Comment from UZURV

SUMMARY: * Uzurv is a Transportation Network Company (TNC) that partners with 20+ public transit agencies and operates an FTA Compliant Drug and Alcohol testing program. * We fully support the FTA’s proposed policy statement. * It is absolutely possible to operate a competitive, large scale TNC effectively in public transit AND comply with drug and alcohol testing requirements. * Reasonable safety measures are not an impediment to innovation and efficiency. And safety comes first in public transportation. * Uzurv and other TNCs have brought significant innovation and efficiency to public transportation, while operating compliant drug and alcohol testing programs. * If FTA Drug and Alcohol testing programs are applied to parts of public transit, they should be equally applied to all. To Whom It May Concern: * Uzurv is a Transportation Network Company (TNC) that has worked with public transit agencies since 2017. * Uzurv’s FTA compliant TNC provides multiple millions of unlinked passenger trips each year, serving 20+ public transit agencies across the United States including 5 of the top 10 agencies by paratransit trip volume. * Uzurv’s drug and alcohol testing program has been part of FTA audits and found to be in compliance with FTA requirements multiple times. This includes triennial audit reviews. * Uzurv provides FTA Compliant TNC service in both very large, high density urban areas, as well as lower-density and rural communities. * This includes operating a compliant TNC at a very large scale. * In one program with a top 5 paratransit service agency by volume Uzurv provides well in excess of 100,000 unlinked passenger trips per month with compliant FTA Drug & Alcohol testing in place. * This includes fully on-demand paratransit service and pre-scheduled service with on time performance of 97.4%+ 0 - 15 minutes from scheduled pickup across all trips. * The program provides significant operating cost efficiencies for the agency Despite assertions to the contrary, it is absolutely possible to operate a competitive, large scale TNC operation effectively in public transit AND comply with drug and alcohol testing requirements. While some TNCs do not choose to meet the requirements of FTA drug and alcohol testing, some do. The choice to allow TNCs and other providers to provide service without drug and alcohol testing is not a market necessity. It is a choice. FTA Drug and Alcohol Testing Is Necessary for Public Safety Each year, drug and alcohol testing programs identify many drivers and safety-sensitive employees who fail drug and alcohol tests. Consider the Federal Transit Administration (FTA) Drug and Alcohol Management Information System 2021 Results Summary. Statistically significant random testing showed rates of positive drug and alcohol test results in active service up for 0.99% of safety sensitive workers on average – and up to 1.56% in some regions. If not identified and removed from service through drug and alcohol testing, these impaired drivers increase the risk of accidents, injuries, and worse risks in public transportation. Safety Measures Should Be Fairly Applied to All Public Transit Riders At the core of public transit is a commitment to the safety of every passenger. Agencies provide many modes of service, from fixed route service, ADA Paratransit, to on-demand services, first / last mile, microtransit, and other innovative forms of service. If FTA Drug and Alcohol testing is applied to parts of public transit, it should be equally applied to all. Private business, in turn, has free choice to comply with equally applied safety standards or choose not to do so. Efficiency Without Compromising Safety It is absolutely possible – and proven with millions of trips annually – that agencies can integrate innovative technologies and TNC partnerships with robust compliance protocols to deliver cost-effective services without diminishing the safety of our passengers or the integrity of transit systems. The requirement also encourages more TNCs to align their safety protocols with proven drug & alcohol testing standards, further strengthening public transit networks as they evolve. Fairness and Accountability This proposed policy statement levels the playing field, ensuring that all providers—whether traditional operators or TNCs—are subject to equivalent oversight and accountability. Fairness in compliance reinforces trust among stakeholders, enables better collaboration, and fosters innovation while safeguarding public confidence. It lets markets, value creation, and fair competition determine outcomes without undue influence or preferential policies under the law. Conclusion Uzurv fully supports and encourages the FTA to finalize and implement the proposed policy statement. The statement eliminates and removes significant confusion introduced by the memos and FAQs referenced in the proposed policy statement. Thank you for your consideration -- Uzurv