February 19, 2015

Change On the Way for Rideshare Regulation in Missouri?

The Mardi Gras celebrations that took place last week in Soulard were met with extremely cold weather, with temperatures dropping into the teens after nightfall. I was driving through the area later that night, directly behind an empty cab. As we neared an intersection, a woman came forward to hail the cab. It drove right by and left her in the cold.

Maybe that cab driver had someplace to go or was simply done driving that day. I do not know. But what I do know is that woman could have used a convenient, inexpensive ride home. The same is true of the 60 drivers who were cited with DWIs before 8 p.m. Unfortunately, the supply of taxis in Saint Louis is strictly controlled by a regulatory body that thinks it knows how many cabs Saint Louis should have and how those cabs should serve customers.
That body is known as the St. Louis Metropolitan Taxicab Commission (MTC), and they have decided that new ridesharing services like Uber and Lyft should not be able to provide needed transportation to Saint Louisans on nights like February 14. Instead, they tightly control the supply and business practices of for-hire vehicles, as we have detailed in previous blog posts. That includes UberBlack (Uber’s expensive black car service), which can only partner with a limited supply of MTC-licensed premium sedans.

But change may be in the air for Missouri cities, including Saint Louis. Other cities, like Kansas City and Columbia, have or are in the process of changing their taxi codes to allow ridesharing. However, Columbia’s changes ask for insurance that is reportedly 20 times the dollar amount they require for cabs, perhaps to make Uber too expensive to operate.

At the state level, two bills in the Missouri Legislature, SB 351 and HR 792, would set a statewide standard for the regulation of Uber, Lyft, and other ridesharing companies (officially transportation network companies) given certain license payments and insurance coverage. If these state standards pass, it would be a dagger to the heart of the MTC, as it would preclude that body from regulating ridesharing companies in any way. The MTC’s significant barriers to entry and management of ridesharing company driver supply would be eliminated. That would open the door for cheaper, more plentiful transportation in Saint Louis.

In the many states where ridesharing companies are allowed to operate, thousands, and sometimes tens of thousands, of for-hire vehicle drivers have entered the market. Even during peak hours, they pick up passengers quickly and offer the ease of app-based payment, all for prices competitive with regular cabs.

Just think, next time it might be you on the street corner in the freezing cold after a big event. Would you want to rely on a few passing cabs to decide whether your fare was worth the trouble? Or would you rather rely on a competitive market that includes cheap, responsive ridesharing services at the touch of a button? Not a hard choice, unless of course you’re a taxi regulator.

February 17, 2015

Don’t Ban Tesla to Protect Middlemen

Missouri auto dealers, through the Missouri Automobile Dealers Association (MADA), is on the offensive. Their target is Tesla, the luxury electric car manufacturer, and their goal is to prevent the company from selling cars in Missouri. They backed a bill in 2014 which would have banned Tesla, and now that that effort has failed, they have filed a lawsuit against the state of Missouri.

The essence of the dispute is that Tesla, uniquely among U.S. car companies, does not use middlemen (dealerships) to sell its cars. MADA, which represents those middlemen, wants it to be illegal for a car company to directly sell its vehicles to consumers. They claim it already is illegal, under the Missouri Motor Vehicle Franchise laws. But the Missouri Department of Revenue disagrees, claiming the laws are only applicable to manufacturers that have dealerships in the state and are not designed to enshrine dealerships as the only method of selling cars.

Along with their legal and legislature maneuvering, MADA is publicizing why Missouri should create more regulations to enshrine the dealership model as the only way to sell cars. They argue that without car dealerships the state’s economy would suffer and that consumers need the type of long-term car care that only they, and not the manufacturer, can provide.

Without a doubt, using car dealerships as a sales and maintenance unit has many advantages for manufacturers and consumers. After all, it became the dominant mode of selling cars for a reason. However, it is not an intrinsically superior way to buy and sell a car and certainly should not be afforded new legal protection.

For example, according to a report from the Department of Justice, dealerships can raise the costs of selling cars. Experiences from General Motors sales internationally have shown that manufacturer-direct sales can lower the cost of a car by 8.6 percent. Furthermore, consumers may prefer manufacturer-direct sales over the uncertainty of haggling with car dealers, if they are given the choice. One poll conducted in the United States found that half of respondents would prefer to buy from the manufacturer even if they were not offered a lower price.

MADA’s efforts would take that choice away. They claim that buying a car is an important financial decision and that dealers provide the long-term care customers need. But there is no shortage of ways consumers could choose to service their vehicles if they buy directly from Tesla, including agreements with auto-repair shops. Car buyers are no less capable of looking after their assets than homebuyers, who somehow manage to purchase and maintain houses without house dealerships.

As for the economy as a whole, protecting a certain way of selling cars is no way to increase jobs or increase competitiveness. Business models change constantly and create new opportunities and products even as they replace older ones. That sentiment underlined the Federal Trade Commission’s (FTC) criticism of Missouri’s legally entrenched franchise system. They stated, “[C]onsumers are the ones best situated to choose for themselves both the cars they want to buy and how they want to buy them.” That may not always be to the benefit of car dealers, but it’s good economics and good for the state.


February 2, 2015

Don’t Ban Tesla, Let It Compete

We wrote last year about the attempt of Missouri Car Dealers and their lobbyists to prohibit Tesla from directly selling its vehicles to consumers. The Missouri Department of Revenue granted Tesla a dealership license in 2013, and the company now has stores in University City and Kansas City. But according to the Missouri Auto Dealers Association (MADA), Tesla is breaking Missouri’s Motor Vehicle Franchise Law and creating unfair competition through its manufacturer-direct sales. Legislative action to shut down Tesla failed last year, so MADA has sued the Department of Revenue.

However, MADA’s claims hold little merit. The Motor Vehicle Franchise Law bans manufacturer-direct sales for franchisors (meaning those with franchises in the state). Tesla does not use the franchise model to sell its cars, and hence is not banned from direct sales. And this is not a loophole. The Franchise Law was designed as a series of protections to prevent large car companies from undercutting their own franchisees. It was not written to enshrine the independent car dealerships as the only method to sell cars in the state.

That is an important distinction, because whether or not Missourians believe car companies need to be legally prohibited from cannibalizing their own marketing and sales outlets, there is no economic justification banning a manufacturer-direct car sales model. As I wrote in a recent op-ed:

. . . vehicle distribution through dealerships can be costly to the consumer. The 2009 Department of Justice paper “Economic Effects of State Bans on Direct Manufacturer Sales to Car Buyers” reported that as much as 30 percent of the cost of a new car is due to auto distribution. Enshrining the car dealership model in law has limited the ability of car manufacturers to both reduce inventory costs and increase customization, practices common in other markets. In Brazil, where GM can engage in direct sales, cost savings from order to delivery averaged 8.6 percent through direct sales.

Car buyers . . . might prefer directly buying from manufacturers for lower prices, customization, or simply to avoid bargaining at a dealership. A J.D. Power and Associates poll found that half of Americans profess a desire to buy manufacturer-direct, even if the prices are equivalent.

While that does not mean the dealership model would or should disappear, the government should not stop Tesla or any other car company from trying something different. That freedom to innovate is essential for a competitive market.

January 22, 2015

Saint Louis Ridesharing Update: MTC Still Dragging Its Feet

Ridesharing has had a bumpy ride in the Saint Louis area. The Metropolitan Taxicab Commission (MTC) strictly regulates the number of cabs, the prices they can charge, and even minutiae like the color scheme of taxis. It is a regulatory system marked by parochial, top-down control. So when Lyft began operating in the metropolitan area without the permission of the MTC last year, the official response was hostile. Police ticketed Lyft drivers, and the company was forced to cease its Saint Louis operations.

The bright spot for residents hoping to use ridesharing was Uber’s entry into the Saint Louis market. By negotiating with regional power brokers, such as Mayor Slay and the MTC, Uber was able to secure regulatory changes that would allow it to operate its expensive black car service, which launched last October.

Unfortunately, the relaxation in regulation was only very slight, and the MTC still firmly regulates taxi operations in the Saint Louis area. For example, the MTC only allows Uber to act as a dispatch service for MTC-licensed premium sedans, the number of which the commission has limited (initially the MTC added only 26 new vehicles to accommodate Uber). The MTC also passed restrictions to ensure that Uber Black uses only premium sedans and charges premium prices, lest they compete with normal cabs.

Notwithstanding the subsequent undersupply of Uber vehicles, Uber claims significant demand and wishes to expand its black car service and begin operating UberX, the company’s true low-price ridesharing service. But unlike cities across the country (including Kansas City and Chicago) the MTC has not shown the inclination to make the large-scale regulatory changes that would open the way for innovative ridesharing companies or create a more robust taxi market.

In a city where officials ceaselessly talk about attracting businesses and innovators downtown, it is shocking that they are unwilling to reduce regulations in order to make the city an easier place to work and play. If Saint Louis is going to experience sustained revitalization, it is going to come from being a leader in fostering new businesses, like ridesharing companies, that residents choose to patronize. It will not come from splashy, taxpayer-funded development schemes that regional leaders repeatedly propose.

January 21, 2015

Level the Playing Field for Uber and Taxi Companies Through Deregulation

Kansas City, Mo., heavily regulates its taxicab industry. As we detailed before, the city limits supply (to 500 cabs), manages pricing, and even stipulates what drivers may wear. These types of limitations have resulted in a stagnant and oligopolistic cab industry, ill-prepared to deal with well-capitalized and innovative competition.

Enter Uber, Lyft, and other app-based ridesharing companies. Kansas City’s stringent taxi regulations are not well designed for new technology or the use of personal vehicles for transportation on which these companies rely. When Lyft entered the Kansas City market without receiving city hall’s permission, officials filed injunctions and accused Lyft of endangering public safety.

Since that time ridesharing has made some progress in the City of Fountains. Uber, with the blessings of city hall, launched its black car service and UberX in the second half of 2014. While the process has encountered a few problems (some UberX drivers are still being ticketed over regulatory issues), the city has shown flexibility. Lyft was even allowed to operate until it voluntarily suspended operations on October 24, 2014, to await possible regulatory changes.

Those changes might be close at hand. The city is in the process of reviewing all of its taxicab policies, and proposed changes include modernizing regulations, removing some barriers to entry, relaxing requirements for vehicle inspections, and easing requirements for vehicles’ commercial insurance. That Uber and Lyft drivers do not carry primary commercial vehicle insurance has often been a cudgel used to attack these ridesharing companies, despite evidence that suggest over-extensive insurance does not protect public safety.

Adopting a “trust but verify” system toward ridesharing companies is a step forward for Kansas City, but that spirit should also include traditional taxis. When Kansas City allowed UberX, a direct competitor to taxi service, to offer services under “livery vehicle” regulations (designed for limousines and premium sedans), it essentially created a two-tiered market: the highly regulated traditional taxis vs. the less regulated Uber. That puts cabs at a distinct disadvantage and may mean they are driven out of the market. Putting cabs out of business through overregulation is not progress, any more than regulating ridesharing out of Kansas City would be.

Instead, Kansas City officials should use this opportunity to stop micromanaging the taxi business and limit itself to requiring taxis to carry adequate insurance, perform background checks, and pass vehicle inspections. A truly open for-hire vehicle market could accommodate both high-quality traditional taxis alongside innovative business models; and that would provide the greatest benefit to the residents of Kansas City.

December 11, 2014

What Is the Right Level of Regulation in Public Education?

Back in September the Show-Me Institute released my paper, “Decentralization Through Centralization,” in which I examined the development of the nation’s first all-charter school district in New Orleans. Though a mouthful, the title was my way of highlighting the tension that exists in the decentralized New Orleans system, which has been created with greater centralized control. In the paper, my co-authors and I highlight several potential pitfalls that might occur because of the power vested in a centralized entity. This week, Reason released a video highlighting another potential pitfall of the New Orleans Recovery School District model—regulatory creep.

As Rick Hess, director of education policy studies at the American Enterprise Institute, notes in the video:

People like autonomy in the abstract, but they get real nervous about it. If any one of a hundred or a thousand schools does something goofy, there’s always a natural temptation to say, “Well, we’re for autonomy, but let’s have a rule that doesn’t let you do X.”

Over time, Hess suggests that these regulations mount. If not checked, the decentralized charter market could become a bureaucratic morass. So what is the right level of regulation? And is it possible for a decentralized school system to resist what Neerav Kingsland, former CEO of New Schools for New Orleans, calls “death by a thousand regulatory cuts”?

If you have seven minutes, you should check out the video.

December 2, 2014

Highway Funding in Missouri: The Fuel Tax Option

The failure of Amendment 7, the proposed transportation sales tax, in August has left the Missouri Department of Transportation (MoDOT) in a financial bind. In the next few years, the department will no longer have the funds necessary to maintain the quality of the state highway system, much less improve it.

Former proponents of Amendment 7 claim that sales taxes are the best solution for MoDOT’s problems because they are the most politically feasible method of raising large amounts of money. Raising the state gasoline tax (currently 17 cents per gallon)—MoDOT’s principle revenue stream, they say—is not good policy because it is a declining source of funds and it does not poll well. But as we have shown before, fuel consumption has been declining very slowly, and it actually increased in the last year. The erosion in the gas tax’s purchasing power is mostly the result of inflation; Missouri last increased its fuel taxes in 1996, since which time prices have increased an average of 34 percent.

Far from being politically unfeasible, raising the gas tax is actually the simplest method for the state legislature to raise more money for MoDOT. That is because the provision that forces tax increases to go to the voters, the Hancock Amendment, has exceptions for small increases of existing revenue streams. Under the amendment, the legislature can increase revenue in any given year as long as new revenue does not exceed $106 million ($50 million in 1980 indexed to personal income growth) or 1 percent of state revenue looking back two years ($84.2 million for last year), whichever is lower.

Using 1 percent of previous state revenue as a cap, the legislature can collect around an additional $84 million in fuel taxes next year. Missouri currently generates about $29 million per cent from fuel taxes, meaning the state could raise fuel taxes by more than two cents without triggering Hancock requirements. Or, if Missouri followed the example of the federal government and many other states in charging diesel at a higher rate than regular gasoline, the state could raise the diesel fuel tax rate by five cents and the regular fuel tax by one cent and remain under the cap. That would generate an addition $78 million for MoDOT next year.

What’s more, because state revenue has been growing and per-cent fuel receipts have been declining recently, the state legislature could raise the fuel tax in successive years, which could give MoDOT the needed funds to maintain and make necessary improvements to state highways. In fact, this is precisely how Missouri last increased its fuel taxes in the 1990s.

Fuel taxes, as indirect user fees, are a preferable and possible way of funding highways in Missouri. If more money truly is required, the legislature has the option to raise fuel taxes without sending the issue to a ballot and without resorting to new, inappropriate funding mechanisms.

October 31, 2014

Ridesharing an Option Regulators Want to Keep from Residents

Recently, Ray Mundy, a professor at UMSL (also the head of a consultant group that works for the nation’s top taxi companies and part of the staff of Airport Ground Transportation Association, an airport taxi lobbyist group), was interviewed on a local radio station. While Mundy failed to state his conflict of interest, he lost no time accusing ridesharing companies like Lyft and Uber of having improper background checks, using inadequate insurance, price gouging, and destroying the cab industry that the needy rely on. But in reality, his statements are misleading, and his recommendation to ban these services will only serve to hurt Missouri residents. I will take his issues point by point:

  1. Lyft and Uber have insurance gaps.

This statement may have had validity a few months ago, but this is no longer the case. In July, both Uber and Lyft changed their insurance policies so that cars operate under liability insurance whenever the ridesharing apps are activated. Commercial insurance becomes primary (not secondary as Mundy stated in the interview) when a passenger has been accepted. Both Lyft and Uber detail their policies, and no driver or customer needs to use these systems if they find them inadequate. But regulators and those of Mundy’s persuasion would rather legislate additional insurance (shown not to improve safety) or ban ridesharing.

  1. Every time the taxi industry has been deregulated, it’s been reregulated.

This statement is empirically false, as a Reason study demonstrates.

  1. Ridesharing companies do not perform adequate background checks.

Mundy claims Uber and Lyft drivers might be dangerous because they do not use the same type of background check as most cab companies. Peruse Uber’s qualifications for yourself:


According the Mundy, these tests do not go back as far as taxi checks and do not include arrests where there are no convictions. That seems like a contrived standard, and once again, customers can decide whether they feel Uber or Lyft drivers are safe. But Mundy and other regulators would rather residents did not have such options.

  1. Uber and Lyft use price gouging.

Mundy, and other defenders of taxi regulations, do not like Uber and Lyft using variable pricing, such as charging more money at different times of night or when demand is higher. In reality, allowing for higher fares means drivers have a larger incentive to take fares at 2 a.m. or on New Year’s Eve. It allows the price mechanism to match supply with demand. But Mundy and other regulators would rather Saint Louisans wait hours for cabs that don’t come rather than have the choice to pay a higher fare.

  1. Uber hurts the poor, because cab companies cannot cross-subsidize service.

It is well known that, despite stringent regulations, taxis around the country refuse fares and avoid depressed neighborhoods. The best protection against fare refusal and more service is a large, diverse supply of for-hire vehicles, which ridesharing can help provide. And what’s more, cities like Saint Louis spend hundreds of millions of dollars a year on extensive public transit and para-transit services to serve the poor and the disabled. The for-hire vehicle market should not be regulated in order to duplicate those efforts.

If there is a common theme to Mundy’s and regulators’ arguments, it is that city officials, and not city residents, should decide whether ridesharing companies are safe enough, charge the right amount, and provide the right kind of service. But in reality, the corrective action of riders and drivers making their own decisions regarding Uber and Lyft are a far better test of all those criteria, and even Mundy admits the popularity of ridesharing where it has not been quashed by city government. The reality is that most Saint Louisans don’t see cabs as an option, because the service does not meet their needs. That’s a shame, because that hurts residents and hurts the city. But Mundy and the taxicab commission would rather keep it the way it is than let residents make their own choices.

October 24, 2014

Bring Dead Capital to Life

Think of that spare bedroom left vacant by children leaving the nest. Think of that empty passenger seat in most cars as they clog traffic in our major cities. To an economist, those are unused bits of capital: The room could be rented out, satisfying someone’s need for a short-term stay in town; that car seat could be occupied by someone heading in the same direction as the driver. Such unused sources of production are, simply put, dead capital.

Arthur C. Brooks, president of the American Enterprise Institute, recently argued that significant amounts of such dead capital could be brought to productive life if only local governments would stop protecting vested interests and allow entrepreneurs to invigorate their local economies.

How? There are new, exciting companies that empower individuals to improve their economic condition and, at the same time, improve the productivity of capital. One example is the ridesharing service Uber. Uber brings together those with empty passenger seats and those needing a ride across town. My experience (unfortunately, not in Saint Louis) is that Uber rides showed up faster than traditional taxis and that the drivers were more attentive to my needs. Because Uber drivers are rated by riders even in transit, poor drivers can lose business for inadequate service. Competition drives out poor performers.

Airbnb is a market solution to the problem of underutilized housing capital. With excess bedrooms in the United States, why not allow the owners of those empty rooms to satisfy the needs of individuals seeking a place to stay for a night or two? The needs of those willing and able to pay for a room are served and the owner is rewarded with, especially in these still-difficult times, an extra bit of income.

Unfortunately, a maze of state and local regulations block Uber and Airbnb from operating in many locales. “Governments have their own golden opportunity,” Brooks writes, “to exercise creativity in service of the common good, whether that entails rethinking anachronistic zoning laws or adjusting tax policies that treat someone’s spare bedroom the same as a Marriott suite.”

If bringing dead capital to life is good for the economy, isn’t it time for politicians and regulators to awaken to the potential benefits that such services can provide?

August 1, 2014

Show Me Better (Part 4): Certificate Of Need And Market Power

How far are you from the nearest hospital? Maybe you wonder why there is a single mega-hospital 10 miles away but aren’t any smaller ones nearby. Part of the explanation may be certificate of need (CON) regulations.

A 2004 report by the U.S. Department of Justice and Federal Trade Commission found that CON programs “pose serious anticompetitive risks that usually outweigh their purported economic benefits.” So far, I have written about how CON regulations can limit access to care and have been shown to not effectively control costs. CON regulations have the potential to stifle competition and grant existing hospitals monopolies over certain regions. Some existing hospitals may even attempt to use these regulations to prevent competition from entering the market.

How does this play out in Missouri?

In the past, any time a new hospital wanted to open up in Missouri, it had to apply for a CON – irrespective of its size and cost. A revision to Missouri’s CON rules changed the criteria for review from every new hospital to every new hospital whose cost is at least $1 million.

In April 2010, Patients First Community Hospital expressed its intent to build a small hospital in Saint Louis County that did not meet the new threshold for certificate of need review. Shortly thereafter, a regional rival, St. John’s Mercy Health System, filed a lawsuit against the Missouri Health Facilities Review Committee and Patients First. St. John’s challenged the legitimacy of the new $1 million amendment and construction of the new hospital. In 2012, the Missouri Supreme Court ruled that the new criteria for review was perfectly legal, thus giving Patient’s First the green light for the project.

Despite the ruling against St. John’s, this is an excellent example of a hospital using the legal system in an attempt to stomp out the competition, all under the pretense of CON regulation. It took about two years for Patients First to have its plan approved. These sorts of delays can deprive patients of new, much-needed medical facilities.

The state should not allow such an environment to exist.

July 29, 2014

Show Me Better (Part 3): Certificate Of Need And The Cost Of Care

As consumers, we like to get more for less – especially when it comes to our health. Usually we feel ripped off if we receive a lower-quality service for the same (or higher) cost of a better service. In a previous blog post, I discussed how, in some cases, certificate of need (CON) programs can be the very reason patients are forced to receive inferior care from less-skilled doctors. Additionally, CON regulations likely do not save patients much money, if any.

In a world of limited resources and virtually unlimited wants, we are forced to make trade-offs. A decrease in the quality of health care might be acceptable if CON led to lower costs. Proponents of CON argue that this regulation does contain the cost of care by preventing the “duplication of services” in a given geographic area. To illustrate this chain of reasoning, let’s say that Barnes-Jewish Hospital and Saint Louis University Hospital buy “too many” MRI machines – as a result, many of the new MRI machines go unused. Because of the outlay, CON proponents assume the two hospitals will probably charge higher prices for MRI scans to make up for the mistake.

There is evidence to suggest that theory is not well founded. One evaluation of Illinois’ CON program found that “there is little direct broad proof that overcapacity duplication leads to higher charges.” CON regulations may result in “tangible savings on the actual costs of specific medical technologies” but these programs tend to “redirect expenditures to other areas.” In other words, CON may actually prevent hospitals from spending too much on a certain type of medical technology, but any savings will be spent on other items instead of being passed onto patients. One study even suggests that strict CON programs may actually increase health care costs by as much as 5 percent.

What use is a program that can be delivering sub-optimal health care without cutting costs?

July 23, 2014

St. Louis Taxicab Commission Giveth With One Hand, Taketh With The Other

The St. Louis Metropolitan Taxicab Commission (MTC) has long stifled competition in the name of customer safety. The MTC controls market entry, tells cab and sedan businesses how they can operate, and sets prices. When Lyft launched in Saint Louis, MTC officials claimed they needed to shut down the app to protect customer safety, despite Lyft’s extensive insurance policy, background checks, and vehicle inspections. Now, with Uber preparing to launch in Saint Louis, the MTC is at it again, proposing more regulations to shut out competition.

Yesterday, the MTC approved changes to the taxicab code that would ostensibly allow a company such as Uber (although not Lyft) to operate in Saint Louis. The MTC altered the section of the code concerning premium sedans, which previously were quite onerous, with the implication that Uber can now pursue a license as a premium sedan company. Previously, premium sedans were required to bear written placards with the names of their customers, premium sedan companies could not start a business with fewer than three sedans, and (critically) sedans had to contract services at least 60 minutes in advance of pickup. The MTC voted to remove or relax these restrictions.

While some restrictions are gone, other competition-stifling regulations remain. Sedan companies still must obtain a Certificate of Convenience and Necessity (CCN) for $2,500, essentially asking companies to prove that Saint Louis needs cab service. Furthermore, the MTC still requires that each individual vehicle be licensed as a vehicle for hire (in Uber’s or Lyft’s cases, a premium sedan) with all the controls the MTC places on the appearance and operation of such vehicles.

While Uber might be able to operate with the code changes, it would be severely limited by regulations that the MTC plans on addingFirst, the MTC is still considering making sedans charge a minimum fare of $25 per trip, although the final decision on this takes place later this month. This essentially limits Uber to its premium, black car service. Second, all sedans now have to pay a permit renewal fee of $500 per year. That is more than double the current cost of renewal for sedans and almost five times the fees required for cabs. Uber has cried foul, correctly calling these practices anti-competitive.

The restrictions on sedans in the taxicab code never had much to do with safety, and it is good to see the MTC repeal some of these regulations. However, the additions for a minimum fee for sedan services and onerous renewal requirements have no safety merit whatsoever. Their only possible purpose is to prevent Uber or Lyft from operating an on-demand, cheap vehicle service that might compete with existing taxicabs. Once again, the MTC has shown its true mission is not customer safety or satisfaction, but rather control over the Saint Louis taxi industry.

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