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

Email to drivetime today.

Mary, when I was in school I was always told there are 32 counties in Ireland.

I,m sick of being told that people shopping up north are unpatriotic by Fianna Failers.

The government has contracted companies up there to provide quangoservices, moyah as part of their contribution to the Peace process, in reality it,s because the wages are lower.

I wonder will Minister Dempsey act in a totally patriotic manner when it comes to sacrificing more jobs from Aer Lingus?

BTW i,m in the private sector, and it,s about time this government were stood up to, maybe next time the unions could possibly persuade the private sector to go out with them.

They should ask their social partners IBEC to sanction their staff participating in the next day of protest.

Regards

John Fitzpatrick

Secret report

Dear Ms Doyle

I would appreciate if you could forward me a copy of the PA Consulting report titled Review of the National Maximum Taxi Fare, October 2008, along with the terms of reference required to produce this report.

I understand you might deem this report confidential on the basis that it is commercially sensitive.

As an Irish taxi operator, I believe that I am entitled to see the report to analyse and understand why my fares are set at the current rates. As I am part of the industry I should not be excluded from analysing this report, as I can assure you any commercially sensitive information contained in the report will remain confidential.

Regards

John Fitzpatrick

To the Minister for Transport

Dear Minister Dempsey

I understand you appoint people to the Taxi Advisory council.

I would like to ask, why, only groups with vested interests, are included, while the vast majority of Independent Taxi Operators are deprived of the opportunity to participate in this process.


Yours sincerely

John Fitzpatrick

The office of the Taxi Commission

Ms Kathleen Doyle
Commission for Taxi Regulation
35 Fitzwilliam Square,
Dublin 2.

Dear Ms Doyle

I feel I have to object to a comment you made to the Transport committee in an attempt to dismiss concerns about driver fatigue being suffered by taxi drivers in Ireland today. In particular where you state they are resting when they are on taxi ranks. My experience is that taxi driving has become the most stressful job that I have ever experienced. The number of jobs I’ve had are substantial and quite varied ranging from the clothing manufacturing trade, to building sites, Lorry driving, scrap metal yard, demolition, car dismantling, and as the managing director of a soft furnishings manufacturing company for fifteen years.

Never have any of those jobs measured up to anywhere near the same levels of stress and anxiety levels that I suffer every day driving a taxi.Regarding us resting at taxi ranks. If I could get on to a taxi rank I would have time to rest, you are waiting that long for a job, but the real reality is, I can’t get on to taxi ranks, and on the odd occasion that I do I spend my time almost fretting for the car in front of me to get a passenger so that my time queuing is nearly up. I watch the body language of people walking around the rank trying to determine who is headed for the first car. I constantly check the radio to try to determine if there is work in a different area. I use a mobile data terminal which means I can’t move away from the car, in case I miss a radio job, which means in reality I can’t even stretch my legs. I am basically in my car from the time I start until the time I park it outside my home.

When I can’t get on to a rank I spend my time driving around from area to area checking the radio, watching out for potential passengers on the streets and a new hazard I have to watch out for is the Gardai, in case I pull in at the wrong place, or forget to indicate, or some other infringements of the rules of the road, which can land me with a hefty fine.

I know you can not do anything about the lack of rank spaces or the attitude of the Gardai, but you should be much more knowledgeable when you speak about a serious issue like taxi driver fatigue. It’s not just simple tiredness, it’s also the stress and anxiety that taxi drivers suffer every day are affecting our health.

I know some people constantly say if it’s so bad then get out, the facts are I can’t. I owe too much money in respect of my investment in what I thought was a stable industry, thus I will have to suffer my stress levels adversely affecting my health.

I don’t have the luxury of limited liability which would allow me to liquidate the company and its assets (an issue I addressed to your predecessor, but alas to no avail) and then I could walk away and leave the debts behind without any worries.

I would also qualify for a Social Welfare payment. None of these options are available to me as a small business operator in Ireland of 2009.I trust you will treat the issue of driver fatigue and stress with a bit more concern for those of us that are suffering from it every day.

Another concern is your statement that the drivers are not availing of the opportunities available to us, in relation to affiliating to despatch companies. I’ve always been a customer of a despatch company and presently I am with the largest despatch company in Ireland. This company constantly uses a very expensive and extensive advertising campaign, national television and radio ads, billboard ads, bus advertising, leaflet drops, key rings, etc, all in an attempt to get more passengers for the drivers. Some of the other larger companies are doing the same. If they needed more drivers, then why would they bother to spend huge sums of money trying to attract more passengers? The fact is they need more passengers not drivers.

Again I trust you will reconsider your opinions on this matter. The facts are, we are all trying as hard as we can.

The last issue I would like to raise with you is the cost of a taxi licence. Justice Murphy’s judgement removing the entry barriers stated that local councils could only charge an administration fee of £100 for the issue of a taxi licence, and he ordered that all wheelchair taxi owners to be refunded any sum over that amount they had paid.

Can you tell me why the commission is allowed to ignore this ruling when the local authorities had to abide by it?

Regards

John Fitzpatrick

Sent to Gerry Ryan RTE2fm

Gerry you may be interested in my blog entry re your interview with Ms Doyle. It,s clear from the interview to me, the reason the taxi industry is in such chaos is that Ms Doyle has no real understanding of what her job is, and whats really annoying is that she went on your programme and tried to convince the taxi operators in Ireland that she has their best interest at heart. At this point she is trying to get us on her side. Well let me tell her and you it,s too late, the Commission for Taxi Regulations days are numbered.

Regards

John Fitzpatrick,




http://dublintaxies.blogspot.com/2008/10/taxi-regulator-from-different.html

Letter to the Irish Times

Madam

It strikes me as a voluntary unpaid director of a credit union that the financial regulators office can police small financial institutions such as credit unions with great rigour and efficiency, but it can not do the same to large commercial companies such as the banks.

As volunteers we work long and hard unpaid to comply with IFSRA regulations and we welcome the scrutinising that is involved to protect members interests, however as unpaid volunteers we would prefer not to have to do this extra work, but we do it in the interest of our members also our commitment to the ethos and principles the credit union movement in general.

As a director of a regulated company (a credit union) and also as a taxi driver to earn my living, it strikes me that compliance with regulations from the state are only for little people. As usual compliance for big companies is subject to their strength to avoid and manipulate the regulators.

As usual in Ireland, its one law for the rich, and a different one for the poor.

The admission today by the NRA, that their system will always only be 98% accurate, and with no means of independent appeal, is another example of the state protecting itself against the ordinary person.
As a taxi operator it amazes me that non civil / public servants can put taxi drivers out of business for fairly trivial reasons, but the IFSRA staff can’t put banks out of business even for serious breaches of regulations.


What we need now is a regulator of regulators.

Regards
John Fitzpatrick