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

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The ACCC also noted that West Suburban’s<br />

geographic coverage is largely complementary to that<br />

of Silver Top.<br />

Figure 11.2 Heat map of West Suburban Taxis<br />

pick-up locations<br />

In relation to the supply of taxi depot services to taxi<br />

operators in the metropolitan Melbourne taxi zone,<br />

the ACCC’s market inquiries suggested that there<br />

was limited competition for drivers <strong>and</strong> operators<br />

between Silver Top <strong>and</strong> West Suburban. 56<br />

As the ACCC’s decision in 2009 lacks any further<br />

details, it is difficult to tell what evidence was before it to<br />

distinguish the two decisions. From the statements made<br />

by the Commission, the inquiry surmises that:<br />

• The concept of ‘closest competitors’ is given greater<br />

credence in the second decision, with some weight<br />

being attached to the market positioning of Silver Top<br />

<strong>and</strong> Black Cabs (now 13 CABS).<br />

• In 1995, it was argued that more concentration would<br />

lead to less incentive for networks to compete for<br />

taxi operators <strong>and</strong> that there was little competition<br />

possible for customers given regulated fares <strong>and</strong> a<br />

fixed quantity of vehicles.<br />

• The complementarity of geographic coverage was a<br />

relevant consideration in the 2009 decision, whereas<br />

in 1995 the two firms were seen as competitors,<br />

notwithst<strong>and</strong>ing their strengths in particular<br />

geographic areas.<br />

Figure 11.3 Heat map of 13CABS pick-up locations<br />

Figure 11.4 Heat map of Silver Top Taxis pick-up locations<br />

At face value, the first <strong>and</strong> third points seem<br />

contradictory. The first says that size in the market<br />

(metropolitan Melbourne) is the important determinant<br />

of competition, not geography (even though there is<br />

significant evidence that Silver Top <strong>and</strong> Black Cabs were<br />

stronger in particular geographic regions of Melbourne).<br />

The third says that geographic factors are important,<br />

as West Suburban’s operations are ‘complementary’ to<br />

Silver Top’s.<br />

Spatial analysis of NSP data, for each NSP over the<br />

same period in 2011, demonstrates the importance of<br />

established networks within a geographic zone. West<br />

Suburban is shown to have a strong presence in the<br />

western suburbs while Silver Top <strong>and</strong> 13CABS have<br />

market dominance in other areas of Melbourne. The<br />

following figures illustrate the pick-up locations of jobs<br />

completed by each of the metropolitan networks with<br />

darker areas indicating a higher number of jobs completed.<br />

Figure 11.5 Heat map of Platinum Taxis pick-up locations<br />

56 ACCC (2009), A Gange Proprietary Limited - proposed acquisition of<br />

West Suburban Taxis Pty Ltd, www.accc.gov.au/content/index.phtml/<br />

itemId/872435/fromItemId/751043 accessed 23 March 2012<br />

Source: TII analysis of NSP supplied data<br />

<strong>Underst<strong>and</strong>ing</strong> <strong>industry</strong> <strong>performance</strong> CUSTOMERS FIRST 241

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