Comment from Easton Coach Company

Dear FTA Administrator, We are writing in response to FTA’s Notice of Proposed Policy Statement Regarding the Applicability of FTA’s Drug and Alcohol Testing Program to Transportation Network Companies (TNCs). Easton Coach Company would like to share our experience with the Taxicab Exception and its impact on our operations. Easton Coach Company partners with NJ Transit and TNCs (primarily Uber and Lyft) to provide safe, reliable, and cost-effective transportation. Since 2023, we have operated three contracts under NJ Transit’s Access Link program, transporting approximately 700 ADA customer trips per day. In 2024 alone, our customers completed over 254,000 trips using these services, all of which rely on the Taxicab Exception. The integration of TNCs into our service has been a tremendous success, significantly improving on-time performance (OTP). Before implementation in early 2023, OTP averaged around 85%. Within three months of introducing TNCs under the Taxicab Exception, OTP rose to 95% and now consistently ranges between 95% and 98%. Additionally, for 10%–15% of daily trips—especially those for ambulatory riders that cannot be grouped with other trips and those on the outer edges of the service area—TNCs can provide the service at a significantly lower cost, often half or less than that of a traditional paratransit vehicle. Together, trip duration and service reliability have measurably improved without compromising service quality or rider satisfaction. Additionally, the TNC providers we work with (Uber and Lyft) are regulated by state and local entities and safely transport millions of passengers—both with and without disabilities—nationwide every day. As a company providing core paratransit services in partnership with transit agencies, we value the FTA's drug and alcohol policies for full-time transit employees. However, the FTA has long specified that these rules do not apply when patrons use subsidized vouchers to select taxi companies for transit services. This distinction acknowledges the challenges of administering testing programs for entities like taxi companies and TNCs that offer transit services incidentally. This policy has enabled us and transit agencies to extend transportation to individuals who might otherwise lack access. As an operations company, we can be the first to say that the collaboration with TNCs has enhanced the quality-of-service statistics we've referenced, by utilizing TNCs and Taxis for riders who choose their services as a complementary option. We are deeply concerned that the FTA’s proposed regulatory changes, after decades of flexibility, could jeopardize these programs. Eliminating them would significantly impact our customers, transit agencies, and the quality and reliability of service they have come to depend on. We respectfully urge the FTA to maintain the current guidance, at least until further discussions can take place with transit agencies and the disability community regarding the potential impacts of these changes. We appreciate your time and consideration on this critical matter. Sincerely, Easton Coach Company