DRIVE A2B June 2018

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RIS FEEDBACK The CPVAA further believes that for a CPV to operate as a TAXI it requires the following attributes: • Branding (external signage) including the word TAXI • Dome (world-wide recognition that the vehicle is a taxi) • Meter (either physical or electronic) • Safety Camera • Stickers stating the calculation of fares, flagfall, etc. ROAD SAFETY ROAD RULES 2017 We believe that there should be legislative recognition of a CPV that meets specified regulations as a TAXI - as this is a publicly recognised world-wide service. Only CPVs that are registered to carry out unbooked trips (ie TAXIS) may stand on taxi ranks. Any change in legislation that reduces the ability of CPVs to service their travelling public will be seen by the public in a negative light. As such, the CPVAA strongly recommends that the use of Loading Zones for VHA - VHZ plated vehicles continues. Also the ability for TAXIS and VHA - VHZ plated vehicles to use bus lanes and transit lanes should be maintained. SAFETY OF THE DRIVERS AND PASSENGERS IS PARAMOUNT The CPVAA insists that safety for both passengers and drivers in an accredited CPV is non-negotiable; regardless of what price point the service is given at. Under the former regulatory regime, where there were only hire cars and taxis, there is no evidence to support the need for safety cameras to be installed in what we knew as traditional hire car services. The CPVAA has paramount concern for the safety of all our members and their clientele and since the new regime’s intentions (if not the law) have been used as the basis for [illegal] operations there have been numerous media reports about some “On Demand Transport” vehicles’ drivers allegedly being involved in assaults. There is sufficient media and anecdotal evidence state-wide and nationally to suggest that “On Demand Transport” vehicles should be fitted with safety cameras. The CPVAA also agrees that all unbooked CPV services (ie Taxi services), such as rank and hail services, should have safety cameras installed in the CPVs. CONDITION OF VEHICLE The CPVAA stands by our previous statement that public safety is non-negotiable. Therefore, it follows that all CPVs should have regular roadworthy assessments carried out on them by a licenced vehicle tester. Our experience tells us that vehicles used as CPVs – that incur higher than average mileage – deteriorate at a much faster rate when compared to vehicles used in a private capacity. It is our understanding that the uptake of 25,000 “On Demand Transport” vehicles have only had a “safety check” that was organised by Uber – not a full roadworthy assessment by a licenced vehicle tester. This is actively misleading the public. Feedback that we have gathered suggests that the public expects all CPVs to be in roadworthy condition at all times. In our discussions with many consumers there is an overwhelming support for annual roadworthy inspections to be undertaken by a licenced vehicle tester. The CPVAA has also collected feedback that suggests that up to 1 in 3 vehicles fail to meet their initial roadworthy expectations and require rectification to ensure they meet the minimum standards. This is supported by our 25+ years industry experience. If the TSC has documented evidence that contradicts this, they should present it as part of this RIS discussion, so that it may be perused and analysed. Currently and in previous years, the TSC has failed to ensure that roadworthy assessments are undertaken. We are aware that the TSC does not send out reminder notices and does not keep track of whether these vital safety inspections have occurred – rather they appear to rely on the goodwill and honesty of operators. The CPVAA believes a simple solution to this issue is that a roadworthy certificate must be submitted at the time of, and be a condition precedent to, receiving both a CPV licence and a CPV annual renewal. Given that there are no longer any age limits on CPVs, the CPVAA feels that this is imperative to ensure the maintenance of the safety of the CPV fleet. 14 DRIVE A2B magazine · June 2018
Australian Design Rules (ADR) are national standards for vehicle safety, anti-theft and emissions of all new and used vehicles entering the Australian market for the first time. These rules were brought in for the protection of the Australian public and their motor vehicle. ANCAP, Australasia’s leading independent vehicle safety advocate, provides consumers with advice and information on the level of occupant and pedestrian protection provided by different vehicle models in the most common types of crashes. ANCAP’s vision is “To eliminate road trauma through the testing and promotion of safer vehicles”. Then there’s the Victorian initiative “Towards Zero”, which strives for us to have a future free of deaths and serious injuries on our roads. The campaign’s aim is to ensure that we have a safe road system in place. A system that protects us from our own mistakes, and those of others. With all this infrastructure and projects relating to vehicle safety surrounding us, the CPVAA finds it staggering that the TSC and TfV failed to consider the safety of the vehicles when granting accreditation of vehicles for use as a CPV. We believe that, moving forward, all public transport vehicles should, as a very minimum, meet a 5 star ANCAP safety rating before they are accredited as a CPV. INSURANCE ALL CPVs must be individually covered by a commercial vehicle insurance policy which includes business liability insurance. This should be a condition of the CPV licence. The CPVAA can provide evidence of “On Demand Transport” drivers being involved in accidents where they have either had minimum (private) or no insurance at all. This is unacceptable both to the CPVAA and the general public. The public expects that the CPV they are travelling in is fully and adequately insured. If the TSC thinks otherwise, they should supply evidence to support their rationale that commercial vehicle insurance is not necessary, for further analysis and discussion. TO REGISTER OR/RENEW AS A COMMERCIAL PASSENGER VEHICLE The CPVAA believes that the following criteria should be met and submitted with every application for CPV accreditation and every annual renewal of same. • Annual Roadworthy certificate (where CPV is a taxi this check to include all taxi equipment– meter, dome, etc. ) • 5 star ANCAP rating certificate • Comprehensive commercial vehicle insurance policy RISK REGISTER The CPVAA recognises that the traditional single car operator will be unduly burdened by the costs of having to create and continuously maintain a risk register. This has been unnecessary for the last 30 years within the pre-booked vehicle industry; we do not feel that it adds any value (except, possibly, to maintaining bureaucracy). The CPVAA does not understand why safety incidents in CPVs need to be logged and maintained? Are these logged and maintained for EVERY driver on the road? Once again, we note that this has been unnecessary for the last 30 years within the pre-booked vehicle industry; we do not feel that it adds any value (except, possibly, to maintaining bureaucracy). The CPVAA does not believe that TfV needs to track notifiable incidents. According to Peter Drucker, “what gets measured gets managed” but we do not see any record of management from the TfV, and in particular from the TSC. Therefore, in our opinion, there is no need to collect data that will not be used and acted upon. We cannot comment on what the expected compliance or implementation costs of the proposed new requirement for BSPs to provide certain information to the hirer, until such time as the operating requirements and conditions of being a BSP are released. We note that at a recent meeting of the CPVAA, 95% of attendees had no idea of the requirement to even become a BSP, let alone any other requirements and their costs. COMMERCIAL PASSENGER Response by the Commercial Passenger Vehicle Association of Australia to the Regulatory Impact Statement for the Commercial Passenger Vehicle Industry Regulations 2018 DRIVE A2B magazine · June 2018 15
Page 1: DRIVE Voice of the Victorian Point-
Page 5 and 6: CONTENTS WHAT’S INSIDE 8 $1 .00 C
Page 7 and 8: VOICE VOICE VOICE profit share prog
Page 9 and 10: Over in South Australia the situati
Page 11 and 12: ROD BARTON President, CPVAA Melbour
Page 13: This document details the response
Page 17 and 18: COMMERCIAL PASSENGER WANT A VOICE W
Page 19 and 20: VEHICLE CHEAP RATES finance EASY CA
Page 21 and 22: New company with a new vision Innov
Page 23 and 24: A new report by the Texas A&M Trans
Page 25 and 26: This new system may sound sensible
Page 27 and 28: INDUSTRY STATISTICS The statistical
Page 29 and 30: Car free CBD zones The City of Melb
Page 31 and 32: INFRASTRUCTURE Applying for a taxi
Page 33 and 34: AUTOMATED & ZERO EMISSIONS In late
Page 35 and 36: Police are seeking to identify thes
Page 37 and 38: NEW SOUTH WALES Taxi operators are
Page 39 and 40: What’s On in Melbourne Melb Int J
Page 41 and 42: ENGLAND CHINA - Beijing by Shunsuke
Page 43 and 44: ARE YOU PUTTING A TAXI ON THE ROAD?

DRIVE A2B June 2018

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