letters ITC - Letters to Commission regarding €250 licence fee (and reply)

17/01/2010
Dear Commissioner.
Please be advised that the members of the ITC will be advising its members and affiliate members as of the above date and until resolution of the set out dispute, not to pay the arbitrary increase of the unexplainable 247e increase to renew our spsv licenses ie our ability to earn a living and provide food. lodging and education for our families.
We can think of no genuine reason to do so with the exception of expanding the NTA's budgets for providing new bus lanes and building new train stations.
The moneys given by the taxi industry (last count 23 million) over the last 7 years should be used for the betterment of the industry and nothing else. We the industry, state to you that we are in industrial dispute with your office and will pursue all legal and just human cause to pursue our aims in regard to your arbitrary decision to effect this unfair and unjustified increase.
Yours sincerely.
Frank Byrne,
Irish Taxi Council.
c.c.
Dept of An Taoiseach, Dept Transport,Dept Justice,OJCT,An Garda Siochana,Attorney General's office, all affiliate chairmen ITC,

Please conduct correspondence with ITC by phone or by email. Thank you

From: commission@taxiregulator.ie
To: franktbyrne@hotmail.com
Date: Tue, 19 Jan 2010 11:36:02 +0000
Subject: RE:

Dear Mr. Byrne,

I acknowledge receipt of your e-mail dated 19 January. The matter of the increase in the licence fee for an SPSV licence was explained to you as below in my letter dated 11 December last.

Renewal of licence increase to €250 euro - Prior to the introduction of the new fee in the Taxi Regulation Act (Small Public Service Vehicle Skills Development Programme and Driver Licence Fee) Regulations 2009 (S.I. 166 of 2009), the fee for a new SPSV driver licence had been set at €12 and the fee for renewal of same was set at €3. This fee had been in place since 1977 and had not been increased in line with inflation for 32 years. This meant that the cost involved in administering the SPSV driver licence system was considerably more than the revenue received from this licence fee and this shortfall was subsidised by the Exchequer. The increase in the licence fee mirrors the actual cost involved in administering the SPSV driver licensing system and ensures that administration, regulatory and processing costs are fully covered.

Yours sincerely,

KATHLEEN DOYLE

COMMISSIONER FOR TAXI REGULATION

Thank you for your prompt reply to our stated dispute regarding the objectionable increase of our renewal fees to 250e.

We acknowledge that you did indeed attempt to justify this increase in your correspondance of 11 december last. However may we point out the following:

1. The ITC, as a representative body do not accept, and never have, your explanation for this unconsulted and unjustifiable increase. If you wish to justify this increase then please provide us with the cost analysis report showing how this figure was arrived at. Indeed we would be placated if An Garda Siochana could supply us with their opinion of the costs involved.Also, the ITC would appreciate if you could provide us with an example of a similar increase level within any licensing system ie bus drivers, the normal drivers llicence, trading licenses etc. The percentages don't add up.

2. With regard to consultation, your employee Ms Sonia Mc Intyre has done a complete turn around by writing to my vice president, Brian Mc Carthy, on one hand confirming that this increase was indeed consulted with the TAC and on being proven to be incorrect then changing her story to say that the commision didn't have to consult with the TAC! Which is it? Are we to believe that the TAC is a genuine consultative body that will take into account the views and feelings of the operators in the industry or is it just a "tiger with no teeth" that will bend to your will? If this is true, why have the TAC? Even with the change of title within the regime of the NTA we wonder! By the way we are quite aware of the 2003 regulation act. Nowhere in the act is it mentioned that the TAC is an instrument of the regulators office as it appears to be now.

3. May I take this opportunity to clear up a few outstanding details, please provide us with the details of,as requested at our last meeting, consultation details ie, who and when, in regard to the skills development programme, the increase to 250e, the 9 year old rule and when steps are going to be taken to address the illegal activity in the rental/leasing market.