Federal Trade Commission staff submitted written comments to the District of Columbia Taxicab Commission (DCTC) on proposed rulemakings regarding passenger motor vehicle transportation services, including rules that would apply to new smartphone software applications for arranging and paying for such services. The staff comments note that recent DC legislation appears designed to facilitate new and beneficial forms of competition for the services, but express concern that some of the subsequent rules proposed by DCTC may unnecessarily impede competition.
The staff comments recommend that DCTC avoid unwarranted regulatory restrictions on competition, and that any regulations should be no broader than necessary to address legitimate public safety and consumer protection concerns. For example, regarding a proposal to restrict how software applications can affiliate with taxicab operators, the comments recommend that DCTC allow for flexibility and experimentation and avoid unnecessarily limiting how consumers can obtain taxis.
Regarding proposed rules addressing disclosure and data security issues that applications may raise, the comments note that requiring certain advance disclosures or provision of certain information in a receipt may be efficient ways to promote pricing transparency, protect consumers from misleading pricing practices, and help avoid or resolve significant consumer confusion. Staff recommends, however, that any such disclosure requirements be reasonably tailored to avoid unnecessarily inhibiting the entry and operation of applications. The comments also emphasize that applications should implement security practices that are reasonable and appropriate in light of the types of information they collect, the risks and vulnerabilities they face, and associated implementation costs.
The Commission vote approving the comments was 4-0. (FTC File No. V130008; the staff contact is Christopher Grengs, Office of Policy Planning, 202-326-2612).