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