Policy on the hoof  (15/1/2004)

Opinion:  A view from Scotland on the uncertain situation in Dundee following the council's partial de-restriction.

Last year Taxi Driver Online reported on the uncertain situation surrounding the future of the taxi trade in Dundee.  In November Dundee City Council removed some of this uncertainty by de-restricting on the basis of new licenses being granted to those willing to operate wheelchair accessible vehicles, but this clarification has arguably led to another set of uncertainties arising.

An initial uncertainty concerned precisely which vehicles would meet the accessibility criteria set down by the council, in particular, the 'will it, won't it' situation surrounding the Fiat Doblo.  While it now seems that the Doblo has been deemed suitable, it is noteworthy that many local authorities will not license this vehicle to carry wheelchairs, and in any case it seems unlikely that it will meet the Disability Discrimination Act specification when it is finally announced - indeed, it is claimed that no currently available vehicle meets the outline criteria.  Thus to comply with the Act vehicles of this type may eventually be disallowed in Dundee anyway.

Another major uncertainty regards whether or not the current taxi fleet will be required to comply with the same accessibility specification as the new plates.  If not, then this seems rather hypocritical from a council apparently keen on equality - the financial advantage of running a saloon is ably demonstrated in other (restricted) locations where a standard plate can be worth several times that of an accessible vehicle plate.  By the same token, it seems unlikely that the problem of illegally hired plates and absentee operators will be eradicated under a mixed fleet scenario - in areas combining restricted saloons numbers and unrestricted accessible vehicle numbers saloon plates can still have a five-figure value, and thus it seems likely that a rental market for saloon plates would still exist in Dundee even with partial de-restriction - if the trade in such areas are willing to buy plates for substantial sums where transfers are permitted, then it seems likely that a rental market would persist in Dundee, even it this was done legally.

Again, however, the 'Doblo factor' is relevant - the cheapness of these vehicles makes it more likely that running a saloon would seem less attractive (at least financially!) thus meaning a higher probability of the absentee plate holders disappearing.

Of course, there is merit on a mixed fleet, particularly given the many people who prefer standard saloon cars and the elderly and infirm who find entering and exiting large vehicles difficult, but surely this should be done on a non-discriminatory basis, and not by the council telling one section of the trade that they must adhere to significantly more costly specifications than another section.

Therefore it must be hoped that the current fleet has not been offered saloon car continuity as a sop, which could conceivably explain the Dundee Taxi Association's decision to drop its legal action regarding the issue of the new licenses.

A related point concerns reports of subsidies which will be paid to the operators of the new accessible licenses.  While such a scheme could be used to provide a mixed fleet on a non-discriminatory basis, this issue is again surrounded by uncertainty - it is claimed that this subsidy will only be available to owners doing a specified number of wheelchair jobs.  This is perhaps unsurprising, since it was apparently the paring down of similar subsidies a few years ago that halved the number of accessible vehicles in Dundee, and to offer £1,500 per annum to 100 new plates (say) would cost the council significantly more than the original subsidies that the council withdrew.  The size of the subsidy also seems surprising given huge disparities in costs of the vehicles apparently meeting the accessibility specification - a £1,500 subsidy for five years would cover almost the entire depreciation of a Fiat Doblo.  To that extent it is unsurprising that at least one member of the public has contacted the local press to complain about the subsidies.

Also uncertain is how the moves in Dundee relate to the Disability Discrimination Act requirement for accessible vehicles.  The proposals in the Act would require all taxis to be accessible, and to that extent Dundee would not comply unless the whole fleet was required to conform to the same specification as the new plates.  Of course, the Act has no current legal relevance as regards wheelchair accessibility, and there was no obligation on the council to do anything at the moment, despite claims to the contrary.  However, the Act merely adds to the uncertainty - while under proposals to implement the Act recently announced by the Department for Transport for England and Wales, a city like Dundee would require all taxis to be wheelchair accessible before 2020, it is not clear whether the Scottish Executive will adhere to a similar timescale or require blanket accessibility.

As usual, this debate is being conducted on the basis of several misconceptions - for example, a letter recently published in the Dundee press claimed that if licenses were only granted to those willing to run LTI TXIIs then they their earnings would not drop because everyone could use them.  This seems a perplexing claim - these vehicles cost at least three times more to buy or lease than the current taxi of choice in Dundee (the Skoda Octavia), consume around twice as much fuel and probably cost more to run in every other regard - and it is difficult to see how earnings could be sustained under these circumstances.

Indeed, if such vehicles were required by every taxi license holder in Dundee then it seems likely that taxi numbers would end up significantly lower than the current level, with much of the current saloon taxi fleet re-licensing as private hire.  Such a scenario is probable even if the cheaper 'Eurotaxis' were licensed, but again the even cheaper Doblo makes predicting the exact course of events difficult - but even allowing for the Doblo factor, the eventual taxi fleet is unlikely to grow to much beyond the current combined taxi/PH fleet.

Dundee City Council's changed approach to these issues is difficult to fathom - for years they seemed unwilling to raise the city's taxi specification above a ten-years-old pint-sized saloon car, and these vehicles were considered to need a protected market to boot.  Now they expect new operators to adhere to a significantly more stringent and expensive vehicle standard while being fully exposed to the rigours of the free market, assuming that there is no bottomless pit of money available to subsidise them.

The more recent uncertainty perhaps confirms the suspicion of policymaking on the hoof.  This is particularly surprising since the Disability Discrimination Act has been on the statute book for nearly a decade, and the availability of accessible taxis has been an issue in Dundee for a similar period at least.  Likewise, the issues of illegally hired plates and absentee operators has been around for at least as long, notwithstanding that the council chose not to highlight the issue until relatively recently.  To that extent it might have been expected that the precise details of any policy change should have been outlined before the de-restriction Rubicon was crossed.

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