Respuestas recibidas sin formulario I - II- III

In these two same sectors, do you believe that the new models should adapt to the current
regulation (sectoral or horizontal), or do you consider it necessary to change the regulation
in order to take into account all business models? What do you think this change could
consist of? (max. 4000 chars)
The question of whether regulation should be adapted to new services, or new services should
adapt to old regulation is arguably misplaced. Instead, it is of capital importance upon government
to ensure that regulation is adapted to an updated appraisal of market failures in light of
technology adoption. Where this appraisal changes, regulation should be adapted.
Regulation should take into consideration technological evolution and the impact on market
failures, reflecting the capacity for the competitive market to self-police. As a consequence, light
regulation is needed for transport services that embrace new technologies that overcomes
previous market failures, also in the case such technology is used by traditional taxi and VTC
service providers.
As a consequence, while the case of hailing may continue to require regulatory attention, for the
rest of the taxi market, the VTCs and the TNCs:
● Price regulation should not be applied when time and distance prices (and an estimated
total fare) are presented clearly to users before reservation; especially when the service
is requested via a technological application.
● Quotas should not be applied to services where drivers are only offering their services
through a technological application, as the application brings the needed efficiency in
matching supply with demand.
● Quality of service for vehicles and drivers could be considered, following the example
of the United States.
● Other restrictions particularly on VTC services, such as the requirement to have a
physical office in town, to have a minimum number of vehicles, to have a minimum
number of drivers and the requirement to contract the provision of VTC services in the
physical office before the provision of the VTC service takes place should be excluded for
all players.
Uber believes that these key requirements should be established as a law.
Uber understands that a level playing field should be ensured for all market players. It is not
reasonable to automatically expand the existing regulations to new service providers who make
use of new technology solutions that overcome market historic market failures. In any case, it
might be reasonable to expand to new comers some existing requirements (quality of service). At
the same time, some obligations on traditional providers could be lifted or at least amended to
allow them to compete on equal foot (evolution from fix tariffs to maximum tariffs).
The case for updating regulation is further strengthened by looking at the dynamics in the
(technology-driven) marketplace: