Action for Public Transport (NSW)

www.aptnsw.org.au

PO Box K606, Haymarket NSW 1240
actionforpublictransport@hotmail.com
24th March 2013
Dr Peter J Boxall AO, Chairman
Independent Pricing and Regulatory Tribunal of NSW
PO Box Q290, QVB Post Office NSW 1230
Level 8, 1 Market Street, Sydney NSW 2000
T (02) 9290 8400 F (02) 9290 2061
www.ipart.nsw.gov.au
Dear Dr Boxall
Review of maximum taxi fares to apply from mid-2013

Action for Public Transport (APT) is a transport consumer advocacy organisation, funded by subscriptions and donations from members. APT’s primary concern is the effect on passengers, and not the effect on taxi plate values, return on investment or drivers’ wages.

In response to your Issues Paper dated February 2013, we consider that a small increase in taxi fares would not be unreasonable.

Most people use taxis rather infrequently, but almost everybody needs them some time. There are people with cars who have a few drinks; or people who choose to live without cars, and will generally use public transport, but who sometimes need quick personal transport.

Although taxis are provided as a commercial service, as a general principle they should be treated as part of the public transport system. This would mean:

Regarding IPART’s specific concerns with the level of fares:

Answers to specific questions in the IPART Issues Paper:

6 Should we consider introducing an additional peak surcharge on Friday and Saturday nights with a corresponding reduction in other fare components? At what level should it be set?
We would recommend no additional surcharge – in fact reduced group fares to more distant suburbs, as in Melbourne, should be applied.

7 Should we consider removing the night surcharge on Sunday to Thursday nights?
Yes. The argument (p.31) that passengers at these times can afford to pay extra seems insensitive. If as suggested there are more taxis on the road than required on these nights, this would then be a supply-and-demand adjustment to reduce these numbers.

8 Should the flag fall be increased in combination with a reduction in the distance and waiting time charges?
We think not. With the philosophy as stated above that taxis should be treated as other modes of public transport, it is probably better that shorter journeys remain proportionately cheaper. Current short-distance passengers may be among the more disadvantaged taxi users.

10 Are the booking fees set at the right level relative to other fare components?
The booking fee component should probably be reduced (i.e. even at cost of increasing distance charges), and possibly as suggested on p.38 private booking agents (including mobile phone apps whose use is sure to grow) should be free to choose their own levels.

12 Should taxi meters be linked to e-Tags so that tolls do not need to be manually added by a driver at the end of a journey?
Yes

13 Should passengers be charged a toll on northbound trips across Sydney Harbour?
Yes – however the toll charged to southbound passengers should be reduced (which might demand some special programming of meters given the answer to question 12).

16 Should the process for setting urban and country fares be the same as that used for Sydney fares?
No – it appears from this paper that the conditions for taxis in regional and rural areas are different.

We would be happy to elaborate on these or other aspects if requested.

APT has no objection to this submission being made public.

Yours faithfully,


Allan Miles
Secretary
Action for Public Transport (NSW)


For reference purposes, we attach a list of questions from IPART’s Issues Paper. Review of maximum taxi fares to apply from mid-2013 1.5 What submissions should address The issues on which we particularly seek comment from stakeholder are highlighted throughout this paper. For convenience, these issues (and the page on which they appear) are also listed below:
1 Would you support reducing fares by 2.5%? 20
2 Would you support a decision not to increase taxi fares this year?20
3 Would you support indexing fares by the Consumer Price Index (CPI)?21
4 Would you support the Taxi Cost Index approach?24
5 If we decide to retain the TCI approach, should different inflators be used for labour costs and annual licence costs?24
6 Should we consider introducing an additional peak surcharge on Friday and Saturday nights with a corresponding reduction in other fare components? At what level should it be set?31
7 Should we consider removing the night surcharge on Sunday to Thursday nights?32
8 Should the flag fall charge be increased in combination with a reduction in the distance (per km) and waiting time (per hour) charges?36
9 If you support changes to the balance between long and short distance fares, which of the three examples outlined in section 4.2 do you prefer?36
10 Are the booking fees set at the right level relative to other fare components?38
11 Should booking fees to continue to be subject to a regulated maximum?38
12 Should taxi meters be linked to e-Tags so that tolls do not need to be manually added by a driver at the end of a journey?39
13 Should passengers be charged a toll on northbound trips across Sydney Harbour?39
14 Should the maxi taxi surcharge be levied as a dollar amount rather than a percentage loading on the metered fare?41
15 Should urban taxi fares continue to be the same as Sydney taxi fares?43
16 Should the process for setting urban and country fares be the same as that used for Sydney fares?44
17 If we decide to use a modified Taxi Cost Index to set Sydney taxi fares, should the same changes be made to the country Taxi Cost Index?44
18 Are changes required to the fare structure (individual fare components) in country areas?44