lights are required in 13 areas. Sixteen jurisdictions require a clean cab exterior and eight jurisdictions infer that companies must maintain the exterior paintjobs on their cabs. Maintenance of the exterior body and trim is required in 13 of the 40 jurisdictions with regulations. The vast majority of areas require companies to paint the company name and taxi permit number (or unique identifier) on the exterior of the vehicle in large letters (visible from 50 feet or more). Operators are only required to post rate schedules on the exterior of the vehicles in Atlanta, Smyrna, and the Cobb County unincorporated area. In College Park and Union City, operators must post the $1.50 flag pull rate on the exterior of the vehicle (but the regulations do not appear to require posting of mileage rates). From the consumer's perspective, companies should probably be required to post rates on the exterior of all cabs in the region. Douglasville requires companies to paint the word "TAXI" in 4" letters on all vehicles. In Stockbridge, operators must paint the words "vehicle for hire" on the vehicle. Lilburn also requires that operators print on the exterior of the vehicle the number of persons that may be legally 2 The Doraville regulations were pieced together from 10 sets of regulation amendments to the 1969 regulation, beginning in 1992. 6

Trans/AQ, Inc. transported in the vehicle. Standardized exterior requirements for the entire region would simplify compliance with regulations. Taxicab Interior Requirements Half of the jurisdictions that have implemented taxicab regulations have adopted requirements that the operators maintain their cabs in clean and sanitary condition. More than half of these regulations specify that the cab must be free of odor and litter, and that the seat fabric, carpets and headliners be free of holes, tears and stains. Surprisingly, only nine of the 40 jurisdictions specifically require that taxicabs be equipped with heating and air-conditioning units in good working order. Eleven cities require that operators equip their taxis with a spare tire and jack and nine cities require that all cabs maintain two-way communication with a base station. Only the City of Atlanta requires operators to have a map in the vehicle. Atlanta also prohibits any items in the cab that could obstruct the driver's vision. Standardized interior requirements for the entire region would simplify compliance with regulations. More than 20 of the 40 jurisdictions require taxicab companies to provide passengers with a visible fare card inside the vehicle. Twelve of the 40 cities have included specific taximeter requirements (typically associated with certification of taximeter accuracy and visibility to the passenger). The Department of Agriculture, or another state agency handling weights and measures regulations, could perform such taximeter certifications if the requirement extended across the region. The City of Atlanta only allows taxicabs to display interior and exterior advertising materials approved by the Bureau of Taxicabs and Vehicles for Hire. Given the significant financial implications associated with approval of advertising, this requirement should be reviewed at the regional level. The potential for abuse of discretion is significant. The regulatory agencies may find it desirable to prohibit certain types of advertising. However, rules and procedures for advertising approval (or better yet, disapproval) need to be formalized so that abuse of discretion cannot occur. Driver Requirements Drivers are required to obtain a permit to operate in 38 of the 40 jurisdictions that have implemented taxicab regulations. Minimum driver age requirements are included in 26 of the regulations (eight stipulate a minimum age of 18 years and eighteen stipulate a minimum age of 21 years). Twelve jurisdictions require that drivers be either US citizens or legal aliens with work permits. Stockbridge issues licenses only to US citizens. Three areas have implemented residency requirements; presumably to ensure that cab operators can find local destinations. Douglasville and Stockbridge require a six months residency in their cities and the City of Fayetteville requires cab operators to have been a County resident for one year. English proficiency is required in 12 of the cities. However, no specific standards are stipulated through which "proficiency" can be determined. In Riverdale, Fayetteville, Hapeville, and rcross, drivers must provide a doctors health certificate conforming that the driver has no health impediments that would prevent him/her from operating a taxicab in a safe manner. Six jurisdictions require the City Council to approve (by vote) all cab licenses. 7

Trans/AQ, Inc. A Georgia Class C driver's license is required of all drivers in Georgia (although it is only specifically listed in 16 regulations). In some areas, such as Lawrenceville, drivers cannot obtain a permit if their state driver's license has been revoked within the previous 6 months. Six jurisdictions require operators to obtain a commercial drivers license from the state of Georgia (the City of Atlanta does not require this) and one requires that the driver have held their license for more than one year. Some jurisdictions allow the issuance of temporary driver's permits. For example, East Point can issue a 45-day temporary permit and Fayetteville can issue a 30-day temporary driver's permit. However, some jurisdictions specifically prohibit the issuance of temporary permits. Most of these jurisdictions require annual renewal of the permit and assess an annual fee. Most jurisdictions (27 of 40) require drivers to post a large driver's permit in a conspicuous place inside the cab (typically on the sun visor in view of the passengers). In Doraville, drivers must actually carry an ID card on their person. A standard driver permit application form would likely benefit all jurisdictions. Uniform applications would ensure that drivers provide all required data. 3 Prospective drivers must undergo a background investigation in 27 of the 40 jurisdictions. The main purpose of the background check appears to be to identify individuals with felony convictions. Twenty-two regulations provide some kind of restriction associated with previous felony convictions. Some regulations list specific felonies that prevent drivers from obtaining a license (typically morals felonies, driving under the influence and other alcohol felonies, and traffic felonies) while other regulations ensure that drivers have never been convicted of any felony. As with the company owner requirements, the felony convictions language in these regulations is usually concise and not subject to judgement or opinion. However, nine jurisdictions impose a general morals clause requiring that drivers must be of 'good moral character.' For example, the Conyers City Council can take 'character, responsibility, and experience of the applicant' into account. In Hapeville, driver applications actually require three character reference letters from individuals that have known the applicant for at least five years. In East Point, no driver 'who drinks intoxicating liquor' can obtain a permit. This requirement, on face value, infers that anyone who even drinks beer on weekends when not on duty cannot receive a driver's permit. Officials have no standards against which they can consistently judge the moral standing of the driver. Again, discretionary permit denial in these areas can be problematic, given the legal requirement that jurisdictions must prevent arbitrary and capricious implementation of regulations. Fourteen jurisdictions require or infer that cab drivers must maintain a safe driving record to obtain/retain their operator's permit. Limitations on the number of moving violations or insurance points are contained in nine regulations. Acworth, Marietta, Fayetteville, Lawrenceville, and Powder Springs may revoke a driver's permit if a cab driver receives a single moving violation. Although the discretionary authority here does provide clear criteria for evaluation (violation of a traffic law) the discretion over when the provision is or is not enforced can create a legal dilemma for the agency (under arbitrary and capricious standards). In Doraville, four moving violations in a 24-month period will result in license revocation. Four moving violations in a 12-month period will result in license revocation in Stone Mountain, College Park, Union City, and rcross. In Roswell, the rule stipulates three violations within 12 months. Only the City of Atlanta requires that drivers undergo training. However, cab 3 In Fayetteville, the regulation still stipulates that the driver application shall indicate the "color" of applicant 8

Trans/AQ, Inc. operators and company owners did raise questions as to the effectiveness and timing of this training during the July 2000 GRTA taxi forum. Violations of the local taxi regulations can result in the revocation of the driver's permit in nine jurisdictions. The general clarity of most regulations provides an unambiguous basis for determining whether a violation has occurred, and almost all of the regulations offer a hearing and/or appeals process. Discretionary permit revocation provisions exist in nine of the 40 jurisdictions. As discussed earlier, with respect to discretionary revocation of taxi or business licenses, similar potential problems exist in the discretionary driver permit provisions. In Lilburn, upon "proper showing by police or records of other courts" a judge may revoke driver's permit. Yet, the regulations are not clear about the basis for permit revocation. In Douglasville even under a discretionary 45-day driver permit suspension, the driver must request hearing or keep suspension. After the hearing determines the issues, the City Council may revoke the permit. Again, the lack of clear and specific standards in discretionary permit revocation is a major issue. Six of the jurisdictions prescribe that each driver must affiliate with one and only one company. In Stone Mountain, driver's can only obtain a permit if the request is submitted on taxi company letterhead. The City of Atlanta is the only jurisdiction that limits a driver's ability to change company affiliation. Drivers must maintain their company affiliation for one year before they can switch companies. Thirteen jurisdictions have implemented requirements associated with driver attire. In general, jurisdictions that limit driver attire use standard language, probably cut, and pasted from a single regulation. Drivers are required to wear long pants, shirts/blouses with sleeves, and shoes. Hats are often limited to baseball cap or chauffeur hat style (in nine cities). Atlanta, Canton, and Duluth prohibit disorderly conduct of drivers. Atlanta and Duluth also prohibit abusive driver behavior. Violations of driver conduct requirements in these cities can result in permit revocation (at the discretion of the police chief). Company and Onroad Operations The regulations covering company and onroad operations vary greatly from city to city. Fare refusal based upon gender, race, age, sexual orientation, etc. is one of the biggest problems in Atlanta according to the Bureau of Taxicabs and Vehicles for Hire. Fare refusal is specifically prohibited in 12 of the 40 jurisdictions. Call jumping, or picking up a fare that has called for another cab, is prohibited in nine of the cities. Onroad operations require taxi operators to take the most direct route to the passenger's destination in only three jurisdictions (Atlanta, Smyrna, and Cobb County unincorporated areas). Drivers and taxi operators must maintain daily records, or trip sheets, in 13 of the jurisdictions and are required to issue passenger receipts upon request in six cities. These logs usually must include notation of any personal property left in the vehicle by a passenger. Proper care of this personal property is specifically required in 10 of these regulations. 9

Trans/AQ, Inc. Taxicabs are prohibited from "cruising" for passengers in 15 of these 40 jurisdictions. In these areas, taxi operators are required to sit at their business office location or in an approved taxi stand and wait for passengers to call for a ride. Such regulations are a major problem for regional mobility. Taxi operators rely upon visibility and convenience to obtain paying passengers. Taxi trips are predominantly impulse decisions and the total number of trips made by taxi is significantly impacted by the visible presence of a taxicab at the trip origin. Unless taxi stands are numerous and well placed, taxi businesses cannot thrive. Prevention of cruising for the purposes of limiting congestion and improving safety on specific corridors is understandable. However, citywide restrictions on taxi cruising constitute a significant impediment to commerce. In nine of the 40 jurisdictions, regulations stipulate that the maximum number of passengers in a taxicab is limited to the number of legal seats (as described by the vehicle manufacturer). Conyers stipulates that a maximum of five passengers may ride in any taxicab. Five jurisdictions allow the use of the front seat by passengers only when the back seats are already in use. Five jurisdictions prohibit the use of the front seat by non fare-paying passengers (i.e. friends of the driver). Passenger comfort requirements appear in the form of smoking and radio restrictions. Drivers are not allowed to smoke or play the radio upon passenger request in nine of these areas. Invehicle televisions may not be used in three cities. Safe driving is a condition of retaining a driver permit under six of the regulations. Obeying traffic laws and discharging passengers in safe locations (from the right-hand side of the vehicle) are often required. As discussed earlier, drivers that violate traffic laws may be subject to permit revocation. In the cities of Canton and Conyers, the violation of any alcohol laws is grounds for revocation of a driver permit (any rule associated with transport, possession, purchase, or selling alcohol). Transport of alcohol is prohibited in eleven jurisdictions. Forest Park and Stockbridge prohibit the transportation of hazardous materials in the taxicab. The cities of Canton and Conyers prohibit the transportation of criminals by taxicab. For example, Canton taxicab drivers may not knowingly transport criminals, narcotics peddlers, prostitutes, bootleggers, or other persons in commission of a crime. Union City states that taxicabs may not 'facilitate' prostitution. However, it is difficult to surmise how the agencies are to enforce the language in these requirements. Interestingly, Doraville requires that cabs drop off passengers at the front entrance of hotels. Presumably, this requirement is in place to help minimize the involvement of taxicabs in prostitution. Canton also prohibits the transportation of weapons in the vehicle. Conyers and Union City have imposed a number of solicitation restrictions on taxi drivers. In Conyers and Union City, drivers may not solicit business for hotels. In Union City, drivers must sit in or stand next to their vehicle and may not solicit passengers by 'loud or annoying voice.' In Union City, cab sharing is only allowed with patron permission (no double charging is allowed). In Union City, drivers may leave a vehicle unattended for only 10 minutes at a time. 10

Trans/AQ, Inc. Taxi Stand/Parking Restrictions Twelve jurisdictions have implemented specific requirements associated with taxi stand operations and/or parking restrictions. In some areas, the police department and/or City Council must approve taxi stands. Vehicle operations in taxi stands and taxi waiting areas is also prescribed in certain areas. The City of College Park provides a detailed description of taxi stands and provides rules for taxicab operators on how they are to operate within taxi stand queues. Hartsfield Atlanta International Airport Policies Hartsfield Atlanta International Airport operates a taxi staging area that accommodates approximately 300 vehicles. All vehicles operating from the airport must obtain a City of Atlanta operators permit or a special permit issued by the Hartsfield airport ground transportation department. Vehicles feed from the staging area (known as the "bull pen") to the ground transportation center under the direction of ground transportation staff. A taxi starter in the passenger assembly area 'rings' for taxis in the bullpen when they are needed for passenger service. Hartsfield has implemented regulations, entitled Taxi Standard Operating Procedures, to manage the operations of taxis on airport property. The Operating Procedures prescribe basic driver and vehicle standards that parallel those of the City of Atlanta. Under the airport regulations, drivers that refuse fares can be dealt with seriously through disciplinary proceedings. The operating procedures affect driver conduct in the staging area (e.g. prohibiting profanity and gambling). The procedures also provide specific instructions to drivers on how to queue for passengers and operate their vehicles while on airport property. POLICY RECOMMENDATIONS The regulatory environment for taxi operations in the Atlanta region is severely fragmented. There are 80 distinct government jurisdictions with potential regulatory authority over the operation of taxicabs (13 counties and 67 cities) in the Atlanta region. The State of Georgia and Hartsfield Atlanta Airport Authority have also adopted various requirements that affect taxi operations. The City of Atlanta (through the Bureau of Taxicabs and Vehicles for Hire) regulates the majority of taxicabs operated in the region. However, all 80 of these government bodies have the authority to adopt specific regulations governing the operation of taxicabs within their city/county boundaries. Most cities and counties have adopted zoning ordinance requirements and business license provisions that affect the industry. Furthermore, half of these 80 jurisdictions have implemented regulations that specifically govern the operation of taxicabs. Hence, taxi operators face a myriad of requirements if they desire to operate throughout the region. Taxi companies have 40 distinctly different regulations to contend with in transporting passengers throughout the region. In some local jurisdictions, local taxi and driver permits are required before taxis can respond to a call for service from within the locality, or even drop off a passenger coming from the airport. While taxi operators typically abhor government intervention in private taxi markets, the current fragmented nature of the regulatory environment is such that private taxi operations could benefit significantly from regulatory streamlining. Based upon the results of this regulatory review, Trans/AQ, Inc. recommends that the Georgia Regional Transportation Authority, through the Governor's Office, submit a regulatory proposal to the legislature that would establish uniform regional policies affecting the licensing and 11

Trans/AQ, Inc. operation of taxicabs in the greater metropolitan Atlanta region. Under this proposal, a new state law would call for the implementation of state regulations that provide uniform requirements for obtaining business licenses, taxicab permits, and driver permits. The Georgia Regional Transportation Administration should propose the new law and regulations only after conducting a series of stakeholder reviews and public workshops. The proposed changes in law and regulation will need to address a number of significant issues that directly affect the livelihoods of current taxi operators. For example, current competition in the City of Atlanta marketplace is a function of the number of Certificates of Public Necessity and Convenience (CPNCs) in circulation. Of prime importance in the proposal of new law and regulations is the property value of the existing CPNCs currently under the jurisdiction of the City of Atlanta. Many taxi drivers choose to operate e solely between the airport and downtown, carrying only two or three fares per day (and making little, if any profit). Yet, many Atlanta citizens complain that it is difficult to find a taxi when they need one elsewhere in the region. If the latent demand for taxi service is significant, the Atlanta taxi fleet is simply not operating efficiently nor is it maximizing potential revenues and profits. This may be the result of limited competition and barriers to entry in the taxi market. It may be worthwhile for stakeholder groups to consider policy means to improve competition for limited operating licenses in an effort to stimulate efficient demand-responsive service. However, any taking or reallocation of these permits may require fair value compensation of permit owners. Proposed regulations could retain the existing certificate system, and provide for new and separate operating certificates in other jurisdictions if deemed necessary. Only a stakeholders group, with input from an appropriate legal team, will be able to develop acceptable policy proposals in this area. Based upon the assessment of the current regulations in the region, there are a number of general provisions that should be considered for integration into any proposal for uniform regulatory requirements: Prohibit exclusionary zoning that would prevent siting of a taxicab operation in any jurisdiction within the region Establish uniform procedures and requirements for obtaining taxicab company operating permits and establish uniform annual regional fees Eliminate minimum vehicle ownership requirements in Atlanta or lower them from the existing 25 vehicle minimum to increase competition Consider annual state-run auctions of CPNC use permits and/or the development of a state-facilitated CPNC trading market Require a permanent office and dispatcher for each company as well as two-way communication between all vehicles and the base Replace all discretionary company, vehicle, and driver permit disapproval/revocation provisions with specific criteria ensuring that enforcement will not be arbitrary or capricious Ensure that permits can be obtained by all citizens with legal work status (not just US citizens) Unify owner and operator age requirements at either 18 or 21 years 12

Trans/AQ, Inc. Perform owner and driver background investigations at the state level and define a single set of standards that must be met by owners and drivers to qualify for a permit (i.e. previous felony convictions, previous driving records, etc.) Eliminate the morals clauses within current regulations that provide determination of 'moral standing' without prescribed guidelines Provide uniform rate regulations that apply throughout the region and require that these rates be posted inside and outside of the vehicle Use the stakeholder review process to define appropriate insurance coverage limits and standardize them at the state level Prohibit the implementation of local regulations that require taxi operators to obtain a permit to drop off passengers within any jurisdiction Develop a regional strategy to implement and allocate taxi permits for picking up passengers anywhere in the region Establish criteria for loss of driver's licenses based upon citations for moving violations Determine whether regional taxi driver training courses should be required and offered by the state Establish uniform driver attire requirements that ensure driver comfort but still provide a positive impression on Atlanta visitors Consider changing driver affiliation requirements so that cab drivers can move from company to company more readily Establish uniform taxicab specifications (size, weight, vehicle age, luggage capacity, seatbelts, etc.) Implement statewide vehicle certification and annual (or more frequent) safety inspection requirements with specific inspection elements, guidelines, and approval processes Issue inspection certificates and window stickers that are valid anywhere in Georgia to vehicles passing each annual inspection Allow periodic safety inspections to be conducted by local law enforcement and establish procedures for documenting and correcting safety violations Implement uniform exterior marking standards for vehicles that include company name, permit numbers, come lights, advertising, fare rates, etc. Implement uniform interior cleanliness standards for vehicles Ensure that air conditioning and heating units are operational year-round and not just at the time of the annual inspection Require all drivers to carry a map, spare tire, and jack Require that taximeters be certified by the state annually and periodically for accuracy Evaluate current advertising approval provisions implemented by the Bureau of Taxicabs and Vehicles for Hire and determine if changes to the regulatory structure are needed Establish uniform requirements for onroad operations, including: fare refusal, call jumping, maintenance of trip logs, personal property care, use of most direct routes, abusive behavior, passenger loading and unloading, issuance of receipts, smoking, use of radios and televisions, and transport of alcohol and hazardous materials Develop a comprehensive policy for more widespread implementation of taxi stands and limited prohibitions on taxi cruising that will maximize regional mobility, increase quality of taxi service, and increase taxi mode share 13

Atlanta City Atlanta City Allowed by Zoning Specific Regulations Company Requirements Jurisdiction Permit Minimum Vehicle Ownership 25 Permanent Office Dispatcher Parking for Every Vehicle Restroom at Company List of Drivers/Vehicles Rates Regulated by Jurisdiction Audits of Financial Records Violation = Permit Revocation Safety Complaints = Suspension Owner Requirements Owner Age Requirement 18 US Citizen Only US Citizen or Resident Felony Vehicle Convictions Owner Bond Insurance Requirements Bodily Injury Per Person (1,000's) 25 Bodily Injury Per Crash (1,000's) 50 Property Damage (1,000's) 25 Personal Injury (1,000's) Automatically Adjust (State Regs) Self-Insurance Allowed Taxicabs Jurisdiction Permit to Pick-Up Jurisdiction Permit to Drop-Off Minimum Vehicle Weight Vehicle Age Mechanical Inspections Certification Annual Inspection Semi-Annual Inspection Quarterly Inspection Periodic Inspection Police can remove from service Exterior Requirements Company Name Permit Number Rate Schedule Roof Dome Light Clean Body and Trim Paint Job Inspection Sticker Insurance Sticker Interior Requirements Clean and Sanitary Odor Litter Holes in Carpet Holes in Seat Fabric Holes in Headliner Air Conditioning/Heating Door Latches Two-Way Communication Spare Tire Visible Jurisdiction Driver Permit Rate Card Taximeter Requirements Map Vision Obstruction Only Approved Advertising A - 1

Atlanta City Atlanta City Driver Requirements Jurisdictional Permit Age Requirement 18 US Citizen, Resident (or Permit) Local resident requirement English Proficiency Health Certificate Georgia Class C Drivers License Commercial Drivers License Hold License for 1 Year Safe Driving Record DUI's MV Felony Convictions Less Than 5 Points Moving Violations Driver Training Operator Bond Disorderly Conduct Company Affiliation Limits Maintain Affiliation 1 Year Proper and Clean Attire Long Pants Shirt w/sleeves (no T's) Shoes Hat Limitations Traffic Violation = Revocation Permit Violation = Revocation Onroad Operations Daily Trip Sheet Cruising Fare Refusal Call Jumping Most Direct Route Safe Driving Right-side passenger discharge Max Passengers = Legal Seats Front Seat only when back are full Issuance of Receipts Personal Property Care Smoking/Radio by Request Television Co-Pilots Abusive Behavior Alcohol Transport HazMat Transport Transport of Criminals Weapons Taxi Stands Taxi Stand/Parking Restrictions A - 2

Cherokee County Unincorporated Ball Ground Canton Holly Springs Nelson Waleska Woodstock Allowed by Zoning Specific Regulations Company Requirements Jurisdiction Permit Minimum Vehicle Ownership Permanent Office Dispatcher Parking for Every Vehicle Restroom at Company List of Drivers/Vehicles Rates Regulated by Jurisdiction Audits of Financial Records Violation = Permit Revocation Safety Complaints = Suspension Owner Requirements Owner Age Requirement US Citizen Only US Citizen or Resident Felony Vehicle Convictions Owner Bond Insurance Requirements Bodily Injury Per Person (1,000's) Bodily Injury Per Crash (1,000's) Property Damage (1,000's) Personal Injury (1,000's) Automatically Adjust (State Regs) Self-Insurance Allowed Taxicabs Jurisdiction Permit to Pick-Up Jurisdiction Permit to Drop-Off Minimum Vehicle Weight Vehicle Age Mechanical Inspections Certification Annual Inspection Semi-Annual Inspection Quarterly Inspection Periodic Inspection Police can remove from service Exterior Requirements Company Name Permit Number Rate Schedule Roof Dome Light Clean Body and Trim Paint Job Inspection Sticker Insurance Sticker Interior Requirements Clean and Sanitary Odor Litter Holes in Carpet Holes in Seat Fabric Holes in Headliner Air Conditioning/Heating Door Latches Two-Way Communication Spare Tire Visible Jurisdiction Driver Permit Rate Card Taximeter Requirements Map Vision Obstruction Only Approved Advertising 21 $500 50 100 10 A - 3

Cherokee County Unincorporated Ball Ground Canton Holly Springs Nelson Waleska Woodstock Driver Requirements Jurisdictional Permit Age Requirement US Citizen, Resident (or Permit) Local resident requirement English Proficiency Health Certificate Georgia Class C Drivers License Commercial Drivers License Hold License for 1 Year Safe Driving Record DUI's MV Felony Convictions Less Than 5 Points Moving Violations Driver Training Operator Bond Disorderly Conduct Company Affiliation Limits Maintain Affiliation 1 Year Proper and Clean Attire Long Pants Shirt w/sleeves (no T's) Shoes Hat Limitations Traffic Violation = Revocation Permit Violation = Revocation Onroad Operations Daily Trip Sheet Cruising Fare Refusal Call Jumping Most Direct Route Safe Driving Right-side passenger discharge Max Passengers = Legal Seats Front Seat only when back are full Issuance of Receipts Personal Property Care Smoking/Radio by Request Television Co-Pilots Abusive Behavior Alcohol Transport HazMat Transport Transport of Criminals Weapons Taxi Stands Taxi Stand/Parking Restrictions 18 $500 A - 4

Clayton County Unincorporated Forest Park Jonesboro Lake City Lovejoy Morrow Riverdale Allowed by Zoning Specific Regulations Company Requirements Jurisdiction Permit Minimum Vehicle Ownership Permanent Office Dispatcher Parking for Every Vehicle Restroom at Company List of Drivers/Vehicles Rates Regulated by Jurisdiction Audits of Financial Records Violation = Permit Revocation Safety Complaints = Suspension Owner Requirements Owner Age Requirement US Citizen Only US Citizen or Resident Felony Vehicle Convictions Owner Bond Insurance Requirements Bodily Injury Per Person (1,000's) Bodily Injury Per Crash (1,000's) Property Damage (1,000's) Personal Injury (1,000's) Automatically Adjust (State Regs) Self-Insurance Allowed Taxicabs Jurisdiction Permit to Pick-Up Jurisdiction Permit to Drop-Off Minimum Vehicle Weight Vehicle Age Mechanical Inspections Certification Annual Inspection Semi-Annual Inspection Quarterly Inspection Periodic Inspection Police can remove from service Exterior Requirements Company Name Permit Number Rate Schedule Roof Dome Light Clean Body and Trim Paint Job Inspection Sticker Insurance Sticker Interior Requirements Clean and Sanitary Odor Litter Holes in Carpet Holes in Seat Fabric Holes in Headliner Air Conditioning/Heating Door Latches Two-Way Communication Spare Tire Visible Jurisdiction Driver Permit Rate Card Taximeter Requirements Map Vision Obstruction Only Approved Advertising Unknown 21 21 21 100 100 300 100 300 300 500 300 50 10 50 50 15 A - 5

Clayton County Unincorporated Forest Park Jonesboro Lake City Lovejoy Morrow Riverdale Driver Requirements Jurisdictional Permit Age Requirement US Citizen, Resident (or Permit) Local resident requirement English Proficiency Health Certificate Georgia Class C Drivers License Commercial Drivers License Hold License for 1 Year Safe Driving Record DUI's MV Felony Convictions Less Than 5 Points Moving Violations Driver Training Operator Bond Disorderly Conduct Company Affiliation Limits Maintain Affiliation 1 Year Proper and Clean Attire Long Pants Shirt w/sleeves (no T's) Shoes Hat Limitations Traffic Violation = Revocation Permit Violation = Revocation Onroad Operations Daily Trip Sheet Cruising Fare Refusal Call Jumping Most Direct Route Safe Driving Right-side passenger discharge Max Passengers = Legal Seats Front Seat only when back are full Issuance of Receipts Personal Property Care Smoking/Radio by Request Television Co-Pilots Abusive Behavior Alcohol Transport HazMat Transport Transport of Criminals Weapons Taxi Stands Taxi Stand/Parking Restrictions $5 A - 6