As part of the review into taxi fares in NSW,
the Physical Disability Council of NSW submits this
feedback to the Independent Pricing and Regulatory
Tribunal (IPART).
1. Executive Summary
The Physical Disability Council of NSW
recommends the Independent Pricing and
Regulatory Tribunal (IPART) advise the NSW
Ministry of Transport to implement the
recommends listed below to increase the
availability and improve the affordability of
taxis providing wheelchair access in the Sydney
Transport District and country NSW.
Summary of Recommendations:
The Physical Disability Council of NSW (PDCN)
recommends:
i. The 15-minute upper limit on
waiting time for wheelchair accessible taxis
be retained unless and until a Smart Card
regime is implemented for passengers entitled
to the NSW Taxi Travel Subsidy Scheme (TTSS).
(Section 4)
ii. The NSW Ministry of Transport obtains
additional data to determine why response
times are unacceptable for 30% of wheelchair
passengers. (Section 5)
iii. Taxi networks in country NSW purchase
taxis for passengers in wheelchairs living in
country NSW, in the local government areas
identified. (Section 6)
iv. There be increased regulation of taxi
drivers with WAT plates to ensure that M50
jobs are equally distributed. (Section 7)
v. The level of TTSS subsidy to be
increased from 50% to 75% of the metered
fare. (Section 8)
vi. IPART to support the current subsidies
provided by the NSW Ministry of Transport,
but consider increasing the Taxi Transport
Subsidy Scheme. (Section 9)
vii. New performance standards for WAT
services be introduced before 2007, in
accordance with the Commonwealth Accessible
Public Transport Disability Standards.
(Section 10)
2. Background Information on Disability
The TTSS provides a vital transport mode
particularly for a significant number of
passengers, who commonly can't use any other
forms of public transport.
PDCN members use taxis which provide
wheelchair access in order to attend employment,
school, tertiary education, leisure and
recreation, medical and hospital appointments,
as well as business and commercial purposes.
Many members of PDCN use taxis with wheelchair
access up to 3 times per week to attend
appointments.
Currently there are only 288 taxis with
wheelchair access within the Sydney Transport
District. When compared to other cities in
Australia, the Sydney Transport District has the
lowest proportion of suitable taxis per regular
fleet. This limited availability impacts
considerably on the mobility and independence of
passengers, particularly at times of the day
when these taxis are contracted by the NSW
Department of Education for school children with
disabilities, and out of business hours.
As many as 40% 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.
(1)
3. About the Physical Disability Council of
NSW
PDCN is the peak body representing people
with physical disability in New South Wales and
a member of the Physical Disability Council of
Australia.
PDCN focuses on issues relevant to people
with physical disabilities, such as access to
the built environment, transport and access to
aids and equipment.
An inclusive society is achieved when people
with disability are involved in every aspect of
political, social, economic and cultural life.
Access to all modes of public transport is
essential to facilitate community inclusion in
all aspects of daily living.
At least 75% of the membership of PDCN are
people with a physical disability and
consequently PDCN is able to represent the needs
and interests of people with a physical
disability. Membership of PDCN includes people
with a variety of different disabilities, from
young children and their carers, to aged people,
living in either metropolitan Sydney or country
NSW from a wide range of socio-economic
circumstances. PDCN has the background,
knowledge and skills to advocate on all levels
of Government regarding the needs of people with
a disability.
Members of PDCN are encouraged to become
involved in the decision making process, so that
Government and non- Government bodies become
familiar with issues relevant to people with
physical disabilities.
PDCN effectively networks with other
disability sector organisations on common goals
and issues. Subsequently PDCN strives to bring
about significant, permanent and positive
changes to the circumstances of people with
physical disability. The goal is to secure equal
civil and human rights for people with
disability.
Promotional activities assist to educate and
inform all members of the community, most
frequently through the media. Publications
produced by PDCN facilitate this educative
process.
PDCN is funded by the NSW Department of
Ageing, Disability and Home Care, employing four
staff members, based in Glebe.
4. Limit on waiting time charge of taxis
that provide wheelchair access
The Physical Disability Council of NSW is not
in favour of the removal of the fifteen-minute
limit on WAT waiting time at this juncture.
The fifteen-minute limit on WAT waiting time
was a mechanism introduced to prevent abuse of
the paper-based Taxi Transport Subsidy Scheme
(TTSS).
Before this intervention, written dockets
were submitted and charges levied for longer
periods of waiting than actually occurred. A
passenger with a physical disability may have
been unable to independently complete the paper
dockets required for the Scheme and/or pay the
taxi driver and hence required assistance from
the taxi driver. Subsequently there was
increased risk of totals being manipulated by
the taxi driver. Passengers were often
manipulated by taxi drivers and subsequently
pressured into covertly participating in this
fraudulent action.
It is understood that the 'Smart Card' has
the capacity to electronically record all
details regarding the taxi journey. Due to the
combined technologies of the Smart Card and
Global Positioning System, it is understood that
when introduced, abuse of the system will be
largely decreased. Implementation of the
'®Smartcard' will provide the opportunity
for all stakeholders including passengers,
drivers, operators, networks and Government
Departments to regain confidence in the Scheme.
Consequently PDCN strongly believes the
Smartcard needs to be introduced before
considering removal of the fifteen-minute limit
on WAT waiting time.
For these reasons PDCN urges the
Tribunal:
- To retain the 15-minute upper limit on
waiting time for taxis which provide
wheelchair access unless and until a Smart
Card regime is established for the NSW Taxi
Travel Subsidy Scheme.
- For the NSW Ministry of Transport to
implement the Smart Card for TTSS passengers
as soon as possible.
5.5. Collection of accurate data to
determine why the taxi response time is
unacceptable for 30% wheelchair passengers.
The Physical Disability Council of NSW is in
favour of the NSW Ministry of Transport adopt a
greater responsibility in monitoring the
delivery of services to ensure that M50 trips
are equably distributed. Particularly in areas
where response times are unacceptable, such as
on the Northern Beaches of Sydney and Liverpool/
Campbelltown/ Camden area.
In 2004/05 TTSS provided 218,892 M50 trips in
the Sydney Transport District. Approximately 30%
of booking response times for taxis providing
wheelchair access took more than the 20 minute
limit, accepted as the limit by the NSW Ministry
of Transport. Consequently PDCN would recommend
that the NSW Ministry of Transport conduct
further analysis to try to determine why a large
portion of taxi passengers are not receiving
services that are acceptable to the Ministry. To
investigate this issue further, it is suggested
that the NSW Ministry of Transport assess the
following: .
- Time of making the booking, dispensing
the taxi trip and the point of pickup
- Locality of pickup and drop-off
- Time taken to conduct taxi trip
- Time of the day and day of the week
- Type of taxi preferred
PDCN urges the Tribunal:
- To recommend that the NSW Ministry of
Transport obtains additional data to
determine why response times are unacceptable
for 30% of wheelchair passengers.
6. Taxis that provide wheelchair access in
country NSW
Research conducted by PDCN has identified the
following local government areas in country NSW
require taxis with wheelchair access or
otherwise require additional taxis services:
- Clarence Valley
- Eurobodella
- Great Lakes
- Hastings
- Nambucca
- Shaolhaven
- Cooma- Monaro
- Forbes
- Gunnedah
- Nambucca
- Narrabri
- Parkes
- Wellington
- Young
- Bathurst
- Broken Hill
- Clarence Valley
- Goulburn
- Newcastle
- Orange
- Queanbeyan
- Tweed
- Wollongong
PDCN recommends the Tribunal:
- To investigate the possibility of
increasing the number of taxis providing
wheelchair access in the local government
areas identified above.
7. Regulation of Taxi Drivers with WAT
Plates
Currently NSW Ministry of Transport provide
taxi operators with cheaper taxi plates for
drivers offering wheelchair access on the
proviso that these drivers transport wheelchair
passengers. The Ministry must regulate to ensure
these conditions are adhered to. Increased
regulation will increase the availability for
service passengers and hence decrease waiting
time for the 30% of service passengers who are
still receiving an unacceptable service from the
M50 taxi service.
PDCN recommends the Tribunal:
- Increase regulation and monitoring of
taxi drivers with WAT plates to ensure that
passengers using the M50 service receive an
adequate service.
8. 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.
Passengers in wheelchairs travelling in Western
Australia are already entitled to a subsidy of
75% with a $25 limit.
In Table 5.4 on page 32 of its Issues Paper,
IPART reports 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 which 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 included
it is clear that for most people with disability
there has been a drop in real income during a
period when taxi fares have increased.
PDCN has argued in favour of an increase to
the subsidy since at least 1998 and will
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 the subsidy be
increased to 75% (2). The
Legislative Council suggested an increase of
five percentage points each year for five years.
We understand their wish to see staged
introduction of any increase herewith the
administrative complexities outweigh the
financial benefits. Therefore PDCN proposes an
immediate increase from 50% to 75% of the
fare.
Many 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 city centres who
may have to travel above average distances more
often than most services passengers. 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 passengers 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 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 the TTSS subsidy
from 50% of the metered fare to 75%.
- To increase the upper limit of subsidised
fare from $30 to $40.
9. Existing subsidies provided by the
Ministry of Transport
PDCN recommends that the NSW Ministry of
Transport retains the current subsidies to the
taxi transport providers and people with
disabilities:
a. $2,000 to purchase a taxi plate to be used
to transport wheelchair passengers
b. Loan of $30,000 available to country taxi
networks
PDCN recommends the Tribunal:
- Support the current subsidies provided by
the NSW Ministry of Transport and increase
entitlements to the Taxi Transport Subsidy
Scheme.
10. Performance Requirements
PDCN calls for the introduction of new
performance standards for WAT services.
The key date for taxi cooperatives, networks
and drivers is 31 December 2007 to ensure
conformance with the Commonwealth Disability
Standards for Accessible Public Transport.