PWD ACT has circulated the Terms of Reference to its Organisational members and to persons known to it to have a longstanding interest in the provision of services for people who use the WATS taxis. PWD ACT also attended the preliminary consultation for special needs passengers held on Tuesday 10 February 2015. This response is a preliminary response only. A Full response will be provided in response to the Discussion Paper to be released later this year.
PWD ACT notes that the Terms of Reference focus on the development of an appropriate regulatory framework to regulate the new digital public alternative transport booking services entering the personal transport market. These new entrants are ride sharing services such as Uber and Go-catch which use GPS and mobile phone technology to bring together drivers and people wanting rides. These services raise a number of potential problems for people with disabilities. People with disabilities use conventional taxi services because the regulated nature of the services means that they can be reasonably assured that the driver is a reliable person who will not harm them and is a person who has undergone appropriate training including disability awareness training. They also know that there is a complaints system to support them in the event that a driver or the taxi company does not provide an appropriate level of service or engages in misconduct towards the passenger. If the ACT Government has to permit these new operators to provide services in the ACT, they need to ensure that the drivers are subject to similar regulatory regime as to those which apply to current taxi drivers and that companies are also subject to similar regulatory regimes as apply to current taxi companies. The benchmark for evaluation of the taxi service and the proposals for regulation should be whether people with disabilities receive a taxi service which is timely, safe and equal to the taxi service received by members of the community. Additionally, the taxi service should be evaluated against the Disability Discrimination Act Transport Standards applicable to taxis.
The agenda for the Stakeholder Consultation Meeting included a number of questions about changes in the effectiveness of WATS services since the introduction of the Centralised Booking Service in 2013. PWD ACT does not have the information necessary to answer these questions. The ACT data suggests that the service has improved. However, people with disabilities and workers in the disability sector continue to tell us that taxi services available to wheelchair users and other people with disabilities are not equivalent to those available to the general community in terms of ease of booking and timeliness. There is still great variation in driver service and quality of WATS vehicles. The new regulatory regime should use the combination of smart card technology and GPS tracking capability to record and monitor and provide reliable data on the effectiveness of WATS services.
At the Stakeholder Consultation Meeting PWD ACT made the point that we have put a lot of effort in getting the level of service provided by operators of taxi services, including WATS, to its current level. PWD ACT would not want to jeopardise these hard won gains in service quality lowering current regulatory standards to accommodate these new providers of personal transport services.
PWD ACT suggests that in addition to the Discussion Paper the Review should include a short easy to read and easy to complete survey of taxi users. This survey should be specifically sent to all holders of TSS Taxi Subsidy Cards.
PWD ACT would also assert that if digital alternative transport booking services are introduced in the ACT there is a need for a targeted educational campaign for people with disabilities to enable them to both use these services effectively and in a way which minimises their exposure to harm and exploitation.
PWD ACT welcomes the inclusion in the Terms of Reference relating to compliance among existing and new drivers and operators with the Disability Discrimination Act Transport 2002 (Cth) PWD ACT suggests that a survey be designed and implemented to gauge the views of taxi users on this matter. PWD ACT also asks the review to measure compliance against the compliance Schedule in the Standards.
Finally PWD ACT asserts that there is a need for stronger monitoring of taxi services by both the industry and the regulatory bodies including Territory and Municipal Services and Transport. There is also a need for greater monitoring of community transport providers to ensure that recipients of these services are getting an appropriate service.