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JOINT COMMITTEE ON TRANSPORT debate -
Wednesday, 25 Mar 2009

Economic Review of Small Public Service Vehicle Industry: Discussion.

I welcome Ms Kathleen Doyle, the taxi regulator, and Mr. Bernard Feeney of Goodbody Economic Consultants. I also welcome the delegates from the Committee on Regional Development of the Northern Ireland Assembly who are in the Visitors Gallery. We are delighted to have our friends from Northern Ireland at this meeting. I understand they have had a productive day in Dublin thus far. We look forward to their presentation later in the meeting.

I propose that we begin with a short presentation by Ms Doyle and Mr. Feeney, after which there will be a question and answer session. Members received the comprehensive document submitted by Ms Doyle. Therefore, I ask that she merely provide a short summary of it. In keeping with our scrutiny and oversight role, I ask that she provide the details of the tender process for this contract, as well as the details of any previous contracts awarded to Goodbody Economic Consultants. We would also like to know the identities of the other tenderers, the prices they offered, the reasons the contract was awarded to Goodbody Economic Consultants and the details of any previous contracts offered in regard to the taxi industry. If Ms Doyle cannot provide all of this information today, I ask that she do so as soon as possible.

I invite Ms Doyle to make a short presentation.

Ms Kathleen Doyle

I thank the Chairman for inviting me to attend this meeting, together with Mr. Feeney, to discuss the economic review of the small public service vehicle industry. The Commission for Taxi Regulation engaged Goodbody Economic Consultants to conduct a review of the trends shaping the general environment in which the industry operated and an assessment of the economic impact of the liberalisation of the sector. Copies of the independent review which was published on 9 March have been circulated, together with a presentation of the key findings of the review.

I will briefly outline the scope of the review and the methodology used. The review focused, in particular, on supply and demand issues and industry earnings. As part of this, there was an extensive review of commission publications and statistical information. Extensive face-to-face consultations were undertaken with key stakeholders. Data collection was conducted through a series of surveys, with research into international experience.

One of the key findings of the review is that consumer demand has increased, with a minimum of 100 million trips being taken in 2008, placing an estimated value of €1.5 billion on the industry. The volume of cab trips has increased by 25% since the last economic review was undertaken in 2005. Small public service vehicles, including taxis, hackneys and limousines, are used more than other modes of public transport such as buses and trains. Although there is increased business use, social and recreational trips remain the main reason for using cabs. Nationally, 63% of trips are now arranged by telephone, while 37% are arranged on the street. The majority are taken between Thursday and Saturday, which reflects the predominantly recreational usage. While the review found that people with disabilities continued to have problems accessing services, overall trends show greater use of and confidence in the sector among the general public.

The review found there had been a significant increase in supply since the liberalisation of the market. For example, many second drivers of taxis, known as "cosies", have purchased their own licences. Between 2000 to 2003, significant numbers of hackneys transferred to taxis. There was lower growth in supply in the industry between 2004 and 2008 and a sharp decline in the number of new entrants since mid-2008. The limousine sector is growing, while the hackney service continues to be prominent in non-urban areas. Some 8.7 million work shifts were undertaken by the industry in 2008. Supply peaked between Thursday and Saturday but was less peaked than demand. The exit rate in the industry is not high.

As I mentioned, the report identified a deficiency in supply for people with disabilities, with wheelchair accessible licences accounting for only 6% of the overall fleet. Usage among this sector is low compared with that of the general population. This low usage is probably a function of both availability and affordability issues.

It has been difficult to ascertain precise data on the earnings of full-time drivers because of varying working hours and the fact that data received from drivers and consumers differed in terms of the average fare paid. While drivers stated the average fare was approximately €9, household surveys indicate it is approximately €15. The report found that drivers had to work longer hours to achieve their income targets, with some earning below the average industrial wage. The driving down of incumbent drivers' earnings is a normal effect of competition, but the review found that earnings were not collapsing.

Full-time drivers work, on average, 52 hours a week, with 25% working in excess of 60 hours and 11.2% working more than 70 hours. The part-time service provides a valuable contribution at peak time, with some 54% of part-time drivers offering service at peak times compared with 36% of full-time drivers. Part-time service is necessary as certain parts of the country could be deprived of a service without it. The commission can consider the capability of the taximeter for recording hours worked and drivers' earnings in the future.

As for dispatch operators, more than 400 such operators are registered with the commission nationally, with 40% of cabs affiliated to them. An increased number of business users use them. The figures increased from 50% in 2005 to 60% in 2008 and 90% of businesses are satisfied with the services provided. However, wheelchair users still encounter difficulties in accessing services from dispatch operators. Moreover, the review notes that increased affiliation to such operators could reduce external congestion costs.

In respect of congestion, there are 13,200 cabs versus 470,000 private cars in Dublin. Cabs, therefore, contribute approximately 9% of car kilometres in Dublin, whereas private cars contribute 91%. While cabs contribute to congestion, they also can reduce it during peak times when drivers leave cars at home and use SPSV services.

From an international perspective, New York usually is the entity compared with Ireland. However, it has a restricted market resulting in poor quality service, long waiting times and high levels of dissatisfaction. Therefore, we have used Washington DC which is more similar to Dublin in that there are no quantitative restrictions on entry, raised standards and a similar number of cabs per thousand of population. Other countries also have adopted regulatory models close to the Irish model, including Austria, Netherlands and Japan, and half of the local authorities in the United Kingdom.

As for the regulatory environment, the OECD and the World Bank support the approach to regulation adopted in Ireland with an emphasis on quality regulation combined with entry deregulation. Moreover, the current regulatory structure is supported by the economic review.

In respect of the impact of liberalisation, consumer use continues to grow, which is of benefit to consumers in terms of reduced waiting times and satisfaction with the quality of service provided. However, increased competition is making it difficult for drivers who had enjoyed low levels of competition prior to liberalisation. The market now is highly competitive and drivers work longer hours to achieve income targets. Enforcement activities have indicated low levels of non-compliance.

As for a possible moratorium, the review shows the decision as to what is an appropriate level of cabs should be left to the market. Current exit levels are not high and the rate of entry is in decline and, therefore, is not a reason for a moratorium. Congestion is not a reason for a moratorium, as peak demand at night time demonstrates the SPSV supply contributes to reduced congestion. The review also states the reduction in drivers' income is insufficient to justify a moratorium.

The commission proposes to take a number of next steps which are set out in the presentation before members. They include the consideration of fast-tracking of new vehicle and driver standards for incumbent licence holders. Details of the recommendations were advertised in national newspapers last Monday inviting submissions from all interested parties to give submissions to the Commission for Taxi Regulation by 5 May, after which the commission will evaluate all the submissions received and seek advice from the advisory council before making any further changes or introducing new reforms.

Mr. Bernard Feeney

Ms Doyle has outlined the key features of the report.

Before Mr. Feeney begins, will Ms Doyle be able to provide members with the information I have requested?

Ms Kathleen Doyle

On the tendering or public procurement process, I do not have details to hand regarding the other parties which tendered for the contract that was awarded to Goodbody Economic Consultants. Nor do I have the contractual information relative to pricing to hand but can supply it to the joint committee. I can arrange to do so tomorrow.

Ms Doyle also should provide information on any previous contracts awarded.

Ms Kathleen Doyle

The previous contracts were with Goodbody Economic Consultants.

On that point, when the contract for the consultancy was advertised, did the regulator indicate therein what was meant by "economic theory", "economic principles" and general theories of economics?

Ms Kathleen Doyle

We can provide a copy of the tendering document for the joint committee.

Did the regulator indicate what "economic theory" or "economic principles" meant?

Ms Kathleen Doyle

As I do not have the document to hand, I cannot recall the exact contents. However, we certainly can provide it for members.

The author of the report constantly refers to economic principles, theories and so on. We are going through a traumatic time——

Perhaps Mr. Feeney might indicate in his response——

——and those of us who have a background in economics would like to know exactly what the regulator stated were economic principles.

Perhaps Mr. Feeney might provide members with his interpretation of what they were, which may answer the Deputy's question.

Mr. Bernard Feeney

As I stated, Ms Doyle has covered much of the detail contained in the report and I do not propose to repeat it. However, I will emphasise a couple of points. First, the methodology we embraced involved substantial data collection, including household surveys and surveys of business users, cab operators and people with disabilities, as well as an extensive consultation process involving various stakeholders, in particular those representing cab operators. In addition — this probably will address the issue raised — I wish to emphasise that it is an economic review in the sense that it examines the issues that arise regarding the operation of the cab industry from the perspective of the impact of such factors or issues on the operation of the cab market. It considered all these matters and asked how the issues that had arisen were affecting the efficient operation of the cab market and drew conclusions on that basis. That perspective underpinned our approach to the assignment.

I will add a little on the issue of a moratorium. We considered it from a number of angles, most notably by considering the extent to which there might be excess supply in the marketplace and whether this might justify the introduction of a moratorium. Essentially, the conclusion to which we came in this regard was that if it could be proved there was a high turnover within the cab industry in the sense of large numbers of operators entering and exiting the industry within a short time, such substantial churning within the industry would be an indication that there was excessive supply. This would be a prima facie case for doing something or intervening in the context of a moratorium.

Will Mr. Feeney repeat what he said in respect of churning? He should explain what it is.

Mr. Bernard Feeney

This issue arises because one of the various arguments made on the question of a moratorium is that the cab industry is oversupplied. Consequently, from our perspective, it was important to try to define what oversupply meant. From an economic perspective, oversupply occurs when people enter the cab market with a view to achieving an anticipated level of earnings, find they are unable to so do and exit within a short period. As a result, the process of churning arises, which would maintain supply in a marketplace at a higher level than would be appropriate or correct. If such churning were found to occur, one could state the market was oversupplied and at least one would have a basis for coming to the conclusion that perhaps there should be some restriction on numbers or, alternatively, that some other way of reducing them should be introduced.

This is how we define oversupply in the market. When we examined the data, we found that at least in the period to date, this element of churning had not proved to be excessive. In other words, we do not see large numbers exiting from the marketplace. In addition, in recent times we have found that the numbers entering the cab industry are in decline. On that basis — this is the only evidence we have — we concluded that the market was beginning to stabilise in some fashion, that excessive churning was not taking place and that, therefore, one could not state the market was oversupplied. As a result, we drew the conclusions that we did, although we noted in our report that a situation could arise in which churning could become more excessive. In other words, if economic circumstances continue to deteriorate and as a result, there is an influx of new entrants into the cab market in the coming year, such entrants might find they cannot make a living within the industry or meet their anticipated earnings and might leave the industry within a short period and this churning process would develop. We recommended to the commission that it should monitor the situation closely and put in place a formal system of assessing the rate of entry to and exit from the industry.

What is the current——

Could we let Mr. Feeney speak?

He is not giving us the key point. What is the current churning rate?

Mr. Bernard Feeney

The entry rate is low, in that approximately 90 licences enter the market per month. The exit rate is approximately 6% or 7% per annum. Although it is rising, it is not excessively high. From these statistics, we know that the churning rate is not high.

Does Mr. Feeney not regard an exit of 1,000 people in six months as high?

Mr. Bernard Feeney

Approximately 1,900 people exit the industry per year. One should consider other jurisdictions. For example, New York's exit rate is approximately the same as Ireland's.

Mr. Feeney without interruption. I will allow questions when he is finished.

Mr. Bernard Feeney

The nub of our recommendations on the moratorium is the question of whether the market has excess supply. In our report, to which Ms Doyle referred in her summary, we make a number of recommendations on other issues, such as access for people with disabilities, improvements in quality control and the need to incentivise dispatch operations and to achieve higher levels of affiliation between dispatch companies. Does the Chairman wish me to go through the recommendations again?

Mr. Bernard Feeney

I shall re-emphasise two points, namely, that extensive data collection and analysis was undertaken and that this is an economic review of the industry based on economic principles.

I put it to Ms Doyle and Mr. Feeney that the committee's examination of the question on the moratorium did not relate to taxi drivers' income alone. Rather, it related to standards of service and the chaos in the industry. Using any objective criteria, Mr. Feeney has got this wrong. His report states:

Precise data on cab drivers' earnings are difficult to obtain. However, comparison of estimated earnings over time indicates that full-time Dublin taxi drivers experienced a reduction in nominal earnings in the period 2005 to 2008. This reduction has been mitigated to a degree by the fares increase granted in late 2008, resulting in a net reduction of approximately 5 per cent in gross earnings for this category. It is clear, therefore, that drivers' earnings are not collapsing as some industry sources would suggest.

This is a ridiculous finding. Is Mr. Feeney telling the committee that, between 2005 and 2008, Dublin taxi drivers experienced an income reduction of only 5%? He should answer this question first.

The report's methodology involved face-to-face consultations with key stakeholders, including national and regional industry representatives, and the completion of questionnaires by small public service vehicle, SPSV, drivers. When did the 5% figure arise during those interviews?

Mr. Bernard Feeney

Let me explain the basis for the earnings calculations. We have undertaken or been involved in such studies since 1998, when we undertook similar studies for Dublin Corporation. In that time, we have attempted to establish the earnings of cab operators by using various methodologies. I remember one instance in which we issued log books to drivers and asked them to fill in the details of their trips, earnings and so on, but we received little response.

We have learned that it is best to survey cab operators directly, either on a face-to-face basis or via postal survey, to try to get details from them in terms of their number of trips, working hours, average fares and so on and to build estimates accordingly. This was our approach in our 2005 review. A prime consideration during the current review was that we ensure consistency of methodology with the 2005 review, as this would give us an idea of the relative movements in earnings and recognise that any earnings estimates would be subject to the statistical errors associated with surveys.

The earnings figure was derived from our methodology. We sent approximately 2,800 questionnaires to cab drivers and received 512 replies. We analysed what they told us about their operations to arrive at an estimate of their earnings. We concluded that, as reported, their annual gross earnings amounted to approximately €33,000 each. Taking operational costs into account, full-time cab operators' net earnings amounted to €16,000 or €17,000. Our study found that hourly net earnings are low because drivers operate an average of 52 hours per week, as Ms Doyle stated. This is an increase on the 2005 estimate. Their hourly earnings are below the average industrial wages of manufacturing workers or other groups.

Using the same methodology, a comparison of the 2005 and 2008 figures showed that, prior to the fare increase, drivers' nominal earnings had decreased by approximately 13%. Given the fare increase's impact, we surmised that the difference could be reduced to 5%. We also found that the number of hours worked had increased by an approximate average of 10%.

There were 500 responses. What did the extensive face-to-face consultations with key stakeholders reveal about incomes?

Mr. Bernard Feeney

Operators complained that their incomes had decreased and that they needed to work longer hours.

How large was the decrease?

Mr. Bernard Feeney

Some individuals claimed to be down by 10% or 20%. There was a range of replies, but we cannot rely on that type of individual response. Considering the earnings reported to our study and their distribution, there is a difference between individual cab drivers. Some reported low earnings. For example, a significant number reported gross earnings of less than €20,000. Others reported earnings of greater than €40,000. There is a variation.

Before I hand over to Deputy O'Dowd, the methodology described in the report is like reading the front of The Beano. Mr. Feeney has no idea about drivers’ incomes. The driver of any cab into which one gets will tell one that he or she is earning below the minimum wage. They cannot all be fooling us. I have been in five or six cabs in recent weeks, the drivers of which told me that they earned €50 over eight or nine hours. The report’s finding is ludicrous and every cab driver in this city and throughout the country is hopping mad about it.

I defend Mr. Feeney's right to put his profession on the line at this meeting and to supply this report. I accept his professional comments and disagree profoundly with the Chairman's choice of adjectives, which were unfair and unprofessional.

I wish to address a different question and to home in on the core issue. Churning involves people leaving the industry. The problem lies in that there is nowhere for them to go. According to Mr. Feeney's report, were I a cab driver, my wages would undoubtedly be decreasing. We all know that this is the case. The market is contracting. In terms of public transport usage, the number of Luas trips has decreased by more than 1 million in the past year. Journeys on the Luas and Dublin Bus have declined significantly so it is a fact that taxi drivers are in the same position. I will not go into the point that self-employed people return different things but the point is that their standards of living are dropping.

The report states:

The present regulatory system has worked well and should be retained. There is an insufficient justification at present for an adjustment to the regulatory structure through the introduction of a moratorium.

When did Mr. Feeney finish this report? What was the date and time he stopped analysing the figures?

Mr. Bernard Feeney

We stopped after Christmas, in early January. The latest data we used were the number of new licences issued. We had the February figure before we went to press.

The points I must listen to and the things I see on the street are that the market and incomes have collapsed since then. There are thousands more unemployed people. I respect the professionalism and integrity of Mr. Feeney and I accept what he is saying. Since that time, when Mr. Feeney finished preparing the report, the situation has changed radically. While I have problems with a blank moratorium because of the issues such as the number of cabs adapted for people with disabilities and I have a problem with saying that if 100,000 people become unemployed, none of them can become taxi drivers, we must address the fundamental issue for change in some form of moratorium, although I do not want to use that term. It must be made more difficult. These taxi drivers cannot go anywhere else. Anywhere they go in Dublin or in Drogheda there are lines of taxis and no one is using them.

As a committee, we must take on board what is in the report but because of the changed economic circumstances, we must re-examine the conclusions. I accept the integrity of what Mr. Feeney is saying but things have changed since then.

I return to the first question I asked the Goodbody consultant. Mr. Feeney refers to economic theory, principles and the economic view of the market in the summary and recommendations of the full report. Whose principles are these? Is it the Queens University economics approach? Is it the Dublin University approach or that of my alma mater, UCD? Is it the London University approach, the Cambridge University or the Chicago school? What economic principle is Mr. Feeney referring to?

Mr. Bernard Feeney

There are certain commonalities across a wide range of teaching institutions in terms of what economics is about. That commonality has been embraced by regulation across a number of sectors in Ireland. It applies to taxis, telecoms and electricity. There is a well-founded and established view of how the market works, how it should work and what regulators are doing to improve the efficiency of the market. This is found in textbooks that deal with microeconomics that are taught in all universities.

Mr. Feeney states that he received responses on earnings from 500 people. In recent weeks 3,000 to 4,000 appeared at one time in front of the Dáil. These are family men and women with small families who tell us a difficult tale of their struggles to earn any kind of living in the current market place with 27,000 licences. I met more than 500 taxi drivers and have walked around town with them. I have listened to the serious situation of these families. Did Mr. Feeney take into account the human side of this? This market is operated by real people.

Regarding earnings, did Mr. Feeney discount the entry costs and the fact that so many drivers are part-time and a significant number of drivers have a full-time second job? Somebody may be happy to earn just over the minimum wage if he is working in this House as a civil servant and will be a taxi driver later tonight. That can be the case.

Mr. Bernard Feeney

The report says that hourly earnings in the industry are well below the average industrial hourly earnings.

Is that acceptable?

How much are they?

Mr. Bernard Feeney

A reasonable estimate is €11 per hour.

Is that the gross or net income after expenses?

Mr. Bernard Feeney

It is net income. There is absolutely no argument that earnings are low in the industry.

They are low and they are falling. They have fallen significantly since 2005.

Mr. Bernard Feeney

The Deputy may be right, given the way economic conditions are deteriorating, in saying they will fall further.

Regarding Deputy Broughan's other point, I understand that since deregulation of the market the average earnings of drivers has tended to fall. There were substantial earnings prior to 2000. There has been a decline since then and hourly earnings are low. I understand that and no one likes that.

The basic table on the earnings shows that over 75% of all drivers earn less than €40,000 gross. Is that not the bottom line?

Mr. Bernard Feeney

They reported that.

Mr. Feeney worked that out himself.

Mr. Bernard Feeney

We are not in disagreement on that point. This refers to reported earnings. I refer to the Chairman's comments on our surveys. When we survey individuals about their incomes there is a tendency to understate incomes. That is true of most of our experience. When cab drivers report earnings we tend to think they may be on the low side. Having said that, I do not deny what the Deputy states, that earnings are low. The kernel of the matter is that if one were to introduce a moratorium on the basis of those earnings, it would amount to the State intervening to maintain the incomes of a particular group of workers. One must then ask the question that if for cab drivers, why not for road operators, bus drivers and so on?

We are not suggesting that.

Mr. Bernard Feeney

There is a principle one must establish.

The idea of a moratorium as it emerged from this committee was to try to bring order to the industry. The earnings of cab drivers comprise only one small but significant part of that. When we first received a report from the regulator she told us about a number of initiatives that were to be undertaken by her office that have not been possible owing to the inability to come up with the money, the shortage of manpower, the fact that there are only nine regulators and the fact that the Garda Síochána was supposed to hand over the testing process, which was a farce.

The group from Northern Ireland told the clerk to the committee that when they asked for a cab from Connolly Station to Buswells Hotel. The cab driver did not know where Buswells Hotel was nor how to get to it. This chaos is in the industry and the regulator's inability to deal with it effectively is the main reason this committee suggested a moratorium, although it is not yet agreed. The moratorium would enable the regulator to put some order on the industry.

I have a brief question on the hours. A damning conclusion of the report is that one quarter of all drivers are working more than 60 hours. An astonishing proportion of those drivers with a second job are working 70 hours and upwards. They do a full-time job and then work an extra 20 or 30 hours. To what extent was this factored in on the economic side? We have the EU working time directive. Did either of the witnesses run this situation past the Health and Safety Authority? Does the regulator consider it has any implications for service quality and for the basic working conditions of taxi workers?

Deputy Broughan raised many of the issues I want to discuss. We seem to be stating that we will stay as we are and that we cannot do anything about this business. Many people will become unemployed and the first thing a high percentage of these people will go for is a taxi. To give an example, I met a civil servant who has a good pension and who is driving a taxi. He told me he goes out only when it suits him. We have an artificial type of service because a large number of people who work in the taxi business are not dependent on it for a living. This creates a problem.

On Deputy Broughan's point that drivers do not know where they are going, a high percentage of them use sat-nav. I think these should be banned in taxis because they do not always give one the shortest route from A to B. Many fraudulent people work in the industry and very little is being done about this. The only way to sort this out is to introduce a moratorium to get a handle on it but this is not happening. It is unfair to people. The old type of a taxi driver who worked hard for a living and who has been there for many years is being squeezed out of the business by people who are not dependent on it for a living. This is the bottom line. As Deputy Broughan stated, we must take into account people's livelihoods. We cannot make it so difficult that it is not worth one's while working.

There are other issues with regard to taxi ranks, such as the one on Amiens Street which I passed this morning. Every morning, the street is jammed up by taxis and it is only a matter of time before a serious accident occurs in the area. There is not enough room for the amount of taxis on the road. We receive reports to beat the band but we do not seem to be making progress. What are the witnesses terms of reference for these reports and what do they cost?

I welcome the witnesses to the meeting. We have discussed this matter at great length over a number of weeks and months. Naturally, I accept the level of professionalism Mr. Feeney has put into this report and I am not in a position to question his findings because I do not have the professional knowledge. We will work on that basis.

I would be the last person to want to interfere with open competition and I have always stated this. Somehow or other the message of what this committee wanted to do seems to have been diluted or twisted. To my knowledge nobody here wants to interfere with open competition in the market. It would be bad. It was bad before the liberalisation programme but now, based on the people I meet and the evidence I can gather, so many families depend on income from taxis that over the past six months it has fallen asunder.

The fanciful term "churning" was used. Many more people would exit the industry if they had somewhere else to go but they do not. There is nowhere to go. They have paid their money and established themselves and it is their job to ferry commuters to where they want to go. They work extraordinarily long hours. I saw comments made by taxi drivers and many of them disagree with this. However, a number of fundamental points show that they work in a very poorly paying industry. This is the bottom line of the document. It reminds me of the dairy farmers and how their incomes have tumbled. Something must be done about this industry as it must be done about the dairy sector. What can be done is another matter.

I see nothing but great sense in implementing a moratorium, and a term of three years has been mentioned. All we are speaking about is slowing down the system and having no newcomers for three years. This will provide the regulator, Ms Doyle, with an opportunity to do all that she told us had to be done on the last occasion she was before the committee, with which I agree. I will not go through the raft of measures that the regulator's office must take and which Ms Doyle agreed she must do. Whatever the reason for not having done them surely there will be a better chance of implementing them over the next three years without an intake of newcomers into the industry. I hope a moratorium is introduced and that the mechanism used will automatically remove it after three years and that there would be no danger that a Minister or committee would even dream of extending it.

The taxi industry is very unsettled and does not know where is its future. It has been particularly badly hit by the downturn of the past six months. All one needs to do is mention the average of 52 hours per week which Mr. Feeney found people had to work for €40,000 gross income which would leave one with a net income of €16,000 or €20,000 after everything has been paid. This is a very poor return for their labour. It makes great sense that, provided all the other measures mentioned by my colleagues and by the regulator at a previous meeting are taken, a cap on numbers is put in place for three years, with not an hour of an extension, to let us see whether the business can be streamlined and provide the people in the industry with an opportunity to make a reasonable living and at the same time ensure that at all times the public has the best possible taxi service.

Deputy Connaughton makes great common sense.

Mr. Bernard Feeney

Ms Doyle would be better placed to address some of the issues raised. With regard to the implications for safety of the extensive hours that cab drivers work, one has a negative gut feeling that they are excessive. At present, legislation on the working time directive does not impact on self-employed operators so it cannot be relied on to make a change and reduce the hours. Therefore, one must examine other measures. In our report we state firmly that the key is not so much whether a particular driver has another job but the number of hours worked and whether they should be restricted. The report explores some means by which restrictions might be placed on working hours. It would be difficult to establish and monitor the working hours of drivers. It would not be an easy or inexpensive thing to do in that regard.

We were unable to find evidence that long working hours were having an impact on road safety. One would anticipate, for example, that higher insurance premiums for cab drivers would reflect the safety implications of their operations but that was not the case. Evidence from the UK suggests no particular contrast between regulated and deregulated authorities in terms of the impact of extended working hours on safety. Although one may be uneasy about the hours worked from a safety perspective, there is no clear empirical evidence to support the suggestion that cab operators are unsafe in that regard. We recommend in our report that a closer investigation be made over time to establish whether safety implications arise and, if so, the methods that can be put in place to address them but we have no solutions at this juncture.

In regard to earnings in the industry and the fact that earnings are declining and may decline even further in the future, we must recognise from an economic perspective that while incumbent drivers may experience a dilution of their earnings, those entering the industry gain in terms of enhancing their incomes. A balance must be sought in any analysis on this issue. If entrants to the industry do not remain in it very long and they are entering irrationally, this indicates that the market is not working properly and, as an economist giving advice on this area, I would have to consider a moratorium if it could be proved that the element of churning was quite substantial.

Questions were also raised about a moratorium to give time to introduce other reforms to the industry but this is outside my area of responsibility.

Ms Kathleen Doyle

I would like to address the issue of working hours and the question of whether we are in contact with the Health and Safety Authority. I can confirm to members that we have corresponded with the Health and Safety Authority, the Road Safety Authority and the Garda Síochána in regard to working hours for drivers.

Mr Feeney has advised us that the working time directive does not apply to self-employed small public service vehicle operators. However, I sought the views of the aforementioned organisations regarding the length of time that taxi drivers are working and the fact that some may be working in full-time jobs before going on to drive or may be driving at night before going to work the following morning. The opinion of the Health and Safety Authority is that drivers are responsible for putting a risk assessment in place because as self-employed drivers, their cars are places of work. They must put such risk assessments in place for both themselves as drivers and for the passengers they carry. If they are in full-time employment, they also have responsibilities to their employers to undertake a risk assessment and to inform the employer of any risks that may impact on their job.

The Road Safety Authority expressed concerns about driver fatigue and felt that adequate rest times should be observed before somebody in full-time employment began driving a taxi, especially during evening hours. It took the view that a driver has a personal responsibility for ensuring he or she is fit and alert before beginning work.

The Garda Síochána pointed out that rules and regulations were formerly in place requiring applicants for small public service vehicle driver licences to undertake that they were available to provide a service over 40 hours per week. That condition was removed by the then Minister for Public Enterprise in 1998 owing to the fact that people wanted to provide part-time services, especially in rural areas where 20 hours per week might comprise an adequate service. A regulation was subsequently put in place prohibiting drivers from driving more than 11 hours per day over any three consecutive days. However, this regulation is difficult for gardaí to monitor because there is nothing in the vehicle to indicate the number of hours driven. We intend to examine the capability of taxi meters in this regard. We are in discussions with Legal Metrology Services, which is responsible for the sealing of taxi meters, and we understand that meters are capable of recording working hours and industrial earnings.

Is it correct that Mr. Feeney received 600 responses to his survey?

Mr. Bernard Feeney

We received 512 responses.

How many of those respondents were personally interviewed to verify their responses?

Mr. Bernard Feeney

It was not possible for us to do this because we wanted to assure drivers they would be anonymous. In other words, we wanted them to feel free to divulge details about their incomes in circumstances where they could not be identified.

Does Mr. Feeney mean to say that he carried out a survey without giving respondents an opportunity to make submissions in person? He has taken for granted that what the respondents submitted on paper was the true position. It is unacceptable in any walk of life that one can carry out a survey, even if it is merely an opinion poll, without seeking verification. This report has been thrown together at enormous expense. I have no doubt we will hear more about its cost. It is totally out of line to base a survey on what is submitted by individuals without verifying their responses. Did Mr. Feeney seek meter readings to verify, for example, the number of hours worked or fares carried per day? Did he get anything from them other than a document full of ticked question boxes?

Mr. Bernard Feeney

I cannot understand the meaning of Senator Ellis's question. If we ask individuals to tell us how much they earn and we receive this information in a written response, why should we ask them again about their incomes? I have to assume that they have had an opportunity to tell me the truth as they saw it. This issue does not arise in surveys whatsoever. I do not see the sense in it.

We tried to verify our information in various ways including, for example, seeking information from consumers on the trips they take and the fares they pay to build up estimates on earnings. We have tried in the past to persuade cab drivers to operate a log system in which they would record day to day the number of trips they make and the fares they receive but we have discovered this is not practicable because of a lack of response on the part of drivers. We are anxious to get the best information possible but it is a universal experience that income information is the most difficult question to ask people in surveys and questionnaires.

There is a simple answer to this problem. These people are all tax compliant and if Mr. Feeney wanted to verify their responses, he should have sought their tax returns which I am sure they would have been more than willing to share. This is a business that is going downhill at a significant rate in regard to service, the standard of vehicles and the livelihood of the people involved.

Has the commissioner done any work in having an examination, as there is in London, prior to a licence being granted? Is such action planned? As the Chairman intimated, one can get into some taxis in this town and if the passenger does not know how to get to the destination, he or she will have no chance of getting there, unless he or she wants to go on a merry-go-round.

Ms Kathleen Doyle

We are rolling out a new skills development programme which will replace the Garda test. We are in consultation with the Garda and it will switch off the Garda test some time in the summer. We will then roll out the programme for new entrants and for incumbent drivers. It will be phased in over the coming years.

Will that include a knowledge of Dublin test or a similar exam for Galway, for example?

Ms Kathleen Doyle

It will be a test of knowledge of the county in which the people are operating.

Will it be a physical interview?

Ms Kathleen Doyle

No. The contract has been awarded to Prometric, which is the same company that operates the driver theory test. An examinee will go into a booth and answer multiple choice questions with one correct answer.

The key issue in the knowledge of London test is that a person attends for interview and would be asked how to get from Westminster to Piccadilly, for example, and the streets they transgress. That seems to be a basic requirement of anybody driving a taxi.

Ms Kathleen Doyle

May I respond?

That should be a part of any new test being put in place.

Ms Kathleen Doyle

The new test has already been awarded to Prometric.

Without an interview where people are asked to give information akin to a knowledge of Dublin, it will be a waste of time.

Ms Kathleen Doyle

It is currently being done in writing and will continue to be so. It will be an in-depth test and one must have the route selection knowledge in his or her head to answer the questions.

I have some points to put to our guests, whom I thank for attending, as well as a question. A justification has been put forward for a moratorium on licence issuing within this industry. I made this point in the last meeting we had on this topic. I find it very difficult to justify any policy with an objective to protect the income of people within that industry. Like everybody else around this table, I am rapidly dealing with the consequences of people who are unemployed. To say to somebody who has just lost his or her job that there is no opportunity to enter a particular industry because there is a need to protect the income of people within the industry is something with which I struggle. I emphasise that point, which I made publicly the last time we discussed the matter. It is relevant to this debate because all the discussion we have had up to this point regarding this report has been about saying that the need to justify a moratorium is to protect the income of people in the industry. If that is the rationale we put forward, I disagree with it.

That is not the rationale.

I would like to finish my point. I will keep on speaking.

The Senator should speak for himself.

I am speaking for myself and I have made that clear up to this point. I have a right to express my own points in this committee.

The Senator should not indicate that he is speaking for us.

Did I say at any point that I was speaking for anybody else?

The Senator spoke of a rationale for a moratorium coming from this committee.

If the Deputy listened to me——

——I stated that the rationale for the moratorium is in this report, not that it is emanating from this committee. If the Deputy is taking the time to interrupt me——

——I suggest he takes the time to read the record of what I said. I referred to the justification for a moratorium in this report, which is about the need to protect the income of people in this industry.

Before the Senator came in, we stated clearly that the committee's rationale was not a moratorium to protect anybody's income.

It is about standards.

It is about trying to restore order and standards to the industry.

People's income is one part of this.

The point I was making is that in this report, the justification put forward for a moratorium is the need to protect the income of people within that industry. I cannot agree with that rationale in the current environment of increasing unemployment, etc.

With regard to the objective for the kind of market we want to have operating here, we have seen the consequences of that kind of market operation in other parts of our economy. With the kind of deregulation I believe is being advocated here, we have seen the consequences of it within housing and banking sectors. There is no adequate regulation in place in that regard. We must learn from that in the discussion we are having here. The approach of light-touch regulation and so on is not working.

If we are looking at a justification for reducing the number of people who can enter into the industry, I would consider whether the revenue levels within that industry will be sufficient to justify and fund the standards of service we hope for in the industry in future. If we are to say the average income per hour within the industry is approximately €11, it would suggest that the money will not be in the industry to fund the kinds of quality improvements we are seeking.

I have indicated that I would have some difficulty with the idea of a moratorium but I would be in favour of giving the regulator the power to determine how many people should be operating within the industry. The outcome of this is maybe to indicate that there should be a moratorium or that fewer people should enter the industry than in the past. If there is to be a regulator, it should have the ability to determine who is playing within that industry. I struggle with a position where we have a regulator without that power.

I thank the witnesses for coming in today. My initial response to the report was that a normal industry and market was being assessed, although the market is shrinking very fast. I know this was done two years ago. The report does not seem to allow for the fact that this industry has many individuals operating their own businesses. It is not like looking at another industry in the country. At the moment we have far too many people in it and we have asked for a moratorium in this committee and to look at uniformity of standards and quality of service. We must also consider how so many people are trying to eke out a living as they are having difficulty reaching normal income targets.

The suggestion in the report that 51% of part-time drivers offer a service at peak time is worrying. These people either have other employment or are retired and augment their income. That these people are doing this work is very worrying, with only 36% of our full-time drivers doing weekend work. I know Ms Doyle was asked about this earlier. I am still not satisfied that anything will be done about that.

Ms Doyle indicated that the drivers must clock up the number of hours that they work and report to their other employer if they do more than a certain number of hours. Stronger action must be seen to be taken on this as it is leaving many of our full-time drivers in a very bad position. People are not leaving the industry because they have nothing else to do and people going into this industry are not sitting down, looking at the market and carrying out commercial research. Such people may have lost work and may be looking for another job. There is much to be done in regulating the industry, which is worrying.

I welcome Ms Doyle and Mr. Feeney. I appreciate that they have a difficult job to do. In this committee we are trying to reach a fair and equitable solution which provides enough taxis for the public while ensuring there is some market there for everybody.

We have failed in the provision of wheelchair-accessible taxis. In 2000, 21% of taxis in this city were wheelchair-accessible, but that number is now only 5%. In the UK, 52% of taxis are wheelchair accessible. We might send a message to the Government. The programme for Government aims for 100% wheelchair accessibility among taxis, which is clearly not achievable, and the six major disability groups are quite happy with 20%. We should immediately consult the Minister fro Transport regarding subsidies for the purchase of accessible taxis and have a realistic goal, for once, of 20%. Representatives of the major disability groups appeared before the committee a few weeks ago and I compliment them on their report. They were quite happy with 20% and that is what we need to aim for. The target of 100% in the programme for Government should be slashed to 20%. In rural areas there is an absence of alternative transport, and fewer wheelchair-accessible taxis or hackneys is a major disadvantage in those areas.

There are obviously major discrepancies between the driver data, which gives a number of 16,150, and the household survey, which gives a figure of 40,350. That represents a difference of nearly 25,000. I will not call it a black economy but there is something happening there. I have seen in the Netherlands and other countries the use of taxi meters to record working hours. This has been going on for 25 years. In the Netherlands every taxi driver gives a written receipt. The only way we can clarify the inequity is to have written receipts. What do the witnesses propose? Have they met the taxi drivers in this regard? We will never find out what taxi drivers are earning from their data or from household data.

There have been major improvements in the past ten years in the number and quality of taxis. We must work together to resolve these difficulties. However, we are in a very difficult market.

It is Mr. Feeney's first time to appear before the committee and there is no question about his integrity, which we respect. This is nothing personal with regard to himself or Ms Doyle. We have the height of respect for both of them. However, I do not accept the accuracy of the findings in this report. This committee wants competition in the taxi industry. It is critically important. We also want good standards, which means that the people in the industry earn at least a minimum wage. We have obtained legal advice as to the avoidability of a moratorium and it is a matter for the Minister, not the regulator. The idea of the moratorium is to enable the regulator to bring about the standards and control in the industry which we are satisfied, from the evidence we have been given, does not exist at the moment. At the last meeting we presented false licences. It was confirmed by members of the Cork Taxi Drivers Association that they were able to have their licences photocopied and laminated, after which they could do anything they wanted with them. They were presented as a test in Cork and of course they passed because they look authentic.

Will the witnesses confirm that in addition to the 27,000 taxi plates in existence, there are 46,000 PSV licences? Will they inform us how many applicants are waiting for a test for a PSV licence? I could not get a reply to this in a recent Dáil parliamentary question.

May I add a brief addendum?

Yes. On that basis, I put it to Mr. Feeney that his findings about churning cannot be regarded as accurate. There could be five different drivers on one taxi. It appears this is one of the things that is happening. We have been given evidence by the taxi driver associations that there is an illegal trade in taxi licences. There are ads about this every day in the Evening Herald and other newspapers. Because only nine inspectors are employed by the taxi regulator for the whole country, it is impossible to trace the illegal activity that is going on. The Garda sees this as a responsibility it lost some time ago with the establishment of the taxi regulator. When this committee first raised this issue with the Garda, it was not a big issue for them. The responsibility that used to be that of the Garda has been taken over by the regulator, who has not been given the resources for proper policing. This, again, is part of the reason this committee has come up with the suggestion for a moratorium for a specific period of time. By the way, our legislative proposals can be lifted at any time if necessary. In this way the taxi regulator would have an opportunity to bring order to the business.

To reiterate what the Chairman is saying, what people want is a taxi market in which the workers can earn a decent living and put bread on the table. Was Mr. Feeney asked to evaluate the regulator in any way? It seems to the workers in the industry that there has been a complete failure of regulation. Many of them, on their demonstrations over the past three or four months, have compared this to the failure of financial regulation. We had a disastrous Financial Regulator which did not do its business, and this led to the country being faced with near economic collapse and has placed us in a dangerous situation. In a similar way, there has been no taxi regulation whatsoever for the past four years. I welcome Ms Doyle to the committee, but she is always telling us things she is going to do — something will be done next year, later this year, in 2011 or even in 2012, for vehicle standards. It is always in the future. I am not saying this is necessarily her fault. When was anybody stopped by the nine inspectors? Not many people are stopped by the Garda Síochána generally so how can we expect nine people to invigilate 30,000 others? It seems ludicrous.

I had the privilege, following representations from the Chairman's home city of Galway, of watching Galway taxi drivers doing their business a few Friday nights ago at 10.30 p.m. or 11.30 p.m., and seeing the problems they illustrated for the Chairman at first hand. They are saying there is no regulation. That is another way of looking at it — we do not have regulation of any kind. That is the problem. Calling it light-touch regulation is a joke. It is non-touch regulation in financial circles and it seems to be the same in taxi circles. We want a well regulated sector that gives people a fair and decent living. Is that too much to ask? That is why I go back to the economic principles. Mr. Feeney and I have similar backgrounds but we do not agree on the principles. That is the problem with this report.

Mr. Bernard Feeney

With regard to the last point about our role vis-à-vis the regulator and so on, we were asked to assess whether the quality of service had deteriorated as a result of liberalisation, and one of the findings of our report was that consumers are generally happy with the quality of service as well as the quantity. We looked at that aspect of regulation from the consumer’s point of view. We are also concerned with some other aspects and wonder if there is a level playing field with regard to the operation of the market, and between groups of taxi drivers. We are concerned about compliance with the regulations because the level playing field would not be level if large numbers of individuals were getting away with non-compliance. From these two points of view we looked at other aspects of the regulatory system but it was not our job to assess the role or impact of the regulator per se. I reiterate that.

The Chairman asked whether there are large numbers of drivers operating with one vehicle with the result that many more people are in the trade than indicated by the number of vehicle licences. In our consultations with the different interests, this point was not made forcefully to us but we know it occurs. In the old days of cosying, that was the prevalent mode. There is no hard and fast data on this but we gleaned from market intelligence that while it is not a substantial issue it may be on the rise. I agree with the Chairman that when considering the issue of journeys, one would have to look at drivers as well as vehicles in order to try to——

What examination did Mr. Feeney make? Can he confirm how many people have PSV licences and how many were on the waiting list when he completed his report?

Mr. Bernard Feeney

We do not have a clear fix on the number of drivers active in the market who are not owner-operators.

How then can Mr. Feeney come up with any recommendation on the amount of income these drivers have?

Mr. Bernard Feeney

We can base it on the large body of drivers, presumably the majority, who are owner-operators.

The report does not refer at all to the fact that there are 46,000 licences. Perhaps the regulator might confirm that figure.

Ms Kathleen Doyle

That is the figure for the number of licensed drivers but it does not necessarily mean they are operating. I shall give an example. When we rolled out, on a country-wide basis, identification cards to be placed on dashboards and smart cards to be carried, the take up was not anywhere near 46,000. There were approximately 42,000 drivers at the time of roll-out, in the year before last. The take-up then was in the high 20,000s which indicated to us that although people might have a small public service vehicle, PSV, driver licence they might not necessarily operate in the industry. Many people undertake that particular programme in order to add it to their CV but they may not use it. The take-up of the driver licence ID system for all the vehicles, which can be seen clearly in all vehicles, was in the high 20,000s which indicated that approximately 15,000 people did not acquire the cards but have a licence nevertheless.

It will be interesting to see what occurs, next time round, when they come to renew their licence because they will have to undertake the new skills development programme to be rolled out by the commission. That will put another onus on them, having to do another test before they can renew their licence. That will indicate who intends to operate in the industry.

How many are, or have been, waiting for PSV tests?

Ms Kathleen Doyle

The latest figures from the Carriage Office in Dublin show that approximately 1,400 people were waiting for Garda tests.

That means 1,400 people are waiting to get licences to get into the business at any one time.

Ms Kathleen Doyle

That is to get a driver licence but whether they intend to operate in the industry remains to be seen.

One would expect that if they apply for a PSV licence they intend to operate in the industry. There is very strong evidence from the taxi driver associations that there is a problem because significant numbers of cars are being driven by several drivers. That is where some of the illegal activity is occurring. The associations claim there is no proper control over that. The illegal activity is almost wholesale in that situation and is very difficult to control. As Deputy Broughan stated, when the regulator's investigator arrives in Galway, half the taxis disappear from the rank because they hear an enforcement officer is around. They are hardly going home for their tea.

Ms Kathleen Doyle

That happens right around the country when the enforcement team arrives on the scene. Having said that, I mentioned that we have nine enforcement officers to examine compliance across the country. As the Chairman knows, gardaí are authorised officers under our legislation. We have agreed with the Garda Síochána on planned joint operations that commenced in 2008. We had more or less ad hoc arrangements last year whereby when we went into local towns or cities, we informed the gardaí and had joint operations. We now have a planned strategy for national operations throughout 2009 with the Garda Síochána.

Were there any check points during the St. Patrick's bank holiday? Constituents complained to us that not only were there no checks on taxis but there were no checks on anybody.

Ms Kathleen Doyle

People were checked during that time but the Deputy will appreciate that we have nine officers who work with local gardaí. We have planned rotas around the country. In addition to the ordinary operations and examination of compliance, the enforcement team must investigate the complaint system we take from the Garda. They have quite a large amount of work.

Is Ms Doyle saying that people disappear from the ranks when her regulators go around the country? What does that tell her?

Ms Kathleen Doyle

It has happened, and it also happens when gardaí appear on the ranks. It is a fact of life that when enforcement officers appear on the scene a number of people may disappear from the ranks. That is not to say the enforcement officer will not stay around to find out what the situation is when these people come back. They do this.

Do they not do road checks outside the city boundaries or some miles from the ranks?

Ms Kathleen Doyle

Those would be the Garda operations. Our enforcement team do not have the power to stop a vehicle, under the legislation. The Garda has that role and the joint operations commence with the checks outside towns.

They could check a driver who was discharging a passenger.

We will allow Ms Doyle conclude.

Ms Kathleen Doyle

Concerning the planned operations, if these take place outside a town and involve road checks they are Garda operations. Our enforcement team will be in local towns where they will contact the Garda and local PSV inspectors in a joint operation at taxi ranks in the area.

If a taxi were taking a passenger on board, or if a passenger were disembarking, can the enforcement officers make a check?

Ms Kathleen Doyle

They could, because the vehicle would be stationary.

I thank Ms Doyle.

Ms Kathleen Doyle

An introduction of standards was mentioned as opposed to a moratorium on the basis of industry earnings. There was a public consultation process concerning the introduction of new standards, for both driver and vehicle. We will have this on a phased basis for incumbent drivers beginning on 1 January 2012, as a result of the response that came back from the industry. This takes note of drivers' financial packages by which they purchase vehicles and have three to five year years to pay for them. For that reason, they requested that we introduce vehicle standards on a phased basis and we respected that.

When will the nine-year rule be in operation?

Ms Kathleen Doyle

That rule operates for new entrants since 1 January 2009.

Is there any intention to introduce a time limit so that people who get an ordinary licence will not be allowed to carry passengers straightaway? Ms Doyle's colleagues in the Road Safety Authority are working on this. Under the taxi regulator's regime such people are allowed to ply their trade as taxi drivers. Has Ms Doyle considered this point? I asked this question on a previous occasion.

Ms Kathleen Doyle

Is Deputy Broughan referring to a driving licence? At present, the requirement for a small public service vehicle driver licence is a full——

In Ms Doyle's last report she stated that her invigilators, such as they are, stopped 53 people who had no driving licence. That is unbelievable.

Ms Kathleen Doyle

That is correct, and they were prosecuted. If a person has no vehicle licence or driver licence, he or she will be prosecuted——

Does Ms Doyle think it is right that a person can get a licence in this way? The committee has heard Mr. Noel Brett and Mr. Gay Byrne on this matter, and St. Patrick's weekend was a very bad one in respect of road casualties. Does Ms Doyle think it appropriate that a person can proceed immediately to drive passengers?

Ms Kathleen Doyle

That is something that we will be discussing with the Road Safety Authority and we will consult with it in respect of new drivers. Is Deputy Broughan referring to persons who have passed their driving test and make an application? The situation now is that they can apply for a small public service vehicle licence.

Has Ms Doyle not considered that it might be a good idea to have a two or three-year rule?

Ms Kathleen Doyle

Any change to driver conditions must involve consultation with the Garda Síochána, currently the licensing authority, and also the advisory council to the commission. When we take over driver licensing from the Garda we will examine all the conditions and will consult both bodies.

Is it not the case that, effectively, the regulator is pulling the rug from under the Road Safety Authority in this regard? While Mr. Noel Brett is attempting to reduce road casualties, the regulator is contravening those efforts.

Ms Kathleen Doyle

No, I am not contravening them because I am not the licensing authority at present. As I stated, when we take over that function we will consult all the appropriate bodies on any conditions which should be in place for a driver licence. The Garda is examining that also in consultation with the Road Safety Authority.

When is it intended this will take place? Effectively, the office of the taxi regulator is being absorbed into the Dublin Transport Authority which may become the national regulator. When does the regulator expect this to occur? When will the Dublin Transport Authority and a national regulator appear before the committee, rather than the taxi regulator?

Ms Kathleen Doyle

There has been no indication to my office regarding when that will take place.

I refer to the point mentioned by Deputy Broughan. We appreciate the regulator has tried to do her best. However, given all the circumstances and all the aspirations of the regulator — we appreciate her desire to get these things done — would it not make good sense to put a stop to the numbers to enable her to introduce some control? This is not in any way to deal with competition in a negative way. As far as I am concerned, competition does not exist anymore, because there are so many people. If a further 1,400 are waiting to do tests, would it not be sensible to propose that until the new test and new standards are introduced — and I strongly recommend to the regulator that the new test should involve an interview — that, at least, we would put a stop to the chaotic situation which exists? Will the delegation consider this following today's meeting?

It is with no disrespect that I say to Mr. Feeney that I cannot accept the conclusions made in the report. He should go away and reconsider them in view of what he has heard today from every member and in view of the situation that exists in the taxi industry now where people cannot earn a minimum wage. It is very difficult to expect them to adhere to the higher standards to which we all wish them to adhere. We will finish with this. If the delegation wishes to make a final comment that is fine. As far as the committee is concerned we are at one in saying that the work we have done in the past two years has led to very different conclusions to those in the Goodbody report or some of the other initiatives we have heard from the consultants.

Mr. Bernard Feeney

Lest anyone think otherwise, I believe the report we produced to be a comprehensive and well-researched report. I stand over the recommendations and conclusions in it and I believe they obtain for the time being.

Ms Kathleen Doyle

The report's recommendations have been published in the national newspapers this week and we will invite submissions from all interested parties who may make comments on the recommendations before we change any further reforms in the future.

I appreciate the delegation's contributions.

Sitting suspended at 5.40 p.m. and resumed at 5.45 p.m.
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