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

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This also means that other NSPs <strong>and</strong> operators will<br />

be concerned about installing equipment that cannot<br />

process Cabcharge-br<strong>and</strong>ed cards. Regular taxi users,<br />

<strong>and</strong> particularly corporate users, who tend to be higher<br />

users of Cabcharge cards likely have an expectation that<br />

these cards will be accepted. If alternative equipment is<br />

installed that does not process Cabcharge cards, there<br />

is a strong possibility of user dissatisfaction <strong>and</strong> ultimate<br />

loss of taxi users.<br />

The inquiry is concerned primarily about the effectiveness<br />

of competition in markets for payments processing <strong>and</strong><br />

payment instruments. Over time, it appears to the inquiry<br />

that Cabcharge has been extremely effective in stifling<br />

the development of competition in these markets. The<br />

merger approval process is clearly not preventing these<br />

competition issues from emerging.<br />

Future issues likely to emerge<br />

A key issue for the inquiry is how future mergers <strong>and</strong><br />

acquisitions might be treated by the ACCC, particularly if<br />

certain changes are recommended.<br />

The inquiry notes that further consolidation of NSPs in<br />

metropolitan Melbourne is unlikely, as a duopoly already<br />

exists. Further consolidation will almost certainly reduce<br />

competition. In addition, even if the current structure<br />

stayed the same there will be little opportunity for future<br />

vertical mergers to lessen competition, as Cabcharge<br />

now has a very strong market presence across payment<br />

instruments, payments processing, taxi equipment supply<br />

<strong>and</strong> network services.<br />

However, the inquiry is concerned about the potential<br />

effect of the ACCC’s recent merger approach if<br />

significant changes in zoning result from the inquiry’s<br />

recommendations.<br />

11.7.2. Barriers to entry<br />

In order to be sustainable, a new network must establish<br />

its business concurrently on both sides of the two-sided<br />

market. Acquiring enough operators to meet customer<br />

dem<strong>and</strong> is further complicated by any restriction on<br />

licence numbers since this means that new NSPs have to<br />

attract taxi operators away from existing NSPs.<br />

Two critical <strong>and</strong> competing elements are present that<br />

further act as barriers to the creation of a successful<br />

new network. The first element is the need to establish<br />

goodwill <strong>and</strong> br<strong>and</strong> underst<strong>and</strong>ing with consumers,<br />

encouraging them to change their behaviour <strong>and</strong> move<br />

away from more established br<strong>and</strong>s. The second element<br />

is that operators need to be assured of a sufficient<br />

supply of revenue derived from booked work from the<br />

new network to meet their own high operating costs <strong>and</strong><br />

retain bailee drivers. These two factors compete in that<br />

a new network may find it difficult to offer acceptable<br />

wait times to customers without an adequate number of<br />

taxis in the fleet, while operators will be reluctant to join a<br />

network that cannot provide them with sufficient work to<br />

make a profit.<br />

As mentioned above, the current limited supply of taxi<br />

licences results in new entrants needing to encourage<br />

existing taxi operators to break their affiliation with the<br />

established providers <strong>and</strong> move to the new network.<br />

Due to the high number of ancillary services currently<br />

provided by the existing NSPs, operators will likely<br />

incur a high level of costs in switching their affiliation,<br />

including equipment removal <strong>and</strong> re-installation (for<br />

payment terminals, dispatcher technology <strong>and</strong> cameras),<br />

refinancing of vehicles <strong>and</strong> licences, a risk of losing<br />

assignments, <strong>and</strong> the loss of supply of network trained<br />

drivers. The inquiry underst<strong>and</strong>s that there are few<br />

instances of operators switching networks.<br />

Where these costs are borne by the operator, they act<br />

as a very effective deterrent to switching. Alternatively,<br />

if these costs are subsidised by the new network as an<br />

incentive for operators to switch affiliation, this will result<br />

in significantly higher set-up costs for the new NSP.<br />

The one new entrant into the Melbourne market in recent<br />

years is Platinum Taxis. Platinum Taxis has experienced<br />

only marginal growth over its first four years <strong>and</strong> continues<br />

to offer its services to taxi operators at a significantly<br />

reduced rate than that of the two major metropolitan<br />

networks. Platinum Taxis have focused their consumer<br />

offerings predominantly at ‘high end’ service in long<br />

wheelbase vehicles having originally emerging from a well<br />

established secondary network. Despite reduced affiliation<br />

fees (see Figure 11.6), Platinum Taxis has not experienced<br />

material growth within the Melbourne NSP market.<br />

Most operators that are affiliated with Platinum Taxis are<br />

also known to continue to source work through their<br />

association to secondary networks <strong>and</strong> through private<br />

clients of the operator <strong>and</strong>/or driver. This reduces their<br />

reliance on booked work from the primary network.<br />

As long as licensing numbers are subject to quantitative<br />

restriction it will be difficult to overcome the barriers to<br />

entry for new NSPs. In this context there is a stronger<br />

case for removing the m<strong>and</strong>atory affiliation requirement.<br />

In an open market there will be more opportunities to<br />

establish new NSPs.<br />

<strong>Underst<strong>and</strong>ing</strong> <strong>industry</strong> <strong>performance</strong> CUSTOMERS FIRST 243

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