The National Transport Commission (NTC) is an independent body created through legislation, much like the TSC or ESC, that seeks to help achieve national transport policy objectives by developing regulatory and operational reform of transport.
While they do not have any direct responsibility for taxi regulation (this is a matter for States and Territories themselves), the NTC has been asked to work on a project to identify regulatory barriers to the safe introduction of more automated road and rail vehicles in Australia. Obviously, this may dramatically affect the taxi industry.
Vehicle manufacturers are progressively introducing higher levels of automation. Gradually we are getting closer to the commercial deployment of vehicles that, in certain scenarios, can drive themselves without human intervention or monitoring.
These concepts have raised questions about whether Australia’s current regulatory regime can support highly or fully automated vehicles on public roads, or shared railways. Issues such as interaction between road transport, rail safety and consumer protection laws, as well as liability and insurance, and common law requirements need to be addressed.
The Australia Taxi Industry Association (ATIA) and the VTA are both preparing a submission to the consultation phase now underway. The below is a brief reflection on some of the key issues for the taxi industry as automated vehicle technology progresses.
The taxi industry throughout Australia has been suffering thanks to the lack of action and planning for the emergence of new service types within the CPV industry. Responding to the emergence of ride hail provider Uber, and those that will follow it, has so far proved very difficult for state regulators and the industry in Victoria continues to be hindered by inaction. Whilst we will continue to work productively with the Victorian Government on a sustainable and equitable solution, we are pleased to see the NTC working to prepare for the technological changes which have the potential to transform road and rail transport in the coming years.
The taxi industry continues to be the subject of highly prescriptive state based regulation and legislation. Whilst taxi and hire car regulation is similar across states, there are important differences that hamper better national coordination and the development of a greater number of national commercial operators in our industry. We believe this will be one of the greatest challenges facing the taxi industry as automated vehicles continue to develop. We strongly support the need for a “support a nationally consistent regulatory framework for automated vehicles” to which all state regulators of CPV services can subscribe or be subject to in order to prevent state based differences from acting as a barrier to widespread uptake and commercialisation of technologies within the industry with the capacity to deliver immense benefits to passengers and the industry alike.
We certainly perceive great opportunities flowing for taxi services and for passengers of point-to-point transport providers from the development of automated vehicles, including:
- Service and cost consistency for passengers and businesses
- Increase the productivity and reduce downtime of each vehicle with an ability to better match supply and demand without major overheads associated with ‘quiet’ periods
- Potential for specialisation and the emergence of services to augment existing transport networks
- Greater capacity for ‘on demand’ services on fixed routes or in defined geographical areas
- Improved potential for contracted service arrangements
- Lower incidence of crashes and savings based on driving efficiency
It is for these reasons that the VTA is keen to engage thoughtfully with the NTC and other stakeholders on how to assist our members and the taxi industry as a whole to be prepared to realise the benefits of the development of automated vehicle technology.
We also are aware of several challenges, regulatory, cultural and commercial, which will need to be confronted as we transition.
Competitors of the scale of Uber, Google, Apple and the likes will likely enjoy significant commercial advantages from their ability to develop and manufacture purpose built vehicles and believe a well-considered and pre-emptive consideration of the regulatory impacts of automated vehicles, such as this project, vital to the ability of local businesses to compete and thus create a thriving competitive industry generating the maximum potential benefit for passengers.
It is accounting for this transition period that will determine the ability of the Victorian taxi industry to realise the benefits and deliver the advantages for customers. In this respect, we must also remain mindful of the large segments of taxis’ traditional customers who may not be able to access sophisticated technology or for whom automated vehicles may not be well suited. For example, specialised work conducted with the disability community who often rely on taxis for their independence, social inclusion and mobility, clients served through the Department of Veteran’s Affairs, those in remote areas and the elderly.
As an industry, we must also be sensitive to the impacts on the large number of drivers who are an integral part of the delivery of taxi services, and their livelihoods. There will be those for whom these developments will be challenging whom we must consider and protect.
There are also structural barriers to the uptake of fully or almost fully automated vehicles.
The project has already identified the sharing of data generated by automated vehicles as a point of consideration and we agree this is one of major significance for the taxi industry given the public safety mandate, ongoing involvement of state regulators and insurers.