To: Director
Transportation Licensing Commission
1417 Murfreesboro Road
Nashville, TN 37219-6300
Re: Chapter 6.74, Other Passenger Vehicles For Hire
Metro Livery, Inc. has served the middle Tennessee area for four years. We are an authorized ground transportation provider for Nashville International Airport with over 30 cars and approximately 200 transfers daily. All units are equipped with GPS tracking and mapping for on-time accurate pickup, with knowledgeable, professionally trained drivers. We have one of the largest car service operations in the South and nationwide affiliate network, providing the people of Middle Tennessee with the optimal level of service and value.
Before METRO LIVERY began serving the Nashville community, consumers lacked an alternative choice and were underserved. They had either the taxi industry or high priced limousines only.
Consumers had a number of issues with the taxi industry:
- Dependability, especially reservations, punctuality, no-show, etc.
- Cleanliness
- Drivers’ and taxi companies’ business ethics, such as refusing short runs
- Rates higher than the national average
- Payment issues, refusing credit cards, general inefficiency
- Not keeping customers’ ride history and records
- Insurance liability issues
- Lack of driver training and customer care programs
Consumers’ only alternative was high priced limousines, primarily serving the upper income demographic only. They were not working for “public convenience and necessity”, but money alone!
New products and services are welcomed by the American people, supported by the principle of free enterprise. Because of the poor quality of service from the taxi industry, Gaylord Opryland Hotel started it’s own car service to better serve guests. They do not offer this car service at any other Gaylord location in United States. After some time, Super Shuttle came to Nashville and offered their door-to-door shuttle service. Because of their quality of service, they were successful from day one.
METRO LIVERY is a cost effective alternative for over priced limousine and taxi. We started our business with only one car. We satisfy all county, state and federal licensing and compliances. We were so blessed because the people of Nashville accepted and gave us the privilege to serve them and accepted METRO LIVERY as a trusted service. They trust our service for on time guaranteed pick up. If our driver is over 10 minutes late, the customer gets a 100% free ride. We offer our point to point transportation to underserved areas, regardless of distance. We meet a variety of needs, whether the customer desires an hourly, mileage-based or flat rate. We apply effective marketing and customer service techniques. We also use efficient dispatch techniques with an online nationwide reservation and payment system. Customers can track their ride history and print their invoice receipts online. Because of our quality of service, METRO LIVERY is Nashville’s first choice. We are proud to call Music City home, and are grateful for the success the city has afforded us. We are ready to meet all needs of this great city. Over the next five years, we are determined to invest in a 100 % hybrid fleet and clean air vehicles, to keep Nashville beautiful and healthy.
We want the Transportation Licensing Commission to support our industry, as our business model is successfully working. Any pre-arrangement or hourly restrictions will have damaging consequences, because 95% of our business is mileage based and flat rates. Please do not merge Limousine operations with sedan or livery service. Allow customers to make their own decision as to what type of service they want to use. How can the consumer save money in slow economy? Let them decide if they need mileage based, flat rate or hourly rates! Let them decide what is most convenient for their unique needs. Why punish our industry in support of taxis? A prime example of favoritism and support is: In November 2004, a cab company was granted 40 additional permits upon two conditions: 1. They will introduce new technology and use DDS computerized dispatch in their 70 cabs and, 2. Fill up 70 permits in six months. It was a deadline. Because of poor quality of service and business practices, this company is still struggling to fill up 70 permits and install DDS dispatch. What happened to their deadline?
It is now 2009. Please do not encourage a monopoly or price fixing. Nashville taxis are allowed to cruise and pick up flaggers, and have free taxi stands to make money. Taxi permits are $75 annually, yet we shall be required to pay $250 per permit? Please apply fairness. We have been paying all metro, county, state and federal taxes for all this time. Our operation and business was grandfathered long before this proposed ordinance. One hour pre-arrangement and hourly restrictions conflict with state and federal laws. We are strongly disagreeing with this part of ordinance.
We are applying the New York City business model because it is the world’s largest livery and luxury limousine operation; with 37,000 licensed luxury vehicles for hire VS 13,000 licensed taxis. New York City defines our operation:
Livery. A for-hire vehicle designed to carry fewer than six passengers, excluding the driver, which charges for service on the basis of flat rate, time, mileage, or zones.
Luxury limousine. A luxury limousine is a for-hire vehicle with a seating capacity of twenty passengers or less, excluding the driver, which is dispatched by its base from a central facility which has certified to the satisfaction of the Commission that more than ninety percent of its for-hire business is on a payment basis other than direct cash payment by a passenger, and whose passengers are charged on the basis of garage to garage service and on a flat rate basis or per unit of time or mileage, for which there is maintained personal injury insurance coverage of no less than five hundred thousand dollars per accident where one person is injured and one million dollars per accident for all persons injured in that same accident.
If said vehicle has a seating capacity of fewer than nine passengers, and meets the minimum liability insurance requirements set forth in these rules if the vehicle has a seating capacity of ten or more passengers.
We are comfortable with other parts of the ordinance. We offer the lowest prices in town while using luxury vehicles and greater limits of liability. We are comfortable to pay the $75 annual permit fee, same as taxi. We disagree with one hour pre-arrangement and two hour minimum service time. We want to offer our customers 15 minute pre-arrangement and also want to offer mileage based and flat rates. Thank you for your consideration.
Yours truly,
Syed A Bokhari
President
Metro Livery
Please get involved and make a comment.
You can read the draft ordinance to regulate non-taxi passenger vehicles-for-hire http://www.nashville.org/tlc/