make recommendations for streamlining the application processes for improved efficiency and service.” Discussion No changes will be made to the TCP and TNC application processes at this time. Are the Commission’s present trade dress rules adequate to ensure public safety and consumer protection, and to encourage innovation? Party Comments SFO/MTA, GCLA, and SFTWA all maintain that current trade dress rules are inadequate to ensure public safety and consumer protection, and advocate requiring permanent TNC trade dress. For example, SFTWA asserts that the current trade dress is easy to hide, which can hamper investigations and lead to insurance fraud. As an alternative to requiring permanent trade dress, SFO/MTA suggests requiring TNCs to predicate tip payment on whether a TNC vehicle is displaying trade dress. GCLA believes TNCs should be required to display their permit numbers in the same permanent manner required for TCPs. Rasier, Lyft, and Sidecar all assert that current dress rules are adequate, and oppose the proposals requiring permanent trade dress. They assert that permanent trade dress would confuse passengers when the vehicle is being used for personal use. Rasier suggests that the Commission clarify that trade dress may be placed in a window, including the front or back windshield. Lyft requests clarification that the existing rule does not prohibit use of more than one type of trade dress by a TNC, long as such use is a result of the TNC “as
make recommendations for streamlining the application processes for improved efficiency and service.” Discussion No changes will be made to the TCP and TNC application processes at this time. Are the Commission’s present trade dress rules adequate to ensure public safety and consumer protection, and to encourage innovation? Party Comments SFO/MTA, GCLA, and SFTWA all maintain that current trade dress rules are inadequate to ensure public safety and consumer protection, and advocate requiring permanent TNC trade dress. For example, SFTWA asserts that the current trade dress is easy to hide, which can hamper investigations and lead to insurance fraud. As an alternative to requiring permanent trade dress, SFO/MTA suggests requiring TNCs to predicate tip payment on whether a TNC vehicle is displaying trade dress. GCLA believes TNCs should be required to display their permit numbers in the same permanent manner required for TCPs. Rasier, Lyft, and Sidecar all assert that current dress rules are adequate, and oppose the proposals requiring permanent trade dress. They assert that permanent trade dress would confuse passengers when the vehicle is being used for personal use. Rasier suggests that the Commission clarify that trade dress may be placed in a window, including the front or back windshield. Lyft requests clarification that the existing rule does not prohibit use of more than one type of trade dress by a TNC, “as long as such use is a result of the TNC
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