Regulators History of Ignoring Good Ideas

Regulators History of Ignoring Good Ideas

Mr. James Holgate

General Manager of the Taxi and Hire Car Bureau

Department of Transport

Locked Bag 5310

Parramatta NSW 2124

Re: Suggestions in draft of Passenger Transport (Taxi-cab Services)Regulation 2001

Dear Mr. Holgate

Thanks for sending us a copy of the proposed draft regulations. Atoutset it appears that many of the proposed regulations are a positive step.Generally, we are supportive of many of them, however we wish to propose some fine tunning as outlined below in order to improve the Service Standard and to stabilize the industry.

Point 17 Information in taxi-cabs After "17 (2)(e)" insert another column before "(f)" "(e)(ii)" a summary of the obligations of the passenger to thedriver.Point 22 Advertisements within or on outside of taxi-cabs

Only the advertisements regarding safety, community good,public education concerning taxi and transport should be allowed butmust preclude commercial considerations.

Point 27 Network Uniforms
Add at the end after "hire" as determined by relevantindustrial instrumentality - i.e. Contract Determination.Point 30 Retention of records and worksheets in relation tooperation of taxi-cab
(b) 6 years instead of 2 years as required under the taxation lawPoint 40 Lost property given to drivers
Add police station as well after " is connected"
Point 48 Use of taxi-cab network

In Principle we do not agree- because it will assist in alteringthe relationship of bailor and bailee to employer and employee.However, consideration may be given for a trial period, providing:(a) Network must follow the procedural fairness and dueprocess of law
(b) Network bi-laws do not affect the civil and industrial right ofthe bailee taxi driver
(c) Same condition as in (a) & (b)

Point 51 Conditions of authorisation to operate taxi-cab network(2) Driver safety
(2)(a) Defines that the workplace (taxi-cab) shall be "safe" and"(2)(a)" becomes (2)(b) ... & so on.
(6) Lost property After a secure storage area add "register, receipt book" and ...
(10) Use of network equipment Due to managerial, and otherwise other manifest technical problems beseting of the networks, this situation of "no destination calling" has become a crucial issue for the taxi workers. Current oppressive industrial conditions have exacerbated this problem further. It is assured that the proposed format would be unworkable unless the Minister for IndustrialRelations genuinely tries to tackle the current anomalies of theNSW Industrial Relations act.

Point 53 Driver of taxi-cab to accept hiring A public education campaign could be initiated for the smooth operation of this section {(a) to (f)} as suggested in point "22".

Point 55 Police officer may direct driver to accept hiring3(b) Is long over due and a step towards the right direction.

Point 69-75 - The general thrust is good. Although it is difficultto enforce however to maximise the efficiency a public educationcampaign on rear of taxi-cab as specified in section 22 could beadopted.We hope that the department of Transport would adopt acautionary approach to the press - release issued by the "taxicouncil" titled "draft new regulations" (also appearing with theirMeter dated July 2001) - and to take a potentially jaundiced viewof it where appropriate.

Sincerely yours

SecretaryNSW CWA