аЯрЁБс>ўџ DFўџџџCџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџџьЅСY П{=bjbjѓWѓW "T‘=‘={9џџџџџџ]2222222FFFFF R,FщЖ’’’’’’’’ЎАААААА$Ÿє“\д2’’’’’д22’’’’F2’2’ЎFF2222’ЎЎЎ22Ў’~`zЩСFFи(Ў 3rd July, 2001 INTRODUCTION The taxi industry in Queensland, in association with our colleagues nationally, has been at the forefront of policy discussions and service delivery to the wheelchair accessible consumer. This approach has been pursued in concert with the desire to provide mobility to these important members of the community. The conundrum is to equitably unite reason, costs, expectancy and subsidy to reach a commonsense but not necessarily comprehensive solution. The ideal of equal access, if not based upon reason, will require the basic philosophy to be revisited. An all-embracing solution will need a significantly higher investment in capital, expenditure and subsidy than is required for conventional taxi services. Currently the industry is providing a level of service that is subsiding the government’s community service obligations rather than the other way around. Subsidy is directed to the user, and the individual providers access to that return does not compensate the extra costs incurred in meeting the licence conditions. Universal wheelchair accessible taxis would exacerbate this economic dilemma unless a whole new approach was developed to ensure equity for all stakeholders. This mainly economic solution resides in the government’s policy approach. The solution cannot rely upon the taxi industry to provide development funds for an uneconomic operation in a public transport market already experiencing increased costs and declining margins, where recovery through the fare box is impractical. These issues require wider debate, and for the purposes of this submission the response is directed only towards the issues headings raised in the Notice of Enquiry. EXECUTIVE SUMMARY Response Times The relationship between response times and wheelchair accessible licence population should be subject to periodic review in various geographic areas. Proportion of Taxi Fleets Accessible Once an agreed benchmark is reached a strategy to encourage the required number of conventional licences to convert should be developed. The continual issue of wheelchair licences beyond the economically sustainable population level could jeopardize all taxi services. The introduction of wheelchair accessible licences into rural and remote area requires specific policy development. Measures to ensure sufficient proportion accessible. Collection of verifiable data from providers and consumers. Universal Taxi. Unsustainable in a small market potential that exists in Australia, without a quantum change in government policy. Economic Factors Set up costs, driver incomes, training costs and subsidy allocation require a balanced approach that recognises the contribution made by providers to satisfy the government’s social agenda. Access to revenue by WAC vehicles must be retained for viability. Effective Use of Accessible Fleets. Allow the use of advanced management systems where required by providers without unnecessary intervention from external authorities. Develop an induction brochure for consumers joining the taxi subsidy scheme that outlines the balanced and reasonable expectation negotiated between stakeholders. Audit existing transport providers in rural areas before introducing additional services. Consider prescribing maximum dimensions for a public transport model wheelchair. ( 1 ) SUBMISSION TO THE ENQUIRY INTO EQUAL ACCESS TO WHEELCHAIR ACCESSIBLE TAXI SERVICES Response Times. It is impossible to make a generic statement in answer to this question. Many factors influence the delivery of services including factors beyond the control of the taxi industry. In Queensland the industry performance overall is quite good, however, certain measures could be taken to improve service levels, which are outlined later in this response. Currently Queensland meets and supports the government’s policy that 10% fleet population should be wheelchair accessible. The industry views this as a benchmark that requires periodic review, not as an everlasting solution. The introduction of greater accessibility into the mass transit market would ultimately relieve the demand upon the taxi industry, but again, only in areas where a mass transit option exists. Proportion of Taxi Fleets Accessible. Overall Queensland exceeds 10% of the licence population required to be accessible. The problem is more specific than introducing an intractable percentage. Since approximately 1994 only accessible licences have been issued in the major population areas of the state. The time has now been reached where the next strategy should focus upon initiatives that persuade existing owners of conventional plates to convert to accessible, rather than increase the overall population of licences to reach the performance levels that are agreed upon. The Act requires the Director General to conform to a prescribed process to issue more licences, and one of those considerations is the viability of operators. The general service levels, accessible or otherwise would decline substantially if the industry were unviable. The other major area of concern is in the rural and remote regional areas of the state, where accessibility is desired. The current system requires the calling of a public tender, a tender price to be submitted for the licence, plus the capital cost of the vehicle face an interested tenderer. The only funding then provided by the Taxi Subsidy Scheme is 50% of the probable minimal customer usage. This is then often complicated by well meaning donations of buses by H.A.C.C. or casino funds. These operate in direct competition with the private taxi operator, who is already trying to supply a needed service in marginal economic circumstances. Two possibilities could assist this disastrous scenario. Direct government funding to the taxi operator of the price difference between a conventional sedan and the wheelchair accessible vehicle, and /or direct purchase of a number of contract hours from the taxi operator, using the funds that are now used to supply the bus. This would improve the viability of a marginal operation and assist it’s continuity. ( 2 ) Measures to ensure sufficient proportion accessible. State Transport Departments need to gather verifiable economic and service level data from dispatch companies, and compare the data with dockets submitted through the taxi subsidy scheme. The experience of user groups is a useful measure, preferably verifiable, supported by an induction document that is issued to everyone when they are approved to access the subsidy scheme, that outlines what can be reasonably expected. The state authorities may need to examine whatever contract terms exist with suppliers to make sure that agreed performance criteria is met. Universal Taxi. This idealistic approach is unsustainable unless funded by government or an enterprising taxation/accounting formula is developed. The manufacturers would not be able to justify tooling and design costs for a potential market of two thousand five hundred units per year. The better alternative is to encourage greater flexibility in the range of vehicles that are economically feasible to use. Although Queensland tenders prescribe preference for dual wheelchair capability, smaller areas and areas exceeding their population ratio may well be assisted by tender processes that do not give preference to dual wheelchair carrying capacity vehicles. The only incidence of a universal vehicle that the council is aware of is in London, where the traditional black cab was a purpose built vehicle anyway. It is understood that little has changed under the bonnet and a long-term program was introduced for complete changeover. Demand for wheelchair accessible taxis has not increased as a result. Dedicated Services Dedicated services cannot run economically due to the lack of consistent demand to keep these vehicles and the drivers income viable. The only experience of direct government involvement occurred in South Australia where the establishment of Access Cabs radio room operations was subsidized by the government. Directors from the taxi industry strived to minimize the operating losses, but the solutions lie in upgrading the technology to overcome some performance difficulties. It became apparent to government that the funding was duplicating services with more advanced technology that already existed in the taxi companies. The service was transferred back to private enterprise as a result. There is a case for a centralized telephone booking service, and Brisbane operated under such an arrangement until the population of wheelchair accessible licences reached a level where equity of opportunity became an issue for taxi companies. In regional Queensland where only one taxi company per city prevails, the problem of maximum utilization is more effectively addressed. ( 3 ) Economic Factors. The cost difference of set up in Brisbane between conventional and a wheelchair accessible maxi taxi is substantial with the major difference being the vehicle price and the hoist installation. $62313 compared to $32222. The annual vehicle income rental from the drivers is $46287 p.a. for wheelchair accessible taxis compared to $62685 p.a. for conventional taxis. An examination of the taxi cost model would give a picture of the economic difference between the two operations, bearing in mind that the maxi taxi has the benefit of being able to charge a high occupancy fare under certain conditions. The other distinctive cost faced by taxi companies is the training regime. It takes a continual effort to attract drivers to the industry and of those that seek authorization, around 5% are interested in driving a wheelchair accessible taxi. Training is generally subsidized, particularly in the metropolitan area, and involves a cost of $13000 per month. Prospective drivers are charged $150 for the course, and wheelchair accessible drivers are required to attend an extra days training at no extra cost. This indeterminate manpower problem then adds difficulties to promotional issues associated with building a delivery confidence and this is unfulfilling to providers and consumers alike. The resultant decrease in driver income is apparent. The Taxi Council of Queensland has sought to introduce a lifting fee for some years. The concept is that the taxi subsidy scheme meets the lifting fee costs for each wheelchair accessible hire, and that the consumer pays 50% of the travel cost only. This should reduce the cost to the consumer, and reward the driver for the extra time and effort and unpaid kilometres spent in satisfying the governments CSO, made on his or her behalf. The rejection of this approach has been couched in the terms that the disability community view this as discriminatory. It is more likely that the real reason lies in the budget allocation in this state, as the principle is accepted elsewhere. The fact is that often the taxi company will pay the driver to fulfill a booking that the driver believes is uneconomical just to meet the expectancy of the consumer and the government. The service would be even less effective without the opportunity to charge HOV fares to the general public, and it is likely that the service would improve with the introduction of a lifting fee. The fact is that despite the points raised, wheelchair accessible tenders have been oversubscribed in Queensland. The prices tendered have been roughly commensurate with a conventional licence less the capital cost of the WAC vehicle. This is in part because the only licences issued in the state for twelve years have been wheelchair accessible and the only other option for entry has been via the private sale market. This reflects a sensible approach by the government in managing the introduction of the wheelchair accessible services in such a manner that keeps the viability of taxi services generally in focus. ( 4 ) Effective Use of Accessible Fleets The major problem facing companies is to enforce the priority condition that is an essential part of the WAC licence conditions. One Queensland company put considerable resources into developing an M50 software management program that was very effective in delivering priority service to the wheelchair accessible consumer. Complaints from the drivers involved the ACCC and consequently, the company faced with that sort of threat, rightly refused to risk their company and personal assets, and withdrew the system. Attempts by the industry to get the system authorized by Queensland Transport through the ACCC, despite widespread support from the local wheelchair community, were unsuccessful and this effective solution remains inactive Relevant performance standards and licence conditions need to be negotiated with all parties and reflect a balanced and practical approach to service delivery. A major step would be the issue of a facts sheet in simple terminology to any user at the time of induction into the taxi subsidy scheme. The facts sheet should be developed in consultation with all stakeholders. Issues regarding competition or co-ordination of services are a cause for concern where additional services are provided without an audit of the existing providers in the area. In the regional and rural areas of the state access to funding rather than creating other subsidized options can mean the economic survival of the existing public transport provider. Equipment and driver skills should be comfortably contained under the existing certificate of inspection and training regimes. These follow the principles of quality control and are about as much as the industry can cope with, in view of the ever-increasing costs in other areas that continually threaten the viability of operations. The issue of compatibility should be addressed through the development of maximum dimensions for a public transport model wheelchair. It is totally unacceptable to expect taxis to cater for every aid that has been developed, particularly as penalties are involved in the event of the failure to provide a service. Issues regarding co-ordination have been addressed in the comments concerning audits of available resources in regional and rural areas. Community Transport plays an important role in areas where distance is a major cost issue, or specialised non-ambulatory attention is required. A program of taxis supplying service to community transport passengers is being conducted, given that most community transport bookings are advised twenty-four hours in advance. 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