Submission to the Commission for Taxi Regulation on the National Review
of Taxi, Hackney and Limousine Services and Vehicle Standards
1st April 2005
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
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.
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
- 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
- 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
- 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
- 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
- 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
- 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
- Trainers should have a good track record of delivering effective
- 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
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
- 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
National Disability Authority