MAYOR & CITY COUNCIL

CITY OF DALLAS

28 April 2015

The Honorable Joe Straus

Speaker of the Texas House of Representatives
Capitol Building, Room 2W.13
Austin, Texas 78711
Dear Speaker Straus:
We are writing to convey our concerns with H.B. 2440 (the Uber bill), particularly the negative
effect a $115,000 annual transportation network company (TNC) fee would have on small or would
be start-up TNC companies. We are also writing to express our support for a statewide legislative
answer to the TNC regulatory question the City of Dallas struggled with the most - the appropriate
liability insurance requirement for TNCs.
As you may know, Dallas recently undertook a year-long review and redrafting of our
transportation-for-hire (TFH) regulations. Our goal was to encourage competition and innovation by
creating a fair and level playing field for all TFH providers, existing and new. Our efforts focused on
removing barriers to entry into the TFH marketplace and eliminating outdated, burdensome
regulation while maintaining a balance between a free market approach and public safety. During
this process, the citizens of Dallas expressed very clear support for new TFH technology like that of
Uber, and an overarching desire to have a variety of safe, quality, and af-fordable options to choose
from in TFH services.
We specifically included TNCs in our new ordinance because our experience with having TNCs
actively working in the City of Dallas for almost two years had taught us that TNCs are far more
similar to than they are different from traditional taxis and limos, and TNCs are in direct
competition with those business models. By the end of our year-long process, everyone agreed that
there could be no fair and level playing field for TFH providers unless a minimum set of uniform
rules applied to every business model. The affected parties - Uber, Lyft, independent taxi drivers and
operators, limousine companies and drivers, and members of the public all expressed strong
support for the ordinance which was passed by Dallas City Council last December.
We are very concerned that H.B. 2440 will erode the fair and level playing field we believe we have
achieved in Dallas by subjecting TFH providers - all of which are more similar than different- to
vastly different levels of regulation. Additionally and of particular concern is the provision in H.B.
2440 that establishes a $115,000 state license fee for all TNC operators. For companies that have not
yet reached the level of success or acquired the amount of venture capital that Uber has, this fee will
most certainly act as a barrier to entry into the TNC market. A fee of $115,000 is an insignificant
amount to companies like Uber. To a small operator in Nacogdoches or Jefferson or Marfa, a fee of
that size could mean the death of an entrepreneurial endeavor.

OFFICE OF THE MAYOR CITY HALL 1500 MARILLA ST., 5EN DALLAS, TEXAS 75201

For these reasons, we encourage you to oppose H.B. 2440, and to consider instead a statewide
legislative answer to the difficult question of TNC insurance requirements. In that regard, we believe
the insurance provisions in H.B. 2440 are wise, and standing alone, would not require a fee that
would in itself create a barrier to the marketplace for small TNC operators.
Sincerely,

Michael S. Rawlings
Mayor

Vonciel Jones Hill

Chair, Legislative Ad Hoc Committee

Sandy Greyson
Chair, Transportation for Hire Task Force
cc: Members of the Dallas Area Legislative Delegation

OFFICE OF THE MAYOR CITY HALL 1500 MARILLA ST., 5EN DALLAS, TEXAS 75201