Submitted by Carolyn Konheim, Dec 31, 2007 21:01

The Cambridge Systematics (CB) report, "Congestion Reduction Policies Involving Taxis" (12/10/07), of which we have just become aware, is misleading in its estimates of the congestion reduction potential of taxi strategies because it ignores:

1. many measures London employs to reduce cruising and expand service;

2. the effect of faster travel due to congestion fees on taxi revenues and trips;

3. proposals of a NYCDOT-taxi industry study to reduce taxi VMT in the CBD;

4. the special adverse effect of black cars and limousines on traffic flow; and

5. the equity of taxi surcharges to offset the high societal costs taxis impose.

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