Respuestas recibidas sin formulario I - II- III

DC, among others, where a regulation for the TNC (Transportation Network Companies) is already
in place.
We believe that the control obligation of a TNC, as they call it in the USA, does not have to stick to
the quality of the service, contrary it should also keep track of the obligations that the driver has to
comply with, as an insurance and a clean criminal background check.
It is not reasonable either to expand to new services the existing restrictions on taxi-pooling -
contartación por plazo con pago individual- (Article 99 Act 16/1987 and similar provision in regional
legislation on taxi services). Technology allows a very efficient allocation of resources while
security is ensured to all the parties, both riders and drivers.
Uber recently started testing in Paris a radically new concept called UberPool. This is a service
that directs drivers along a route that involves a sequence of pickups and drop offs, with
passengers sharing common parts of the ride together. The result is a triple-win of a reduced
environmental footprint, a sharing of costs for riders, and more ‘on-time’ for drivers. What the
appropriate pricing of such a new service should be is impossible to know - consumers and
market players will need to explore that together, and regulation should not become a barrier to
such triple-win opportunities.
Finally, very strict conditions have been imposed in Spain on VTC services (see Articles 181 and
182 of Royal Decree 1211/1990): 1) Quota restrictions (1 to 30 taxi licenses); 2) Obligation to have
a physical office in town; 3) Obligation to have a minimum number of vehicles; 4) Obligation to
have a minimum number of drivers; and 5) Obligation to contract the VTC service in the physical
office of the VTC provider before the provision of the service. It is difficult to understand how these
obligations restore any market failure. On the contrary, they seem rather directed to protect the
existing players in the taxi industry.CNMC has already informed against the re-introduction of some
of these obligation (Report IP/DP/002/14 of 30.1.2014). We share this analysis. It does not seem
reasonable neither to maintain/reintroduce these obligations nor to expand them to new p2p
providers.