Submission to the Commission for Taxi Regulation on the National Review of Taxi, Hackney and Limousine Services and Vehicle Standards

1st April 2005

Introduction

The National Disability Authority (NDA) welcomes the opportunity to express its views in relation to the national review of taxi, hackney and limousine services and vehicles standards.

The NDA was established in June 2000 as an independent statutory body operating under the aegis of the Department of Justice, Equality and Law Reform. The National Disability Authority Act, 1999, defines the principal function of the NDA as "to advise the Minister and keep him or her informed of developments in relation to any disability of persons which concerns issues of policy and practice…"

Furthermore, two of the core statutory functions of the NDA are:

'to advise the Minister on appropriate standards for programmes and services provided or to be provided for persons with disabilities and to act as an advisory body with regard to the development of general and specific standards in relation to such programmes and services', and

'to monitor the implementation of standards and codes of practice in programmes and services provided to persons with disabilities and to report to the Minister thereon'.

In the view of the Commission on the Status of People with Disabilities (1996) taxis are the ideal form of transport for people with disabilities. However, according to the Commission they have two major disadvantages: costs and the lack of accessibility.

Accessible taxi services are a vital element in the public transport chain providing a demand-responsive 24-hour door-to-door service. With improved access being provided to other modes of public transport, the usage of taxis by people with disabilities will if anything increase, since a significant proportion of people with disabilities would require transport from home/work, etc., to public transport pick-up points.

An accessible taxi service is a service that is available, affordable and provided to customers in an efficient and effective manner. In this context accessibility includes accessible vehicles, a quality customer service (for example a Charter of Rights), provision of accessible information, accessible communication and an integrated accessible transport services.

The NDA supports the Government's commitment to continue the process of making taxis wheelchair accessible (Agreed Programme for Government between Fianna Fail and the Progressive Democrats, 2002).

The NDA welcomes the establishment of the Commission for Taxi Regulation and is looking forward to working in partnership with the Commission in the development of quality regulations for small public service vehicles and their drivers providing for the safety, security and comfort of passengers, drivers and other road users.

People with Disabilities in Ireland

Recent surveys have reported different figures of incidences of disability, ranging from a 8.3% proportion of the total population in the Census 2002, to 10% of the labour force (15-64 years) in the QNHS 2002 to 17% in the Living in Ireland Survey. Some of these differences may relate to the explicit inclusion of long-term illness in the QNHS and the LIS. Despite the differences in definitions used, there are some strong similarities in what these three sources of information show. The age profile of people with disabilities is very similar, with the incidence of disability rising steadily with age.

To enable people with disabilities to participate in normal activities of daily living, i.e. work, education, leisure and social activities, transport is an essential prerequisite. Factors such as inclement weather, physical barriers resulting from a poorly designed pedestrian environment and aging mean that for many people with disabilities door-to-door transport is a preferred option. An accessible and affordable taxi service has the potential of being the most efficient and economic means of meeting this need.

The proportion of the population who would benefit from an accessible taxi service is sizeable. The economic benefits of the increase in cab usage levels by people with disabilities are significant. It is sometimes not appreciated that the size of the market influenced by the needs of people with disabilities is far greater than statistics on disability would suggest. Carers, partners, families and friends are all affected by the needs of any person with a disability they may be accompanying. This 'multiplier' effect provides a further significant market opportunity for all taxi operators.

Small Public Service Vehicles - Present Situation

As part of the European Year of People with Disabilities 2003, a consortium of disability representative organizations commissioned Transport Planning International (TPI) to identify the most suitable accessible taxi/hackney service in the Irish environment.

This report, 'Towards an accessible taxi service for all' (2004), shows that there are approximately 1,200 wheelchair accessible taxis in Ireland, representing 10.2% of the total fleet. The report notes that at the time of deregulation there were 840 wheelchair accessible licenses, representing over 21% of the total taxi licenses issued.

The report (2004, p.7) also highlighted 'the importance of the availability, accessibility and affordability for people with disabilities'.

In the NDA's submission to the Department of the Environment and Local Government (2003), the NDA commented on a number of difficulties regularly experienced by people with disabilities, such as:

Delays between time of calling for an accessible vehicle and its arrival at the pick-up point.;
Difficulties experienced by people with hearing impairments in contacting the taxi operator. Bookings still can not be made by fax, email or SMS text messaging;
Refusal of taxi operators to accept a booking for an accessible vehicle. Fingleton (1997, Executive Summary, point 10) refers to this as 'cherry picking' (refusing less economic fares). This is further complicated by an 'inaccessible' complaints process, for example a person with a visual impairments may have difficulties finding out the name and badge number of the driver;
Lack of training and awareness on the part of drivers as to the requirements and safe handling of passengers with disabilities;
Safety concerns, for example wheelchair not being adequately secured.
Complaints about the non-professional approach towards people with disabilities by taxi drivers;
Difficulties for people with visual impairments in hailing taxis because of their lack of visibility;
Experience of communication difficulties, for example no pen and paper available when communicating with people with hearing impairments.

Recommendations

In this short submission, the NDA would like to highlight a number of recommendations in relation to the development and maintenance of a regulatory framework for the control and operation of small public service vehicles.

Market Performance
Several reports have commented on the lack of available accessible taxis. The report on the quality of Dublin's city-centre taxi service undertaken by the Centre for Urban and Regional Studies in Trinity College Dublin (2001, p. 15) raised this as an important issue: 'Broadly, it would seem that the main negative implication of the low proportion of accessible cabs overall (11%) is that the general service at peak times in the city centre is irregular and unreliable'. The 'Toward an accessible taxi service for all' report (2004. p. 65) comments that during their consultation 'time and again we heard that the number of wheelchair accessible taxis available at peak times does not meet current demand'.
Figures from the UK (Oxley and Stahl, 2001) show that more than 70% (22,000) of all of the purpose-built taxis are wheel-chair accessible (Metrocab or LTI vehicles). This represents a total of 30% of the total fleet.
The NDA recommends the phased introduction of accessible vehicles. All new licenses issued should be on the basis that the extra vehicles are accessible to all people with disabilities in accordance with international standards, regulations and best practice (see also section 4 below).
In order to achieve this aim, the Commission could either (1) recommend to the Department of Finance to provide financial incentives (such as appropriate relief from VAT/Excise Duty to operators) to encourage and facilitate the changeover, (2) impose a mandatory requirement that all new licenses are issued only to fully accessible vehicles and/or (3) maintain the dual standard of taxi licensing with a concessionary license for fully accessible taxis.
The NDA prefers the mandatory order policy, as was suggested by the Commission on the Status of People with Disabilities in 1996. The Commission recommended to attach mandatory conditions to new licenses, in particular in relation to training.
In the United Kingdom and Scotland a number of licensing authorities have decided to implement mandatory licensing arrangement. In Edinburgh, since January 1997 all taxis in Edinburgh have to be equipped to carry a wheelchair user, as part of the licensing conditions.
Institutional Arrangements
A significant number of institutions have a role to play in the administration of taxi, hackney and limousine market. The Commission will play a crucial role in reforming the entire cab system in Ireland.
One of the key barriers for people with disabilities is the inaccessibility of the environment, such as taxi ranks, kerbs, and signage.
Local authorities need to ensure that taxi ranks are fully accessible and regular access audits take place to assess the situation.
The NDA recommends that the monitoring and enforcement mechanisms should be improved and streamlined.
Fare Setting Procedures
Passengers with disabilities should not be subject to additional charges for the transportation of aids to mobility e.g. wheelchairs, crutches, walking frames etc. nor for any specific assistance or service provided by the driver - e.g. positioning of ramp, fixing restraints etc. Similarly no additional charges should be made for the additional time required boarding and unloading.
The NDA supports the idea of a uniform fare structure for the country as a whole which should absorb the additional costs for accommodating passengers with disabilities.
Consideration should be given to alternative ways of compensating or subsidising people with disabilities for the incurred additional costs of transport, in the form of an extension to the Free Travel Pass and the development of an integrated ticketing system, for example. This will also work as an incentive to taxi drivers. The Commission could make these recommendations to the Departments of Transport and Social and Family Affairs. The Goodbody Report (2001, p. 35) indicates that 69% of people with disabilities would welcome a voucher-based scheme/initiative.
Quality and Standards
NDA defines an accessible vehicle as one that is capable of carrying passengers with disabilities, including wheelchair users, without requiring a passenger to leave his/her wheelchair to enter, travel in or leave the vehicle. An important implication of this definition is that an on-board ramp is carried at all times or is an integrated part of the vehicle design
The NDA recommends that the Commission for Taxi Regulation would develop standards for an appropriate universal accessible vehicle.
The universal accessible taxi design should have features such as:
Accessible vehicles should enable people with disabilities to board and disembark from in a safe manner.
Accessibility goes beyond just physical accessibility, it should also focus on accessible communication and information. For example, accessible vehicles that are equipped with two way voice intercom systems for communication between the driver and passenger should have an induction loop system installed to facilitate passengers who are hard of hearing and who use hearing aids.
Current legislation (Road Traffic Act 1998) stipulates that fare cards, licence plate and driver ID should be easily seen. However, the specific needs of people with disabilities need to be addressed in order to ensure that a fair service is provided to them. Special arrangements may need to be put in place to particularly address the needs of people with a visual impairment and learning disability, e.g. voice activation when meter is turned on and off.
The vehicle should be equipped with hand-holds in contrasting colour and floor colour contrasting with seat colour, to assist those with visual disabilities to board and alight from the car.
In relation to technical specifications, the Australian Disability Standards for Accessible Public Transport (2002) give as a minimum vertical opening 1400 mm for an accessible taxi, maximum width of 800 mm, allocated space of 800 mm wide by 1300 mm long and a 1 in 12 grade ramp (unassisted) and 1 in 8 grade ramp where the ramp is less than 1520 mm.
Taxis (especially wheelchair accessible taxis) should be easily distinguishable from other traffic.
The NDA calls for an introduction of a Charter of Rights and Responsibilities for all customers of taxi services. See also Appendix 1 for an example of a similar initiative in Northern Ireland. The Charter of Rights and Responsibilities should be clearly visible to all customers and should include the drivers' license number and outline the complaints procedure.
All people involved in the taxi industry (i.e. license holders, drivers, base staff, civil and public servants etc.) should be required to undergo disability awareness and equality training. This training should be a requirement for new license holders and existing license holders who renew their license.
There are a number of important things to bear in mind with disability awareness training:
Training should be equality orientated, focusing on the fact that the custom of passengers with disabilities is as valuable as that of all other passengers and that they must be afforded the same right to travel.
It is essential to involve people with disabilities in the design of the training.
Trainers should have a good track record of delivering effective training.
If the trainers are not people with disabilities, it should be ensured that they have worked extensively alongside people with disabilities, or have been trained by appropriate registered organisations specifically to deliver the training.
The views and experiences of people with disabilities should be heard in the training, however that training is delivered. Courses, for example, could include video footage of people with disabilities discussing their experiences. In printed training material, case studies of people with disabilities and their experiences could be included.
The training event itself should reflect the principles of good access. Training should be held in accessible venues.
People with disabilities still experience numerous difficulties in relation to booking the taxi service. Operators should ensure that all communication is accessible, for example in ordering a taxi, people should be able to use on-line booking, fax, SMS text etc.
Monitoring and Evaluation
Over the years, people with disabilities have expressed a number of specific concerns around the use of a taxi service, such as: safety concerns (wheelchair not being adequately secured); complaints about the non-professional approach towards people with disabilities by taxi drivers; difficulties for people with visual impairments in hailing taxis because of their lack of visibility; the response times for accessible taxis is not always the same as for other taxis and communication difficulties (no pen and paper available when communicating with people with hearing impairments).
However, the 'Towards an accessible taxi service for all' report acknowledges that very few people with disabilities actually complained about the customer service delivered by taxi drivers (2004, p. 74).
The NDA recommends that the Commission establish clear and effective monitoring and redress system. The monitoring system should be enforced and include a number of sanctions, including withdrawal of license and fines.

Conclusion

The above recommendations, if implemented expeditiously, will go some way to meeting the pressing transportation needs of people with disabilities, particularly in relation to accessible transport to venues such as employment and training and hospital.

In summary, the NDA recommends that the Commission for Taxi Regulation, in developing a regulatory framework for the control and operation of small public service vehicles and their drivers, should focus on:

Ensuring that, in due course, the entire fleet is accessible to all people with a disability, within agreed time frames;
Taking steps to facilitate and promote the process of ensuring that taxi, hackney and limousine services are fully accessible by developing and monitoring quality customer service standards and vehicle accessibility standards;
Making sure that all people involved in the provision of taxi services are adequately trained and adequately respond to the needs of all passengers, including people with disabilities;
Establishing an effective and fair system for customer feedback and complaints monitoring and redress.

The NDA views the establishment of the Commission for Taxi Regulation as a key step towards the integration of people with disabilities into the mainstream of society.

The NDA would welcome the opportunity to further assist the Commission in the development of quality regulations of small public service vehicles and their drivers.

Page last updated: 01/12/2009