1. The
15-minute upper limit on waiting time for
wheelchair accessible taxis should be retained
unless and until a Smart Card regime is
established for the NSW Taxi Travel Subsidy
Scheme. (Section
2)
2. IPART should do
all that it can to expedite the introduction by
Transport NSW of a Smart Card for the TTSS.
(Section
2)
3. IPART should
reject proposals to introduce a pick-up fee for
wheelchair passengers using WATs.
(Section
3)
4. We seek the
introduction of a $6 performance incentive fee
to be paid to drivers and radio operators if the
wheelchair user is picked up within 20 minutes
of the booked time. (Section
4)
5. To offset some
(perhaps all) of the additional costs of
introducing a performance incentive, we propose
that the annual charge for a wheelchair
accessible taxi plate be increased to between
$2,000 and $3,000. (Section
4)
6. The level of
TTSS subsidy should be increased from 50% of the
metered fare to 75%. (Section
5)
7. The upper limit
of subsidised fare should be increased from $30
to $40. (Section
5)
8. New performance
standards for WAT services should be introduced
by 1st January 2004. (Section
6)
Contents
Summary of
recommendations
About
the Physical Disability Council of
NSW
Limit
on waiting time charge of Wheelchair Accessible
Taxis
Additional
pick-up fee paid to drivers of
WAT
Introduction
of a performance incentive for drivers of
WATs
Taxi
Transport Subsidy Scheme
Performance
Requirements
1. About
the Physical Disability Council of
NSW
PDCN is the peak body
representing people with physical disability in
New South Wales. We are part of a network, which
makes up the membership of the Physical
Disability Council of Australia. At least 75% of
the members of PDCN must be people with a
physical disability. We believe, therefore, that
what we say and the representations we make to
Government are based on the direct experience of
people with disability. We are, we believe, an
'expert organisation'.
PDCN operates
democratically as part of an effective network
of disability sector organisations. We work
collaboratively with agencies that share common
goals. We strive to bring about significant,
permanent and positive changes in the
circumstances of people with disability. Our
goal is to secure equal civil and human rights
for people with disability.
PDCN assists people with
physical disability to represent themselves and
express their own points of view to
decision-makers in all sectors.
PDCN helps to keep people
with disability informed of developments of all
types that might affect the lives of people with
disability.
PDCN represents the views
and interests of people with disability to
government and non-government
decision-makers.
PDCN works to educate
members of the general public about the needs
and aspirations of people with
disability.
Membership of PDCN is open
to individuals with a physical disability living
in NSW and to any person or organisation with a
commitment to consumer rights and the
empowerment of people with disability. PDCN's
Management Committee has twenty-one members,
most of who are people with physical disability.
Parents of children under 16 years of age are
members of our committee. One third of the
committee places are reserved for people with
physical disability who are not resident in
greater metropolitan Sydney.
The NSW Department of
Ageing Disability and Home Care funds PDCN. We
employ four members of staff, based in our
office in Glebe.
2.
Limit on waiting time charge of Wheelchair
Accessible Taxis
The Physical Disability
Council of NSW is against the removal of the
fifteen-minute limit on WAT waiting time at this
juncture.
The fifteen-minute limit
on WAT waiting time was introduced as a
mechanism to prevent abuse of the paper-based
Taxi Transport Subsidy Scheme (TTSS). The
Tribunal may not be aware that before the
introduction of the fifteen-minute limit there
was misuse / abuse / minor fraud attributable to
WAT waiting times. Claims were submitted /
charges levied for longer periods of waiting
than actually occurred. It may be that a small
number of drivers and passengers considered the
additional periods of waiting time charged to be
'victimless crime', largely because the paper
dockets of the TTSS made / make it possible to
'transfer' culpability.
We are certain that it was
a small number of drivers and passengers who
were responsible for the abuse of the system. We
are just as sure that the majority of drivers
and passengers would (and do) condemn such
behaviour. Nevertheless, for as long as the
paper-based arrangements for the TTSS remain in
place, there is a real possibility that
significant levels of abuse could return if the
upper limit on waiting time was
removed.
We feel strongly that the
introduction of a 'Smart Card' for the TTSS
would allow all stakeholders (passengers, WAT
drivers and NSW Government) to have confidence
that abuse of waiting times would be negligible.
Unless and until the TTSS moves to Smart Card
technology (with its capacity to record times,
durations, etc) there should be no change to the
current limit of fifteen minutes waiting time
for WAT vehicles.
For those reasons PDCN
urges the Tribunal:
- To retain the
15-minute upper limit on waiting time for
wheelchair accessible taxis unless and until
a Smart Card regime is established for the
NSW Taxi Travel Subsidy
Scheme.
- To do all that it
can to expedite the introduction by Transport
NSW of a Smart Card TTSS.
3.
Additional pick-up fee paid to drivers of
WAT
The Physical Disability
Council of NSW is against the introduction of an
additional pick-up fee to be paid to drivers of
WATs.
A pick-up fee is
discriminatory and probably breaches the terms
of the Disability Discrimination Act 1992 (DDA).
Any fee of this type is built on the premise
that a particular group of people, by virtue of
their disability, would be or should be treated
less favourably than the population as a whole.
Even if the entire additional fee were to be
paid by Government there would still be a breach
of the requirement in the DDA to eradicate
disability discrimination.
We oppose the introduction
of a pick-up fee because it further undermines
the right of people with disability to be
treated no less favourably than people with no
disability. But we also oppose the suggestion on
pragmatic grounds.
On page 5 of its Issues
Paper, IPART notes that the "nominal" cost of a
taxi plate for so-called standard taxi is "about
$290,000". Figure 2.1 on page 5 of the same
document shows that the "nominal" cost has risen
more than four-fold since 1985. Even using 1985
dollar-values the price of a plate for 94% of
taxis has more than doubled. During the same
period, the cost of a WAT plate has dropped in
both cash terms and real terms. Even allowing
for the more expensive vehicles that tend to be
used for WAT services, PDCN has shown that over
a twenty-year period it remains cheaper (all
costs considered) to operate a WAT rather than a
taxi that cannot accommodate wheelchair users.
1.
With taxi plate costs of
$290,000 for an inaccessible taxi and $1,000 per
year (for twenty years) for a wheelchair
accessible taxi, the NSW Government effectively
subsidises WAT entrants to the market by more
than $250,000. In such circumstances, we feel it
would be wrong to further subsidise WAT activity
by introducing a 'pick-up' fee.
Secondly, with regard to
our pragmatic opposition to the 'pick-up' fee,
we ask IPART to recognise that such a fee does
nothing to enhance the quality of service to
wheelchair users. There is nothing inherent to a
'pick-up' fee that produces improvement in the
key area of concern to passengers in
wheelchairs: chronic delay of service
provision.
A 'pick-up' fee that would
be paid to drivers simply for accepting a job
would not necessarily mean that passengers in
wheelchairs were picked up any closer to booked
time than is currently the case. We remind IPART
that the NSW Taxi Regulations currently require
drivers of WATs to give priority to wheelchair
users. The pricing / fare structure ought not to
make more costly an activity that is already a
duty placed upon WAT operators and drivers as a
condition of their licence. A 'pick-up' fee,
applied regardless of performance improvement,
merely adds cost to an already heavily
subsidised niche of the market. We are against
the suggestion
PDCN urges the
Tribunal:
- To reject proposals
to introduce a pick-up fee for wheelchair
passengers using WATs.
4.
Introduction of a performance incentive for
drivers of WATs
PDCN proposes the
introduction of a $6 performance incentive for
picking up wheelchair users. The fee would NOT
be paid for every job but only in those
circumstances where agreed performance standards
are met.
From the perspective of
wheelchair users, the NSW taxi industry is
fundamentally deficient in a number of ways.
These include:
- As HREOC has shown
2., of all States and
Territories, NSW has the lowest proportion of
its taxi fleet that are wheelchair
accessible.
- According to the NSW
Taxi and Hire Car Bureau, 6.16% of taxis (365
out of 5,924 vehicles) are wheelchair
accessible.
- As many as 80% of all
bookings for wheelchair accessible taxis are
made through private booking arrangements
principally because of the risk of delay of
services booked through the '0200' central
booking service. (According to the
now-disbanded Department of Transport WAT
Sub-committee).
- At least one major
network continues (reportedly as a "business
decision") to not use its Global Positioning
System (GPS) technology to direct the closest
available WAT vehicle to wheelchair users
waiting for a booked taxi.
Although it is profoundly
disappointing, it surprises no one that the
greatest cause for complaint by wheelchair users
about wheelchair accessible taxi services is
late arrival or delays. It is common for PDCN to
be told by wheelchair users that their taxi was
between 45 minutes and 1 hour late for a booked
appointment. At meetings in Campbelltown, Ryde,
Bondi Junction, Penrith, Glebe and Parramatta
wheelchair users have told us of waiting between
two and four hours for taxis booked through the
'0200' central booking system. Some wheelchair
users have told us that they have given up on
taxi services altogether because vehicles were
so late, so often (or simply never showed up)
that the delays made life virtually impossible.
In such circumstances people find their lives
become dramatically constrained.
No one disputes the fact
that there are delays and long waiting times
experienced by wheelchair users. There are,
however, a variety of interpretations or
explanations offered dependent, by and large, on
the perspective of the speaker.
PDCN does not wish to
re-hash old debates, although our own views have
not altered since we wrote our submissions to
the HREOC Inquiry into wheelchair accessible
taxi services. We believe, however, that IPART
has an opportunity to use its regulatory powers
to help overcome the problem of unreasonable and
discriminatory waiting times (by and large the
problem does not exist for people who do not use
wheelchairs).
PDCN proposes the
introduction of a $6 performance incentive for
picking up wheelchair users. The fee would NOT
be paid for every job but only in those
circumstances where agreed performance standards
are met. Our proposal is modelled on the South
Australian experience. Our information from the
trial in that State (the formal report of the
experiment has not yet been written) is that the
introduction of a performance related incentive
has improved (reduced) delays.
We propose a performance
related incentive of this type:
- A $6 incentive fee /
bonus would be paid if the wheelchair user is
picked up within 20 minutes of the booked
time.
- $5 of the fee would be
paid to the driver picking up the
passenger.
- $1 of the fee would be
paid to the radio operator issuing the
job.
- By "picked up" we mean
the taxi has arrived at the pick-up point,
the passenger is onboard, securely restrained
and the vehicle is ready to move
off.
- For as long as the
'0200' central booking service operates, the
performance incentive would be paid only for
bookings made through that official booking
service.
- If the exclusive role
of the '0200' service were to be abolished in
favour of direct booking through radio
networks, the performance incentive would be
paid only for bookings made through those
networks.
- In short, private
bookings would not be eligible for the $6
performance incentive. WAT drivers would have
the right to choose between preferential
access to and by some customers or the
performance incentive fee, not
both.
- All of the $6 would be
paid through the TTSS by the NSW
Government.
To offset some (perhaps
all) of the additional costs of introducing such
a performance incentive, we propose that the
annual charge for a wheelchair accessible taxi
plate be increased to between $2,000 and $3,000.
The combined effect of these changes would
be:
- Owners and operators
would pay a higher annual fee for a WAT
licence plate but still receive an effective
subsidy (based on current figures) of between
$230,000 and $250,000 over a twenty-year
period.
- Drivers would receive
a $5 bonus for each passenger picked up
within 20 minutes of the booked time. A bonus
at this level represents an increase of 25%
on the current average urban fare of $19.54
(32% on the Taxi Council's preferred figure
of $15.48) and 51% on the current average
country fare.
- Telephone operators
with the booking service would have a direct
incentive for assisting drivers to meet their
performance target of 20 minutes.
- The NSW Government
would increase income from the new licence
fee.
- Wheelchair users could
expect to see improvements in performance not
unlike the experience of their counterparts
in South Australia.
- New entrants to the
industry would see even greater incentive in
selecting a wheelchair accessible taxi plate
as their business choice. The potential would
be created to increase the number of WATs in
NSW.
- For the first time in
NSW some of the subsidy received by WAT plate
holders / owners would be diverted to
drivers.
PDCN urges the
Tribunal:
- To recommend the
introduction of a $6 performance incentive
fee to be paid to drivers and radio operators
if the wheelchair user is picked up within 20
minutes of the booked time.
5.
Taxi Transport Subsidy Scheme
PDCN proposes that the
level of subsidy be increased from 50% of the
fare to 75% of the fare and that the upper limit
of the subsidy be increased from its current $30
to $40
In Table 5.4 on page 32 of
its Issues Paper, IPART reports that taxi fares
in NSW are currently 22.3% higher than they were
on 1st July 1999. During the same period there
has been no increase in the level of subsidy
made available to people eligible for support
through the TTSS. It is well known that most
people with disability live on fixed incomes
that have barely kept pace with inflation.
(According to various sources it is about 80% of
the total number of people with disability.)
When the effects of the introduction of GST are
also considered it is clear that for most people
with disability there has been a drop in real
incomes during a period when taxi fares have
increased in cash and real terms.
PDCN has argued in favour
of an increase to the subsidy since at least
1998. We continue to do so.
The Final Report on
Disability Services, entitled Making It Happen,
published by the Legislative Council of the NSW
Parliament in December 2002, recommends that the
subsidy be increased to 75%
3.. The Upper House suggests
an increase of five percentage points each year
for five years. We understand their wish to see
staged introduction of the proposed increase but
we feel that the administrative complexities
outweigh the financial benefits. Consequently,
we propose an immediate increase from 50% to 75%
of the fare.
Some people with
disability rely more than most on wheelchair
accessible taxi services. They may experience
some of the greatest financial difficulty of all
groups who make use of these vehicles. We are
thinking, particularly, of people who live in
regional NSW or on the fringes of the major
conurbations and who may have to travel above
average distances more often than most services
users. It is to recognise the financial burden
placed on people in such circumstances that we
propose an increase of $10 in the upper limit of
the subsidy. We seek its increase from $30 to
$40.
Most wheelchair users will
never need to avail themselves of the upper end
of the scale of subsidy available because they
make journeys that are, most of the time, below
the upper limit. For people whose living
situations mean they must make longer journeys,
however, to reach health, community or other
settings, an increase to the upper limit of the
fare subsidy would be a just
development.
PDCN seeks the support of
the Tribunal:
- To increase the
level of TTSS subsidy from 50% of the metered
fare to 75%.
- To increase the
upper limit of subsidised fare from $30 to
$40.
6.
Performance Requirements
PDCN calls for the
introduction of new performance standards for
WAT services.
Draft performance
standards for wheelchair accessible taxi
services were included as part of the 1995
tender documentation linked to the central
booking service. Those performance standards
have never been introduced. PDCN calls on IPART
to require the NSW Government to issue and
enforce performance standards for WAT services
that would take effect from 1st January
2004.
Physical Disability
Council of NSW
30th May 2003
Review
of fares for taxis, private buses and private ferries in NSW
by the Independent Pricing And Regulatory Tribunal of
NSW