Contents. 1. Summary Introduction Key Complaints Regulatory Failure The Way Forward? Labour s Proposals 20

Transcription

1 Contents 1. Summary.2 2. Introduction 5 3. Key Complaints.6 4. Regulatory Failure The Way Forward? Labour s Proposals 20

2 Summary Taxis are an integral part of our public transport system and the taxi sector requires high quality service and safety standards. Taxi users have rightly welcomed the ending of the pre-2000 situation where it was often impossible to get a taxi at closing time and other peak periods for taxi use. However, the current deregulated taxi sector is seeing increasing problems with more and more complaints from both passengers and drivers on a range of issues including vehicle standards; driver knowledge; fare increases; health and safety standards; market saturation; drivers incomes; ranks and taxi infrastructure; and most critically, taxi accessibility for citizens with a disability. The current light touch regulatory system established by the Fianna Fail government with its inadequate licensing, entry and monitoring standards is grossly failing passengers and taxi workers alike. There are now an unprecedented 27,000 plus taxi plates and 47,000 plus Small Public Service Vehicle (SPSV) driver licenses in operation in towns and cities across Ireland. This is unsustainable and will result in an industry that no longer provides a basic, liveable, full-time income for its workers. There must be a massive overhaul of the taxi regulation and enforcement system to achieve the highest quality service for passengers as well as providing a decent, sustainable income for all taxi workers. The Labour Party believes that the way forward in the taxi sector must include the following measures and where necessary amendments to the 2003 Taxi Regulation Act: New rigorous programme of entry, licensing and quality service standards. We will establish a comprehensive new driver knowledge 2

3 exam; end the transferability of licenses; introduce a three year full and clean driving license qualification before an individual can apply for a taxi license; restrict the issuing of SPSV licenses to one per individual; impose new minimum availability for work regulations for full-time and part time drivers; introduce strict new quality service standards in the taxi industry for drivers and vehicles; introduce new uniform vehicle standards for 2015 with clear specifications on luggage and leg space; fasttrack the proposed Quality Assurance Scheme and a Quality Mark schemes and pilot programmes on new vehicle security shields, transparent divisors and in-vehicle CCTV systems to enhance the safety and security of taxi workers. We also suggest a Taxi Passengers Champion as part of the taxi regulatory system within the new Dublin Transport Authority/National Transport Regulator (DTA/NTR). A new strict enforcement and regulatory regime. The current regulator should be immediately merged into the new Dublin Transport Authority/National Transport Regulator with strong regional taxi regulation and full responsibility for licensing and contracts, high quality standards and all taxi infrastructure. Given the current 27,000 plus taxi plates the number of Enforcement Officers should be increased by up to 50 officers and a basic minimum ratio of two officers per 1000 drivers established. There must be enhanced regulatory power including an increase in the value of on the spot fines to 500. This should be accompanied by a clear right of appeal process for drivers within the Commission on Taxi Regulation system itself. Evaluate a new long term market demand evaluation mechanism for regulating the taxi sector. Labour believes that new legislation should be considered taking taxi capacity and the taxi demand-supply balance into account as a key condition of issuing licenses on a regular basis and which exists in other regulated markets (as for example in 3

4 broadcasting and communications under the Broadcasting Commission and ComReg). The achievement of a truly wheelchair accessible fleet. A new initial target for a 20% wheelchair accessible fleet by 2012 must be established as a first step with the longer-term objective of a 100% accessible fleet. We will also consider the implementation of a VRT/VAT rebate scheme for drivers who purchase a new wheelchair accessible taxi. And finally, support for a temporary moratorium while the new regulatory framework is put in place. 4

5 Introduction: The Deregulated Taxi Market Taxis are an integral part of our public transport system and the direct interaction between taxi drivers and the general public requires the most rigorous of safety and high quality service standards. It is also an industry that has been valued at approximately 1.5 billion per annum. The taxi industry was fully deregulated in 2000 and at that stage there were around 4,000 taxi licenses across the country. Throughout the 1990s there was a major problem with lack of capacity of taxis in cities and towns across Ireland which was particularly bad at the weekends, at Christmas and other holiday periods. After the 1997 General Election, Fianna Fail sanctioned an increase of 800 Dublin taxis and then the complete deregulation of the industry in This devastated the income and vocational pension provisions of many long-term taxi drivers. Since deregulation there has been an explosion in the numbers of taxis on the streets of our cities and towns. More than 27,000 taxi licenses have now been issued by the Taxi Regulator. This has led to the most critical and positive impact of deregulation the elimination of the key pre-2000 problem of a serious shortage of taxis for passengers. However, many taxi users also believe that the taxi sector is increasingly characterised by poor quality service and have deep concerns about standards and safety. Falling incomes and excessive working hours within the industry are also causing hardship to workers within the taxi sector. There is a strong concern that the current free-for-all and light touch regulation of the taxi sector is failing many customers and drivers. Labour believes that the taxi industry must not be allowed to deteriorate into a permanently low quality, very low wage industry. 5

6 Key Complaints on the Deregulated Taxi Industry It must be emphasised again that the pre-2000 situation of a serious shortage of taxis has generally been eliminated for passengers. There have also been important changes in public transport since Not least of these have been the impact of mandatory drink driving laws on driving behaviour and the important evening and late-night role now being played by taxis in ferrying pub patrons home. However, significant complaints that are currently being raised about the deregulated taxi sector include: 1. Driver Behaviour & Vehicle Standards Anecdotally there continues to be a large volume of complaints about taxi vehicle standards and driver behaviour. In 2007 and 2008 the Regulator also received 763 and 551 complaints respectively. In 2008, 60% of these were in Dublin City and County, 5% in Cork, 3% were in Galway and 2% in Louth and Limerick. Of the 2008 official complaints to the Taxi Regulator, 239 complaints related to overcharging, 156 complaints to the conduct and behaviour of drivers, 67 to the condition and cleanliness of drivers and vehicles and 89 to hiring issues. Shockingly, 51% of offences in 2008 involved the driver having no vehicle license and 33% of offences involved the person driving the taxi having no driver s license. The fixed 250 fine that the Taxi Regulator can impose is very low given the seriousness of some of the offences that the fine applies to, such as overcharging, failing to operate a meter, operating without satisfactory street knowledge, failing to display driver or vehicle identification or displaying forged identification. There have been other serious complaints about the illegal cloning of taxi licenses, of bogus taxi signs being on sale for as little as 200 in Dublin and significant numbers of illegal taxi drivers 6

7 operating vehicles in Limerick, Cork and Dublin. One well publicised example reported a taxi driver noticing another taxi out plying on the street which was using his own legally registered number on the sign. There appears to have been no serious examination of the number of illegal drivers operating in our cities and towns which is creating a potentially very dangerous environment for taxi passengers. Yet given all of these significant issues the Taxi Regulator employs just nine Enforcement Officers to police an industry with more than 27,000 taxi license holders and with taxis on the road on a round the clock basis. The clear lack of Enforcement Officers and the deficient enforcement system to strictly monitor the huge number of licensed taxis leaves huge scope for unacceptable behaviour by any unscrupulous drivers. 2. Driver Knowledge There are regular complaints about the decreased quality of the taxi service since deregulation especially in relation to driver street knowledge. A central requirement of the job once a driver passes all background safety checks must be a clear and significant standard of knowledge of the area within which the taxi driver will be operating. Yet, there continues to be astonishing cases of passengers in Dublin, for example, finding that their driver does not know the way from the City Centre to well-known and longstanding suburbs or landmarks such as Dundrum, Crumlin, Coolock or major hotels in Ballsbridge. The brief knowledge exam that all applicants for a SPSV driver s licence currently undertake is completely inadequate and is failing to ensure that all taxi drivers have the requisite knowledge and experience to carry passengers within their designated area. 7

8 In contrast, drivers of London s famous Black Cabs must undertake an intensive seven stage examination system which includes a series of written, oral and practical exams before they are licensed as taxi drivers and can take three or four years study to achieve. Most other EU states such as Sweden, Germany and France also require taxi drivers to pass through a comprehensive examination system including vetting, driver training and street knowledge before they receive a license. 3. Market Saturation Given the high ratio of taxis per head of population in Ireland, there is a huge concern that the industry has collapsed as a source of decent and living wages for its fulltime workers. The Taxi Regulator reported that as of April 1 st 2009 the number of licensed taxis currently stands at 27,385 across the whole country with 47,176 active SPSV driver licenses. The March 2009 Goodbody Economic Review s figures reported the following vehicle licenses issued on a county-by-county basis : Dublin 13,244 Cork 2382 Meath 1408 Kildare 1259 Galway 1231 Limerick 930 Louth 754 There has also been a significant change in the ratio of taxis to hackneys and other cabs since 1993: 8

9 Year Total Taxis Hackneys/Other ,144 2,726 3, , 637 4,218 9, ,429 21,177 6,252 In contrast, the Greater London Area with a population of more than 7.5 million has approximately 25,000 licensed taxi drivers. New York City has a population of over eight million and had just over 13,000 taxis at the end of In Finland, for example, there are a total of 10,000 taxis for a population of over 5 million. Even the deregulated taxi industry in New Zealand has approximately 8000 taxis in total across the country for a population of around 4 million. The taxi density across most EU and OCED states is significantly lower than in Ireland, even if similar policies of deregulation have been introduced. 4. Health & Safety: Excessive Working Hours There are clear health and safety issues in the taxi industry as many drivers are now working excessive weekly hours and driving shifts of 20 hours plus in order to earn a liveable income. The recent Goodbody Taxi Report presents some alarming statistics on current working conditions in the sector. For example, according to Goodbody, 25% of all drivers are currently working more than 60 hours a week and 11.2% of drivers are working more than 70 hours a week. Goodbody s extimates that in just three years between 2005 and 2008 the percentage of Dublin taxi drivers working 70 hours a week plus more than doubled from 4% to 9.8%. Astonishingly, the Report also found that one in five drivers with more than one occupation is working more than 75 hours a week and one third of drivers with more than one occupation are working between hours a week in that occupation. 9

10 Yet even with some of these conservatively estimated statistics there are no suggestions in the report to address excessive working hours and the maintainence of critical health and safety standards for drivers and the general public. The Taxi Regulator has stated she will not enforce the EU Working Time Directive (which regulates adequate rest and maximum working hours). This is because the majority of SPSV drivers are self employed and a self employed SPSV driver is not covered by the time restrictions imposed by the Working Time Directive. Instead the Taxi Regulator oversees a little, if ever, enforced standard that over a three consecutive day period a driver must not drive for more than 11 hours a day. 5. Part-Time & Double Jobbing There are also many part-time taxi drivers who have other full-time and well-paid jobs, and use the taxi business to supplement their regular income. In 1998 the Department of Transport abolished a previous regulation that stipulated that taxi license holders must be available to work for 40 hours a week. Goodbody s Economic Review estimated that at a minimum 15.6% of drivers are part-time and 14.1% have another job. But the Goodbody report also found that there is an increasing trend towards double jobbing in the taxi industry as 48.2% of drivers who have another job are in the taxi business less than five years. Many full-time drivers have now complained that driving a taxi full-time has become so economically unviable that it makes more economic sense to leave the taxi business and sign on for social welfare 10

11 6. Price Increases & Drivers Incomes As in other deregulated markets, the promise of lower fares for passengers has not been realised. Indeed recent price increases have hammered taxi passengers. The Taxi Regulator increased rates over the Christmas and New Year period in order to encourage drivers to operate on those days and improve supply. It is ludicrous that passenger fares have to be increased during this time period in order to get more drivers on the roads given the massive volume of taxi licences that have been issued. A better regulated market should ensure sufficient taxis on the roads at peak holiday periods. The Transport Minister and Regulator should have examined other measures such as the demand-supply balance of taxi capacity, better regulation to ensure the availability of taxis at peak times or the impact of fuel costs on the industry rather than simply sanctioning more fare increases for passengers. Instead of providing the promised hard facts on the current economic situation in the taxi sector, the recent Goodbody Economic Report is vague in terms of drivers' incomes. It estimates average gross earnings for drivers at 40,350 after costs but before tax at the highest estimate and 16,147 per annum at a lower estimate in And it acknowledges that the net hourly earnings of drivers in 2008 was approximately 11 (below the average industrial wage and above the minimum wage). In fact, the report baldly states that drivers have to work longer hours to achieve income targets and on an hourly basis they are earning well below the current industrial wage. Goodbody estimates that in Dublin there has been a drop in gross earnings of 5% between 2005 and 2008 although many drivers have estimated that wages have dropped by at least 25%-30% in the past three years. 11

12 7. Taxi Accessibility The poor regulation and trend towards low incomes and inadequate standards in the taxi business has left us a national taxi fleet which is severely failing citizens with a disability. The Irish Wheelchair Association recently told the Dail Transport Committee that just 6% of the Irish taxi fleet is wheel chair accessible (compared to approximately 52% in the UK) and which is down from 21% of the fleet being accessible in 2000 (out of a total fleet of 13,637). Transport Minister Dempsey then reported that the percentage of the whole taxi fleet that was wheelchair accessible in 2008 was 7.5% and the number of wheelchair taxis has increased but not at the same rate as the overall expansion of the fleet. There were 1,600 license wheelchair accessible taxis in 2008 up from 1,246 in But this is still an appallingly low figure in the context of a national taxi fleet of well over 27,000 taxis and cabs. The Irish Wheelchair Association has welcomed the progress that has been made on issues such as signage, driver training, the licensing of dispatch operators and vehicle design and specification that were highlighted in their key 2004 document Towards an Accessible Taxi Service for All. However, as the Irish Wheelchair Association stresses the key problem remains the deficient number of wheelchair accesible taxis in the taxi fleet. The high cost of purchasing a wheelchair accessible taxi (estimated at between 43,000 and 65,000) is the major barrier to increasing the number of wheelchair accessible taxis in the fleet. Currently the only financial incentive available for the purchase of wheelchair accessible taxis is a reduced cost for purchasing a taxi license. The current severely falling income levels in the taxi sector are also strongly discouraging new and existing drivers from purchasing wheelchair accessible cars because drivers believe they will never be able to recoup any of their investment given the low and decreasing income levels for taxi drivers. 12

13 8. Ranks & Taxi Infrastructure There has been practically no rise in the number of taxi rank places and other related taxi infrastructure since deregulation even though the number of licensed taxis has soared past 27,000. For example, Taxi Unions have estimated that in Galway there are just 65 rank places for 1,150 drivers and in Waterford there are 30 rank places for 370 taxi plates. This has resulted in incredible taxi congestion on the roads in Dublin, Galway, Cork and our other towns and cities and there is also a growing problem with informal ranks springing up in many cities and towns especially outside hostelries at night. The lack of taxi rank spaces: o hinders the fast pick-up of customers who may be queuing at designated ranks and makes it exceptionally difficult for drivers to work around the city. o creates unnecessary extra traffic congestion and C02 emissions because of the thousands of taxis constantly driving with no passengers around the city. o provides a massive further financial whammy for drivers given the current high fuel costs that taxi drivers face. It is very unsatisfactory that the Taxi Regulator has no responsibility or input into the location, operation and funding of taxi ranks (this is solely the remit of local authorities) which are the critical part of the taxi system s infrastructure. 13

14 Regulatory Failure: Taxi Commission Failing to Impose & Enforce Standards Since the Commission for Taxi Regulation was established in September 2004 the standards and enforcement mechanisms brought in to regulate the industry have been grossly inadequate. There have been some new worthwhile procedures including a national complaints procedure, a consultation on new vehicle standards, a new national register of licenses, a new national vehicle licensing system, an information and awareness campaign and new national consumer and industry telephone lines. Yet there has been little action on a number of key substantive issues including streamlining and reforming the current chaotic system for issuing SPSV licenses where there appears to be few controls in the free-for-all, liberalised market. For example, an individual applies to An Garda Siochana for a small Public Sector Vehicle driver license and then to the Taxi Regulator for a Small Public Sector Vehicle (SPSV) license. There have long been plans to streamline this cumbersome process and give the Taxi Regulator full responsibility for the driver and vehicle licensing function and the driver license entry process was intended to pass from the Carriage Office to the Taxi Regulator in June Yet, the transfer and reform of the driver licensing function has now been delayed indefinitely because of an embargo on the hiring of additional staff at the Commission on Taxi Regulation. There are other major flaws and anomalies in the taxi licensing system. For example, there are no limits to the number of SPSV vehicle licenses that an individual can apply for an individual with a SPSV driver s licence can apply for an unlimited amount of taxi plates. The Taxi Regulator told the Dail Transport Committee in December 2008 that over 91% of vehicle licence holders only have one vehicle licence. There is a small percentage of entities which have between ten and 20 licences as well as a small percentage that 14

15 have between 20 and 80 licences. We have one entity with over 100 licences. About 2,500 plates seem to be owned by a small number of operators. Licenses can also be transferred between individuals which leaves scope for unscrupulous persons to engage in unwelcome and possibly even criminal activity in the sector. It is commonplace now to see large numbers of ads in the national, regional and local press advertising vehicle licenses for sale. This clearly highlights the major holes in the current system for vetting prospective taxi license holders. However, in 2006 the Regulator accepted that the transferability of licenses and renting of licenses should continue. According to the Taxi Regulator the new vehicle standards for new taxi and hackney drivers came into force from January 2009 and will apply to all license holders by January The Regulator intends to rollout the Skills Development Programme from Summer 2009 and new standards on wheelchair accessible vehicles are waiting for sanction from the Transport Minister. Yet why are all of these developments being done on such a lengthy phased basis? And who is invigilating the standard and compliance level of the new procedures? There is no real evidence that standards in the taxi sector are being seriously invigilated and monitored instead strict and strictly enforced standards seem to have been put on the long-finger. Lax enforcement will clearly lead to wide non-compliance with basic standards. With just nine Enforcement Officers, the Taxi Regulator will remain a paper tiger no matter how many new standards or codes of conduct are introduced. In Finland, new 2007 taxi legislation included basic quality norms which were accompanied by a Taxi Quality Scheme that was established by the Finnish Taxi Federation (of which 90% of Finnish taxi drivers are members). Finland, however, does also retain a taxi quota system. 15

16 In New Zealand the taxi industry was deregulated in Deregulation there ushered in a period in the New Zealand taxi industry which was recently characterised by the New Zealand Taxi Federation as one of lower driver and vehicle standards; street confrontations; dishonest practices, credit fraud, assaults on passengers; fraudulent practices in driver qualifications and where regulators/compliance officials couldn t cope. It took a major investigation and highly critical 2005 report by New Zealand s Auditor General into the performance of the regulator of the New Zealand taxi industry to initiate a root and branch reform of the regulatory and compliance system for New Zealand s taxi service. Similar comprehensive regulatory reform is now critically necessary in the Irish taxi sector. 16

17 The Way Forward? 1. Goodbody Economic Review The recently published review of the Small Public Service Vehicle (SPSV) Industry by the economic consultants Goodbody for the Taxi Regulator was hugely disappointing. Goodbody rightly acknowledged that liberalisation of the taxi industry has brought benefits to taxi users. Yet, disturbing statistics on wheelchair accessible taxis, health and safety and wages were provided in the Review but Goodbody made no link between these glaring problems in the taxi industry and the current system of regulation. Instead the report seemed stuck in the time warp of the now discredited "light touch" regulation ideology that has disastrously characterised other sectors of the Irish economy including finance, planning, housing and construction. Indeed, many critical elements of the Taxi Regulator's entry and monitoring mechanisms were simply not adequately investigated in this report including the current deficient local knowledge entry exam; the existence of just nine enforcement officers to police an industry with more than 27,000 license holders; the transferring of licenses, the operation of bogus licenses and the implementation of the EU Working Time Directive. The Report summarily dismisses any concerns about the expontential explosion in taxi licenses since deregulation and the inability of many taxi drivers to earn a living wage. It also states that falling wages or drivers being forced to work longer and longer hours should not even be considered as factors in any debate on the possible introduction of a moratorium. The Goodbody Report should have examined measures to reform the entry and license conditions and operational monitoring which would greatly help to bring the number of plates and market demand into line and should help eliminate rogue operators within the industry. 17

18 The suspicion remains that this report and its dismissal of a temporary moratorium was written to conform to the prevailing liberalisation agenda of Minister Dempsey and his colleagues. 2. Moratorium & Government s Legal Advice Taxi drivers and their representatives have been calling for at least a short-term moratorium on the issuing of licenses for a fixed period given the current number of taxis operating in cities and towns. Minister Dempsey and the government say that a limit on taxi licenses is legally impossible due to the case of Humphrey v the Minister for the Environment which found that under Section 82 of the Road Traffic Act the Minister could issue regulations for the control and operation of public service vehicles but could not impose a numerical limit on the number of taxi licenses. 3. Dail Transport Committee & Moratorium However, the Dail Transport Committee has also been examining and investigating the taxi sector over the last nine months. The Committee has received comprehensive submissions from the Commission of Taxi Regulation, taxi drivers from around the country and their union representatives An Garda Siochana and the Competition Authority at a series of full scale Dail Transport Committee hearings. It has now also advertised in the media for submissions from the general public on their views on the current workings of the taxi industry. The Competition Authority has suggested that it is not legally possible to cap or impose a moratorium on the number and issuing of taxi licenses. But, the Dail Committee has been reviewing the government s legal advice on imposing a cap or moratorium on licenses and its legal advisors have suggested that a moratorium is a legally viable option. Many contributors to the Committee have argued that other professions have strict entry standards and qualifications that must be adhered to 18

19 for the proper functioning of the industry. Why should the taxi sector be any different given that the key aim must be for a high class and professional national taxi fleet as a critical element of our public transport system? The Transport Committee Chairperson Frank Fahey T.D. now looks set to recommend a new bill that would introduce a four year moratorium on the issuing of taxi licenses. The proposed bill (Taxi Regulator Amendment Bill, 2009) would effectively suspend aspects of the 2003 Taxi Act for four years and the act would operate with a legislative sunset provision. 19

20 Labour s Proposals: The Labour Party believes that the way forward in the taxi sector must include: new rigorous programmes of entry, licensing and quality service standards; a new strict enforcement and regulatory regime; the evaluation of a new long term market demand evaluation mechanism for regulating the taxi sector; the achievement of a truly wheelchair accessible fleet; and finally, support for a temporary moratorium. To achieve this we must: 1. Abolish the current stand alone regulator and merge strong regional taxi regulation into the new Dublin Transport Authority/National Transport Regulator with full responsibility for licensing and contracts, high quality standards and all taxi infrastructure. Ensure the formal input into the regulatory process of taxi users and workers through passengers and drivers forums. We also suggest a Taxi Passengers Champion as part of the new DTA/NTR Taxi Regulator. 2. Establish a new comprehensive entry exam similar to the London The Knowledge to ensure drivers have extensive local knowledge and practical experience of the area within which they will be driving before they are awarded a license. 3. Introduce a three year full and clean driving license qualification before an individual can apply for a taxi license. 4. Restrict the issuing of SPSV licenses to one per individual and make sure that there is just one address associated with each taxi license holder. 5. End the current system where licenses can be transferred between individuals to ensure a transparent regime which includes all relevant background and suitability checks. 20

21 6. Impose new minimum availability for work regulations for full-time and part time drivers and adopt the EU Road Transport Working Time Directive on working time limits for all drivers. 7. Significantly increase the number of Enforcement Officers from the current nine for over 27,000 license holders. For current license numbers there should be up to 50 officers and a basic minimum ratio of two officers per 1000 drivers should be established to monitor and enforce standards. The Finnish model of roving Taxi Inspectors with a continuous high level of spot checks on drivers and vehicles should also be emulated. 8. Enhance regulatory power to include an increase in the value of on the spot fines to 500 and the power to immediately suspend a license for serious breaches of licensing regulations by a driver. 9. Introduce a right of appeal for drivers within the Commission on Taxi Regulation system itself. 10.Work towards new uniform vehicle standards for January 2015 with clear specifications on luggage and leg space. 11.Introduce strict new quality service standards in the taxi industry for drivers and vehicles including a regular quality assessment, a dress code, and personal and vehicle hygiene standards. 12.Immediately introduce the proposed Quality Assurance Scheme and a Quality Mark for vehicle, driver standards and dispatch operators. 13.Fast-track pilot programmes on new vehicle security shields, transparent divisors and in-vehicle CCTV systems (closely invigilated by the regulators) to enhance the safety and security of taxi workers. 14.Consider the formation of a national taxi co-operative (similar to the Danish taxi co-operative model) where each driver would be encouraged to become a member. 15.Incorporate responsibility for ranks and other taxi infrastructure under the control of the new Taxi Regulator (which would fully liaise its rank requirements with every local authority transport management plan and County and City Plans). Maintain a fair minimum ratio of rank spaces to taxi licenses issued and make sure that adequate rank spaces are in 21

22 place at key locations such as train and bus stations, shopping centres, sports and recreational facilities, hospitals etc. 16.Consider the introduction of flexible taxi ranks in the short term i.e. spaces that can be designated as ranks at core times such as night times, bank holidays and special events to provide immediate extra capacity and new initiatives such as Safe City Taxi Ranks with enhanced safety and security measures for passengers and drivers. 17.Establish a new initial target for a 20% wheelchair accessible fleet by 2012 with the longer-term objective of a 100% accessible fleet. 18.Implement a VRT/VAT rebate scheme for drivers who purchase a new wheelchair accessible taxi as proposed by the Irish Wheelchair Association. 19.Consider similar incentives to encourage the development of an electric and biofuel accessible taxi fleet. 20.Evaluate a market-led regulatory mechanism which would take market conditions and equilibrium into account when issuing licenses in the future. If necessary, under new legislation reforming the 2003 Taxi Act, the Dail may have to consider taking capacity and the demand-supply balance into account as a key condition of issuing licenses on a regular basis. There are precedents for this in most other regulated markets (as for example in broadcasting and communications under the Broadcasting Commission and ComReg). 21.During the implementation process of a new regulatory system establish a moratorium or cap on the issuing of licenses to provide a breathing space for the industry to stabilise and while a new framework which addresses the key economic, licensing, and other issues is being put in place. 22