ࡱ> -  !"#$%&'()*+,./012Root Entry FmObjectPool7 m7 mWordDocument_WuIZjklJ K L Y \ f g    - M D 1 7 8 9 v JKLfgh|=>?OU5>`abGHIJKLVccUVcUc_LstuEO*+,: !!!###,$.$/$0$$$$h&&&&'''>((()) ) )))))******+,4-5-6-u-v------.////_/c//00K00[11112b2c2d2x2!3"3#3UccVcUVc_ܥe- mN_mK^^_____&_&_&_&_&_&_B_&_X_A________________T_ ___(,__________________Queensland Transport is pleased to present the following submission in response to the Notice of Inquiry : Equal access to wheelchair accessible taxi services. Since 1993, Queensland Transport has been actively increasing the provision of wheelchair accessible transport services to the community through a range of means. At that time, in the absence of accessible urban buses, taxis were recognised as the most easily accessible form of public transport for wheelchair users and, for this reason, considerable effort has been expended on increasing the number of wheelchair accessible taxis available in the state and improving their service delivery. Since early 1993, the number of wheelchair accessible taxis operating in the state has increased from 32 to 292. Ten percent of the States entire taxi fleet is now accessible with some centres having over 30 percent of the local fleet accessible. Rural towns which support only one or two taxis, most of which are of meter exempt status, have much lower access rates. A range of options have been developed to address this and the situation is improving in these areas. The taxi industry in Queensland has certainly accepted and actively participated in the provision of accessible taxis. Nevertheless, it is still considered that the industry as a whole has a long way to go in the area of accessible services. It is important to recognise that a fundamental change has occurred over the past five years. This trend is continuing and improving through increased controls and technological developments which improve the efficiency of the fleet. Queensland Transport continues to strive for improved access to public transport services for people with disabilities by communicating with the both the users and providers of services and by ensuring that the legislative environment is flexible enough to allow the industry to respond rapidly to changing demands. Response Times: Are response times significantly longer for passengers requiring wheelchair access than other passengers making taxi bookings? In most parts of Queensland, waiting times for passengers requiring wheelchair accessible vehicles are still longer (in some cases significantly so) than for passengers using conventional vehicles. Since the introduction of performance-based taxi service contracts with taxi booking organisations, waiting times for passengers using wheelchair accessible services have decreased dramatically and in a number of areas in the state, passengers using wheelchair accessible vehicles are experiencing the same waiting times as other passengers. The department is confident that these contracts are an appropriate tool for monitoring service levels and for achieving stated performance outcomes. Some adjustments to the contract regime are currently being developed, including improved enforcement processes, to increase the efficacy of the contracts in achieving high levels of service provision. Proportion of taxi fleets accessible: What proportion of the taxi fleet is wheelchair accessible? 10 percent of the total taxi fleet in Queensland is wheelchair accessible. Individual fleets range from no accessibility to over 30 percent accessibility. Are these proportions sufficient: Is the proportion of taxi fleets which is wheelchair accessible insufficient in any areas of Australia to enable service to be provided to passengers requiring wheelchair accessible taxis with equivalent reliability and waiting times to those for other passengers booking taxi? If so, what proportion of taxi fleets would be sufficient? In most areas, the current proportions are insufficient to adequately meet demand. However, Queensland Transport does not consider that fleet proportions and vehicle-to-population ratios are an effective means of managing demand as they do not necessarily correlate to actual service delivery. Service delivery can be impacted by a range of factors such as topography, urban density, urban sprawl, traffic and road conditions and even weather. Driver and booking company behaviour and despatch practices also impact significantly on service delivery. For example, in Hervey Bay, thirty percent of the taxi fleet is accessible. However, waiting times for wheelchair accessible services still fall well below the stated targets. On the other hand, only seven percent of the fleet is accessible in Bundaberg and targets are being achieved. Another example is the Brisbane area. Until recently, three taxi booking companies operated in this area. While none of the companies are currently meeting the waiting time standards, significant differences are evident in service delivery. Over a specified period, for example, company A undertook over 75 percent of the total hirings in the area and five times as many hirings per vehicle per day as company B. However, the waiting times for company As vehicles were shorter than for company Bs vehicles. This is directly reflective of driver and company behaviour. As a result, Queensland Transport advocates the use of waiting times standards, as opposed to proportions, in order to best meet the needs of people with disabilities. Measures to ensure sufficient proportion accessible: What measures have transport authorities taken or do they intend to take to ensure that a sufficient proportion of taxi fleets are accessible? Queensland Transport's target is to achieve equivalent waiting times for taxi users whether they are requesting a wheelchair accessible vehicle or a conventional vehicle. Based on user surveys of what are considered acceptable waiting times, this is between 10 and 20 minutes during off peak periods and between 18 and 30 minutes during peak periods. In order to monitor these waiting times, and thereby take action to improve waiting times, Queensland Transport has entered into taxi service contracts with all taxi booking organisations operating in areas with populations over 10,000. These contracts set a minimum standard which states that 85 percent of hirings during off-peak periods must be met within 10 minutes and 95 percent within 20 minutes. During peak periods, these figures are 18 and 30 minutes respectively. These standards apply across the whole taxi district serviced The contract standards recognise that it is not possible to get a taxi within the required time frame in all cases. Issues such as traffic, weather and accidents all effect the ability of a taxi to meet a waiting time standard and are all beyond the control of the industry. Similarly, during periods of exceptionally high demand, such as New Years Eve, extended waiting times will occur regardless of the number of vehicles available. However, the contract standard does determine that, generally, 10 minutes is an acceptable time to wait for a vehicle and that this applies regardless of the type of vehicle booked. Queensland Transport has adopted waiting time standards as the primary measure of service delivery because waiting times is one of the foremost concerns of users of taxis. In attempting to meet the established targets, a range of activities have been undertaken and interim vehicle targets set. In areas where fewer than ten percent of the taxi fleet is accessible, any new taxi service licences issued are wheelchair accessible taxi service licences. For example, in Brisbane, all of the 120 licences issued since 1996 have been for wheelchair accessible vehicles. This has brought the area up to the interim ten percent target. From now on, new licences will be issued on an as needs basis as determined through an examination of the waiting times achieved for each type of hiring. In areas where users have indicated that there is a need for additional (or any) wheelchair access, a review is undertaken of the area. These reviews must examine the views of users in the area, recent changes in travel patterns, the types of taxi services available and the performance and productivity of the existing fleet. If the review identifies that there is a need for additional licences, an appropriate number of wheelchair accessible taxi service licences will be issued. In many recent cases, reviews have determined that there is generally not a need for additional licences and that, therefore, any additional licences may unduly impact on the viability of existing services, but that wheelchair access is required. In these cases, a number of options are available. The first of these is that an existing operator volunteer to convert an existing vehicle to a wheelchair accessible vehicle. This has been successful in a number of areas of the state. If all operators in the area indicate that they are not prepared to provide a wheelchair accessible vehicle, Queensland Transport scans surrounding areas to identify other wheelchair accessible taxi providers who might be willing to undertake additional work in the area in question. The success of this option is limited by the proximity of the area to other towns. However, it has succeeded in three areas of the state. If neither of the above options are successful, Queensland Transport may issue an additional taxi service licence to meet the demand. Generally this is done with an undertaking that the Department will continue to monitor service levels and may agree to transfer a conventional licence out of the area at a later date if appropriate. In order to ensure that a sufficient number of wheelchair accessible taxis are available, Queensland Transport will continue to monitor service provision, to enhance the current taxi service contracts and is also examining the feasibility of extending the contract regime to smaller areas. Universal taxi: If 100% of fleet accessibility is necessary or desirable to ensure fully equal access to services, what measures may be feasible and necessary to make possible the achievement of this level of accessibility. Queensland Transport does not believe that 100% accessibility of the fleet is necessary to achieve equal access or is, in fact, desirable for many taxi users. As noted above, areas with as little as 7 percent accessibility are achieving equal waiting times. In considering a universal taxi, vehicle design is an issue of utmost concern. Queensland Transport has favoured dual wheelchair access for most taxis operating under wheelchair accessible taxi licences. This has generally limited the market to light bus style vehicles. These vehicles are able to deliver the required service to people using wheelchairs although, even in those cases, they are not always optimal. Of particular concern is that accessing these vehicles is difficult for people with some disabilities or for the aged and infirm who are not using wheelchairs. To date, a vehicle suitable for use as a universal taxi has not yet been identified. Should such a vehicle be identified and required for introduction in 100% of fleets, at least an 8 year transition period would be required. This is the allowable age limit which currently applies to wheelchair accessible vehicles in metered taxi areas. Consideration would need to be given to rural areas of the state where demand is minimal and vehicle ages are unlimited. It is important to note that, since their introduction, there have been significant improvements in the public acceptance of wheelchair accessible vehicles. This is partially reflected in the market value for wheelchair accessible taxi licences. When first introduced, wheelchair accessible taxi service licences were given to taxi booking organisations for free or for the nominal fee of $1. Despite this, the take up rate was low. Currently, wheelchair accessible taxi service licences sell for approximately 75 percent of the value of a conventional taxi service licence in the area. On the Gold Coast, for example, they are valued at over $300,000. To a large extent, public acceptance of the wheelchair accessible fleet in Queensland has been advantaged by the generic marketing of the vehicle as a larger taxi designer for all users and groups. Dedicated Services: What experience or issues are there with operation of wheelchair accessible taxi services as a dedicated service rather than also being available for mainstream service? Queensland Transport has no first hand experience with a dedicated para-transit fleet as the Department has heeded users concerns regarding the importance of using a mainstream service as opposed to a special service. However, issues which might arise from dedicated services include viability of service provision and the associated impact on fares and inefficiencies arising from the duplication of despatch systems. That being said, it has also been identified that, in centres with over 80 vehicles, dedicated despatch facilities for wheelchair accessible taxi services deliver much improved services. In particular, the use of dedicated and appropriately trained despatch personnel who are familiar with the needs of their individual clients has been lauded by users. Economic Factors: Are there any economic disincentives to the provision of wheelchair accessible taxi services which have been addressed by taxi regulatory authorities, by other government agencies or by industry? Wheelchair accessible vehicles are more expensive to purchase than conventional vehicles. As a result, and to encourage their provision, wheelchair accessible vehicles in Queensland have an additional two year age limit over conventional vehicles. Wheelchair accessible taxis are also required to undertake more empty running than conventional vehicles and consequently their earning capacity is considered by many industry representatives to be less and, therefore, wheelchair accessible taxi service licences sell for less than their conventional counterparts. It should be noted that Queensland Transport is unable to verify comments in relation to the earnings of taxis and the comments above are merely a reflection of industry feedback. In Queensland, high occupancy wheelchair accessible vehicles are permitted to undertake group bookings for a fare which is higher than the standard taxi fare. This provides some additional incentive to operate such vehicle, particularly of a night and weekend. Wheelchair accessible vehicles also undertake a significant proportion of regular work, particularly the carriage of students with disabilities and taxi subsidy scheme members, both of which are subsidised by government. This means that wheelchair accessible taxis are less susceptible to fluctuations in taxi usage. Taxi fares for wheelchair accessible vehicles are an issue of ongoing concern. Industry representatives have consistently called for the introduction of a boarding fee which drivers claim will cover them for the additional time taken to assist a wheelchair user to enter and exit the vehicle. In Queensland, drivers are permitted to activate the meter once the passenger has been notified of the taxis arrival (regardless of whether they are ready to board) and to stop the meter immediately upon arrival at the passengers destination. Thus, the time taken when a passenger enters the vehicle is covered under the fare but the time taken to exit the vehicle is not. This applies to both conventional and wheelchair accessible vehicles. One of the issues associated with charging for entry and exit time is that, in the case of people using wheelchairs, driver competence is an issue. Where a driver is experienced, very little time is spent in entry and exit procedures. However, drivers who are less competent may take significantly longer. Queensland Transport firmly believes the user should not have to pay for driver failings. Effective use of Accessible fleets: Are there any regulatory or technical measures being taken which would ensure that any given level of accessible taxi fleets meets demand for wheelchair accessible taxis more effectively? Taxis operating under wheelchair accessible taxi service licences are required to give priority to hirers requesting a wheelchair accessible vehicle. Most of the larger centres in Queensland operate Global Positioning Systems (GPS) which allow taxi booking companies to accurately identify vehicle locations and to despatch more efficiently than was previously the case. GPS has certainly led to significant improvements in wheelchair accessible taxi service provision. Where licence holders comply with the priority requirement, wheelchair accessible services are operating reasonably well. However, the enforcement of the 'priority' requirement by Queensland Transport is time consuming and requires cooperation of the despatch company. Technology and data is now available to allow the department to accurately identify where drivers are operating in contrary to the priority rule. Queensland Transport has recently increased its enforcement efforts of this rule. It is anticipated that, following this enforcement activity, the Department will be able to provide more detailed information on the efficacy of the priority system and whether it is sufficient to achieve the stated outcomes or whether other restrictions/regulations may be necessary. Having a single provider of despatch services for wheelchair accessible vehicles does lead to the optimisation of the fleet and is preferable in that regard to multiple service providers. In most areas of Queensland, only a single booking company operates. However, in areas where a number of taxi despatch companies operate, users of wheelchair accessible taxis have expressed a preference for all companies to despatch wheelchair accessible taxi services. This then affords these users the same choice of providers as is afforded to other users of taxis. Queensland Transport has established wheelchair accessible taxi user group forums in most larger centres to inform the department about users needs and to provide an avenue for information sharing. The forums have been a valuable tool in identifying issues facing wheelchair accessible taxi users and in achieving improved service provision. Issues which have been identified relate to equipment in taxis, vehicle specifications, despatch practices and driver training, for example. Queensland Transport and the taxi industry have raised issues regarding the appropriateness of various types of wheelchairs for carriage in taxis. Drivers are often asked to carry wheelchairs which they consider to be unsafe either because they do not provide a means for adequately restraining the passenger or because they cannot be adequately restrained. The Disability Discrimination Act reference to Assumptions about mobility aids, is considered insufficient to assist industry in this regard. Unfortunately, when confronted with these situations, drivers either refuse to carry the wheelchair to the detriment of the passenger or carry the wheelchair despite possible safety and liability issues should an accident occur. Drivers do not have the expertise to make judgements about the suitability of a wheelchair for carriage. Both Queensland Transport and industry would welcome the development of any national standards which could assist in this area. A.#3f3k3t3444 4n444445506162636B6C6F6 7 7 787c77888999:::;<:<;<<<#?$?%???@@@@@@@@@@@@AAAAB-BHB|BBBBCoCpCqCrC(DDDDdFeFiFmFnFFFFnGGHHHIJJJJVcUcc`JJK~KKLL-LLLLMeMM8NiNjNkNlNmNcklK L   8 9 KLgh>?abJKLtu7++,!!##/$0$$$&&'') ) )))****5-6---//11c2d2!h 4hw&d2"3#34444162636 7 78899::;<<<$?%?@@@AAqCrCDDFFHHJJLLjNkNlNmN*LK @Normala .A@.Default Paragraph Font ]cb`"O" Default TextKca mKNL#3JmN()*+d2mN,-.ATimes New Roman Symbol ArialWingdings"@@