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Rasier-CA, LLC
1455 Market Street , 4th Floor
San Francisco, CA 94103
1
December 24, 2014
Via Email
Denise Tyrrell
Acting DirectorSafety and Enforcement Division
California Public Utilities Commission
505 Van Ness AvenueSan Francisco, CA 94102-3298
[email protected]
Re: Clarification of TNC Vehicle Inspection Requirement
Dear Director Tyrrell:
We write to request that the Commissions Safety and Enforcement
Division (SED)
clarify the manner in which inspections are conducted on
vehicles used by Transportation
Network Company (TNC) drivers who accept trip requests from the
Uber smartphoneapplication. Decision 13-09-045, entitled Adopting
Rules and Regulations on TNCs, sets
forth, in Section 2.24, that vehicles used by TNC drivers must
be inspected annually:
Prior to allowing each TNC driver to operate a vehicle, and
annuallythereafter, a TNC must inspect the drivers vehicle, or have
the vehicle
inspected at a facility licensed by the California Bureau of
Automotive
Repair, and maintain complete documentation of such inspections.
A TNC
drivers vehicle must, at a minimum, pass a 19 point inspection
prior to
allowing the driver to operate the vehicle under the TNCs
platform.
It is our understanding that Section 2.24 requires vehicles to
be inspected by a certified third
party (i.e.,a licensed California auto repair facility), or, an
employee-representative of the TNC
itself, and Rasier-CA, LLCs (Rasiers) policies continue to
reflect that understanding.
Interpreted differently, however, this requirement may appear to
allow a TNC to rely oncontracted driver partners, who are not
certified mechanics, to conduct inspections on other TNC
drivers vehicles. Given that this TNC driver peer-inspection
practice exists today in the
California TNC industry, we are writing to ask for clarification
on whether the SED believes thatvehicle inspections conducted by
TNC drivers who are not certified mechanics is consistent with
the letter and intent of Section 2.24.
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Beginning on February 2, 2015, Rasier will explore the
possibility of using its own driver
peer-inspection program, similar to current practices of others
in the TNC industry, unlessotherwise notified by SED that TNC
driver peer-inspections are not permitted under Section
2.24.
Clarification from the SED on this issue would assist Rasier in
ensuring driver partnersreceive the most accurate information. We
look forward to your response to our request for
clarification, and thank you for your consideration.
Sincerely,
K. Juvvadi
Krishna K. JuvvadiSenior Counsel
