ࡱ> q sbjbjt+t+ mAAo]BBBBBBB4vvvvh$v0-l(,,,,,,,$/1-B-DBBDDDBB,vvBBBB,D D^%BB,@2Dvv4,h RESPONSE TO THE HREOC NOTICE OF INQUIRY Equal access to wheelchair accessible taxi services TRANSPORT WA JULY 2001 TRANSPORT WA - RESPONSE TO THE HREOC NOTICE OF INQUIRY Overview Transport WAs response to the HREOC inquiry is split into two sections. The first section explains the approach of Transport WA to taxi regulation. The second section specifically examines key issues raised by the HREOC inquiry. Section 1 Regulation of the Taxi Industry Role of Department of Transport and the Taxi Unit Transport WAs aim is to achieve the best transport system for Western Australians. Within the Department of Transport the Taxi Unit is responsible for the regulation of the taxi industry consistent with the needs of the customers and industry viability. The Taxi Unit has focuses upon four main areas of regulation: waiting time standards; driver standards; vehicle standards; and fare standards This inquiry specifically focuses on the waiting time standards and vehicle standards. In regard to waiting time standards, the Taxi Unit has introduced from the July 1, 2000 performance standards for Taxi Dispatch Services (TDS) in the metropolitan area. For each performance standard there are three levels of performance: Green Standard this represents a high level of performance at which the vast majority of customers have their expectations meet. This is the level of service that the Industry should aspire to achieve at all times. Amber Standard this is an acceptable level of service, but with real concern regarding service performance; action required to improve service delivered to the customer. Red Standard a below acceptable level of performance; does not meet customer expectations; immediate action required to rectify service delivered to the customer. There are two types of waiting time standards; waiting time on the phone and waiting time for the taxi. Waiting Times on the Phone The telephone waiting standards are noted below. The standards have been developed on the basis of customer surveys. Benchmarking of other relevant organisations has also been undertaken in support of the development of standards. GreenAmber RedTelephone waiting time period on hold once answered. Peak 15 seconds or less 16-60 seconds 61-90 seconds More than 90 seconds Off peak 15 seconds or less 16-60 seconds 61 seconds or more More than 75% Less than 25% Less than 5% Less than 0.05% More than 85% Less than 15% Less than 1% More than 70% Less than 30% Less than 5% Less than 0.1% More than 80% Less than 20% Less than 1% Less than 70% More than 30% More than 5% More than 0.1% Less than 80% More than 20% More than 1% Note: These service levels are set as preliminary standards, pending assessment of the current industry performance. In addition, standards are also being developed for the number of abandoned calls and busy calls. The number of these calls is indicative of whether customers are unable to place a booking for a taxi. Waiting Time for the Taxi Once a customer has made a call to a taxi company customers have clear expectations about the extent of waiting time. Customers vary their expectations between peak and off-peak times, and also on the basis of where they live. There are also different expectations regarding pre-booked and ASAP taxi bookings. A pre-booked call is defined as a call requesting a taxi made at least 30 minutes prior to the required time. All other jobs are as soon as possible (ASAP) jobs. The performance standards are identified on the following pages. The measurement of the level of performance is through the data downloaded from the Raywood dispatch system. This dispatch system is used at both the major TDSs. This method of measurement allows assessment of every trip booked through a taxi dispatch service providing a detailed picture of the level of service provided by the taxi industry to its customers. The opportunity is also provided through the dispatch data to separate out the Multi Purpose Taxi (MPT) trips from the conventional taxi trips. MPTs are used by people with disabilities who are constrained to a wheelchair while travelling in a taxi. ASAP Jobs GreenAmber RedWaiting time for a ASAP taxi request, proportion of jobs: Peak 0-20 minutes 21-30 minutes 31-45 minutes 46 minutes or more Off peak 0-15 minutes 16-30 minutes 31-45 minutes 46 minutes or more  More than 90% Not more than 10% Not more than 0.5% Not more than 0.1% More than 90% Not more than 10% Not more than 0.2% Not more than 0.1%  More than 80% Not more than 20% Not more than 1% Not more than 0.3% More than 80% Not more than 20% Not more than 0.5% Not more than 0.3%  Less than 80% More than 20% More than 1% More than 0.3% Less than 80% More than 20% More than 0.5% More than 0.3%  Pre-booked Jobs GreenAmber RedWaiting time for a pre-booked taxi request, proportion of jobs: Peak 0-5 minutes 6-10 minutes 11-15 minutes 16 minutes or more Off peak 0-5 minutes 6-10 minutes 11-15 minutes 16 minutes or more  More than 90% Not more than 10% Not more than 1% Not more than .5% More than 95% Not more than 5% Not more than 0.5% Not more than 0.1% More than 80% Not more than 20% Not more than 2% Not more than 1% More than 90% Not more than 10% Not more than 1% Not more than 0.5% Less than 80% More than 20% More than 2% More than 1% Less than 90% More than 10% More than 1% More than 0.5% MPT vehicles work under peak standards at all times. This was done on the basis that there is no definite peak for MPT vehicles but rather they have a relatively consistent level of demand through out the whole of the week. Jobs not Covered One area that the HREOC inquiry does not consider is the extent of jobs not covered. Of all possible service failures, a taxi that fails to pick up a passenger creates a strong negative customer reaction and is regarded as a major service failure. Consumers rightfully expect that if they book a taxi it should attend. The performance standards for jobs not covered is noted below. In general, the percentage of jobs not covered for MPTs is very low. GreenAmber RedProportion of jobs covered. Peak and Off peak More than 99.9%  More than 99.7%  Less than 99.7%  Service in the Country Area The level of service provided by multi purpose taxis in the country is more difficult to determine although as a result of customer input in the National Competition Policy the level of service in the country areas appears to be reasonable. Attachment A outlines the number of taxis in each of the country towns and those towns that have an MPT service. Section 2 - Response to the Specific Issues Raised by the HREOC Inquiry Response times: Are response times significantly longer for passengers requiring wheelchair accessible taxis than other passengers making taxi bookings in any part of Australia? On the basis of the performance standards data available to the Taxi Unit, people with disabilities using the MPT service wait significantly longer for a taxi than persons using a conventional taxi service. In making this statement there are a number of key points to consider: There are less MPT taxis covering the same geographical area as that covered by conventional taxis resulting in longer driving time for MPT jobs. Examination of this issue suggests, however, that this issue has a relatively small impact on the level of service to people with disabilities compared to able bodied persons. There are greater factors at work. Some of these are explored in this paper. It does, however, appear that there is a need to better understand this issue. Analysis of the data is available through the performance standards process provides an opportunity to do this. Transport WA is, however, at the early stages of this analysis and there is still significant work to be undertaken to identify the range of factors that are resulting in the difference in the level of service that is provided to people with disabilities compared to able bodied people. The extent of private MPT jobs is worthy of note. Private jobs are those taxi jobs that are done outside the taxi dispatch system. That is a customer and driver have come to a private agreement for the provision of taxi services. This most often happens in the circumstances where the customer takes a regular trip from A to B and / or where the customer undertakes lucrative trips and the driver, therefore, will ensure that he makes himself available for trips undertaken by that passenger in order to maintain to the business of that particular customer. As a result of private jobs, the jobs that are left on the Taxi Dispatch Service system may be less attractive to the taxi drivers. This is known by the MPT drivers. They are, therefore, not always that keen to run for MPT jobs on the dispatch system. Drivers also get to know about Mrs Smith who lives in suburb X who just goes around the corner to the local church. And on this basis Mrs Smith is unlikely to get a good service. In summary, therefore, persons with disabilities who make regular and / or long taxi trips are therefore likely to get good taxi service, as the driver has a strong incentive to provide good taxi service in order to maintain the business of the customer. This also works well for the customer. The customer not only gets timely service but as time goes by gets comfortable with the driver. So, for some, over time rather than being handled by an unknown taxi driver they are handled by a friend who understands the particular needs that they have and, therefore, is able to provide a very high level of service. Proportion of taxi fleets accessible: What proportion of existing taxi fleets is wheelchair accessible? In the metropolitan area of Perth there are 81 Multi Purpose Taxis (MPTs) capable of transporting people with disabilities. This compares with a total 924 standard or conventional taxis. The country towns that have MPT services are identified in Attachment A. Are these proportions sufficient: Is the proportion of taxi fleets which is wheelchair accessible insufficient in any areas of Australia to enable services to be provided to passengers requiring wheelchair accessible taxis, with equivalent reliability and waiting times to those for other passengers booking taxis? If so, what proportion of taxi fleets being accessible would be sufficient? In general terms the answer to whether there is enough MPTs in the taxi fleet to meet the needs of people with disabilities is yes. The reason for this is that the extent of trips made by taxi by people with disabilities is relatively low. There is at any one time throughout the week significantly less that 10% of the MPT taxi fleet occupied undertaking taxi trips with people with disabilities, excluding private taxi trips. So, from these statistics the extent of the taxi trips undertaken by the taxi fleet for people with disabilities can be seen to be very low and significantly below the capacity of the fleet. The quandary that these statistics raise is that if it is believed that the size of the fleet is sufficient then why isnt the level of service better. Or is the level of service delivered to people with disabilities reasonable, given the size of the taxi fleet? Already, in the sections above it has been indicated that the size of the fleet is not sufficient reason for the service difference between that received by people with disabilities and people that are able to use the conventional fleet. This question is answered, to some degree, in the sections below. Measures to ensure sufficient proportion accessible: What measures have transport authorities taken or could they take to ensure that a sufficient proportion of taxi fleets is accessible? If the Taxi Unit is of the view that there are sufficient taxis in the taxi fleet in order to meet the needs of people with disabilities then the way to improve service is through fleet management. The keys issues involved here are: Performance Standards for the Taxi Industry: Performance standards have been in place since 1 July, 2000. The Taxi Unit now has 12 months data, which provides for the first time, a detailed picture of the level of service provided by the MPT fleet. The Taxi Dispatch Service (TDS) which currently holds the central co-ordination contract is required to meet the performance standards nominated in the first section of this document. Attachment B identifies the process required of the central co-ordinator where the performance of the fleet is short of the performance standards. The Taxi Unit is hopeful that the performance standards process provides a clear and substantial opportunity to improve performance of the MPT fleet for people with disabilities. The expectation of the Taxi Unit is that the performance standards plans will have as a part of them a range of carrots and sticks for drivers within the MPT taxi fleet. For example, where a MPT jobs is less attractive to the driver it is the expectation of the Taxi Unit that the TDS who has the central co-ordination contract will take action to reward drivers for taking that job. In this way the level of service received by person who wants to undertake a less attractive job still gets a good level of service. Similarly, the TDS can put in place sticks where a driver chooses not to take a MPT jobs where there are conventional taxi jobs available. The TDSs dispatch system has mechanisms through which driver performance can be managed. Central Co-ordination Contract: The central co-ordination contract is a relatively lucrative contract, being worth approximately $100 000 in rank fees over 12 months. On this basis the TDS with the contract could be expected to work hard to the provide the level of service expected by people with disabilities in order to ensure that they continue to be the contracted central co-ordinator. This contract is about to re-tendered. The re-tendering of the contract provides the opportunities for all TDSs in Perth to compete for the contract. It is hoped that this competitive process will provide a mechanism for the TDSs to re-examine the methods by which they manage their fleets so as to develop a bid that is successful in securing the contract and in so doing better meet the needs of people with disabilities who travel by taxi. The Taxi Unit also has a responsibility as the contract manager. The Taxi Unit has to ensure that the contract is managed in such a way that under-performance is quickly identified and acted upon. The performance standards data provides the opportunity to more closer manage this contract that was the case in the past. Bringing Additional Taxis into the Fleet: Where there is clearly identified that lack of MPT taxis then the Taxi Unit has a responsibility to recommend to the Minister that additional taxis are required in the taxi fleet. Subsequent to the National Competition Policy review 25 additional MPT taxis were added to the fleet. It is also worthy of note that the only full time taxi plates issued since 1989 have been MPTs. In addition, industry has taken its own action. The TDS which does not have the co-ordination contract has set up a limited number of its own MPTs by converting conventional taxis so as to be able to the service this segment of the community. Universal Taxi: If 100% fleet accessibility (the "universal taxi" approach) is necessary or desirable to ensure fully equal access to services (whether to achieve access to hailed services as well as booked services, or to reduce problems regarding priority for wheelchair user passengers, or to increase general public acceptance of wheelchair accessible vehicles, or for other reasons), what measures may be feasible and necessary (currently or within a reasonable period) to make possible the achievement of this level of accessibility? On the basis of first principles, it could be expected that if all taxis were accessible through the development of a universal taxi then the level of service to people with disabilities could be expected to improve in terms of waiting time. On this basis, from the viewpoint of the long term desirable outcomes, in the same way as the public transport system is moving towards accessibility on all buses, trains and train stations it is reasonable to expect that the taxi industry should aim to do the same. The first steps towards this process would appear to be the following: 1. A vehicle that meets the needs of the taxi industry. A universal taxi that does not have the support of the industry is not going to succeed. This issue needs to be considers from a range of perspectives including both design issues and maintenance cost issues. 2. The second and possibly more difficult issue is the financial and economic issues surrounding the production of a universal taxi. What is the cost differential between a conventional and universal taxi and who is going to meet the cost of that differential? It is worth noting that even if all taxi cars were universal taxis it is likely that the level of service experienced by people with disabilities is still likely to be less than that received by able bodied persons. This is from both the perspective of the waiting time and the level of service provided by the driver. The transport of people in wheelchairs is much more demanding on drivers than popping the boot for able bodied passengers. Thus even if all taxis were accessible waiting times for some people with disabilities could be higher than able bodied passengers because drivers choose not to undertake wheelchair jobs. In the same way, able bodied persons who want to undertake short trips are currently discriminated against by taxi drivers because such jobs are less attractive. Even if the job is not identified as a wheelchair job on the in taxi computer the drivers will, as a result of learning to identify the addresses which are wheelchair jobs and are not attractive, choose not to pick up these jobs. Dedicated services: What experience or issues are there with operation of wheelchair accessible taxis as a dedicated service rather than also being available for mainstream service? The major issue that would be faced by a dedicated fleet would be whether there was sufficient work to sustain the additional costs associated with the operation of an MPT taxi which are significantly more expensive than a conventional taxi. Certainly the data that has become available to the Taxi Unit through the performance standards process would suggest that there is very little likelihood that a dedicated fleet would be economically feasible at present levels of demand. Economic factors: Are there any economic disincentives to provision of wheelchair accessible taxi services (either in provision of accessible vehicles or in their use to serve passengers using wheelchairs) which could be addressed by taxi regulatory authorities, by other relevant government agencies or by industry? In particular: Issues affecting capital or running costs of accessible vehicles One of the major issues faced by regulatory authorities is the design specifications for the MPTs. The Taxi Unit has aimed to develop MPT design specifications which cater for the vast majority of wheelchair types and wheelchair users. In addition, the design specifications currently require that the taxi is able to take two people in wheelchairs. These relatively high standard design specifications impact on the cost of the MPT vehicle. Removing the requirement that the vehicle has to be capable of carrying two people in wheelchairs would, for example, reduce the costs of the MPT vehicle. Any other distinctive costs in providing wheelchair accessible services The additional training for MPT drivers is currently picked up by the Department of Transport but there is a requirement for the drivers to spend additional time to become an MPT driver. Fare structure and fares income received for wheelchair accessible taxis in comparison to other taxi services In responding to this issue it is worth providing some background information regarding calculation of fares when people in wheelchairs are being transported and subsidy available to people travelling in wheelchairs through the Taxi User Subsidy Scheme. Loading time for wheelchairs and scooters is allowed to be included in the total taxi fare. Passengers in wheelchairs are subsidised for the additional waiting time costs through a higher subsidy from the Taxi User Subsidy Scheme. The subsidy available to people in wheelchairs in Western Australia is 75%. Non wheelchair members of the scheme receive a 50% subsidy. Some drivers who have MPT licences argue that they are unable to make a reasonable income from doing wheelchair work clearly driver viability is a key issue. On this basis they have abandoned wheelchair work and are just focusing on conventional work. However, on the basis that the MPT licence was issued on the basis that priority would be given to people with disabilities it is the responsibility of the Taxi Unit and the MPT Co-ordinator to ensure that the mechanisms are in place to overcome this problem. Nonetheless, it is evident how the extent of MPT jobs available impacts on the decision making process of the MPT drivers and, therefore, service to people with disabilities. Effective use of accessible fleets: Are there any regulatory or technical measures being taken or which could be taken which would ensure that any given level of accessible taxi fleet meets demand for wheelchair accessible taxis more effectively? In particular: Possibilities for more effective implementation or enforcement of priority systems including issues affecting use of GPS and other new technologies, and barriers to effectiveness of priority systems GPS certainly can provide the opportunity for improvements in service. Currently GPS does not exist in Western Australia. Close and able management of priority systems in the taxi dispatch system computers provides the opportunities for improvements in the levels of service. The taxi dispatch services do, however, often have to walk a fine line between keeping the customers happy and keeping the drivers happy. Relevant performance standards and licence conditions Performance standards have previously been dealt with in this submission. Conditions of licence provide a further mechanism through which service standards to people with disabilities can be met. Clarification of responsibilities of booking services, taxi operators, regulators and any other relevant industry participants One of the major outcomes coming from the NCP review in Western Australia has been the clarification of roles of Government and Industry. The final recommendations of the review stated: There will be clear and separate roles for Government and industry. The role of the Government is as a policy leader and a standard setter. The role of industry is to meet the needs of their customers. This clarification of roles will mean that Government is responsible for outcomes and industry is responsible for inputs. Government will set standards of performance and industry will be responsible for devising strategies to meet performance standards. Government will no longer enact regulation to require industry to act in certain ways. Government will set outcomes and industry will determine how to act to achieve these outcomes. As Government will no longer be regulating inputs this provides significant scope to reduce regulation. Where regulation can be deleted then this course of action will be followed. From the perspective of MPT service to people with disabilities this will mean that the TDS holding the MPT co-ordination contract will be required to perform to identified performance standards. Where there are insufficient taxis additional taxis will be tendered. Where the standards are not being met processes will have to be put in place to rectify this by the MPT co-ordinator. Where this is not the case then the MPT co-ordinator will face financial penalties and risk losing the right to the MPT contract. Issues regarding competition or co-ordination of services In general terms, the view of the Taxi Unit is that through requiring all MPTs to work with one co-ordinator ensures that customers can access all MPT taxis through one phone call. Measures to ensure accessible taxis are complete with necessary equipment and driver skills to ensure accessible service with an equivalent degree of safety to other passengers is available in practice The Taxi Unit aims to ensure that the vehicle specifications and driver training are such that the level of safety afforded to the passenger is of a very high standard. The course in multi-purpose taxi operations, which all MPT drivers undertake, is a nationally accredited training course. Issues regarding compatibility of different types or sizes of wheelchairs or other mobility aids with accessible cabs and possibilities for certification or consumer information regarding public transport compatibility of these aids No comment. Issues regarding co-ordination with or substitution for other modes of accessible public transport (generally or for specific purposes such as school transport), including relationship to "community transport" services. No comment. Attachment A Taxis, MPTs and Private Taxis Per Town - 1999 TownTaxisPrivate TaxisMPTsTaxi CompaniesKalgoorlie / Boulder 1425(2Mandurah288(1Carnarvon2412Bunbury237(1Port Hedland2233Geraldton (includes Greenough) 1226(2Broome 2176(4Albany155(2Karratha153(1Collie1121Busselton 71(1Derby 3721Esperance621Northam61Kunnanura 465East Pilbara (Newman)421Fitzroy41Margaret River441Onslow42Roebourne41Tom Price41Exmouth31Manjimup311Murray (Pinjarra)31Narrogin321Shark Bay (Denham)311Dongara21Donnybrook21Dunsborough211Katanning21Merredin211Mount Barker211Wyndam22Augusta11Boddington11Dandaragan111Denmark11Halls Creek 511Harvey11Kojonup111Leonora11Meekathara11Northampton111Southern Cross111Wagin11Total 31668 Attachment B Performance Standards Process Where the TDS falls short of the performance standards they are required to develop a performance standards plan which aims to identify strategies to improve performance. Where an improvement plan is not lodged by a TDS then a sanction, consistent with Taxi Act and regulations, will be imposed upon the TDS. Subsequent to the TDS receiving the next Performance Standards report, an assessment will be made identifying the extent to which the TDS has improved performance in the areas which were nominated as requiring improvement. Where there has been no improvement a show cause letter will be sent to the taxi company asking why a sanction, consistent with the Taxi Act and regulations, should not levied against this company. A suitable response from the taxi company, that would avoid a sanction being levied, would be a modified improvement plan. This modified improvement plan must contain two components. The first component is to outline the outcome of the actions taken, as identified in the initial action plan. In addition, it is important that the reasons why the actions undertaken did not result in improvement are identified. The second component is to nominate new or modified actions that the TDS will undertake in order to improve performance. The TDS has 20 working days, from receiving the show cause letter, to submit the modified improvement plan. Where a modified improvement plan is not lodged or does not contain the two required components then a sanction, consistent with the Taxi Act and regulations, will be brought against the TDS. The approach nominated above - performance assessment, show cause letter, submission of modified improvement plan - is consistent with the performance standards being a process through which improved customer service is the central objective rather than the imposition of sanctions. The MPT co-ordination contractor has submitted their first performance standards plan. A second or updated performance standards plan is due shortly. 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