Roy January 11th, 2012
Some initial thoughts on some of the proposed actions in the Draft report:
Action: Plate Transfer
To introduce during 2012 a prohibition on the transferability of taxi vehicle licences such that after that date all taxi vehicle licences will be unique to the person to whom the licence has been issue and cannot be transferred or sold to another individual.
Thoughts on this action:
In the case of Corporate Plates, do they know the iperson” to whom the plate was issued and can they restrict ownership to that “individual” if the company is sold?
I guess once enacted it will stop further incorporation of plates
Action: Vehicle Standards
Following the recent vehicle standards consultation by the NTA proposing to strengthen vehicle standards, the vehicle age limit at licence issue or licence renewal for taxi, wheelchair accessible taxis and hackneys should remain at nine years for all new vehicles entering the fleet and for vehicles that have entered the fleet since 1st January 2009. For existing vehicles in the fleet prior to 1st January 2009, those vehicles will be allowed to operate up to 14 years of age, subject to passing a roadworthiness (NCT) test and an NTA Licence Renewal Assessment at six monthly intervals where
the vehicle is nine years old and above. Over a period of time, vehicles over nine years will gradually transition out of the fleet
Thoughts on this action:
Could it be argued that everyone who bought a replacement vehicle post 2009 were aware that the vehicle needed to be less than 9 years old and that it therefore stands that they knew the vehicle would only remain in service provided it was less than 9 years old ….whereas those that bought pre 2009 did not have that proviso in place.
Therefore a person who replaced their car in December 2008 with a 08 Mondeo can operate it for 14 years
And another person who replaced their car in January 2009 with a 08 Mondeo can operate it for 9 years
Seems unfair ……… but probably totally legal
Action: New WAT Specifications
To review the existing specifications for wheelchair accessible taxis and hackneys to establish whether an adjustment to the current wheelchair accessible vehicle standards would assist in increasing the supply and availability of wheelchair accessible vehicles. In particular, consideration will be given to relaxing the current requirement for the vehicle to be able to carry three passengers in addition to an occupied wheelchair, in order to facilitate the possible introduction of a wider, and potentially less expensive, range of wheelchair accessible vehicles into the SPSV fleet.
Thoughts on this action:
Will they continue to restrict new plates to a higher standard of entry or could this action (lower spec WAT) enable cheap entry to the business and a huge expansion in the rental sector
Clarification required?
Action: More power to the Gardai
To extend the current range of SPSV Fixed Charge Penalties available to An garda Síochána from the current single offence to a total of twelve specified offences. This will enable the Gardai to issue fixed penalty notices for breaches of the relevant regulations for a variety of offences, rather than having to pursue a prosecution through the Courts system as at present. This facilitates a more efficient use of garda resources, reducing the need for time consuming court prosecutions
Thoughts on this action
Since returning back to work after the Christmas I’ve witnessed the Gardai move on drivers queing to get on to legal ranks while ignoring illegal ranks nearby, the illegal ranks cause the stagnation of the legal ones (they set up closer to the action) I don’t trust the Gardai to behave any differently after they gain new powers
Action: Working Time
In order to ensure, in the case of part-time drivers, improved compliance with working time legislation, it is proposed to require a declaration by SPSV licence holders at licence application or renewal as to whether they have any other employment. Where answered in the affirmative, the application will require the submission of a form signed by the applicant’s employer confirming that they are aware that the applicant is seeking a SPSV driver licence or is the holder of an SPSV driver licence and that the applicant’s operation of an SPSV vehicle is compatible with his/her other
employment. In addition, the SPSV licence holder would be under a continuing obligation to inform the NTA and provide an employer confirmation form when he/she takes up other employment or changes employment.
Thoughts on this action
Provided this is administered fairly, (those working in second jobs have their time measured also) I have no problem with this action
Action: Rentals
To move towards a more professional taxi rental industry, it is proposed to prohibit the practice of the renting of taxi licences only (i.e. without vehicle), while facilitating the continuation of “full package” taxi rental, which includes the vehicle, complete with roof sign, taxi meter and printer.
Additional requirements will include that:
· The person/entity providing the rental is tax compliant and of appropriate character;
· The person/entity providing the rental has responsibility for the condition of the vehicle at
the time of rental and can only rent a vehicle in roadworthy condition;
· The person/entity providing the rental also provides insurance on the vehicle for the rental
period;
· The person/entity providing the rental must own both the vehicle and the SPSV licence; and
· Rental agreements (in terms of who has rented the vehicle and period of rental) are notified
on-line to the NTA database at rental commencement.
As part of the development of this proposal, consideration will be given to introducing a new licence
to operate a taxi rental business, without which it would be illegal to rent out taxis
Thoughts on this action
Without this:
Quote:
As part of the development of this proposal, consideration will be given to introducing a new licence
to operate a taxi rental business, without which it would be illegal to rent out taxis.
Rentals just blend in to the fleet and the whole sector will remain unenforceable, black market rentals will flourish
