Respuestas recibidas sin formulario I - II- III

CNMC consultation - Sharing Economy
Phase N2. Effects on markets and regulation of new models for service delivery -
Deadline: January 13th, 2015
Questions
Do you agree with the description and characterization of the new service delivery models
and of the “sharing economy”? Can you provide any additional characteristics? (max. 4000
chars)
Uber agrees with the broad thrust of the CNMC’s characterization of the new service delivery
models. We will comment on some of the specifics, but the key element of this contribution is a
discussion of the future of urban mobility services, which we believe the CNMC has not covered
with significant depth. Uber expects a far greater demand for mobility services than is implicit in the
consultation document and that has implications for future policy.
Throughout this paper, we shall to refer to companies focusing on dispatching-like services using
mobile internet technologies as “Technology Network Companies” (TNCs).
It is important to take into consideration that this kind of services are “Information Society Services”
subject to Directives 98/34/EC and 2000/31/EC. As a consequence, restrictions on the provision of
such services are severely limited by the EU legislation. A prior authorisation cannot be imposed
on these services (Article 4 of Directive 2000/31/EC) and free movement of information society
services from the Member State where the provider is established cannot be obstacles in the
Member State where the service is provided (Article 3 of Directive 2000/31/EC, which exhaustively
lists the derogations allowed).
New, and more intense, competition between intermediaries
With respect to the taxi and VTC industry, it is primarily the “information society service”
(‘dispatching’) that is evolving quickly to the benefit of consumers.
Dispatching involves the matching of drivers with requests for rides. No matching takes place when
hailing a cab, or taking the first from a taxi rank, but human matching is undertaken at phone
dispatch centres. Matching is a task that lends itself to computers and algorithms as they can do
the job more effectively and more cheaply. The result is better for consumers, and for drivers as
they are in the situation to provide their service more efficiently.
As dispatching becomes more convenient, we expect its use to increase. As a result, Uber does
not share the CNMC’s contention that there will be ‘reduction of intermediaries’ but we do agree
that there will be a reduction in their ‘transaction costs’, and this will of course be to the benefit of
consumers.
Competition between intermediaries will in turn take on new dimensions - whereas traditionally the
largest taxi firm inevitably offered the best average pickup times, competition today and tomorrow