ࡱ> cebq _bjbjt+t+ xAA[]L$DDDDDDDD$$$$$$$%'$DDDDD$DDDD.DD$D$ ni#$D8 (rq$ Response to Human Rights and Equal Opportunity Commission Inquiry: Equal access to wheelchair accessible taxi services Passenger Transport Board, South Australia June 2001 The Passenger Transport Board is committed to providing passenger transport services to people with disabilities. South Australia is committed to having a fully wheelchair accessible fleet of buses and aims to have all routes accessible by 2015. The commitment to service delivery for people with disabilities is also demonstrated by South Australia being one of the first states in Australia to establish and support an efficient and effective fleet of wheelchair accessible taxi cabs. South Australia also recognises that people who are confined to wheelchairs may need additional assistance with transport and provides a subsidy for taxi travel for people who are unable to physically use public transport through the South Australian Transport Subsidy Scheme. The Passenger Transport Board welcomes the inquiry concerning equal access to wheelchair accessible taxi services undertaken by the Australian Human Rights and Equal Opportunity Commission. The Board looks forward to the findings of the inquiry and particularly to the identification of best practice models of wheelchair accessible taxi services. The following information is provided to assist the Australian Human Rights and Equal Opportunity Commission in its inquiry into the issues associated with improving wheelchair accessible taxi services. BACKGROUND INFORMATION: Access Cabs At present, there are 68 wheelchair accessible taxi licences that comprise the fleet of taxis delivering services to people with disabilities. The vehicles are owned by independent operators who have taken up special licences that set out specific conditions related to provision of Access Cab services and are tied to one centralised booking service (CBS). The current conditions for these licences are contained in Attachment 1. 1.1.1. Central Booking Service (CBS) A single centralized booking service is used to dispatch all fully Accessible vehicles. The system uses a global positioning system to dispatch work. Manual intervention can take place and vehicles can be dispatched to specific areas to cover work. 1.1.2 Cost of Licences Access Cab licences trade at significantly lower prices than general licences in South Australia. The lower price reflects the special conditions and cost of vehicle for accessible cab services. 1.2. General Taxi Cabs and Hire Cars There are no limitations on the number of accessible vehicles which can operate in the general taxi fleet in South Australia. Taxi Cab providers have vehicles which can undertake multi-seater and wheelchair accessible work. These are not part of the Access Cab fleet because they operate under general taxi licences. Small passenger vehicle numbers are not restricted in South Australia. There are no limitations on the number of vehicles which can be wheelchair accessible. Hire cars compete directly with taxi cabs for the pre-booked market. South Australian Transport Subsidy Scheme People who are unable to travel on public passenger vehicles due to mobility impairment may be eligible for subsidised taxi travel through the South Australian Transport Subsidy Scheme (SATSS). People who are confined to wheelchairs or other large mobility aids are eligible for a 75% subsidy to a total fare of $30, whilst people who are ambulant can receive a 50% subsidy to a total fare of $30. As at 31 May 2001 there were 37,889 members of SATSS, 87% of whom (or 33,148) were ambulant and 13% of whom (or 4741) were wheelchair users. The South Australian Transport Subsidy Scheme is not means tested. The subsidy through SATSS may only be used for trips in taxi cabs and Handi-Bus company vehicles in the metropolitan area. In country areas, the subsidy vouchers can be accepted by taxis or hire cars. Priority is given to local taxi operators in country areas. However, where no taxi cabs exist, the Passenger Transport Board approves local hire car operators to accept SATSS vouchers. At present metropolitan hire cars are not able to accept SATSS vouchers. Hire cars operate on agreed or negotiated fares with their clients (eg. there is not a maximum fare regulated by government). Hire cars are not required to have a centralised booking service and , most importantly for the provision of accessible services, are not required to accept any hiring, including short trips. Short trips may not be economically viable to operators but are essential for many people with significant transport disadvantage. In essence, because hire cars are not required to accept any hiring, it could be appealing for operators of taxis to leave the prescriptive licensing of taxis for the relative freedom of hire cars if the SATSS was also available to hire cars. The risk is that customers seeking to travel short distances may be particularly disadvantaged. ISSUES IDENTIFIED FOR COMMENT BY THE INQUIRY Waiting Times Waiting times for Access Cabs have improved significantly. Average waiting times for Access Cabs have fallen over the last five years by more than 5 minutes to an average of 12 minutes in May 2001. Figures provided by an independent market research company indicate that the average waiting time in the general taxi industry is 6 minutes. Figures provided by the general taxi industry indicate that approximately 98% of all jobs are started within 20 Minutes. Figures provided by Access Cabs indicate that approximately 83% of all work is started within 20 minutes. An issue for consideration in the inquiry is what measure should be used for response times and what should be the appropriate comparison? Is a comparison with the general taxi fleet an appropriate one (eg are they equivalent services)? Is setting a maximum waiting time for a booking likely to be a more realistic performance target for accessible taxis, as endeavouring to match average waiting times of the general fleet would require significantly higher numbers of accessible taxis on the road and may impact on viability for accessible taxi operators and the general taxi fleet? The service provided by wheelchair accessible taxis is not necessarily equivalent to the general taxi fleet. Drivers of wheelchair accessible taxis provide some different services by assisting people with disabilities to enter and exit the vehicle, to be secured in the vehicle and to possibly give more assistance with any luggage or equipment they may have. This takes additional time. Average subsidy payments through SATSS (for 1999/2000) show that costs per trip are higher for people who use wheelchairs or other large mobility aids (an average fare of $15.44) than people with mobility impairments who are ambulant (an average fare of $5.92), due in part to the longer time taken providing a service. Requests for specific vehicles in the general taxi fleet often results in longer response times or issues of availability for required times. Specific vehicles in the general fleet include high end market or elite vehicles, station wagons (for luggage or to transport bicycles or other large goods), vans for multi-seater work and requests for specific drivers. Is a more appropriate comparison between accessible taxis and specialist vehicles, rather than with all vehicles in the general fleet? It is suggested that consideration be given to investigating service standards delivered by specialist vehicles in the general taxi fleet. Comparisons on waiting times can also be effected by the measure employed. For example, the meaningfulness of comparisons between accessible taxis and the general taxi fleet is affected by the options available to customers. The general public may seek other travel options if forced to wait for a long time for a cab. They may call a friend for transport, drive themselves or proceed to walk towards their destination and look to hailing a taxi along the way. In pursuing these alternatives they may cancel the request for a cab or simply not be there when the taxi arrives. These are then recorded by the CBS as cancelled or no jobs. People who require accessible taxis do not necessarily have those options available to them and must wait for the taxi to arrive. This is recorded by the CBS as waiting times. Therefore there is not a direct comparison available between the general fleet and the accessible taxi fleet for all late jobs. Proportion of taxi fleets accessible and sufficiency of this proportion. In South Australia, there are currently 68 wheelchair accessible taxi licences for a known market of around 5,000 users (ie members of SATSS who rely solely on wheelchairs for mobility). There are around 1,000 general taxi cabs for the rest of the population in metropolitan Adelaide of approximately 1.1 million people. Wheelchair accessible vehicles comprise approximately 7% of the taxi fleet. These equate to: 1 wheelchair accessible vehicle to every (approximately) 70 wheelchair users 1 general taxi cab to every (approximately) 1,100 people State and Territory governments employ licence controls to ensure sufficient proportions of wheelchair accessible taxis by releasing licences that trade at lower values. 2.2.1 Regional South Australia Some regional areas of South Australia do not have wheelchair accessible taxi cabs. Local operators have advised that this is the result of market demands where the number of potential customers for wheelchair accessible taxis is perceived as too low for viability. The Passenger Transport Board does not regulate taxis outside the metropolitan area of Adelaide. There are no regulatory impediments to operators providing accessible taxi services in regional areas other than economic viability. Where there are limited transport options available in regional areas, Community Passenger Networks can arrange for substitute services. These are described in greater detail below (see section 2.7). The issue of service viability in regional and remote areas requires careful consideration. 2.2.2 Metropolitan Area In the metropolitan area viability is also an important issue for consideration with regard to the number of accessible vehicles available in the fleet. All taxi and hire car service providers experience periods of high demand and of low demand. Should the proportion of accessible vehicles be based on the highest demand days and times, such as Christmas day and school opening and closing times, or for the average level of demand? More vehicles competing for the wheelchair accessible market create issues of viability for individual operators who are confined to be available for that market. That is, it could lead to greater lengths of nonproductive time for individual operators who may wish to take their vehicles off the road at those times or pursue general taxi work, at the expense of availability for wheelchair accessible work. An additional issue for consideration concerning the number of wheelchair accessible vehicles available is the commitment and dedication of drivers to provide wheelchair accessible services. What mechanisms are there to encourage drivers to provide these services, given that taxi and hire car services are commercial enterprises? If the main incentive is higher fares, how can this be afforded by passengers? State and Territory governments already expend significant levels of funding on subsidised travel. 2.2.3 General Taxi services are provided by independent operators as a commercial enterprise. Patronage levels for taxis will determine whether services are viable and can be provided in certain areas. The cost of purchase, modification and resale of wheelchair accessible vehicles may be beyond the capacity of single operators to provide in low population/patronage areas. This raises the issue of whether the service is provided as a taxi service or as a community service through government funding. Universal Taxi People with disabilities are not a homogenous group. Certain vehicle designs, such as vans, are not suitable for some customers with particular mobility impairments or customer preferences. The majority of people with mobility impairments who receive subsidised taxi travel through SATSS are ambulant and use the general taxi fleet. A universal design for taxis while well intentioned may restrict consumer and provider choice. A universal taxi design will not necessarily improve services to people who use wheelchairs. Quality service provision is influenced by drivers maintain commitment to providing services to people who rely on wheelchairs. What mechanisms can be employed to ensure drivers commitment to this group of customers? Are wheelchair accessible taxis expected to be equivalent to general taxis in seating capacity? Currently general cabs will carry a minimum of four passengers. There would be practical (eg. size of vehicles) and cost implications if accessible cabs were also expected to carry four passengers in wheelchairs. If a universal taxi design results in a van style vehicle for taxis will this impact on consumer choice to use hire cars instead, if these vehicles are not subject to the same accessibility requirements as taxis? An issue is whether there is a resale market for universal taxi vehicles and how commercial operators may recover some or all of their costs to change vehicles over. Another issue for consideration is whether a universal taxi design will lead to a monopoly situation within the vehicle manufacturing sector; in which it might only be commercially viable for one manufacturer to make the vehicles. This may result in adverse impacts on costs and service quality from the monopoly vehicle provider. The introduction of universal taxis would require suitable road infrastructure, such as kerbing at taxi ranks, to be consistent with the design of wheelchair accessible vehicles. Dedicated Services If there are currently difficulties reported where accessible taxi cabs are dedicated to wheelchair accessible work under government regulations, how can services be improved in a less controlled service model? Services to people with disabilities frequently involves additional commitment and effort for drivers (eg loading and securing passengers comfortably and safely) that does not apply in relation to general taxi services. Evidence suggests that If there was not a dedicated service, the additional effort and commitment required could act as a disincentive to undertake accessible taxi services where general taxi work was available. Do dedicated services enable greater controls to maximise the efficiency of the fleet available at any particular time to optimise viability for providers and services for passengers? Economic Factors Current regulations in South Australia require wheelchair accessible vehicles to be replaced every 10 years. In comparison, vehicles in the general taxi fleet must be replaced every 6.5 years. Wheelchair accessible vehicles cost more to purchase, equip and maintain compared to basic vehicles in the general taxi fleet. A fundamental issue to be considered in regard to economic viability is whether wheelchair accessible taxis should be commercially operated vehicles for profit, as are other general taxis, or should be considered a social service funded by government. If disincentives to the delivery of high standards of service are of an economic nature, then; what fare levels should passengers be expected to pay for higher cost services or to offset disincentives and should all passengers be charged the same fares; to what level should government subsidise fares for passengers or subsidise higher costs or for operators of wheelchair accessible taxi services; at what point is service delivery deemed no longer to be a profitable service and therefore could be considered a deficit funded service through government subsidies; should services, which are subsidised or deficit funded, be provided by private for commercial bodies or not for profit organisations? Within South Australia the high demand periods for accessible taxis are focused on periods at early morning and mid afternoon during weekdays and for special events such as Christmas Day. These seem to generally coincide on weekdays with access times for specific government services such as schools, veterans affairs and health service provision. There is lower demand at nights and weekends. Economic viability must consider the impact of periods of low demand as well as high demand. Effective Use of Accessible Fleets Wheelchair accessible taxi vehicles are subject to special licence conditions to maximise their availability to people with disabilities. These are described above in section 1.1. Additional arrangements are made by the Passenger Transport Board, for high demand days, such as Christmas day and Mothers day. These arrangements can be made available on request. The National Competition Policy poses issues with regard to taxi cabs. The National Competition Policy Council argues that licence restrictions are anti-competitive and increase costs, that are consequently borne by consumers. If licence conditions to ensure the provision of accessible taxi services are removed, how can operators be encouraged to service this market? The public benefit test for competition needs to include an understanding of the most appropriate manner for all consumers to have access to public transport and how this can be best provided, particularly for market segments which have specific requirements. Deregulation of taxi cabs, including wheelchair accessible taxis, would significantly reduce the level of control and influence that State Government industry regulatory bodies have on ensuring service performance. In a deregulated market the key issue is how can performance be ensured? Where would responsibility for ensuring performance or creating incentives for performance rest if State Government regulatory bodies have a greatly reduced or no role; with the Human Rights and Equal Opportunity Commission or with the federal government? General 2.7.1 Technology While Global Positioning Satellite technology is used to assist the efficiency of the Access Cab fleet there are still issues it cant address with regard to improving response times. For example the technology is unable to predict factors such as temporary or locally imposed road closures or traffic flow and able to deal with various geographic barriers. 2.7.2 Carriage of Mobility Aids The Passenger Transport Board supports the concept of certification of mobility aids for different forms of public passenger vehicles, together with information and education of mobility aid users and suppliers and has undertaken preliminary investigations into this area. There are issues concerning the safety of drivers and passengers where mobility aids, such as scooters, or their passengers can not be secured safely in a wheelchair accessible taxi. Large mobility aids, such as scooters, may not have design features suitable for safe transportation in public transport (eg. secure batteries, attachment of luggage) and users may not be aware of the suitability of their particular aid for different public transport vehicles. 2.7.3 Community Passenger Networks In country areas, community passenger networks provide a co-ordination service to arrange for appropriate transport for people who may be transport disadvantaged. The CPNS can arrange for substitute transport services for people who rely on wheelchairs, where accessible taxis or accessible hire cars are unavailable. There are currently nine CPNs across rural South Australia, with gaps in coverage only on Yorke Peninsula, for which negotiations are underway, and Kangaroo Island, which is currently being investigated. CPNs are generally auspiced by local government, but in the South east and Eyre Peninsula they are auspiced by Red Cross. 3. CONCLUSION The challenge to the current arrangements for providing accessible taxi services is to attain the right balance between the needs of customers and taxi operators. Customers require services and operators require economic viability. The Passenger Transport Board is committed to exploring ways to assist continuous improvement in service delivery that can be best achieved in South Australia. The Passenger Transport Board would be pleased to meet with the Australian Human Rights and Equal Opportunity Commission to discuss any of the issues or information raised in this response. The Passenger Transport Board looks forward to the identification of models or practice, which have been proven to work effectively, to improve wheelchair accessible services available in South Australia. ATTACHMENT 1. CURRENT LICENCE CONDITIONS FOR ACCESS CABS IN SOUTH AUSTRALIA 1. The Vehicle The Vehicle must comply with a range of Acts and design rules that ensure the safe carriage of people with disabilities. 2. Conditions related to the Operation of the Licence The Operator must connect the Vehicle to a Centralised Booking Service (CBS) nominated from time to time by the PTB, and enter into an agreement with the CBS, in terms approved by the PTB and the CBS. The Operator must ensure that the driver of the vehicle (Driver) will be in two way radio or telecommunications contact with the CBS at all times and must comply with all requests from the CBS operator in relation to bookings and associated matters. The Driver must provide a dedicated service to bookings made through the CBS between hours determined by the PTB and the CBS. The period of dedicated service may occupy up to 11 hours daily. The present hours are 7.30 am to 6.30 pm daily. This period may be greater on holidays and other days of special events when Vehicles may be the subject of a roster system to provide the services. The Operator must provide a priority response to bookings made through the CBS at other times. At times where there is not demand for services by people with disabilities, the Vehicle may, by agreement with the CBS, be rostered off and deployed in general taxi work. This work may be obtained through attachment to a second CBS or through rank or hail methods. The Operator will be required to ensure that the vehicle meets any quotas or other measures imposed by the CBS to ensure effective distribution and servicing of bookings to people with disabilities. The Operator will be required to participate in the South Australian Transport Subsidy Scheme. The PTB has determined under Section 47(6)(f) of the Act that the particular licences issued as a result of this tender cannot be leased. This determination does not apply to the form of dealing with a vehicle known as shift leasing, where the vehicle is made available to an accredited driver who is not an employee of the licencee. The Operator will be required to engage Drivers who have sufficient responsibility, skills and aptitude to drive a wheelchair accessible Vehicle and to provide related services to people with disabilities. They will be required to have completed any course of training required by the PTB for this purpose. The Operator must ensure that all Drivers are made aware of, and comply with, these conditions. 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