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 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:


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.


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:

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.



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