A wheelchair accessibility rule for the city’s for-hire fleet, with a deadline and no way yet to track it. Left behind the systems that made compliance measurable.
- Walked into
- A finalized rule, a deadline, and no infrastructure to tell whether anyone was complying.
- Built
- Process maps across every system the rule touched, product specs for tracking compliance, and an inspection process tested end to end on the floor with the inspectors.
- Kept running
- Accessibility built into how the for-hire industry operates, and compliance the agency can measure.
For years, the app-based companies that had come to dominate New York’s for-hire trips only carried passengers who could transfer into a car and fold their wheelchair, which shut out everyone who couldn’t. The TLC set out to change that with a rule requiring the whole for-hire industry, from neighborhood car services to Uber and Lyft, to provide equivalent wheelchair accessible service.
The rule on paper
By the time it reached me, the policy was decided. What didn’t exist was any way to make it real. There was a rule, a deadline, and no infrastructure to track whether anyone was following it. My job was to work out, from a technology and data perspective, how the agency would actually run it.
Every system it touched
A rule like this looks like one requirement. In practice it touches everything. Tracking compliance meant following vehicles and trips through systems that had never been built to know anything about accessibility. It also meant working across nearly every part of the agency, including legal, enforcement, licensing, policy, and IT, plus the industry groups who would have to change how they operated.
I mapped how the change would move through each system, wrote detailed product specs for what needed to be built, and drafted communications for each type of licensee. A small car service and a national app company needed to hear very different things.
Deciding when no one would
The rule said what had to happen. It didn’t answer many of the questions that determined whether a given company was compliant, and there wasn’t much appetite inside the agency to make those calls.
Which vehicles could be converted to be accessible was one example. There were no hard rules. The taxi industry had established standards for accessible vehicles, so I based the requirements on those, put the decision forward, and watched the response. Where no objections came, the decision held.
On the inspection floor
Every accessible vehicle had to pass through the agency’s inspection facility, and that inspection decided a lot downstream. Whether a vehicle counted as accessible determined its eligibility and how its trips were monitored for compliance. If the inspection data was wrong, everything built on it would be wrong too.
So I worked with the outside vendor who managed the inspection software, then went to the facility to confirm the whole thing worked end to end. I stood with the inspectors as they confirmed each vehicle met the standard, and watched those results flow into the systems that would track eligibility and compliance.
Getting this right mattered in both directions. The rule existed to open the fleet to New Yorkers who’d been shut out of it, so the tracking had to hold companies accountable. But bad data would also mean summonses for businesses that were actually complying, in an industry already under strain, and extra work for the agency’s own staff.
It worked. In the first six months, the number of accessible for-hire vehicles on the road grew more than tenfold, and monthly trips in them rose from under 7,000 to nearly 140,000.
What travels
A policy isn’t finished when it’s adopted. That’s when the operational work begins, and much of it is making decisions the policy left open. When nobody wants to own a call, waiting for consensus stalls the work.
It’s often better to make a reasonable decision, anchored in whatever precedent exists, and put it where the people affected will see it. A concrete proposal draws out objections that an open question never will. The reaction is the review.