Taxi consultation Process.

Dear Sir /Madam

In relation to the current consultation process that your office is overseeing at the moment, I would like to make some observations.

1 The consultation document has a preconceived outcome, as the questions that are posed do not seek to address any of the problems being experirenced currently by taxi operators. In fact the outcome of all of these questions will impose extra costs on taxi operators with no corresponding means to recoup those costs.

2 The whole consultation process is presented in a way that almost specifically excludes or prevents the ordinary taxi operator from participating in the process, and as taxi operators are one of the most important stakeholders in the taxi industry as a whole, there should be an easier way to consult with us. We spend massive amounts of time on taxi ranks looking for work, and most of us go home so tired that we can not participate in any activity other than sleeping, and therefore to sit down and write a written submission would be the last thing any of us would be motivated to do. Writing submissions and opinions are extremely difficult for the best of us, and if you look at some of the writings by paid authors and journalists etc, you can understand how difficult a task, it is for somebody that is not trained in writing these submissions. In all community development training it is taught that official bodies insisting on written submissions is a huge barrier to the participation process. Your office should know and understand this, and should be actively promoting meaningful ways of communicating with all taxi operators. Even the online submission form is designed to limit the participation of taxi operators and would seem it is purposely designed to confuse the issues, (e.g Table 1 below:) or to elicit a specific response that can be interpreted in many different ways.


Table 1


Questions for response
1.1 Do you prefer Option One or Option Two?
1.2 Do you have any views as to the proposed April 2012 introduction date?
1.3 Do you agree that it is only reasonable that all vehicles over 9 years of age receive a 6 month licence period regardless of licence category?
1.4 Do you agree with the concept of an upper age ceiling of 14 years (at licence renewal) for all taxis and hackneys?


Answers to all of these questions, in my case (as a taxi operator), would be subject to the other questions being answered first. Option one or two are very different for taxi operators, but they are also asterisked as (“*Subject to consultation and agreement with the Department of Transport, Tourism and Sport and the Road Safety Authority. “) . Maybe these options should also be subject to agreement with taxi operators.

I also can not understand, why an ordinary email would not suffice, this is clearly a barrier to participation.






3 The real problems in the Irish taxi industry today (affecting both taxi operators and passengers) will not be addressed by any of the issues under consultation.

4 This process actually presumes to know the outcome of Minister Alan Kellys current review process.

5 Most of the consultation paper is concerned with the provision of limousine services, and various other things like crew cabs and their suitability, hybrid vehicles, and new technologies etc. The only items that really affect taxi operators are the age of the car, the size of the car and branding. The blacked out windows are not really an issue.

6 The age of the car. The age of the car is open to debate, as there has been no scientific evidence put forward for consideration. Most taxi operators would suggest that the age of the car does not matter, its the mechanical condition that is important, i.e. You could have a four year old Toyota Avensis with half a million miles on the speedometer, that is mechanically defective, but that legally qualifies under the age system as it is quoted in the consultation paper, and, then you could have a Mercedes E Class car that is fourteen years old with one hundred thousand miles on the speedometer, and that is excluded. For personal safety reasons I,d rather be in the fourteen year old Mercedes instead of the four year old Toyota in these circmstances.

6 The size of the vehicles. Most taxi operators already have a vehicle that exceeds the current and the proposed specifications, so I suppose I would agree with that one as a proposal.


7 Blacked out windows. I do not think any taxi operator would agree with having blacked out windows in a taxi, this is almost dependent on what type of glass is in the vehicle when it is purchased, I do not know of any taxi that have had their glass replaced with blacked out glass, so I presume we would all agree that clear glass would be most suitable.



8 “The Authority is seeking views on introducing a form of distinctive external branding or signage on all taxis to help the consumer better identify vehicles for hire on the street. “
The consumer does not need any help in identifying vehicles for hire on the streets, the current roof sign is more than adequate for this purpose.

9 The rest of the paper is for limousines and to be perfectly honest I know nothing about this industry, so I will not comment on the proposals in the consultation paper, however I would like it if the limousine operators afforded me the same courtesy.

Heretofore the limousine industry have used their influence on the taxi advisory committees thinking, in relation to taxi operations. As they are in a completely different industry it would be more appropriate for them to declare a professional interest and then to leave the meeting, when taxis are under discussion. This is all anecdotal I know, as the minutes of the TACs meetings are private and confidential but either way when anybody is participatiing in a process such as this, it would be good practice, honest and transparent, if they were to declare any commercial or professional interest they have.


I would also like to add something which has nothing to do with your consultation paper, but, as this is being submitted to the relevant official bodies, I want to point out, that the current crisis being experienced by Irish taxi operators has been totally engineered by the agents of the Irish State. Taxi operators did not have any part in the decisions that have us where we are today, and I do not accept the taxi regulators assertions that we took part in the decisions by the participation of the so called taxi representative organisations. They are not, and never have been mandated, by the vast majority of taxi operators in this country. They are equally as guilty, as the taxi regulators office, of mismanaging the situation we find ourselves in today, where a disproportinate number of taxi drivers are commtting suicide as the financial burdens that are placed on them become to much to bear. Thats just for the record, and in my most humble opinion.

Finally and again in my most humble opinion. When you have finished with this charade that you present as meaningful consultation, maybe you could use your time to address the issues that are adversely affecting all legitimate taxi operators means of earning a living and allow us to conduct our businesses with some small level of profitability.


Your sincerely

John Fitzpatrick