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COMES NOW Petitioner, Randell S. Hynes (“Hynes”), President of the United Taxicab Drivers
Corporation chartered in the State of Nevada as a non-profit cooperative corporation, and hereby
applies by Petition to the Nevada Taxicab Authority (“Authority”) for an Advisory Opinion concerning
decisions of the Authority. This application for Petition for Advisory Opinion is made pursuant to NAC
I. Petitioner
Hynes is a former taxicab driver who commenced work as a taxicab advocate in October 2007.
The United Taxicab Drivers Corporation was chartered to formalize his work of helping taxicab driver
All correspondence can be mailed to Hynes’ current residence, or personal email address:
Randell S. Hynes
6180 S. Torrey Pines Dr.
Las Vegas, NV 89118
(702) 456-2899
randy@hynes.com
…
II. Exhibits and Key Indicators
Hynes seeks the opinion of the Authority on whether decisions to increase the number of
medallions deviated from a previously adopted standard, namely the allocation of medallions to
Exhibit A is a Memo from TA Staff Analyst Kelly Kuzik to Administrator Yvette Moore on
July 14, 2003 stating clearly that the Taxicab Authority Board had previously adopted 24 trips as the
annual average trips per shift goal. A formula shows the number of additional shifts needed to
Exhibit B is a table displaying data from Taxicab Authority records for 1984 to present that
shows up until 2003 the average trips per shift were maintained near 24. The table also displays the
fact that the decline started from a peak in 2000 of 23.92 average trips per shift and the following
contrasting data from 2000 to the “projected” end of 2008. [A projection assuming the same statistics
III. Introduction
Since 2001 Hynes has observed the taxicab industry in Clark County. Wages have eroded for
taxicab drivers, service has stagnated for the local population and service has degraded for tourists.
By law taxicab drivers welfare is not considered by the Taxicab Authority. Previous TA Boards
adopted a standard that was adhered to for at least 20 years but has been ignored since at least
2003. The riding public has suffered as the workforce has transitioned from moderately transient, with
a core of proud professional drivers to a largely transient workforce. The core of professional drivers,
great ambassadors to Las Vegas has dwindled. 50% to 77% more cabs for 18% more business since
2000, resulting in 27% less trips per shift has made it difficult for honest taxicab drivers to earn a
The question Hynes respectfully submits to the Taxicab Authority Board and Taxicab
Administrator is:
Exhibit A shows the Authority deviated from the adopted standard in May 2003, and Exhibit B
Deviation from the adopted standard to maintain trips per shift at about 24 has resulted in
historical increases in the number of medallions, has eroded the workforce and directly effected the
most important lawful consideration, the welfare of the riding public. Also, given the widely contrasting
statistics of 50% to 77% more taxicabs, depending on the shift, for only an 9% net increase in the
number of rooms and a mere 18% increase in the number of annual trips since 2000 would the
Authority advise a decrease both commensurate with the increase in business and the previously
In 2008 we have the benefit 20/20 hindsight. What if the Authority had not deviated from the
previously adopted standard and increased the number of medallions 18% for the actual 18%
increase in business since 2000? Adding 18% to the 2000 number of medallions of 1,246 24-hour
equivalent medallions in 2000 would add 224 medallions, 14 medallions for 16 companies, for a total
of 1,470 medallions. The projected total number of trips for 2008 is 25,632,117, which is
coincidentally 23.88 trips per shift for 1,470 24-hour equivalent medallions, correcting the deviation
from for the previously adopted standard in question. There are 1,870 24-hour equivalent medallions
presently allocated, 400 more than required to adhere to the adopted standard of near 24 trips per
shift. The Authority must decrease the number of 24- hour equivalent medallions by 400, 25 per
through attrition. If the companies simply don’t replace drivers that leave or not replace cars until they
are needed, then attrition is the answer. Companies will have to buy new cars eventually and they
can petition the Authority to extend the maximum period a car can be in service, if needed later.
V. Conclusion
The Nevada Taxicab Authority has historically upheld provisions of Orders. Just recently the
question of the adopted standard for considering the removal of the fuel surcharge was discussed at
an Agenda meeting with a heated commentary between Frias and YCS. Despite no statutory or
regulatory obligation the Authority had adopted a standard and all agreed it should be upheld.
The Finding of Facts for the Annual Reviews of Medallion Allocations, such as 3 to 5 year
projections on tourism by expert witnesses and projected loss of taxicab ridership due to increased
competition from the testimony of four cab company owners who each own charter limousine
companies that compete for on-demand taxicab rides ring hollow. Given the glaring contrast of the
increase of business to the increase of medallions, and having read all available minutes for Annual
Review of Medallions word for word, Hynes strongly believes annual increases in medallions were
made by the Authority as a reaction to peak demands at the airport and the convention centers and
additional fears of coming up short. The 2004 to 2005 increases were made on casual comments that
service at the airport was poor, but demand was up. No weight was given to testimony on traffic
problems, despite a major sewer project on Flamingo, Tropicana and Swenson during that period
creating significant but temporary traffic problems. Staff’s recommendation in 2005 was business did
not warrant the addition of medallions. The Authority made a record 21% increase in the number of
medallions by making the 2004 temp increase permanent, in a period when there was a 3% increase
in room inventory and 2.5% increase in total annual trips. The total annual trips has hovered at
25,000,000 for 2004, 2005, 2006, 2007 and 2008, but the number of medallions has been increased
29%. Today, about 500 to 800 more drivers are competing for virtually the same sized pie as 2004.
…
Former Chairman Werner-Collins was a Board Member when Exhibit A was published. The
Chairman commented twice on the record since 2003 about the concern for an allocation “trigger”. No
action was taken. None of the present Board Members has first hand knowledge of the adopted
standard in question. Perhaps, Mr. Kusik, the Memo’s author can shed some historical light and
Hynes respectfully submits this Petition seeking the opinion of the Authority deviation from an
adopted standard and a remedy to correct the resulting over-allocation of 400 medallions.
By: ____________________
Randell S. Hynes
6180 S. Torrey Pines Drive
Las Vegas, NV 89118
(702) 456-2899
OATH
STATE OF NEVADA )
) ss:
COUNTY OF CLARK )
I, Randell S. Hynes, being duly sworn, state that I file this application as President of the
United Taxicab Drivers Corporation that, in such capacity, I am qualified and authorized to file and
verify such application; that I have carefully examined all the statements and matters contained in the
application; and that all such statements made and matters set forth therein are true and correct to
the best of my knowledge, information, and belief. Affiant further states that the application is made in
good faith, and presents evidence in support of said application on every particular requested by the
________________________
Signature of Affiant
State of Nevada
County of ____________
______________________
Notary Public
My Commission Expires:
__________________