Comment from Guide Dog Users Inc.

RE: Docket No. FTA–2024–0020 Notice of Proposed Policy Statement on Drug and Alcohol Testing Programs for TNCs On behalf of Guide Dog Users Inc., I am writing to express our strong support for FTA's proposed policy statement clarifying the applicability of drug and alcohol testing requirements to Transportation Network Companies (TNCs) providing public transit services. As an organization representing individuals who partner with guide dogs, we have a unique perspective on the critical importance of safety in public transportation. An increasing number of our members now rely on TNCs through paratransit programs for their daily transportation needs. While this integration of TNCs has expanded transportation options for guide dog handlers, it has also raised significant safety concerns when these services operate under different safety standards than traditional transit services. Guide dog handlers place immense trust not just in their dogs, but in their transit operators. When our members board any vehicle – whether it's a traditional paratransit van or a TNC vehicle operating under a transit agency contract – they need absolute confidence that the driver is held to the highest safety standards. The current interpretation of the "taxicab exception" as it applies to TNCs has created an inconsistent safety environment that puts riders at risk, particularly those who cannot visually verify a driver's condition or behavior. The FTA's proposed policy statement appropriately recognizes that when TNCs enter into formal arrangements with transit agencies, they become an integral part of the public transportation system. This integration should carry the same responsibilities and safety requirements as other transit modes. We know this is achievable because several TNCs already successfully implement FTA-compliant drug and alcohol testing programs while maintaining efficient operations. The clarification provided by this policy statement would: Ensure consistent safety standards across all transit services used by guide dog handlers Protect vulnerable riders who rely on paratransit services Maintain the integrity of public transportation safety programs Provide clear guidance for transit agencies and TNCs working with passengers who use service animals For our members, the stakes are particularly high. Guide dog handlers must be able to focus on working with their dogs and navigating their environment without the additional concern of whether their TNC driver is held to the same safety standards as other transit operators. The current situation, where TNCs may operate under different safety requirements, creates unnecessary anxiety and risk for our community. We particularly appreciate that the proposed policy statement doesn't restrict the use of TNCs in public transit; rather, it ensures that when TNCs participate in public transportation programs, they meet the same safety standards as other providers. This approach maintains innovation and expanded service options while protecting public safety. Guide Dog Users Inc. urges the FTA to finalize this policy statement as proposed. It represents a necessary step toward ensuring that all transit riders, including those partnered with guide dogs, receive the same level of safety protection that Congress intended when establishing drug and alcohol testing requirements for public transportation.