Supplementary Submission 		     Allen Ringland  
Review of Standards for Accessible Public Transport

This submission supplements my initial submission (22/8) and challenges some of the misleading statements made in the Australian Taxi Industry association’s submission (24/8), including with regard to: 
·	the validity of Queensland taxi service reports
o	arrival time of taxis
o	private bookings;
·	the responsibility of the taxi dispatch company.

Comments on Professor D Nicholls report attached to Taxi industry submission
·	taxi dead running;
·	the profitability of accessible taxis.

The validity of Queensland taxi services reports

Arrival time of taxis

The taxi industry claims the reported time of pickup within Queensland is compromised because the taximeter is started after the arrival of the taxi, effectively when the wheelchair customer is secured within the taxi. This statement is questionable because it doesn’t follow Queensland law or the natural instincts of taxi drivers, who generally receive a percentage of the taxi fare as their only income. Cairns drivers work for a percentage of vehicle income. 

An archived copy of the Cairns Black & White taxis web site (link) from October 2003 is attached which clearly states “Drivers normally start the taximeter before loading the wheelchair, then at journeys end stop the meter, accept payment and then unload the wheelchair.” This web site was running from 2nd December 1998 till 25th October 2003 updated 8 times without change to the loading procedure. The website was shut down in late 2003 and has only just started again leaving this section out.
 
In practice the taximeter is started when the driver leaves the drivers seat in preparation for assisting the customer into the taxi. The meter is turned off as the driver leaves the drivers seat to assist the customer from the taxi. The only proviso on this is the vehicle must be ready to accept a wheelchair, eg seats that may need to be stowed are done so without running the meter.  

Curiously it has been reported that over recent months B&W taxis Cairns has made changes within their training course, instructing trainee drivers to start the taximeter after loading. It could be expected they would know that this instruction would be overturned when the trainees spent their compulsory 16hrs as shotgun driver in accessible taxis as stated elsewhere.
Experienced drivers have confirmed to the author this week they are still commencing the taximeter at arrival before loading.   

Queensland’s transport regulations state (Transport Regulations public transport act 1994) 
Operation of taximeter by taxi driver
(1) The driver of a taxi that has a taximeter must only activate
it—
(a) for a hail or rank hiring—when the hirer enters the taxi;
or
(b) for a booking—when the hirer is notified of the taxi’s
arrival; or
(c) for a booking for a specific time—at that time or the
time when the hirer enters the taxi, whichever is earlier.
Maximum penalty—5 penalty units.

In my 12 years as an owner driver of an accessible taxi the taximeter was always started before loading. Under local company rules, experienced taxi drivers are required to train new drivers; the new driver must spend at least 16 hours as a shotgun driver in wheelchair accessible taxis (even if the new driver may have no intention of driving an accessible taxi) before becoming an accredited taxi driver. These drivers are shown when to start the taximeter.   
Under some circumstances where the driver may wish to limit the charges to the customer the taximeter is started as normal then placed on stop. This indicates pickup but the taximeter doesn’t start increasing until the driver clears the stop function before starting the journey. 
The taxi company until recent months supported and promoted this procedure, it helped their statistics. 

I wrote to a regular user of accessible taxis in Cairns this week seeking her views on the veracity of the Australian taxi industry’s submission. 
The following is a note from Gail Harris a long time user of accessible taxis in Cairns.�
I find the referred to statement in the Australian Taxi Industry (Blair Davies Queensland Taxi Council) submission regarding the calculating of taxi response times to be quite misleading.  In my experience as a user of accessible taxis since 1991, I have found that 80% of the time the meter is started immediately the taxi arrives to pick up - before loading, not after loading and securing as stated.

Private Bookings

The taxi industry claim high numbers of private bookings. 
The taxi arrival time however may not be when the customer wants but when the taxi can reach the customer. The attraction of private booking is mainly in the certainty a taxi is coming and a reasonable idea of its arrival time. Dispatch companies could provide this service.
Cities such as Canberra may have large numbers of private bookings. These bookings are recognised by those that understand the industry as highly disruptive and detrimental to most taxi users leading to inefficient distribution of taxi work. Private bookings are usually the result of poor service delivery and distrust in the taxi dispatch. However it has been stated within control circles of Cairns taxi service that any jobs serviced privately are less jobs the dispatch system will need to worry about. The figure for Cairns in my experience was less than 5%. I personally refused any such approaches from customers attempting to bypass the taxi company.

Responsibility of the taxi company

If the recommendation of the Australian taxi industry in Q5 were to be accepted, that the taxi dispatch companies should only be responsible for processing the initial booking and not the service to the customer total disruption of the existing service could be expected. It could be said the submission is calling for deregulation of this part of the taxi market, an issue that would be most alarming to the sedan taxi industry.

Taxi dead running

It has been described that accessible taxis do considerable dead running. It must be remembered that if a taxi is required to travel excessive distances to reach a customer then the customer will need to wait an excessive time. This is a function of insufficient accessible taxis within a fleet or poor dispatch procedures. It will only be overcome when commitment to meet the needs of the disabled community matches the rhetoric of those involved.

Profitability of accessible taxis

Some Australian regions have problems making accessible taxis profitable. The reason Queensland’s taxis have a considerable market value is they are run on a commercial basis and operate as a standard taxi when not engaged in wheelchair work. The time spent assisting accessible customers is paid for as with standard customers. My taxi business was sold last year for $420,000 about $50,000 less than standard licences at the time. The business was, shares of B&W taxis Cairns value $45,000 a three year old vehicle with over 500,000km travelled and a wheelchair taxi licence for Cairns. At least one accessible taxi has sold since at a higher price.

Attachment B&W (Cairns) taxis web site December 98 till October 2003.
http://web.archive.org/web/20030415120512/www.blackandwhitetaxis.com.au/maxi.htm

Black & White Taxis have a fleet of wheelchair-accessible taxis.

All vehicles are rear loading on an electronic ramp, it is not necessary to leave your chair.		

Most taxis can carry 2 wheelchairs together.		
	Other combinations are:	
	·	2 wheelchairs plus 1- 5 passengers 
·	1 wheelchair plus 1 - 8 passengers 	

Drivers normally start the taximeter before loading the wheelchair, then at journeys end stop the meter, accept payment and then unload the wheelchair.		

These vehicles when not carrying wheelchairs can operate as both a normal taxi or a maxicab. 		

Loading a wheelchair usually only costs approx $3.00