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16 November 2015

Mr Ng Chee Meng
Senior Minister of State
Ministry of Transport

Dear


National Taxi Association’s Recommendations on
Private Hire Vehicle Services

The NTA is of the view that any review pertaining to private hire vehicle services should adhere to three key principles:

    Assurance of commuters’ Safety and Security
    Ensure Fair Competition amongst service providers offering point-to-point transfers
    Embrace new technology and evolve business model for Greater Efficiency on the use of our transport assets


1. COMMUTERS’ SAFETY AND SECURITY

For all point-to-point transfer services, the safety and security of commuters must be of utmost importance.

1.1 All Drivers of Point-to-Point Transfers should be similarly Qualified and Certified

Taxi drivers are subject to stringent checks by the Land Transport Authority (LTA) and the Singapore Traffic Police. They are first required to pass medical and criminal background checks before they can go through the Taxi Driving Vocational Licence (TDVL) course. Upon passing the 60-hour TDVL course, drivers are also subject to regular checks by authorities to ensure that their TDVL and driving licences remain valid. Depending on the age of taxi drivers, medical tests are conducted as necessary. Upon reaching age 70, taxi drivers are required to attend and pass fitness and driving agility tests for the renewal of their TDVL. Any behaviour contrary to the standards will result in penalties imposed by the LTA, including fines and/or suspension or even revocation of their TDVL for the taxi drivers. These standards that ensure the safety and security of the commuters should not be compromised.

NTA recommends: All drivers and service providers who provide point-to-point transfer services serving the same consumer market should be similarly qualified and certified.


1.2 Transport Vehicles and Drivers Must Be Distinctly Identified

Taxi vehicles are clearly marked for easy identification for commuters and enforcement purposes. Specifically for taxi drivers, the photo identification issued by LTA enables commuters to easily identify the driver, and be assured that they hold a valid TDVL. As it is, private hire vehicle services are not expected to provide either form of identification.

NTA recommends: Private hire vehicles and drivers serving the same consumer market should adopt similar identification protocol for consumers’ safety and security.


1.3 Clear and Transparent Accountability and Liability

Besides a safe and comfortable ride, commuters also expect “peace of mind” with regard to liability claims or disputes pertaining to chargeable rates and standards of service. For taxis, commuters can approach LTA or taxi operators directly for help or liability claims in event of unfortunate incidents or disputes, whereas for existing private hire vehicle service providers, it is currently unclear as to who the commuters can make claims from; the apps providers, car leasing company or drivers.

NTA recommends: Need for clear accountability with regard to unfortunate incidents, disputes and claims.


2. NEED FOR FAIR COMPETITION

2.1 Review Point-to-Point Transfer Services’ Operating Costs and Fees and Rates

Taxi operators are subjected to a plethora of compliance costs, which ultimately translate into higher rental cost for taxi drivers and charges for consumers. For example, the shelf life of a taxi is capped at eight years and taxi operators are not allowed to repurpose the vehicles for private use at any point in time, taxi vehicles are required to go through half yearly statutory vehicle inspections and meet Euro 5/6 emission standards, etc. Taxi drivers are also required to undergo training, refresher and renewal courses to obtain and maintain their vocational license, again adding to the higher costs for drivers.

NTA recommends: Ministry of Transport reviews the standards imposed and the cost structure for taxis with a view of levelling the competition field between taxis and private hires.  


2.2 Charge Rates Differentials

Taxi operators adhere to fixed schedule of charges approved by LTA while private hires are able to dynamically change their pricing according to demand and supply.

NTA recommends: Charges and fees of point-to-point transfers which serve the same consumer market to be reviewed to allow taxi drivers to compete fairly and allows commuters to have easy access to clear and transparent fee structures.


2.3 Embrace New Tools and Review Relevance of Existing Availability and Service Requirements and Tracking Methods

In the past, statutory requirements were put in place to meet availability and quality of taxi services standards. For instance, taxi operators are required to ensure that 85 per cent of their taxi fleet meet the daily minimum mileage of 250km, and that at least 92 per cent of call bookings are successfully matched. Failing which, they will be financially penalised. This led to taxi operators investing in manpower and resources to track such requirements, which resulted in higher operating costs and inevitably, higher rental and fuel costs for taxi drivers.

Today, consumers are able to provide direct feedback through user reviews and have greater access to taxi services with the use of technology and new tools such as third-party apps. Therefore, the existing requirements and methods of tracking need to be reviewed to ensure relevance.

NTA recommends: LTA to recognise and embrace the effectiveness of these new tools to determine service and availability standards without the need for statutory requirements that have become prescriptive, distorting and costly.

 

2.4 Consistency in Regulating Taxi and Private Hire Services

Laws were recently passed in August 2015 to regulate third-party taxi booking service providers. The regulations help ensure that the taxi fare and bookings, as well as the responsibility of these apps providers to commuters and drivers are clear and transparent. For example, apps providers must provide information such as vehicle type, flag-down rate, booking fees to commuters before they confirm the bookings. Commuters are also assured that such apps do not infringe on any taxi regulations i.e., overcharging on fare, etc. For private hire vehicle service providers, there are currently no regulations in place to provide any similar reference for commuters.

NTA recommends: LTA to be consistent in regulating and monitoring any point-to-point transfer service providers i.e., private hire vehicle services and drivers serving the same consumer market.
 

3. GREATER EFFICIENCY IN MEETING TAXI DEMAND

Various new and emerging apps have allowed for better matching of supply and demand in the private hire market.

NTA recommends: The government and taxi operators to take bold steps in leveraging these new technologies and practices to improve the riding experience of their passengers and matching efficiency of taxi drivers. It is important that our transport policies and regulations as well as taxi business model keeps pace with technology advancement and consumer preferences. Ultimately, this should improve transport availability and contribute to greater efficiency in the use of our transport assets.

The above feedback and recommendations balance the need to level the playing field for the various stakeholders in the industry, and at the same time safeguard the interests of our end users.

 

Yours sincerely


Ang Hin Kee
Executive Advisor, National Taxi Association
Assistant Secretary General, National Trades Union Congress

 

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