Transportation Alternatives Submitted Comments on the Taxi and Limousine Commission (TLC) Proposed Rule on Electric Vehicle Specifications
For almost 50 years, Transportation Alternatives has been a leading organization advocating for better walking, biking, and public transportation access in New York City. Today, we urge the Taxi and Limousine Commission to reject the amendment proposal to approve electric vehicles that reach 0 - 60 mph in 4.4 seconds as a matter of public safety.
As New York faces a climate crisis, electrification offers an important option in sustainability. But we cannot allow the shift to electric vehicles to lead to an increase in traffic violence and this proposal is a critical opportunity to address a growing challenge. New electric vehicles are getting larger, heavier, and faster, impeding visibility and speeding up acceleration to dangerous speeds for road users. TLC should instead consider implementing measures that address safety and sustainability for their EV fleet through speed limiting technology, limits on vehicle size and weight, and requirements for slower acceleration speeds.
Supercharged acceleration puts all road users at risk and must be regulated in a dense city like New York. The 0 - 60 mph metric emerged in the 20th century as a way to determine whether drivers could safely accelerate onto a highway. However, its continued use as a safety measurement today ignores the fact that most of today’s slowest cars are faster than the fastest cars of the 1960s. The competition to have the fastest 0-60 electric vehicle speed is not a fight that benefits New Yorkers or street safety, and the proposed rule would allow taxis to accelerate faster than NASCAR drivers could merely fifteen years ago – making it nearly impossible for people walking, biking, or using a wheelchair nearby to get out of the way in time.
At 0 - 60 in 4.4 seconds, a pedestrian walking down 5th Avenue would have only 2.35 seconds to avoid cars accelerating from a stop at the light across the street. That’s faster than the average 2.5 seconds it takes a driver to perceive and react to road conditions. And yet given the average Manhattan taxi cab travels under 10 mph, the potential for TLC vehicles to accelerate at such fast speeds is not useful for New York streets. Other cities have taken steps to address acceleration concerns; in London, the new electric black cab reaches 0 - 60 mph in 13 seconds, and in Paris, one taxicab company suspended usage of the Tesla Model 3s due to unsafe accelerations. We encourage the TLC to look to these other city models in considering permitted acceleration speeds for EVs.
The crisis of traffic safety in New York cannot be ignored: every year, crashes seriously injure 3,000 and kill approximately 250 people on New York City streets. Speeding is a major factor in crashes nationwide, and driving at a higher speed directly impacts the likelihood of a person being killed upon impact. We have the tools to save lives and prevent traffic deaths and we cannot go backward in using them.
By withdrawing this current proposed rule and requiring safer vehicle acceleration standards, New York has the opportunity to support the health and wellbeing of NYC residents and be a leader in creating a positive ripple effect on reducing global traffic violence. TLC drivers deserve to navigate the streets safely, yet the proposed rule would set an unsafe acceleration speed standard and could potentially lead to a greater number of crashes. NYC cannot wait and see how many more people are killed before we regulate acceleration. We urge the TLC to withdraw this proposal.
