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Part D – Understanding and improving industry performance (PDF ...

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Some respondents argue that the market concentration<br />

of recent years has also had a negative effect on the<br />

quality of taxi services more broadly, as reflected in the<br />

comments from one operator/driver:<br />

In the last eight years, we have gone from multiple<br />

smaller companies to two companies running the taxi<br />

<strong>industry</strong> … this has impacted the integrity of the<br />

<strong>industry</strong>: more companies meant more competition<br />

which then in turn meant customer satisfaction. 9<br />

Others argue that, as NSPs receive no direct benefit or<br />

income from their booking <strong>and</strong> dispatch services (<strong>and</strong><br />

have their income guaranteed by m<strong>and</strong>atory affiliation),<br />

they have little incentive to improve service quality.<br />

CabFare’s submission to the inquiry reflects these<br />

concerns:<br />

The desire to improve st<strong>and</strong>ards <strong>and</strong> to require<br />

taxi operators to be affiliated with a NSP network,<br />

when combined with the concentration of NSP<br />

ownership, has encouraged an environment of<br />

anticompetitive behaviour. 10<br />

Additional concerns relating to competition <strong>and</strong> affiliation<br />

raised with the inquiry include:<br />

• The bundling of services by the large NSPs (such as<br />

car financing <strong>and</strong> in-car technology), which means<br />

that operators must pay for services they perceive<br />

they do not require <strong>and</strong> makes it difficult for new<br />

entrants in the NSP market to gain a critical mass of<br />

affiliated taxis<br />

• The costs incurred by operators if they wish to move<br />

from one NSP to another.<br />

Concerns about market concentration <strong>and</strong> m<strong>and</strong>atory<br />

affiliation are not shared by the Victorian Taxi Association<br />

(VTA), which argues that NSPs operate in a competitive<br />

environment that leaves room for other business models,<br />

such as secondary networks. The VTA argues that<br />

the number of NSPs reflects the reality of commercial<br />

processes <strong>and</strong> the size of the market in which they<br />

are operating, <strong>and</strong> that their investment in subsidiary<br />

businesses benefits the <strong>industry</strong> by providing more<br />

efficient <strong>and</strong> <strong>industry</strong> specific services.<br />

A key reason that Victorian taxis are better equipped<br />

than those in other jurisdictions is because Victoria’s<br />

NSPs are large enough to invest in real goods <strong>and</strong><br />

services that benefit the customer. 11<br />

More broadly, the VTA argues that the taxi <strong>industry</strong><br />

faces a high level of internal <strong>and</strong> external competition<br />

at all levels: drivers have to compete with other drivers<br />

for fares; operators face competition for licence<br />

assignments; <strong>and</strong> the <strong>industry</strong> faces external competition<br />

from hire cars, community transport <strong>and</strong> providers of long<br />

term car parking at Melbourne Airport.<br />

The Essential Services Commission, the Department<br />

of Treasury <strong>and</strong> Finance (DTF) <strong>and</strong> others point out<br />

that while a move to remove m<strong>and</strong>atory affiliation (or to<br />

introduce greater contestability into the NSP market)<br />

may have benefits in terms of service innovation<br />

<strong>and</strong> downward pressure on fares, it will need to be<br />

accompanied by reforms to ensure that safety <strong>and</strong><br />

universal access objectives are met. DTF also notes:<br />

Recent developments in economics, particularly when<br />

combined with modern communications, spatial<br />

referencing <strong>and</strong> information technology, may provide<br />

the ideas <strong>and</strong> the tools to help develop efficient<br />

markets in the sector. 12<br />

Engaging the <strong>industry</strong> on networks<br />

In November 2011, the inquiry released a discussion<br />

paper on networks titled Improving taxi booking services<br />

for customers, drivers <strong>and</strong> operators. The inquiry received<br />

only three submissions in response to this paper, two of<br />

which were confidential.<br />

In contrast, the issues of m<strong>and</strong>atory affiliation <strong>and</strong><br />

the <strong>performance</strong> of NSPs has been the subject of<br />

considerable debate through the inquiry’s social media<br />

channels. One Facebook contributor notes:<br />

The taxi booking companies are a racket. They add<br />

NO value. Ever since the early eighties the taxis have<br />

been forced to operate under radio control from an<br />

approved depot. Can ANYONE tell me why this<br />

licence condition was introduced? It wasn’t for the<br />

benefit of the owners <strong>and</strong> it sure as hellfire wasn’t<br />

for the benefit of the poor driver. The booking<br />

companies CANNOT guarantee a service level.<br />

They should be abolished. 13<br />

The inquiry initiated conversations with the VTA <strong>and</strong> the<br />

major NSPs in Melbourne on the issues raised in its<br />

discussion paper. These conversations were helpful in<br />

developing the inquiry’s proposals for reform.<br />

9 Anonymous submission to the Taxi Industry Inquiry, SS108<br />

10 CabFare, Submission to the Taxi Industry Inquiry, SS92, p.11<br />

11 VTA, Submission to the Taxi Industry Inquiry, SS60, p.13<br />

12 Department of Treasury <strong>and</strong> Finance, Submission to the Taxi Industry<br />

Inquiry, SS179, p.5<br />

13 Kevin V. Russell, comment on Taxi Industry Inquiry Facebook page,<br />

25 March 2012<br />

<strong>Underst<strong>and</strong>ing</strong> <strong>industry</strong> <strong>performance</strong> CUSTOMERS FIRST 225

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