I've pasted this from last months Taxi'talk', it was a presentation from SCATA to Chelmsford Councillors.
Half way through reading it I lost the will to live, but it came to me as no surprise that Chelmsford later de-limited.
What's the rush?
IN the light of reported hasty moves by local authorities towards delimitation arising from recent Government declared policies for the taxi industry, the Chairman of Chelmsford Taxi Association, Garry Millar, has submitted to TAXI "talk" the text of the written address to the Chelmsford Borough Council, delivered by Doug Friswell, Secretary of SCATA, the Southern Counties Alliance of Taxi Associations, in support of the Chelmsford Association's Campaign to oppose the imminent threat of that Council to apply full-blooded delimitation policies along with the mandatory imposition of a 100% Wheelchair Accessible fleet.
Mr. Millar says that he believes that the content of this address should be delivered in full to all local authorities across the UK by local representative bodies of the taxi industry, suitably adapted to the circumstances in each locality. In this, he believes the address comprehensively appraises the likely outcome of such Government proposals and the necessary requirement for all local authorities to "take their time" to consider the validity of the contents of this address and the likely negative outcome of the Government's plans for this industry that it lays bare.
The address: 2nd November, 2004:
This address is delivered as a supporting statement to the previously delivered SCATA document encompassing SCATA's submissions to the Deputy Prime Minister in matters of delimitation and Wheelchair Accessible fleets.
Mr. Chairman I must at first express SCATA's thanks to the Councillors of the Chelmsford Borough Council for agreeing to receive the dissertations of the SCATA Movement in the matter of the Chelmsford Taxi Association's plea to the Council to retain a numerically controlled entry of taxi vehicles into its fleets.
To circumvent further debate in this one particular instance, I am obliged to make clear that the Southern Counties Alliance of Taxi Associations declares its full support of the policy document laid before you on behalf of the Transport and General Workers’ Union by its spokesman Mr. Peter Kavanagh, in support of the Chelmsford Taxi Association's plea.
It can be said that in the view of the SCATA Movement, the T&G's presented document is a sensible response to the present proposed unwelcome statutory developments that are now occurring within the National Taxi Industry.
The T&G's document offers in SCATA's view, a holding response being close to a status quo that in the next two years will enable a hoped for united response of the representative bodies of the whole taxi industry to lay before Government a cohesive plan, comprehensively formulated that will reflect a correct evaluation of the current structures of the industry and the required measures that must be applied to its regulatory procedures where it is shown to fall short.
It is regrettable that such forethought has not been revealed in the "hotch-potch" presentations of the Office of Fair Trading that in its ideological aspirations for the development of a free laissez faire market, it has chosen to take into account the questionably declared wishes of the national populace without due regard to the effects of such policies upon the providers of such services, or indeed, to the normal procedural requirement of Ministries, that all reformulation of matters of established regulation involving finance, must be accompanied by a "cost impact" assessment of the effect of such changes upon all those involved. This is notably absent from the OFT's report.
It is indeed, in SCATA's view, amazing that such a lop-sided presentation of the proposals of the OFT should have been taken up by the DTI and announced by the DTI's Secretary of State Patricia Hewitt on the 18th of March, 2004.
SCATA believes that the OFT's proposals can be regarded as nothing more than a "wish list" of what it supposes to be the public's required needs without due regard to the consequences of its application upon those required to provide it, or the likely negative effects upon the viability of taxi business that upon their exit from the trade as a result of OFT proposals, may actually reduce the availability of taxi services within the industry that the council is morally bound to maintain.
Of "Delimitation" of entry!
Both national and international examples of delimitation of the number of vehicles entering taxi industries have been available to the OFT in its presentation and it is a matter of dismay that none have been revealed in the submission of the OFT's case.
Whether this is an example of its inept evaluation of the circumstances prevailing, or a deliberate attempt to evade the revelation of circumstances that would harm the OFT's case is a matter of conjecture. But the fact that such situations exist at all must be weighed against its proposals, and in the absence of such declarations it has clearly not been possible for Patricia Hewitt to take into account the likely full impact of the OFT's proposals prior to her declaration of the Government's adoption of the OFT's flawed documentation.
Matters that the OFT should have conveyed to Patricia Hewitt!
Did it report that:
In the US City of Atlanta in the State of Georgia, a City with a population of half a million, the City Council found it to be necessary, following "Delimitation,” to re-regulate entry of vehicles into its fleets in the face of "Cut-price" Taxi Wars, consequent depletion of standards of maintenance and presentation and the lowering of geographical standards of a knowledge of this City by the transient invasion of part time drivers entering the business to "top-up" depleating wages from their normal workplace?
Did it report that:
Anecdotal evidence of people from New Zealand who are now reporting the same emerging situation as Atlanta arising from that country's entry into taxi delimitation of entry policies?
Did it report that:
Evidence emerging from T&G Research Departments and known of within the trade had revealed that some at least six local authorities have all in the recent past applied delimitation policies only to find it necessary to retract and return to previous controlled entry by virtue of the very same consequences already illustrated in this address?
Did it report that:
In 1980 the avant-garde innovators of laissez faire open market policies, "The Association of District Councils", had brought to the Miscellaneous Provisions Act, 1976 an edict that local authorities that had been applying numerical controls of entry of Private Hire vehicles into their districts were operating "a restraint of trade" which could not be applied from thereon within the 1976 Act?
Did it report that:
The Miscellaneous Provisions Act 1976, that had for four years been no more than an innocuous regulatory Act for the provision of Private Hire services, had by the mandatory enforcement of the Association of District Council's edict, become at once a threat to the Taxi industry through enormous increased competition through the imposed mandatory policy of delimitation that evidence from the National Office of Statistics 2,000 has clearly revealed to be a consequence of "delimitation", and upon which I trust your attention will be engaged in the following reference.
Did it report that:
The overwhelming increase of vehicles attributable to the 1976 Act has been borne out in the report of the DETR's "Transport Statistical Bulletin - 2000" which revealed an increase in the number of taxis during 1985 to 1999 to be from 18,900 to 42,100, an increase of 23,200, with an increase of Private Hire over the same period from: 25,800 to 75,800, an increase of 50,000 Private Hire vehicles when there were only some 60,000 Hackney Carriages within the UK community.
This being an increase of about 180% of previously serving vehicles for a population that had increased by no more than 4.7% over the same period?
Did it report that:
Factual and anecdotal evidence had shown that the workload of individual vehicles had decreased by probably 30% due to the influx of that 50,000 additional Private Hire vehicles into the market.
Did it report on any of the above matters? "NO".
What of the effects upon the taxi industry of the OFT's biased appraisal of consumer needs alone?
In its obsession with consumer requirements the OFT has evaded, deliberately or otherwise, being a matter of conjecture, any assessment of the earning ability of the drivers of the National Fleet.
In his initial approaches to me to support the Chelmsford Taxi Association's approaches to you, the Councillors of Chelmsford, Chairman of the Association Mr. G. Millar implied in his remarks that the commission might be a little more difficult in Chelmsford than in other areas because, he said: "In comparison with those other areas, Chelmsford could be, in colloquial terms, interpreted as being 'A nice little earner!'"
Councillors, SCATA believes that workers anywhere within the taxi industry, in comparison with "blue collar workers" in most UK manufacturing or service industries, have a long way to go before their work opportunities avail them of any such rewards.
I am informed that average income achieved by owner drivers working within the Chelmsford taxi fleet amounts to an approximate gross figure of £600, secured by working ten to twelve hours or more a day, or approximately 70 hours in any given week.
SCATA is aware from reports from its affiliates that overheads arising in the work of a taxi can be anything from twenty to fifty per cent of metered returns from fares.
In taking a middle assessment of 33% of the Chelmsford's drivers £600 gross income, it would seem that net income in Chelmsford for its taxi drivers is probably no more than £400 for a shall we say a 65 hour week. Or £6.15 an hour before personal taxation, pension and sickness contributions.
One pound thirty above the minimum earnings level is hardly a significant wage where average wages for men across the UK in accordance with the Office for National Statistics, Social Trends (2004 edition) is now £12.00 an hour.
But the Office of Fair Trading still sees fit to recommend that potential clients should attempt to negotiate reduced fares from taxi workers earning incomes probably far below the average earnings of those seeking to hire his or her services at reduced rates!
A further extension of hours: "An unsafe proposition"!
The OFT's proposals to the clients of the taxi industry to haggle for a reduction of fares can logically only lead to a need for the taxi owner or driver to further extend his or her hours to compensate for his reduced income.
SCATA believes that the hours being currently worked by taxi drivers across the UK are now bordering upon unsafe margins, and to create the need to further expand their presence on the road should be clearly unacceptable to a responsible controlling local authority.
It doesn't stop there! The Council must clearly consider the consequent further congestion of roads and all that that situation can bring, together with the environmental considerations of further pollution.
Effective stewardship.
Despite that which some might say are the listed shortcomings set down herein that the Council has yet to face, the Council must be congratulated upon its stewardship of the affairs of its taxi industry thus far, and much will depend upon its foresight in the weeks to come.
Abdication
In the light of the dedication of Councillors in their commitment to a balanced responsive stewardship in the matter of the services that they would seek to provide, the Government's unneeded intervention is nothing more than an inducement for them to abdicate themselves from the activities they were elected to provide, and is a reversal of the Government's manifesto commitment of devolution of power.
The DTI's statement of the 18th of March, and the options that SCATA believes might be available to the Chelmsford Council.
Despite the worst fears of the taxi industry, Secretary of State of the DTI, Patricia Hewitt's statement on behalf of the Government did not set down immediate mandatory requirements for the delimitation of entry of taxi vehicles in areas of local authority control.
It did however, make firm recommendations that delimitation within the context of the OFT's recommendations to the DTI should be applied wherever and whenever possible.
In the light of the shortcomings of that which SCATA believes to be a flawed OFT document that has been laid before the DTI, the urgent pleas of the DTI to conform with its recommendations is not a possible recommendation that SCATA could make to others to duly fulfill.
Whilst the DTI is insisting that those local authorities that intend to continue with there previously adopted policies of controlled entry must submit to the general public and the Government their reasons for maintaining such a stance, it has made clear that there will be no mandatory requirement at this time to comply with those recommendations.
In recognition of the Government's apparent conciliatory approach to this situation, SCATA believes that there is a measure of sophistry in its statements when it says that it will take no action against local authorities maintaining numerical entry controls. In this SCATA believes that the reason for its insistence on the submission of explanatory reasons for the rejection of its recommendations can only be that those submissions will be part of a monitoring operation to verify the need for its further intervention through Regulatory Reform Orders as contained within its Regulatory Reform Action Plan of 2002 if delimitation does not move forward at the pace it requires, when it will then intervene through Clause 1.147c of the Act, allowing the Government to implement mandatory orders without further consultation for the delimitation of entry of vehicles into the taxi industry. But this is not likely to be applied until beyond 2006.
In recognising that this is clearly a continuing existent threat to the rights of councils to administer through their stewardship important aspects of the management of services for the populace that accorded to it the democratic right to manage its affairs. It does also give time for local authorities to consider the best outcome of the present choice of options before it in the matter of delimitation or not through the ensuing two year period.
In simpler terms there is no haste.
Who will leap the abyss.
Since the DTI declaration of its recommendation to delimit vehicle entry. The facility previously available to those local authorities in the UK that had tried to implement delimitation policies and ultimately pulled back from such enactment some time after taking the leap, SCATA believes that this facility is not likely to be available to those who would "now" like to adopt such an approach. Because, since the DTI's statement saying that it would not oppose continued controlled entry at this time if adequate explanatory literature was laid before it, Councillors will readily recognise that although there is nothing set down to the contrary, it is unlikely that the Government would tolerate a Councils return to controlled entry once it had made the leap across the abyss to delimitation.
Clearly, there will be no going back!
SCATA believes that the T&G proposals laid before you for a virtual status quo, maintaining controlled entry on the evidence of proven demand is a matter that would not be challenged by the Government for the next two years.
An adherence to such a policy accords the Council the opportunity of moving back from the abyss and making a jump from which there is likely to be no return, and to await the development of further negotiations in the matter of the possible amendment of the terms of this ill-judged Government manoeuvre that could damage the adequate provision of the services of this industry.
Douglas V. Friswell,
Secretary for the SCATA Movement.
2nd November, 2004
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