DPTAC response to:
Office Of Fair Trading - Consultation on the Regulation of Licensed Taxi and PHV Services in the UK
Introduction
1. The Disabled Persons Transport Advisory Committee (DPTAC) welcomes the opportunity to comment on the Office Of Fair Trading: The regulation of licensed taxi and PHV services in the UK.
2. DPTAC was established under the Transport Act 1985 to advise the Government on the transport needs of disabled people. Our role was recently extended, on a non-statutory basis, to advise the Government on the built environment needs of disabled people.
3. DPTAC has identified four overarching principles on which to base its advice to Government, other organisations and disabled people. Those principles are that:
- accessibility for disabled people is a condition of any investment;
- accessibility for disabled people must be a mainstream activity;
- users should be involved in determining accessibility;
- accessibility for disabled people is the responsibility of the provider.
4. These principles are the basis of DPTAC's response to the OFTs 'The regulation of licensed taxi and PHV services in the UK'.
General Comments
5. Whilst DPTAC welcomes the opportunity to comment on the consultation paper, we also have to register our unhappiness at the inadequate timeframe given for responses.
6. We are pleased the OFFT consulted disability organisations whilst carrying out their study. However, as the committee with the statutory responsibility to advise the Minister of State for Transport, we are disappointed not to have been consulted as well.
The UK Taxi and PHV Services Markets
7. The report identifies disabled people as using taxi/PHV services more frequently than non-disabled people use. Recommendations made by the OFT must reflect the importance of the taxi/PHV's to disabled people.
8. Currently wheelchair accessibility is varied. Whilst taxis conforming to the Metropolitan Conditions of Fitness (MCF) are accessible, most others aren't. On the other hand, PHVs tend to be inaccessible to wheelchair users unable to transfer from their chair into a vehicle.
9. Wheelchair users only use taxis in areas where hiring accessible vehicles from the street is easy.
10. Although data is unavailable, we suspect the availability of wheelchair accessible taxis is one of the reasons Londoners expenditure on taxis/PHVs is 70% higher than the rest of the country.
11. Not withstanding the above, DPTAC recognise that taxis meeting MCF conditions aren't necessarily accessible to all disabled passengers. Ambulant disabled people especially have difficulty using 'London' taxis and where possible will book a private hire vehicle instead as saloon cars are normally used.
Review of Quantity Regulation
12. Unlike PHVs, taxis are accessible to wheelchair users. Until such time that a completely accessible taxi is commercially available we would like all licensing authorities move towards making their entire taxi fleet wheelchair accessible, as in London and other cities.
13. At the same time, the importance of services provided by PHVs to disabled people, particularly those who are ambulant disabled, must be acknowledged. Until completely accessible taxis are commercially available it is important to maintain the status quo and maintain separate taxi and PHV industries.
14. In principle we have no objection to licensing authorities removing quantity controls from their taxi industry. However, all new licenses should be awarded only to drivers of wheelchair accessible vehicles and licensing authorities must ensure their PHV sector remains viable.
15. We share the reports concerns regarding the safety of unlicensed PHVs.
Review of Quality and Safety Regulation
16. We agree with the reports central conclusion that quality and safety controls should be maintained and effectively enforced.
17. Driver training off taxi & PHV drivers needs improving. Licensing authorities should make undertaking disability awareness training a condition of the licence.
18. Allowing local authorities to impose their own quality and safety regulations will not necessarily raise standards in every authority. Instead there should be a national standard with local authorities retaining the power to set additional conditions to meet local requirements.
Review of Fare Regulation
19. DPTAC supports retaining fare controls - for taxis and PHVs.
20. It is common practice for disabled passengers to pay for their disability by being charged waiting time by drivers, regardless of the cause for the wait. Disabled passengers shouldn't be penalised for taking longer to get into a taxi/PHV than able-bodied passengers and charging this 'premium' should not be allowed.
21. Taximeters & talking metres should be fitted to all vehicles as a condition of licence.
Further Issues that Impact on the Market
22. DPTAC welcomes the Department for Transport's announcement they will begin to implement the DDA 1995 taxi provisions from 2010.
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