Economic
Review of the
Small Public Service
Vehicle Industry

Commission For Taxi Regulation
An Coimisiún Um Rialáil Tacsaithe

1

Economic Reviewof the Small PublicService Vehicle
Industry

Goodbody Economic Consultants inassociation with Faber Maunsell and
IMS Millward Brown

2

ContentS

Glossary of Terms

4

4 Competition and Overall Market Supply

28

Executive Summary

6

4.1 Introduction

28

4.2 Competition in the Cab Market

28

4.3 Effects of Increased Competition30

1 Introduction

10

1.1 Background10

1.2 Objectives of the Study

10

1.3 Study Methodology

10

1.4 Review Layout

11

2 Legislative and Institutional Background12

4.4 Effects of Competition on Structure of Supply

36

4.5 Conclusions

38

5 Structure of Cab Industry Supply

40

5.1 Introduction

40

5.2 Structure of the Industry

40

5.3 Cab Industry Level of Supply

41

5.4 Temporal Pattern of Supply

42

5.5 The Earnings of Drivers

43

5.6 The Role of Part-Time Drivers

45

2.1 Introduction

12

2.2 Controlled Entry to the Taxi Market

12

2.3 Liberalisation of Entry

13

2.4 Qualitative Regulation of the Market

13

2.5 Reform of the Cab Market

14

5.7 The Role of Cab Drivers withAnother Occupation

46

2.6 Overview of Developments

15

5.8 Cab Drivers and Working Hours

46

3 Market Demand16

5.9 Conclusions46

3.1 Introduction

16

6 Quality of Cab Services48

3.2 Market Size

16

6.1 Introduction48

3.3 Demand for Different Cab Services

18

6.2 Waiting Times48

3.4 The Temporal Pattern of the
Demand for Cab Services

19

6.3 Availability of Cabs

50

3.5 The Demand for Cabs byDifferent User Groups

6.4 Vehicle and Driver Aspects of Quality of Service

53

21

3.6 Cab Demand and the Fare Structure

24

3.7 Conclusions

26

Goodbody Economic Consultants in association
with Faber Maunsell and IMS Millward Brown.
Published by the Commission for Taxi Regulation.

6.5 Value for Money55

6.6 Consumer Complaints

56

6.7 Conclusions

56

Disclaimer
This publication is not a legal document anddoes not purport to be a legal interpretationof the relevant legislation.
March 2009

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7 Regulation of the System

58

10 Conclusions and Recommendations86

7.1 Introduction

58

10.1 Introduction

86

7.2 Background58

10.2 Trends in the Industry

86

7.3 Agenda for Industry Reform

59

7.4 Progress in Implementing Change

61

10.3 Impact of Market
Liberalisation and Reform87

7.5 Cost and Benefits of Regulatory Changes

65

10.4 Recommendations

89

7.6 Future Needs and Actions

66

10.5 Overview of the Review’s Findings

91

7.7 Conclusions

66

Appendix 1

92

List of Consultees

92

8 Economic Rationale forRegulation of the Cab Market

68

8.1 Introduction

68

Appendix 2

93

8.2 Economic Theory and Market Regulation

68

8.3 Entry Regulation

70

Estimating the Value of Consumer
Benefits Post-liberalisation

93

8.4 Implications of Economic Theory
for Market Regulation

Time Savings to Cab Users

93

71

Value of Time93

8.5 The Irish Regulatory Framework
in a Comparative Context

71

Estimate of Consumer Benefits

94

8.6 Conclusions

73

9 Evaluation of the Issues

74

9.1 Introduction

74

9.2 Impact and Benefits of theCurrent Regulatory Structure74

9.3 Issues Raised by the Cab Industry

75

9.4 Other Issues

77

9.5 A Moratorium on the Issue of Licences

83

9.6 Conclusions

84

4

GloSSaRy of teRmS

advisory Council – the Advisory Council to the Commission
for Taxi Regulation was established under Part 4 of the Taxi
Regulation Act 2003 to advise the Commission in relation
to matters pertaining to small public service vehicles (SPSVs).
affiliate (to a dispatch operator) – to pay a radio rental fee
to a dispatch operator in exchange for bookings.
back to work enterprise allowance – employment support
scheme run by the Department of Social and Family Affairs
which allows participants to retain a proportion of their social
welfare entitlement provided that they take up full-time self
employment. It is a condition of the scheme that the enterprise
undertaken should not displace an existing enterprise.
bounded rationality – the idea that individuals may not havethe cognitive power to make decisions in their best interests.
Therefore, individuals may intend to be rational but not actually
behave in a rational manner.
Call-out market – demand for cabs through telephonebookings.
‘Churning’ – the process by which the individuals making
up the industry are subject to change due to persons enteringand exiting the industry.
Commission – the Commission for Taxi Regulation, an
independent public body established under the Taxi Regulation
Act 2003, is responsible for the regulation of taxis, hackneys andlimousines. It should also be noted that the terms Commission
for Taxi Regulation, Commissioner and Taxi Regulator are one
and the same and tend to be used interchangeably.
Contestable industry – an industry with low barriers toentry and exit.
‘Cosying’ – a practice whereby a vehicle licence holder rents,
or allows or employs a second driver to operate their vehicle
when they themselves were not operating it. This practice
resulted in intensive use of licensed SPSVs prior to liberalisation.
Discretionary income – income after subtracting taxes andstart-up and other usual expenses.
Dispatch operator – a dispatch operator is a person engaged
in the activity of taking a booking of an SPSV that is operated
by another person and arranging with the operator or driverof the vehicle to provide the service booked.
Dispatch operator register – a register of dispatch operators
in Ireland currently being compiled by the Commission for Taxi
Regulation.

Driver iD cards – large display card and a smart card. The
large card is displayed on the dashboard of all SPSV vehicles,
provides passengers inside the vehicles with a picture of thedriver, their licence number and the corresponding licence expiry
date. Facing towards the windscreen is information on where
the driver is licensed to ply or stand for hire as a cab. All drivers
must also carry a smart card with them when operating as SPSV
drivers. This card can be requested by enforcement officers
and checked with hand-held devices and is a form of ID for
customers picked up at their homes.
Driver licence register – a register of all licensed SPSV
drivers in Ireland.
economies of scale (network economies of scale) – factors
which cause the average cost of producing a commodity orservice to fall as output of the commodity or service rises,
thereby increasing efficiency.
fare structure – the various components that, taken together,make up the method by which a taxi fare is calculated.
hackney – an SPSV licensed to carry up to eight passengers
which must be pre-booked privately and cannot ply for hireon the street or stand at taxi ranks. The fare must be agreed
in advance with the customer. Hackneys may not use bus lanes.
liberalisation – this refers to fewer government regulations andrestrictions in the economy in exchange for greater participationof private entities thereby increasing efficiency and effectiveness.
In the case of the SPSV sector in Ireland liberalisation relates toremoval of restrictions of controls on the number of licences
issued, but does not control quality standards.
limousine – an SPSV licensed to carry up to eight passengers
which must be pre-booked privately and cannot ply for hireon the street or stand at taxi ranks. The fare must be agreed
in advance with the customer. A limousine must be suited byits style and condition to be used for ceremonial, corporate
or other prestige purposes.
market failure – when the competitive outcome of markets
is not efficient from the point of view of the economy asa whole, ie. when the private returns which an individual
or firm receives from carrying out a particular action diverge
from that of society as a whole.
market segmentation – the process of classifying a market
into distinct subsets (segments) that behave in similar ways
or have similar needs.
maximum fare – the maximum amount which may lawfully
be charged by a taxi driver.

5national register of licences – under Section 38 of theTaxi Regulation Act, the Commission is required to maintaina national register of licences. There are currently two separate
registers – a register of licensed SPSVs (vehicle register) and aregister of licensed SPSV drivers (driver register). The Commission
provides information from these registers to appropriate
enforcement agencies on request to ensure compliancewith legislation.

with disabilities. These are usually provided by community-basedorganisations and involve minibus and, to some extent, SPSVs.

nCtS – National Car Testing Service.

SPSv driver licence – the SPSV driver licence required to drive
an SPSV.

network externalities – the effect that one producer
or consumer of a good or service has on the value of that
product to other producers or consumers.
nSai – National Standards Authority of Ireland.
Quality assurance scheme – a scheme for the recognitionof a high level of service in the provision of vehicle standards,
driver standards and booking standards in the SPSV industry.
This is currently being developed by the Commission.
Peaked demand – a historically high point in the sales ofa product or service. Peaked demand describes a period ofstrong consumer demand.
Private hire vehicle – an SPSV which must be pre-booked
and cannot ply for hire or stand at taxi ranks – ie. hackney
or limousine.
Public hire vehicle – An SPSV vehicle which can ply forhire on the street or stand for hire at taxi ranks or be calledout or pre-booked by a passenger – ie. taxis or wheelchair
accessible taxis.
Qualitative restrictions – restrictions on the operation of
the market due to factors such as legal requirements. In termsof SPSVs this relates to such factors as vehicle standards, driver
knowledge etc.
Quantitative restrictions – specific limits or quotas on thequantity or value of goods. In terms of SPSVs this relates tothe number of licences issued.
Rational/irrational entrant – rational entrants are those thatenter the market having evaluated the potential financial returns
and concluded that the costs and benefits of entry are such as
to make it worth their while. Irrational entrants are those thatenter the market either having failed to evaluate the returns
either adequately or at all or having ignored the evaluations
undertaken.
Rural transport Programme (RtP) – this provides subsidisedtransport services for a range of target groups including people

Skills Development Programme – a new programme
legally required for all SPSV drivers and dispatch operators.
Small public service vehicle (SPSv) – the term refers
collectively to taxis, wheelchair accessible taxis, hackneys andlimousines which are also referred to as ‘cabs’ within this review.

Statutory instrument (Si) – A form of secondary legislationthat includes regulations and is made in the exercise of astatutory power.
Street market – demand for taxis at ranks or by hailing on
the street.
tamper-proof licence disc – a disc affixed to the front andrear windows of a licensed SPSV. The discs display the detailsof the vehicle registration in accordance with Regulation, the
SPSV licence number, the expiry date of the SPSV licence and thenumber of passengers the vehicle is licensed to carry. The discs
remain in place for the duration of the SPSV licence. The discs
are visible to passengers and enforcement agencies from insideand outside the front and back of the vehicle. They containa hologram and advanced security features making transfer,
replication or forgery difficult.
taximeter area – the area which has been designated by
the Commission where taxis can operate. The Commission
has designated the whole country as a taximeter area.
taxi – an SPSV licensed to carry up to eight passengers which
can ply for hire on the street or stand for hire at taxi ranks or
be called out or pre-booked by a passenger.
vehicle licence – the vehicle licence required to operate
an SPSV.
vehicle licence register – a register of all licensed SPSVs
in Ireland.
wheelchair accessible hackney – a new category of SPSV
under consideration by the Commission, the proposed
specification for which is set out in the Commission’s Vehicle
Standards publication of November 2007.
wheelchair accessible taxi – a taxi which meets a numberof additional vehicle specifications to allow use by persons
using their wheelchairs.
2003 act – Taxi Regulation Act 2003 (No 25 of 2003).

6

eXeCutive SummaRy

introduction
The Commission for Taxi Regulation
appointed Goodbody Economic
Consultants, in association with Faber
Maunsell and IMS Millward Brown, tocarry out an economic review of thesmall public service vehicle (SPSV)
sector in Ireland. The key objectivesof this study were to:• Undertake a review of the trends
shaping the general environment
in which the industry operates• Assess the economic impact ofliberalisation of the SPSV sector,
in particular on supply, demandand industry earnings

The Review encompassed a significant data collection
exercise to establish the behaviour and views of consumer
groups and the approach of drivers to the business. This
took the form of surveys of consumers, including people
with disabilities, businesses and cab operators. In addition
to the data collection process, an extensive consultation
process was undertaken with a number of key stakeholders and interested parties and bodies.
The Review established that a minimum of approximately
100 million cab trips were made nationwide in 2008.
This represents an increase of over one quarter comparedwith 2005. The value of the industry is estimated at €1.5
billion in 2008. In meeting this demand, the cab industry
operated an estimated 1.6 billion vehicle kilometres.
Cabs undertook some 8.7 million work shifts per annum,
comprising an estimated 69 million working hours.
With regard to the demand for cab services, theReview concluded that:• The use of taxi services is rising faster than thatfor hackney services.
• The majority of consumers access cab services
through telephone booking.
• The demand for cab services is a peaked demand,with Fridays and Saturdays accounting for 73 percent of all trips.
• Cab use by people with disabilities is lower than thatby the population in general and has fallen since 2005.
• Cabs are used predominately for social andrecreational purposes.

7Turning to the supply of cab services, the Review
has found that:• The supply of cab services peaks in the period
from Thursday to Saturday. However, in this regard,
supply is not as peaked as demand.
• In 2008, cab drivers worked more shifts and worked
longer hours than three years previously.
• The supply structure of the cab industry is undergoingsignificant change. This involves increased part-timeworking and an increased proportion of drivers witha second job.
• Part-time drivers are much more likely to supply
services on days of peak demand than are their fulltime counterparts. Therefore, part-time drivers makea valuable contribution to meeting peak demands.
• Of taxi drivers who have another occupation,
approximately one third are working between
30 and 45 hours per week in that occupation.
Approximately one-in-five cab drivers with two
occupations is working in excess of 75 hours per
week in total. Their contribution to serving the
Friday and Saturday peak is not as substantial asthat of part-time drivers.
• It is estimated that approximately 40 per cent of cab
vehicles nationwide are affiliated to a dispatch operator.
There is evidence, however, that the level of affiliation
has declined in Dublin. There are over 400 dispatch
operators currently registered with the Commission,
with only five per cent of these having more than
100 affiliated vehicles. The fact that there are so few
large dispatch companies in Ireland limits the extent
to which economies of scale are being realised.

• Precise data on cab drivers’ earnings are difficult toobtain. 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 mitigatedto a degree by the fares increase granted in late2008, resulting in a net reduction of approximately
5 per cent in gross earnings for this category. It isclear, therefore, that drivers’ earnings are not collapsing
as some industry sources would suggest.
• Cab drivers have to work longer hours to achieve theirincome targets and on an hourly basis, they are earning
well below the current average industrial wage.
The major supply deficiency within the industry is forpeople with disabilities. There is no one policy initiativethat will remedy this situation. The Review indicates thatthe current policy of seeking to provide financial support
for the purchase of wheelchair accessible cabs andensuring that minimum levels of service are provided
to people with disabilities is the correct approach. It
is recommended that the Commission engages witha number of other stakeholders in the provision oftransport services for people with disabilities with aview to establishing the role for cab services relative
to other transport services, so as to support a more
integrated and comprehensive response to the transport
needs of people with disabilities.
Since its establishment in 2004, the Commission has
embarked on an ambitious programme of reform of thecab industry. The reforms implemented by the Commission
relate to vehicle quality, service quality, and cab licensing
and administrative systems. The Review indicates that:• The Commission has made substantial progress in
implementing its reform programme. This programme
will benefit the cab industry and will be implemented
at relatively low cost to cab operators.

8• Consumers find the new uniform fare structure
easier to understand and believe that the current
structure is providing better value for money.
• Consumers have also benefited from a more coherent
system of redress and will in future benefit from thehigher standards that the industry will adopt.
• The streamlining of administration of the cab licensing
system has been of benefit to operators.
On the basis of consultation with the industry, theCommission has set the reform period to run until 2012
to give individual operators enough time to arrange
financial investment or other planning to meet the newstandards. Given the support throughout the industry forensuring quality standards and in light of the importanceof maintaining high standards in a liberalised market, it isadvised that the Commission revisit these timelines to see
if any fast-tracking of individual reforms could be agreed.
Any such fast-tracking would have to take into accountany financial costs arising.
Enforcement of the regulations is vital to ensuring theprovision of quality cab services and maintaining a levelplaying field for cab drivers. In view of the scale of theindustry, which is now valued at €1.5 billion, and itschanging nature, the Commission needs to be given
the opportunity to leverage the administrative advances
made through additional resourcing of its dedicatedenforcement function. It is also recommended that theCommission continue to collaborate with other relevantbodies, including the Gardaí, the Revenue Commissioners
and the Department of Social and Family Affairs to ensure
maximum compliance with regulations in the industry.

The Review considered the regulation of the cab industry
in Ireland and concluded that:• The regulatory structure of the cab industry in Irelandclosely follows that suggested by economic principles
in that there is free entry to the market, but maximum
fare control in respect of taxis.
• The emphasis by the Commission on enhancing
vehicle and driver standards directly addresses amarket failure and is a particularly valuable initiative ina quantitative entry-deregulated market and a similar
approach is being followed in other jurisdictions.
• The OECD and World Bank favour the approachto regulation adopted in Ireland and the former
emphasises the value of quality regulation combinedwith entry-deregulation.
• As a result of liberalisation, the cab market in
Ireland is highly competitive and contestable andhas no significant barriers to entry or exit.
• Liberalisation of the cab industry has brought profoundchanges in the relative market share of hackneys
and taxis in Ireland. Since liberalisation, taxi numbers
have increased rapidly. This suggests that prior toliberalisation, there was a substantial imbalance
between cabs serving the street and call-out markets,with the former being undersupplied.
• Estimates for cab trips by residents of the Dublin areasuggest that, since liberalisation of the market, demandin the Dublin market has increased from 22 million trips
in 1997 to 40 million in 2008, or by some 82 per cent.
• Liberalisation of the market has resulted in significant
benefits to consumers. The value of the postliberalisation reduction in waiting times to Dublin
cab users is estimated to be €300 million at a minimum.
On a proportionate basis, the benefit of waiting time
reductions to consumers throughout the country
is estimated at €780 million.

9• There is no evidence that the increase in cab use
and reductions in waiting times has been at theexpense of the quality of the services provided. The
general perception of consumers is that the overalllevel of cab service provided in Ireland, as well as
vehicle quality, vehicle cleanliness and the helpfulnessof drivers, is good.
• As a result of liberalisation, new entrants to the cab
market have also benefited from the opportunity toearn a livelihood through participation in the industry.
The scale of the cab industry indicates that congestionand environmental impacts associated with the cab
industry could become significant, if the market continued
to grow. However, controlling the numbers of cabs is nota recommended solution to congestion on its own given
the importance of this sector in the overall public transport
network. The peaked demand and supply in the sector,
and its particular contribution to reducing reliance on
private transport at night time, also mitigate the impact
of cab operations on overall traffic congestion. There are
a number of other initiatives, such as measures to secure
greater affiliation of cabs to dispatch operators to reduce
cruising for hire and the provision of additional taxi stands
in areas with demonstrable unmet demand for street hirethat would help alleviate any congestion or environmental
impacts from cab operations. However, the debate about
the extent of external congestion costs is taking place ina relative information vacuum. It is recommended that
the Commission research the extent to which external
congestion costs are arising in practice and the cost-benefitof alternative mitigating measures. This should be done incollaboration with wider transport policy development on
the issue.
The Review recommends that the present regulatory
structure should be retained. There is an insufficientjustification, at present, for an adjustment to theregulatory structure through the introduction of a
moratorium. The evidence is that exits from the industry,
although increasing, are not at problematically high levels.

It is not possible to determine what proportion of exits isdue to decisions to retire or change profession as against
early exits. Also, as the rate of entry is in sharp decline,
the number of cabs in the market may stabilise in the near
future, provided that deteriorating economic conditions do
not upset this trend.
However, it is also recommended that the Commission
develops a formal and transparent process to monitor
entry and exit from the industry and particularly earlyexit. Information on the level of early exit in local markets
should also be made publicly available to assist would-be
entrants to conduct more informed research into market
opportunities. It is also recommended that the Commission
uses such measures as its industry information service andthe imminent Skills Development Programme to ensure that
persons entering the industry are aware of general market
conditions but also the importance of properly researching
their local market.
The Irish cab industry has undergone substantialchange since the 1990s. Three periods in the recent
development of the industry may be discerned. The
Pre-Liberalisation Period existed up to the year 2000 and
was characterised by restricted entry to the taxi market,
a fragmented administrative structure, and diversity intaxi fare structures and levels across the country. The
Post-Liberalisation Period, commencing in 2000, saw
the complete liberalisation of entry to the market, but
the fragmented administrative and fare structures wereretained. The Reform Period, prefaced by the establishmentof the Commission for Taxi Regulation in late 2004, beganwith the introduction by the Commission of a national
taximeter area and national fare structure and otherreforms in 2006.
The reform process, on which the Commission has
embarked, will increasingly benefit consumers andcab operators alike. The challenge for the Commission
is to consolidate the gains already made, throughthe active pursuit of its current reform agenda.

101
intRoDuCtion

1.1 background

1.2 Objectives of the Study

The Commission for Taxi Regulation

The key objectives of this study were to:was established on 1st September 2004

• Undertake a review of the trends shaping the general

under Part 2 of the Taxi Regulation• Assess the economic impact of liberalisation ofenvironment in which the industry operates
the SPSV sector, in particular on supply, demandand industry earnings

Act 2003. The principal function of theCommission is the development andmaintenance of a regulatory framework
for the control and operation of small

In this regard, there were a number of issues which
needed to be researched, as follows:• The structure and economics of the industry,
particularly with regard to the trend in SPSV numbers,
the hours worked and earnings.

public service vehicles (SPSVs)1 andtheir drivers.
Since its establishment, the Commission has been
putting in place a number of reforms across a broad
range of areas to improve the quality of SPSV services,to enhance awareness and to promote accessibility
and stronger enforcement.
The Commission has sought a review of the economic
situation facing the SPSV sector as a whole and inparticular, how supply currently matches demand andhow the provision of services is made available toconsumers by a largely self-employed industry.
The Commission appointed Goodbody Economic
Consultants in association with IMS Millward Brown
and Faber Maunsell to carry out an economic reviewof the SPSV sector in Ireland.

• The trends in demand for SPSV services, specificallythe trends in the number of taxi journeys made.

• The services offered to people with disabilities andthe extent to which current services satisfy demand.

• The profile of new entrants with regard to levelof investment and skills base.

• The level of competition in the industry andidentification of any remaining barriers to entry.

• The impact of regulatory reform, with regard tooperating costs, supply and demand and thepossible implications of future regulation.

1.3 Study Methodology
In line with the terms of reference, the study:• Examined the nature and structure of the SPSV
market in Ireland.

• Assessed the impact of liberalisation and institutionalchange on the market.

• Examined the level of competition in the industry
and developed a profile of income generated.

• Assessed the level and adequacy of services forpeople with disabilities, businesses and individuals
and their demand for such services.

1 SPSVs include taxis, hackneys and limousines and are referred to as ‘cabs’ throughout this report.

11

Sec tion 1 introduc tion

• Researched the international experience in relation
to policies and practices operated elsewhere.

1.3.1 Data Collection
The review of supply and demand and the overall qualityof services required a significant data collection exercise
to gauge the behaviour and views of consumer groups andthe approach of drivers to the business. Taxis, hackneys
and limousines are used by the general public and business
users. Each of these consumer groups includes people
who use wheelchairs and people with other disabilities.
Therefore, a number of surveys were carried out toascertain the supply and demand for services and toestablish consumers’ views on the services provided:• A national household survey was carried out to establish
cab usage levels by private individuals and to assess
consumer satisfaction with the levels of service provided.
Conducted during September 2008, the survey took theform of a personal interview with a target representative
sample of 1,022 adults across all four provinces.
• A telephone survey was carried out in September
2008 across a random sample of 250 Irish businesses
within Ireland. Issues discussed included usage levelsof cab companies, the type of company used, the typeand level of service demanded, as well as the level ofservice delivered.
• A postal survey was also administered, with theassistance of the Irish Wheelchair Association, toa random sample of 1,000 of its members – 144
questionnaires were completed and returned. The
survey focused on issues such as frequency of use,
helpfulness of cab drivers, factors inhibiting cab use,and conditions of accessible vehicles.
• A postal survey of drivers was also completed.
Conducted during October 2008, the survey detailed
the level of service drivers provide, their operating
performance and the role of cab companies. The
survey took the form of a self-completion postal
questionnaire and was sent to approximately 2,800
cab drivers across Ireland. Random, stratified sampling
ensured the sample was representative of the population
as a whole. A total of 512 individuals responded
to the survey, resulting in a favourable 18 per centresponse rate.

1.3.2 Consultation Process
In addition to the data collection process, an extensive
consultation process was undertaken. Extensive faceto-face consultations were held with a number of key
stakeholders and interested parties and bodies, including
the Taxi Companies Owners Association, the National Taxi
Drivers Union, the National Private Hire & Taxi Association,
the Irish Taxi Drivers Federation, the Rural Taxi Alliance,
SIPTU, the National Disability Authority, the Road Safety
Authority and others. In addition, consultations of regionalcab associations were undertaken. These comprised faceto-face and telephone consultations across the country.
A full list of the bodies contacted is set out in Appendix 1
at the end of this report.

1.3.3 Prior Research
The analysis in this report was further facilitated by thesurveys carried out as part of this review and by three key
studies carried out over the last ten years. These are:
• Review of the Taxi and Hackney Carriage Service
in the Dublin Area, 1998. Oscar Faber in association
with Goodbody Economic Consultants and Irish
Marketing Surveys.
• Review of the Taxi and Hackney Market, 2001 – Demandand Supply. Goodbody Economic Consultants, 2001.
• National Review of Taxi, Hackney and Limousine
Services. Goodbody Economic Consultants in association
with the Institute of Transport Economics, Norway andMillward Brown IMS, June 2005.

1.4 Review Layout
The report begins by setting out in Section 2 a brief
history of the legislative and institutional developmentsin the administration of the cab industry since the late
1990s. An overview of market demand is presented in
Section 3. Section 4 assesses overall market supply and thedegree of competition in the market. Section 5 examines
the structure of cab industry supply. The quality of cab
services as perceived by the general public, business
users and people with disabilities is reviewed in Section
6. Section 7 discusses the regulation of the industry andreforms that have been put in place and are ongoing.
Section 8 examines the economic rationale for regulationof the cab market. Section 9 evaluates the issues raised bythis analysis and the consultative process. The conclusions
and recommendations of the report are presented in
Section 10.

122
leGiSlative anD inStitutional baCKGRounD

2.1 introduction

2.2 Controlled Entry to the Taxi Market

This section of the Review provides

For more than two decades prior to the year 2000,
entry to the taxi market, but not the hackney market,
was substantially restricted. While some additional taxi
licences were granted by the licensing authorities, theincrease in numbers was curtailed, especially during the
1980s. By the early 1990s, however, this restrictive policy
was giving rise to a poor level of service, particularly in the
Dublin area2, and there was increasing public pressure
to grant additional licences. An interdepartmental review
group was established to examine the situation and its
report was published in 19923. This report acknowledged
the existence of supply inadequacies but maintained therestrictive policy, recommending, for example, that the
number of licences be increased by only 100 in the Dublinarea, at a time when there were 1,600 taxis licensed in thatarea (1991). The 100 extra licences were issued in 1991,
followed by the issue of another 50 wheelchair accessible
licences in 1992. Further issue of licences occurred in the
Dublin area throughout the 1990s with, for example, afurther 200 wheelchair accessible licences being issued
in 1997. By the year 2000, the number of taxi licencesin the Dublin area had risen to some 2,700, by virtue of
this periodic issuing of licences.

a brief history of the legislative andinstitutional developments in theadministration of the cab industry
since the late 1990s.

However, substantial economic growth and a recovery in
the national population levels took place during the 1990s,
and the supply of taxi services did not keep pace with thedemand that arose. This was evidenced by:• The increasing market value ascribed to taxi licences,with market values rising from £40,000–£50,000 in theearly 1990s to £80,000 towards the end of the decade4• The widespread use of second drivers (‘cosies’) bytaxi licence holders and the resultant intensive useof licensed vehicles• The increasing role of hackneys in meeting thedemand for cabs

2 References to the ‘Dublin area’ are normally to the area of the four Dublin local authorities.
3 Interdepartmental Committee on the Operation of Small Public Service Vehicles. Stationery Office, 1992.
4 These figures equate to €51,000, €63,000 and €102,000 respectively.

13

S e c t i o n 2 l e g i s l at i v e a n d i n s t i t u t i o n a l b ac kg r o u n d

Whereas in 1991 there were some 450 hackneys licensed
in the Dublin area, this had increased to 3,500 by theyear 2000. This meant that hackneys had come to exceed
taxis in numbers and accounted for 56 per cent of all cabsin that year. In 1997, the local authorities in the Dublinarea commissioned a team of consultants to examine thesituation and their interim report gave rise to the 200
additional wheelchair accessible taxis issued in 1997. Whenthe consultants reported in 1998, they concluded thatdemand for taxis was growing strongly and there was a
shortage of supply amounting to at least 2,000 taxis in
the Dublin area, so that an immediate doubling in taxi
numbers would be warranted5. While favouring complete
liberalisation of entry to the market, the consultants
recommended a gradual approach to full liberalisation
to ensure both an orderly market transition and to avoid
immediate and substantial losses for taxi drivers that had
recently purchased taxi licences in the open market for up
to £80,000 (€102,000). Accordingly, the report favoured
a policy of issuing 350 extra licences annually, with fullentry deregulation after 10 years.

2.3 Liberalisation of Entry
In the event, a different approach was followed
by Government. In 1999, the then Minister for theEnvironment and Local Government6 proposed that
supply in the Dublin area would be increased by issuing
an additional licence to all holders of existing taxi licences,with an additional 500 being issued to those currently
without a licence.
These proposals were subject to a legal challenge by
hackney operators, who questioned the restriction of theadditional licences to existing licence holders and a limited
number of other applicants. The hackney operators were
granted a judicial review by the High Court, which foundin their favour7. In particular, the High Court held that
the Minister could not restrict the granting of additional
licences in the manner described above, as it would affect“the rights of citizens to work in an industry for which they
are qualified and, further, which affects public access totaxis and restricts the development of the taxi industry”.

Following the ruling by the High Court, the Minister for theEnvironment and Local Government introduced regulations
in late 2000 which provided that any suitably qualified
person could obtain a licence. The result was an immediate
and full liberalisation of entry to the taxi market.
Following these fundamental changes to the market,
there was a sharp increase in the number of taxis. By theend of 2001, the number of taxis in the Dublin area had
doubled from 2,700 pre-liberalisation to 5,500. In contrast,
the number of hackneys fell to 2,700, as drivers switchedto taxi operation. These trends continued, so that by theend of 2003, the number of taxis in the Dublin area had
increased to 8,400, with hackneys standing at 1,500,
making a total of 9,900 cabs in all. Similar trends wereseen in the country as a whole. In 2000, there were atotal of 13,500 cabs in the country and this had risen to
19,500 by end 2004.

2.4 Qualitative Regulation of the Market
Following liberalisation and the substantial increase in thenumbers of licensed cabs and drivers, there was concernthat the quality of the services provided be maintained andimproved. In 2002, the Government developed proposals
for the establishment of a Commission for Taxi Regulation.
The Minister for Transport established the Commission for
Taxi Regulation as an independent public body under Part
2 of the Taxi Regulation Act 2003 on 1st September 2004 8.
The principal function of the proposed Commission
was to be the development and maintenance of a new
regulatory framework for the control and operation of
SPSVs (cabs) and their drivers. In exercising this function
the Commission was to pursue a range of objectives
focused on the promotion of quality services by all cab
operators and drivers. This was to be based primarilyon the deployment of new qualitative standards to be
applied to the licensing and ongoing operation of vehicles
and drivers, with the emphasis on the enhancement ofcustomer services. It should be noted that the Commission
was not given powers under the 2003 Act or otherwise toimpose quantitative restrictions on entry to the cab market.

5 Review of the Taxi and Hackney Carriage Service in the Dublin Area, 1998. Oscar Faber in association with Goodbody Economic Consultants and Irish Marketing Surveys.  
6 Those currently renting a plate were to be favoured.
7 Judicial Review. Record No.38, JR/2000. Christopher Humphrey and Others v the Minister for the Environment and Local Government, the Attorney General and Others. October 2000.
8 Referred to as ‘the Commission’ throughout this report.

14

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

2.5 Reform of the Cab Market
During 2005, the Commission engaged in extensive
consultations with stakeholders and undertook acomprehensive review of taxi, hackney and limousinesservices in Ireland. This resulted in the publication of
National Review of Taxis, Hackneys and Limousine
Services9. The Review identified a number of regulatorychanges, which were encompassed in a Roadmap Towards
a New National Code of Regulation for Taxis, Hackneys
and Limousines. This set out the changes which theCommission proposed to make in response to the findingsof the National Review and sought feedback on thesechanges. Following this, in Autumn 2005, the Commission
published a strategy statement setting out its proposed
actions during the period 2005–2009.
This statement of strategy identified seven goals for theCommission for the period 2005–2009. These were:
Quality of Service
The delivery of quality services by all SPSVs to the highest
standard of comfort and safety for passengers and drivers.
Accessibility
A first class taxi, hackney and limousine service which
provides accessibility for all, including passengers
with disabilities and others with particular accessibility
requirements.
Fares
A new, simplified and unified fare structure with all taxi
fares subject to maximum fares and charged on the meter.

A High Performing and Effective Organisation
An organisation which delivers a first class service toall its users based on effective and accountable processes
and systems and a highly skilled and motivated staff.
A Transparent and Accessible Regulatory Process
A regulatory code based on six principles – necessity,
effectiveness, proportionality, transparency, accountability
and consistency.
Since the strategy was adopted, very significant reform
has been effected as set out below.

2.5.1 National Taximeter Area andNational Maximum Taxi Fare
In 2006, the Commission abolished the existing systemof 34 discrete taximeter areas and the entire country
became one taximeter area. This was a fundamental
reform in that not all urban areas and few rural areas
were previously designated as taximeter areas. As a result,
all taxi journeys in the State are now charged on the meterand taxi operators are obliged to accept all journeys up
to 30 kilometres in length. A new national maximum taxi
fare was introduced to apply across the country as awhole. Previously, the fare structures in place across the
34 taximeter areas varied in terms of their structure andthe level of charges. The new national fare simplified thefare structures through, for example, the abolition of
additional luggage charges and standardisation of unsocial
hours charges and the introduction of a graduated farestructure based on journey distance and time.

2.5.2 Administrative Reforms
Licensing and Administrative Procedures
A more streamlined licensing process with enhanced
security features.
Vehicle Standards
Enhanced vehicle standards and improved accessibility
that balance overall quality and safety improvementswith cost and other practical implications for drivers
and operators.

The Commission also embarked on wide-ranging
administrative reforms encompassing vehicle and driver
licensing, vehicle standards, dispatch operation, consumer
information and enforcement. These reforms, which areongoing, are discussed further in Section 7.

9 National Review of Taxi, Hackney and Limousine Services. Goodbody Economic Consultants in association with the Institute of Transport Economics,
Norway and Millward Brown IMS, June 2005.

S e c t i o n 2 l e g i s l at i v e a n d i n s t i t u t i o n a l b ac kg r o u n d

2.6 Overview of Developments
The cab industry has undergone substantial change
since the 1990s. Three periods in the recent developmentof the industry may be discerned:
The Pre-Liberalisation Period
This existed up to the year 2000 and was characterised
by restricted entry to the taxi market, a fragmented
administrative structure, and diversity in taxi fare structuresand levels across the country.
The Post-Liberalisation Period
This period commencing in 2000 saw the complete
liberalisation of entry to the market, but the fragmented
administrative and fare structures were retained.
The Reform Period
Prefaced by the establishment of the Commission for Taxi
Regulation in late 2004, this period commenced in 2006
with the introduction by the Commission of a national
taximeter area and national fare structure and otherreforms. This period of major reform is continuing apace.
The focus of this report is on the impact of theliberalisation and reform of the market on the quantityand quality of cab services in Ireland.
The next section of the report examines how theliberalisation and reform processes have impacted
on the overall demand for cab services.

15

16

3
maRKet DemanD

3.1 introduction

3.2 Market Size

This section profiles the current

3.2.1 incidence of Cab use by Consumers

demand for cab services. It commences

In 2008, 48 per cent of all adults had used a cab within
the six months prior to the survey. Relative to 2005,
the proportion of the adult population using cab services
has increased by 9 percentage points. See Table 3.1.10

by evaluating the aggregate demandfor cab services. This is followed by

The use of cabs is high relative to some other modes oftransport available. For example, a higher proportion of
adults had taken a cab in the last six months than had usedtrain or local bus services. In Dublin, where there is themost substantial local bus service, 59.9 per cent of adults
used cab services compared to 51.9 per cent availing of
local bus services. It should be noted that these figures
do not take account of frequency of usage which is
examined in the next section.

an analysis of demand in the different
markets and by the main consumer
groups. Where data is available, theimpact of liberalisation of the market
on demand is assessed.

table 3.1
Distribution of Adults by Modes of Transport Used in Last Six Months
2005

2008

method of

all Cab users

all Cab users

DublinRest ofmunster

Connaught/

transport

(%)

(%)

(%)

leinster (%)(%)

ulster (%)

Bus (Local)

38.8

32.6

51.9

27.1

26.1

20.8

Bus/Coach

20.6

18.6

12.9

20.4

14.2

31.8

Luas

9.4

12.4

17.8

12.1

8.3

11.5

Train/DART/Arrow

21.2

24.4

14.3

29.6

23.8

33.9

Car

82.5

86.0

77.4

88.8

92.7

84.9

Motorbike/Moped

1.7

1.0

0.3

2.1

0.7

1.0

Bicycle

9.5

6.0

4.9

5.4

7.6

5.7

Taxi/Hackney Cab

38.8

47.8

59.9

52.1

36.0

43.2

Walking (non-leisure)

39.4

38.3

48.4

32.1

38.0

31.3

Note: Totals do not add up as many respondents reported using more than one method of transport.
Source: Goodbody Survey of Households, 2005 and 2008

10 The survey did not question respondents on their use of limousine services as limousines are a mode of transport generally used for corporate and ceremonial purposes and therefore
not easily comparable to other modes of transport used on a daily basis by consumers. Limousines account for approximately 5 per cent of the cab market in Ireland.

17

Sec tion 3 market demand

Figure 3.1
Total Distribution of Cab Users by
Frequency of Use Nationally, 2008

3.2.2 Frequency of Cab Use by Consumers
The frequency with which cab users made cab trips in2008 is illustrated in Figure 3.1. In 2008, the proportion
using cabs at least once a week or more was 53.8 per
cent, marginally up from 52.9 per cent in 2005. When
compared with 2005, cab usage in 2008 is therefore
relatively unchanged. The increase in cab usage over theperiod since 2005 therefore largely derives from increases
in the numbers using cabs rather than increased averagefrequency of use. Relative to other modes of transport,
cabs are relied on more frequently than coach, Luas, train
or Dart services. Only local bus services are used more
frequently than cabs.

Once a week or moreOnce a month
Less often

21.8%
53.8%
24.5%

On an area basis, people in Dublin are most likely to
use a cab at least once a week (66.7 per cent). The
corresponding proportion falls to 38 per cent for Munster.
Munster also had the highest proportion of infrequentuse, with 33.3 per cent reporting using cabs less often
than once a month.

Source: Goodbody Surveys of Households, 2008

Figure 3.2
Geographic Distribution of Cab Users by Frequency of Use, 2008%

Dublin80

70

Rest of Leinster

66.7%

Munster50

40

Connaught/Ulster

56.8%

60

47.6%
38.0%

33.3%

33.3%

28.7%
30

27.9%

24.6%
17.5%

20

15.8%
9.9%

10

0

Once a week or more

Source: Goodbody Surveys of Households, 2008

Once a month

Less often

18

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

3.2.3 Aggregate Demand for Cabs

3.3 Demand for Different Cab Services

The data on incidence and frequency of use may be used
to estimate the total number of cabs trips made in Ireland.
The data suggests that some 100 million cab trips weremade in 2008, of which 3.5 million were made by tourists.
Approximately 40 million or 41 per cent of cab trips weremade by residents of the Dublin area.
The data collected since 1997 permits similar estimates forcab trips by residents of the Dublin area for the last decade.
The results are presented in Figure.3.3. In interpreting theseresults, it should be borne in mind that they are based on
surveys and that sampling errors are present. This suggeststhat the focus should be on the broad trends that emerge,rather than year-to-year changes.
The data suggests that since liberalisation of the market,
demand in the Dublin market has increased from 22 million
trips in 1997 to 40 million in 2008, or by some 82 per cent.
Figure 3.3
Trends in Demand for Cabs in the Dublin Area
(Million Trips per Annum)

Some 77 per cent of national demand for cabs in2008 was for taxi services with 23 per cent for hackneyservices.11 This compares with an equivalent share in 2005
of 72 per cent for taxis, so that the demand for taxis isrising over time. In the Dublin area, the proportion ofdemand for taxi services has risen from 77 per centof the cab market in 1997 to 83 per cent in 2008.
Table 3.2 presents a breakdown of the demand for cabs
by street and telephone-booked services. Nationally, 63.2
per cent of trips were arranged by phone in 2008, with
36.8 per cent hired on street. These proportions haveremained relatively static since 2005.
Table 3.2
Distribution of Journeys by Method of Hire2005 and 2008 Nationwide

Market TypeCountry as a Whole

All CabAll CabUsers 2005

Users 2008

(%)

(%)

By phone from residence

39.4

42.0

By phone from work

2.3

2.1

By phone (other)

22.6

19.1

Sub Total

64.3

63.2

Queued at taxi rank

15.5

16.8

Hailed on street

17.6

18.3

Other

2.6

1.7

Sub Total

35.7

36.8

Total

100

100

Phone Hire

Dublin Area
Million trips
per annum

100

100

77

80

Street Hire
60

40

40
27

28

22

20

Source: Goodbody Survey of Households, 2005 and 2008

N/A

1997

N/A

2001

2005

Source: Based on the Goodbody Surveys of Households
for 1997, 2001, 2005 and 2008

11 Based on the household survey response to last cab trip undertaken.

2008

The data indicates, that immediately after liberalisation,
the demand for street services increased as a proportionof the total, but that telephone-booked services are
now preferred.
In relation to Dublin, over the period 2001 to 2008 theproportion of cabs arranged by telephone has increased
from 37.7 per cent to 58.1 per cent, with a significant
increase occurring among trips organised from home

19

Sec tion 3 market demand

Table 3.3
Distribution of Journeys in Dublin by Method of Hire, 1997, 2001, 2005 and 2008

Method of Hire2001 (%)

2005 (%)

2008 (%)

By phone fromresidence

26.4

42.1

43.7

By phone from work

2.7

4.0

2.4

By phone (other)

8.6

6.5

12.0

37.7

52.6

58.1

Queued at taxi rank

29.1

9.7

11.4

Hailed on street

32.6

37.7

30.5

Other

0.6

0.0

0.0

Sub Total

1997 (%)

47.9

Sub Total

52.1

62.3

47.4

41.9

Total

100

100

100

100

Source: Goodbody Surveys of Households, 1997, 2001, 2005 and 2008

and non-work locations. The proportion of cab trip
journeys hired on the street has fallen significantly
from 62.3 per cent in 2001 to 41.9 per cent in 2008.

3.4 The Temporal Pattern of
the Demand for Cab Services

Table 3.4
Distribution of Cab Trips by Day of the Week
for Most Recent Trip Taken 2005 and 2008

Day of the Week

All CabAll CabUsers 2005

Users 2008

(%)

(%)

The demand for cab services is a peaked demand.
Demand peaks on Fridays and Saturdays, which together
account for 73.4 per cent of all trips. This reflects thedemand for cabs for social and recreational purposes.
The evidence is that this peakedness in demand isincreasing. See Table 3.4.

Monday3.4

1.9

Tuesday

4.2

2.5

Wednesday

6.0

6.2

Thursday

7.9

12.3

There is evidence also that demand is peaked by timeof day. Just over 50 per cent of demand arises between
18:00 and 03:00 and the period between midnight and
03:00 accounts for 22 per cent of demand. However, there
has been a relative decline in usage between midnightand 03:00 since 2005.

Friday25.0

30.2

Saturday

45.2

43.2

Sunday

8.3

3.7

Total

100

100

The peaked nature of demand for cab services presentsa challenge for the cab industry in that a flexible supply
response is required to ensure that peak demand ismet. This is further discussed in Section 5.

Source: Goodbody Surveys of Households, 2005 and 2008

20

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 3.5
Distribution of Cab Trips by Time of Day and Age Group for Most Recent Trip Taken 2005 and 2008

2005

2008

Time of Day

All Cab Users (%)

All Cab Users (%)

15–35 Years (%)

35+ Years (%)

00:01–03:00

28.0

21.7

27.0

16.3

03:01–06:00

4.4

6.5

7.2

3.5

06:01–09:00

4.6

3.8

1.8

6.6

09:01–12:00

15.3

15.8

11.7

19.4

12:01–15:00

15.4

16.2

11.7

19.4

15:01–18:00

7.7

6.1

12.6

4.0

18:01–21:00

15.9

18.8

18.9

18.1

21:01–00:00

8.7

11.0

9.0

12.8

Total

100

100

100

100

Source: Goodbody Surveys of Households, 2005 and 2008

Figure 3.4
Distribution of Trips for All Cab Users by Time of Day for Most Recent Trip Taken 2005 and 2008

%
30

2005
2008

28.0%

25
21.7%
18.8%

20
15.3% 15.8%

16.2%
15.4%

15.9%

15
11.0%

10

7.7%

6.5%
4.4%

5

8.7%
6.1%

4.6%

3.8%

Hours
00:01–03:00

03:01–06:00

06:01–09:00

Source: Goodbody Surveys of Households, 2005 and 2008

09:01–12:00

12:01–15:00

15:01–18:00

18:01–21:00

21:01–00:00

21

Sec tion 3 market demand

The data for Dublin shows that, since deregulation,
there has been some smoothing of peak demand. Whiledemand for trips between midnight and 09.00 is still alarge proportion of the total demand, it is in decline. There
has been a marked increase in the proportion of trips taken
between the hours of 09.00 and 15.00, up from 13 percent in 1997 to 37.8 per cent in 2008. See Table 3.6.
Table 3.6
Distribution of Journeys by Time of Day,
1997, 2001, 2005 and 2008

Time of Day

1997

2001

2005

2008

(%)

(%)

(%)

(%)

00:00–09:00

52.0

43.7

31.0

26.8

09:00–12:00

7.0

10.3

11.8

23.2

12:00–15:00

6.0

10.7

15.7

14.6

15:00–18:00

6.0

7.9

11.2

9.1

18:00–21:00

19.0

19.6

24.0

12.8

21:00–00:00

9.0

7.9

6.4

13.4

Total

100

100

100

100

Source: Goodbody Surveys of Households, 1997, 2001, 2005 and 2008

Figure 3.5
Distribution of All Cab Users by Purposeof Most Recent Journey 2008
%
80
70

65.0%

60
50
40
30
20
11.3%

10

8.1%

5.7%

8.7%
1.2%

In theShopping
course oftrip
work/businessSocial/Rec

Personal/familyTo/from othertransport
terminal

Source: Goodbody Surveys of Households, 2005 and 2008

Other

3.5 The Demand for Cabs byDifferent User Groups
3.5.1 Introduction
Figure 3.5 describes the journey purposes recorded bycab users in 2008. This data is relatively unchanged from2005. This indicates that cabs are used predominately forsocial and recreational purposes. This data is derived fromthe Household Survey. The Household Survey indicated thata relatively small proportion of cab use was in the course ofwork or business. The reason for this may be that peopleinterviewed at home may be more likely to remember atrip from home rather than a trip taken during the courseof work.
The data also does not reflect the role of the cab industry
in catering for demand from institutions such as hospitals.
Cabs provide a valuable service in transporting ill people orpeople with disabilities to and from medical appointments.
This sub-section of the report examines the demandfor cab services from these two key groups namely
the business sector and people with disabilities.

22

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

3.5.2 Demand for Cabs from the Business Sector

84 per cent of businesses use the services of taxi
companies, with just 20.4 per cent using hackneycompanies. Over the 2005–2008 period, there has
been an increased tendency for businesses to use theservices of taxi companies as opposed to hackneycompanies. Businesses also make significant use oflimousine services.

The data used below is drawn from a survey ofbusinesses in Ireland carried out in 2008, as well asa similar survey carried out in 2005.
Analysis of the 2008 survey results showed thatapproximately 60 per cent of businesses held at least
one account with cab companies, up from 50 per centin 2005. Businesses outside Dublin were more likely tohold dispatch operator accounts.

Table 3.7
Proportion of Businesses with one or more Accounts, 2005 and 2008

2005

2008

Total

DublinRest of

Total

DublinRest ofSample (%)(%)

Ireland (%)

Sample (%)(%)

Ireland (%)

Yes

50.0

60.8

39.5

60.0

65.1

53.1

No

50.0

39.2

60.5

40.0

34.9

46.9

Total

100

100

100

100

100

100

Source: Goodbody Surveys of Businesses, 2005 and 2008

Table 3.8
Distribution of Businesses by Type of Dispatch Operator Used

2005

2008

Total

DublinRest of

Total

DublinRest ofSample (%)(%)

Ireland (%)

Sample (%)(%)

Ireland (%)

Taxi Company

74.0

85.6

62.1

84.0

93.4

68.8

Hackney Company

31.2

20.8

41.9

20.4

9.2

38.5

Limousine Company

3.2

4.0

2.4

4.4

4.6

4.2

Source: Goodbody Surveys of Businesses, 2005 and 2008
Totals do not add up as some businesses used more than one type of operator

23

Sec tion 3 market demand

Table 3.9
Distribution of Businesses by Number of Cabs Ordered per Day

2005

2008

Total Sample

DublinRest of Ireland

Total Sample

DublinRest of Ireland

(%)

(%)

(%)

(%)

(%)

(%)

1 cab

13.2

11.2

15.3

11.2

10.5

12.5

2 cabs

8.8

8.8

8.9

6.4

5.9

7.3

3 cabs

7.2

8.8

5.6

6.8

6.6

7.3

4 cabs

4.0

4.8

3.2

2.8

3.9

1.0

5 cabs

2.4

2.4

2.4

6.8

6.6

7.3

>5 cabs

7.6

7.2

8.1

8.0

6.6

9.4

It varies

54.4

55.2

53.2

49.6

50.7

47.9

Don’t know

2.4

1.6

3.2

8.4

9.2

7.3

Source: Goodbody Survey of Businesses, 2005 and 2008

Table 3.9 gives an indication of the level of demandfor cabs among the business sector for the country as awhole. In total, 17.6 per cent of businesses use one or two
cabs daily. A further 24.4 per cent use three or more cabs
daily. There are no significant differences in the numberof cabs ordered by businesses in 2008 compared to 2005.

3.5.3 Cab Use by People with Disabilities
The use of cabs by people with disabilities is low in
Ireland relative to usage among the general population.12
Almost half of all persons with disabilities use cabs lessthan once a month with a very small number using cab
services daily or more often. With regard to full-time
wheelchair users, 55.2 per cent of this group use cabs
less than once a month.

Table 3.10
Distribution of People with Disabilities by Frequency of Cab Use

Frequency

Proportion (%)

Proportion (%)

Proportion (%)

All people with Disabilities

Full-time Wheelchair Users

General Population

Daily or more

2.2

3.4

1.0

Every 2–3 days

5.8

3.4

6.6

Every 4–5 days

5.1

1.7

11.2

Once a week

14.5

15.5

34.9

Once a month

23.9

20.7

24.5

Less often

48.6

55.2

21.8

Total

100

100

100

of UseSource: Goodbody Survey of People with Disabilities 2008

12 Demand, and not need, is the focus of discussion here.

24

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

When these figures are compared to the general
population, they show a large difference in the frequency
of use. Approximately 54 per cent of the general
population use cabs once a week or more often comparedwith 24 per cent amongst full-time wheelchair users.
The level of usage has also fallen since 2005 for full-time
wheelchair users with 55.2 per cent now using cabs lessthan once a month compared with 40.4 per cent in 2005.
Table 3.11
Distribution of Respondents by
Frequency of Usage 2005 and 2008

Rate of use

2005

2008

Proportion (%)

Proportion (%)

Full-time

Full-time

Wheelchair Users

Wheelchair Users

Daily or more

6.3

3.4

Every 2–3 days

10.6

3.4

Every 4–5 days

8.5

1.7

Once a week

14.9

15.5

Once a month

19.1

20.7

Less often

40.4

55.2

Total

100

100

Source: Goodbody Survey of People with Disabilities, 2005 and 2008

It should be noted that the usage levels as outlined above
should not be taken as an indicator of the demand for cab
services among people with disabilities. Evidence suggeststhat people with disabilities continue to experience
difficulties obtaining cab services (see Section 6.3.3).

3.6 Cab Demand and the Fare Structure
As mentioned in Section 2, in 2006, the Commission
abolished the existing system of 34 taximeter areas andthe entire country became one taximeter area. As part ofthis process, the Commission also introduced a uniform
national structure. Prior to this change, there were 34
taximeter areas in the country, each of which operated
a different fare structure. For example, different perkilometre charges operated and the range of extra charges
applied (such as luggage charges) varied considerably.
This meant that the price of travelling by taxi varied for
consumers both in terms of the level of charges overall
and the charges for different types of journey.
The argument for a single national maximum taxi fare
was that there would be significant benefits in terms ofboth consumer information and additional administrative
simplicity. A further argument in favour of a national
maximum taxi fare was that there did not appear to be any
significant or systematic difference between taxi operating
costs across different taximeter areas.13 It was also notedthat the then current ‘fare cards’ did not vary according
to any urban-rural divide or other regional differences.
Differences between fare cards arose as a consequenceof arbitrary differences in the fare-setting methodologies
employed by various local authorities over time.
Accordingly, a national maximum taxi fare was introduced,
applying common rates, extras and unsocial hours charges
across the country. The new national fare structure was
implemented in the context of a fare revision. As a result,while the fares charged for some journeys in some former
taximeter areas declined, the overall impact was a modest
fare increase across the board.
This change in fare structures would appear to havebeen broadly accepted by the consumer. As has been
demonstrated above, the demand for cab trips has
increased from 77 million annually in 2005 to 100 million
in 2008, an increase of over one-quarter. Furthermore,
there has been a switch in demand from hackneys to taxis,
although the latter would have been more directly affectedby the changes. More significantly, there is evidence that
consumers find the fare structure easier to understandand that the current structure is providing better value formoney. Table 3.12 shows that, since the reform of the farestructure, the proportion of cab users who feel that fares

13 See: Goodbody Economic Consultants: Review of Taxi Fares and Taxi Fare Structures. March 2006.

25

Sec tion 3 market demand

are easier to understand has risen by 2 percentage points
and the proportion who have difficulties understanding
fares has dropped by almost 5 percentage points. These
represent significant improvements in the understandingof fare structures, especially in view of the necessarily still
complex fare-charging processes that take account of bothjourney time and distance.
Table 3.12
Distribution of Adults by Ease of Understandingof Fare Structures, 2005 and 2008

Proportion of Cab Users
How taxi/hackney fares

2005

2008

are calculated is easy

(%)

(%)

Strongly agree

10.1

13.5

Agree

52.7

51.3

Neither agree nor disagree

14.6

17.4

Disagree

18.8

13.0

Strongly disagree

3.8

4.8

Total

100

100

to understand

Table 3.13
Distribution of Cab Users by Perception of Value for Money:
2005 and 2008

Proportion of Cab Users
Cabs provide good

2005

2008

value for money

(%)

(%)

Strongly agree

6.5

12.2

Agree

51.8

50.4

Neither agree
nor disagree

15.2

15.1

Disagree

20.8

19.0

Strongly disagree

5.7

3.3

Total

100

100

Source: Goodbody Surveys of Households

Source: Goodbody Surveys of Households

Table 3.13 indicates that consumers increasingly see
cabs as good value for money. The proportion of cab
users who feel that cabs are good value for money has
increased by 4 percentage points, while the proportion
who do not has declined by the same margin.

26

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

3.7 Conclusions
Overall Market Demand• An estimated 100 million cab trips were madenationwide in 2008. This represents an increaseof over one-quarter compared with 2005.
• Estimates for cab trips by residents of the Dublin areasuggest that, since liberalisation of the market, demandin the Dublin market has increased from 22 million trips
in 1997 to 40 million in 2008, or by some 82 per cent.
• One in two adults has made a trip by cab in thelast six months. Demand for cabs is high relative todemand for other modes of transport. For example,
when surveyed, a higher proportion of adults hadtaken a cab in the last six months than had usedtrain or local bus services.
Demand for Different Cab Services• Some 77 per cent of national demand for cabs
in 2008 was for taxi services with 23 per cent for
hackney services. This compares with an equivalentshare in 2005 of 72 per cent for taxis, so the demand
for taxis is rising proportionately over time.
• In the Dublin area, the proportion of demand fortaxi services rose from 77 per cent of the cab market
in 1997 to 83 per cent in 2008.
• Nationally, 63 per cent of trips were arranged byphone in 2008, with 37 per cent hired on-street.
These proportions have remained relatively static
since 2005.
• In the Dublin cab market, in 2008, 58 per centof trips were telephone booked, with 42 per centstreet hired. The data indicates that immediately
after liberalisation, the demand for street services
increased as a proportion of the total, but that
telephone-booked services are now preferred.

Temporal Nature of Market Demand• The demand for cab services is a peaked demand.
Demand peaks on Fridays and Saturdays, which
together account for 73 per cent of all trips. This
reflects the demand for cabs for social and recreational
purposes. The evidence is that this peakedness indemand is increasing.
• There is evidence also that demand is peaked bytime of day. Just over 50 per cent of demand arises
between 18.00 and 03.00 and the period between
midnight and 03.00 accounts for 22 per cent of demand.
However, there has been a relative decline in usage since2005 between midnight and 03.00.
Market Demand by Type of User
• Cabs are used predominately for social and recreational
purposes. However, approximately 60 per cent ofbusinesses hold one or more accounts with cab
companies, up from 50 per cent in 2005.
• Cab use by people with disabilities is lower than by thegeneral population with approximately 50 per centusing them less often than once a month.
• The level of usage for full-time wheelchair users has
fallen since 2005 with 55 per cent now using cabs lessthan once a month compared with 40 per cent in 2005.
Cab Demand and Fare Structure• In 2006, the Commission introduced a uniform
national maximum taxi fare structure. This change
in fare structures has generally been accepted by the
consumer. There is evidence that consumers find thefare structure easier to understand and believe that thecurrent structure is providing better value for money.

Sec tion 3 market demand

27

28

4
ComPetition anD oveRall maRKet SuPPly

4.1 introduction
Section 2 set out details of theextensive changes that have occurredin the cab industry in Ireland in thelast two decades. During this period
the industry has transformed from one
where there were strict controls on the

Under the Taxi Regulation Act 2003, one of theobjectives of the Commission is ‘to encourage andpromote competition in relation to services (including
fares) offered by small public service vehicles’.
This Section starts by establishing the degree to which
the cab industry in Ireland is competitive by looking at
the extent to which barriers to entry and exit from theindustry exist. It then sets out what have been the effects
of increased competition within the industry. Finally,
the likely future trends in a highly competitive industry
are presented.

numbers entering the taxi industry to
one where entry has been completely
liberalised. Following liberalisation andthe increase in the number of licensed
cabs and drivers, there was concernthat the quality of the services provided
be maintained and improved. The
Commission for Taxi Regulation wasestablished in 2004 to develop andmaintain a regulatory framework forthe newly liberalised market.

4.2 Competition in the Cab Market
According to strict economic theory, a competitivemarket is a contestable one ie. where there are no
significant barriers to entry or exit. In this section, theextent to which there are barriers to entry and exit to
the cab market in Ireland is analysed.

4.2.1 barriers to entry to Cab industry
In order to enter the cab industry as a fully licensed
taxi operator in Ireland, prospective entrants must fulfil
the industry licensing requirements and make an upfront
financial investment.
The current costs associated with entering the industry
include the cost of purchasing an SPSV vehicle licence.
Taxi vehicle licences can be bought from the Commission
for Taxi Regulation for €6,300.14 To obtain a licence,
entrants must have use of a vehicle, which, from January
2009, must be no more than nine years old from the firstdate of registration. The other upfront costs that must
be borne by entrants to the taxi industry include vehicle
insurance, road tax, meter calibration (taxis only), meter
verification (taxis only), NCT suitability and roadworthinesstests as well as an SPSV driver licence. Table 4.1 sets out
the upfront costs associated with entering the taxi industry.
As the table highlights, prospective entrants to the industry
must currently invest approximately €13,000 prior tocommencing operation as a taxi.

14 The corresponding price of hackney, limousine and wheelchair accessible taxi licences are €1,000, €1,000 and €125 respectively.

29

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p lyof €200/€300 weekly, translating to annual costs
of approximately €10,400–€15,600.

Table 4.1
Financial Costs associated with entering Taxi Industry

Cost

€

SPSV Licence

6,300

Annual Vehicle Costs15

3,777

Vehicle Insurance

1,706

Road Tax

79

NCT and suitability inspection

91

Meter Calibration

60

Meter Verification

91

SPSV Driver Licence

15

Roof sign/meter/printer

850

Total

12,969Source: PA Consulting Limited, Review of National
Maximum Taxi Fare, October 2008

It should be noted, however, that many entrants to theindustry will already be in possession of a vehicle which
they use for their own private motoring purposes. As aresult the inclusion of vehicle, insurance and road tax costs
may distort the upfront costs associated with entering the
SPSV industry and the actual financial cost of entering theindustry may be closer to €7,400.
In the case of operators wishing to operate a wheelchair
accessible taxi the initial vehicle costs are substantiallyhigher as few would already own a suitable vehicle. A
new wheelchair accessible vehicle to the current suitability
requirements currently costs an estimated minimum of€39,000.16 The costs of second-hand wheelchair accessible
vehicles is dependent on many factors but is estimated to
be at least €15,000. The wheelchair accessible taxi licencecurrently costs €125.
Entrants who do not have the financial means necessary
and/or entrants who wish to test the industry prior toinvesting in it have the option of renting out a licensed,
insured, fully equipped vehicle. While renting costs vary
according to a number of factors including the region of
the country and the vehicle type, they can be of the order

To obtain a taxi vehicle licence, a potential entrant musthave a vehicle that has passed a suitability inspection
and a roadworthiness test.
In addition to a taxi vehicle licence, an entrant to theindustry must also obtain an SPSV driver licence which
entitles them to drive any category of SPSV – taxi, hackney
or limousine – for a period of five years. Currently, toobtain an SPSV driver licence an applicant must interact
with up to four bodies, namely their local motor tax office,their local Garda station, the relevant regional PSV office
and also the Commission for Taxi Regulation.17
The broad process of applying for an SPSV driver licence
involves an applicant contacting their local Garda station or
PSV office to acquire an application form. The completed
form is submitted along with all necessary documents tothe applicant’s local Garda station. The applicants are put
forward for vetting and, if deemed a suitable candidate,their file is then returned to their local PSV office. If all
requirements are met, they will be informed of when they
can attend a local area knowledge test.18 If successful inthe test, the applicant is then issued with an SPSV driver
licence certificate and appropriate identification cards.
As described above, the barriers to entry to the cab
industry are, at present, not significant once the licensing
requirements have been fulfilled. Entry to the industry
is possible if applicants have access to a lump sum of
approximately €6,500, or €200 weekly, and if they:• have use of a vehicle meeting SPSV standards• are of good character in terms of Garda vetting• have a good working knowledge of the area inwhich they intend to operate
Table 4.2 sets out the number of entrants to the cab
industry in Ireland over the 2007–2008 period. For theoverall net changes to vehicle licence numbers please
see Table 4.3. The total number of new entrants relate
to those purchasing new cab licences as well as thoseentering the industry as a result of taxi licences that havebeen transferred from one person to another. In 2007,
the number of new entrants, as a proportion of the total

15 The vehicle costs are based on the costs of financing a 2005 Saloon 5-door Toyota Avensis with a 2.0 litre diesel engine and assume a five year finance package.
16 In the submission made by the Commission to the Minister for Transport in January 2008 (for a subsidy package to assist in the financing of a wheelchair accessible service)costs of €52,000 were indicated for a wheelchair accessible vehicle. This was based on a UK vehicle that had full Type Approval and cannot be directly compared to the €39,000
Irish vehicle as they do not currently conform to the same specifications. Changes in the exchange rate since then also makes such direct comparison invalid.
17 The Commission for Taxi Regulation is currently preparing to take over the processing of the driver licensing from An Garda Síochána which administers the process.
When the Commission takes over the driver licensing process it will introduce changes to streamline the process (see Section 7.4.4).
18 The Commission is currently developing a mandatory Skills Development Programme for all SPSV drivers and dispatch owners/operators. This programme will replace thecurrent Garda test required for an SPSV driver licence. New SPSV driver licence applicants will be required to undertake the programme from mid 2009. Existing SPSV driver licenceholders will be required to undertake the programme on renewal of their licences with effect from 1st January 2012. For further details see Section 8.4.1.

30

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 4.2
Entry to SPSV Industry 2007–2008

Cost

Number of

Number of

Total New

Total New

New Licences

Transferred

Entrants

Licences as %(All SPSVs)

Taxi Licences

January–December 2007

4,439

1,328

5,767

17.3

January–December 2008

3,036

1,993

5,029

11.1

of Total Fleet

Source: Commission for Taxi Regulation
Note: See Table 4.3 for net changes to vehicle licence numbers

number of vehicle licences operating in the industry,
totalled 17.3 per cent. The equivalent figure in 2008 was
11.1 per cent. The historic levels of new entrants to theindustry, while falling, support the findings that there
are no significant barriers to entry to the cab industry
in Ireland.

4.2.2 Barriers to Exit from Cab Industry
Participants in the cab industry in Ireland are free at any
time to stop operating and exit the industry. The only realpotential cost associated with exit from the cab industry
occurs if persons exiting the industry experience difficulty
selling their taxi licence19 (assuming persons exiting theindustry keep their vehicles for their own private motoring
purposes). Owing to the ease with which licences canbe purchased from the Commission for Taxi Regulation,and the security features associated with licences issued
directly from the Commission in terms of their guaranteed
legitimacy, it is possible that persons exiting the cab
industry may experience difficulties selling their taxi vehicle
licences. Therefore, the maximum cost associated withexiting the industry is the upfront €6,300 investment costs
required to purchase a taxi licence. This cost, or part of it,
can be avoided if persons exiting the industry succeed inselling (transferring) their taxi vehicle licence to anotherindividual. As hackney and limousine licences cannot betransferred to another person, persons with these licencetypes wishing to exit the industry bear a loss totalling the
upfront vehicle licence costs of between €250 and €1,000,
depending on when they purchased their licence.20

4.3 Effects of Increased Competition
We have seen in Section 4.2 above that the cab industry
in Ireland is competitive, as there are no significant barriers
to entry and exit. This Section sets out what have been theeffects of the increased competition within the industry.

4.3.1 Trends in Cab Numbers
Throughout the period 1993 to 2007 the number of cabs
in Ireland grew significantly (see Figure 4.1 and Table 4.3).
By 2008, the total number of SPSVs in the country totalled
27,429. Between 1993 and 2000, when liberalisation
occurred, the number of licensed cabs increased froma base of 6,144 to reach 13,637 (an increase of 122 percent). There was a slightly smaller increase in the numberof licensed cabs in the years post-liberalisation, namely 101
per cent over the 2000–2008 period. The corresponding
increases in cab numbers in the Dublin cab market overthe same periods were 155 and 111 per cent respectively.
See Figure 4.2.
It is noteworthy that immediately after liberalisation, overthe period 2001–2002 there was a very substantial increasein the number of licensed cabs, of the order of one-third.
This reflects the level of pent-up historical demand for cabsthat existed at the time. Since 2002, the growth in thenumber of licensed cabs annually has been generally
in single-digit figures.

19 There is no reliable source of information as to whether taxi licence holders experience difficulties selling their taxi licences.
20 The cost of purchasing hackney and limousine licences was increased from €250 to €1,000 in 2008.

31

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p ly

Figure 4.1
Trends in Cab Numbers in Ireland 1990–2008
Numberof cabs

Taxis

Hackneys

All cabs

Major reforms
initiated

30000
Taxi Commission
established
25000
Liberalisationof the market

20000

15000

10000

5000

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Source: Vehicle Registration Unit, Department of Transport (VRU 1993–2006) and Commission for Taxi Regulation (2007–2008)

Figure 4.2
Trends in Cab Numbers in Dublin 1990–2008
Numberof cabs

Taxis

Hackneys

All cabs

Major reforms
initiated

15000
Taxi Commission
established

12500

Liberalisationof the market

10000

7500

5000

2500

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

Source: Vehicle Registration Unit, Department of Transport (VRU 1993–2006) and Commission for Taxi Regulation (2007–2008)

2008

32

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 4.3
Number of Cabs in Use 1993–2008 Ireland and Dublin

Ireland
Year

Taxi*

Other

DublinTotal

Annual (%)

Taxi*

Other

Total

Change

1993

2,726

3,418

6,144

1994

2,929

3,996

6,925

1995

3,002

5,084

1996

3,145

1997

Annual (%)
Change

1,822

643

2,465

12.7

1,955

863

2,818

14.3

8,086

16.8

1,972

1,291

3,263

15.8

6,074

9,219

14.0

2,016

1,949

3,965

21.5

3,212

7,128

10,340

12.2

1,994

2,502

4,496

13.4

1998

3,639

7,610

11,249

8.8

2,276

2,546

4,822

7.3

1999

4,063

9,013

13,076

16.2

2,719

3,420

6,139

27.3

2000

4,218

9,419

13,637

4.3

2,757

3,518

6,275

2.2

2001

8,025

8,522

16,547

21.3

5,465

2,767

8,232

31.2

2002

10,757

7,495

18,252

10.3

7,270

2,096

9,366

13.8

2003

12,781

7,075

19,856

8.8

8,407

1,655

10,062

7.4

2004

14,171

6,573

20,744

4.5

9,123

1,348

10,471

4.1

2005

15,686

6,202

21,888

5.5

9,934

1,077

11,011

5.2

2006

17,287

5,293

22,5803.2

10,623792

11,415

3.7

2007

19,496

6,199

25,695

13.8

11,768728

12,4969.5

2008

21,177

6,252

27,4296.7

12,568676

13,244

6.0* Includes wheelchair accessible taxis
Source: Vehicle Registration Unit, Department of Transport (VRU 1993–2006) and Commission for Taxi Regulation (2007–2008)

4.3.2 Geographic Distribution of Cabs by Type
Dublin accounts for 48 per cent of all cabs and 59 per centof all taxis nationally. However, it is likely that these figures
underestimate the proportion of the fleet operating in
Dublin. This is because vehicles tend to be licensed in the
county in which the vehicle owner is resident. Therefore,
vehicles licensed in Louth, Meath, Kildare and Wicklow
could be operating in Dublin, assuming drivers have passed
the SPSV driver knowledge test for Dublin. County Cork
provides the next largest cab market.

While taxis are the predominant type of cab overall,hackneys are still in the majority in ten of the 26 counties.
This trend is at least partly explained by the low degreeof urbanisation in these counties. Figure 4.3 overleaf
and Table 4.4 illustrate this.

33

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p ly

Figure 4.3
Number of Cabs by County, 2008
Majority Taxi
Majority Hackney

558

107
144

217
234

448

164

754

125

1408

396

1231

262

1259

554

289

503

13244

200

930
535

394

267

398

2382

426

34

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 4.4
Number of Cabs by County, 2008

CountyTaxi

Wheelchair

Hackney

Limousine

Total

accessible taxi

Carlow

111

26

58

5

200

Cavan

99

13

119

3

234

Clare

206

14

237

46

503

Cork

1,376

88

751

167

2,382

Donegal

203

25

314

16

558

Dublin11,831

737

255

421

13,244

Galway

699

102

383

47

1,231

Kerry

223

17

222

73

535

Kildare

759

95

309

96

1,259

Kilkenny

162

28

60

17

267

Laois

151

42

88

8

289

Leitrim

27

13

62

5

107

Limerick

613

42

219

56

930

Longford

76

11

35

3

125

Louth

509

47

154

44

754

Mayo

184

18

218

28

448

Meath

1,075

90

181

62

1,408

Monaghan

8

8

118

10

144

Offaly

80

18

148

16

262

Roscommon

33

10

113

8

164

Sligo

141

14

41

21

217

Tipperary

39

4

319

32

394

Waterford

230

30

83

55

398

Westmeath

283

42

61

10

396

Wexford

151

32

205

38

426

Wicklow

308

34

161

51

554

Total

19,577

1,600

4,914

1,338

27,429Source: Commission for Taxi Regulation

35

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p ly

Figure 4.4
New Vehicle Licences Issued, January 2007–February 2009
New
Licences

2007

2008

2009

500

400

300

200

100

0

January

February

March

April

May

June

July

AugustSeptember

OctoberNovember December

Source: Commission for Taxi Regulation

4.3.3 Trends in New Vehicle Licences
Figure 4.4 shows the number of new licences issued
each month during 2007 and 2008. For the overall net
changes to vehicle licence numbers please see Table 4.3
above. From a peak of approximately 450 licences issuedin July 2007, the general trend has been downward, withfewer than 200 licences issued in December 2008. The
data for January and February 2009 indicates that thetrend of reduction in the number of new vehicle licences
issued monthly has been reinforced, with 92 vehicle
licences being issued in January and 89 in February,
compared to 188 in December 2008.

4.3.4 Trends in Cab TypeAs Table 4.3 indicates, these overall trends in cab numbers
mask different trends with regard to taxis as distinct
from hackneys.21 In 1993, other cabs (mainly hackneys)accounted for the major share of the cab market in
Ireland, namely 55.6 per cent of the total 6,144 cabs thenlicensed. By the year 2000, the dominance of hackneys
had increased to approximately 69 per cent of the total cab
fleet. Since liberalisation, hackney numbers have declined
and now amount to 18 per cent of the total. In contrast,
taxi numbers have surged to 21,177 from a base of 4,218
in the year 2000. Figure 4.5 presents an overview of thechanges in the market breakdown of cab types over theperiod 2000–2008.
These trends were mirrored in the Dublin area, althoughhackneys have never played as strong a role there as they
do nationally. In 1993, hackneys accounted for 643 vehicles
or 26 per cent of the total fleet of 2,465 cabs in Dublin.
By the year 2000, hackney numbers had risen to 3,518 or
56 per cent of the total. By the year 2008, hackneys wereplaying a very minor role in the Dublin market, with only
255 licences or 2 per cent of the total market.
With regard to limousines specifically, although the market
share is quite small, it is worth noting that there has beena steady growth in limousine numbers over the last eight
years. In 2001 limousines accounted for 0.85 per cent of
the cab market or 141 licences, by 2004 this had risen
to approximately 2.5 per cent and as of the end of 2008
limousines accounted for approximately 5 per cent of theoverall cab market or 1,338 licences. This steady but slow
increase in the market share of limousines is a reflectionof the fact that limousines operate in a niche market but
could also indicate that operators are less likely to enter thismarket without due consideration to the costs of enteringand likely returns from the limousine trade. Wheelchair
accessible taxis account for only 6 per cent of the overall
cab market at present.

21 Limousines are included in ‘hackneys’ for the purposes of this discussion, unless otherwise stated.

36

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

Figure 4.5
Breakdown of Cab Types Nationally, 2008

4.3.5 Age and Investment in Cab Fleet

Taxis
Wheelchair
accessible taxis

5%

Hackneys
Limousines

18%

71%

6%

Figure 4.6 sets out a comparison of the age profile of thecab fleet in Ireland in 2004 and 2008. In both years, 35
per cent of the fleet was five years old or less. However,when the proportion of the fleet more than nine years
old is analysed in both years, it emerges that there has
been a slight decline in the level of investment in the cab
fleet. In 2008, a total of 24.5 per cent of the cab fleet
was more than nine years old, compared to 22.9 per centof the fleet in 2004.

Source: Commission for Taxi Regulation

Breakdown of Cab Types Nationally, 2005

Taxis (including WATs)

3%

Hackneys

4.4 Effects of Competition
on Structure of Supply

Limousines

25%

72%

The increased numbers entering the market have broughtsignificant changes. As was demonstrated in Section 3,
the demand for cab services has grown rapidly. Part ofthis demand growth is likely to have been induced by theadditional supply, as consumers were enticed to undertake
more cab trips as their availability increased.
In the year 2000, taxis accounted for 31 per cent andhackneys accounted for approximately 69 per cent of
the total cab fleet. Since liberalisation, hackney numbers
have declined and now represent 18 per cent of the total.
However, hackney numbers continue to exceed
taxi numbers in counties with few urban centres.

Source: VRU Data

Breakdown of Cab Types Nationally, 2000
Taxis (including WATs)
Hackneys

31%

69%

Source: VRU Data

In 2008, 3.7 per cent of the total cab fleet (including taxis,
hackneys and limousines) was bought new during the year.
Regarding taxis, 728 taxi vehicles, or 3.4 per cent of thetotal taxi fleet, were bought new during that year. Thislevel of investment lags significantly behind the level ofinvestment in the private passenger car fleet where newvehicles typically represent 10 per cent of the overall fleet(9 per cent in 2007, the most recent year for which suchdata is available).

These trends were mirrored in the Dublin area, althoughhackneys have never played as strong a role there as they
do nationally. In the year 2000, hackney numbers were56 per cent of the total. By 2008, hackneys were playing
a very minor role in the Dublin market, with only 2 per centof the total market.
It might be expected that increasing cab availability would
give rise to more price competition. There is some evidence
of increased price competition eg, through advertised
discounting by dispatch operators and the quoting offlat fares by cab operators in certain towns. However,widespread fare competition is not evident.

37

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p ly

Table 4.5
Distribution of Cab Fleet by Year since First Registration, 2008

CountyTaxi

Wheelchair

Hackney

Limousine

Total% of Total

accessible taxi<=1994

281

5

105

21522

606

2.2

1995

284

0

81

13

378

1.4

1996

483

4

153

23

663

2.4

1997

820

14

251

37

1122

4.1

1998

1,253

176

331

48

1808

6.6

1999

1,465

230

410

56

2161

7.9

2000

1,962

181

520

104

2767

10.1

2001

2,096

190

498

92

2876

10.5

2002

2,144

110

526

89

2869

10.5

2003

1,922

89

443

98

2552

9.3

2004

1,929

121

410

87

2547

9.3

2005

1,816

131

411

103

2461

9.0

2006

1,318

128

286

140

1872

6.8

2007

1,161

136

291

149

1737

6.3

2008

643

85

198

84

1010

3.7

Total

19,577

1,600

4,914

1,338

27,429100

Source: Commission for Taxi Regulation

Figure 4.6
Distribution of Cab Fleet by Year since First Registration, 200815

% Fleet 200412

% Fleet 2008

12.2%

11.9%

11.6%

10.5% 10.4% 10.5%

8.6%

9

9.0%

9.3%

10.1%

9.3%
8.7%
7.5%

7.9%

6.8%
6.3%

6.6%

6.0%

5.8%

6
3.7% 3.7%

4.0%

3.8%

4.1%

2.4% 2.4%

3

2.2% 2.2%
1.2% 1.4%

1 year

2 years

3 years

4 years

5 years

6 years

7 years

8 years

9 years 10 years 11 years 12 years 13 years 14 years 14+ years

Source: Vehicle Registration Unit, Department of Transport (2004) and Commission for Taxi Regulation (2008)

22 Includes vintage vehicles used for ceremonial purposes.

38

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

Survey evidence shows that, while approximately twothirds of consumers regard cab fares as good value, theyalso identify cheaper fares as the single most importantfactor that would encourage them to use cabs more often.
With regard to taxis, the maximum fare may be a factor
inhibiting consumers from seeking lower fares. They mayview the maximum fare as the legally established fare,rather than a maximum that can be subject to downward
negotiation. If taxi fares are not subject to discounting,then hackney fares are likely to be maintained at similarlevels. A recent report has confirmed that hackney fares
reflect the maximum taxi fare.
Increased competition has undoubtedly made it moredifficult for drivers to achieve high earnings. This isparticularly the case for those taxi drivers that enjoyed
low levels of competition in the market place prior toliberalisation.
More recent trends in earnings are explored in Section 5
which presents evidence that, while earnings have declinedin the Dublin market, high earnings are still available tosome drivers, particularly those that do not compete
exclusively in the street market.
Any increase in numbers and the competitive pressures
may induce some cab operators to abuse the regulations
so as to avoid costs and boost revenue. Section 7 sets
out the steps that the Commission is taking to avoid thisoutcome, which is a concern in other liberalised markets.
With regard to the future, it might be expected, as
economic conditions are expected to deteriorate in the
short term, that there may be further large-scale entry
into the industry. To date, the decline in new entrants
does not support this view. An alternative possibility isthat the numbers of cabs will stabilise. However, given the
anticipated further decline in the economy, demand forcab services may fall. This would mean that, while current
operators might not face competition from large numbersof new entrants, they may find their revenues coming
under pressure. In these circumstances, operators that
adapt to the market by identifying and servicing niche andunder-supplied market segments will tend to do better.

4.5 Conclusions
The cab industry in Ireland is a highly competitiveand contestable industry where there are no significant
barriers to entry or exit.
Overall market supply• After liberalisation of the market in 2000, a large
increase in the number of cabs occurred• By 2008, the number of cabs in the country totalled
27,429 and as of end February 2009 it totalled 27,383• However, for the period since 2000 as a whole, cab
numbers have increased broadly in line with theirrate of increase prior to liberalisation• The number of new entrants to the cab market isin decline, which suggests that overall cab numbers
are stabilisingMarket share in the cab industry• Liberalisation of the cab industry has, however,brought profound changes in the relative market
share of hackneys and taxis in Ireland.
• Since liberalisation, taxi numbers have increased
rapidly and hackney numbers have declined.
• This suggests that prior to liberalisation, there wasa substantial imbalance between cabs serving thestreet and call-out markets, with the former being
under supplied.
• However, hackneys are still dominant in ten counties.
• There has been steady but slow growth in limousine
numbers over the last eight years. Limousines accounted
for only 0.85 per cent of the cab market in 2001 andnow account for approximately 5 per cent  of theoverall cab market.
• Wheelchair accessible taxis account for only
6 per cent of the overall cab market.
Investment in the cab industry• In 2008, 3.7 per cent of the total cab fleet
represented vehicles bought new during that year.
• This level of investment lags significantly behind thelevel of investment in the private passenger car fleet
where new vehicles typically represent 10 per centof the overall fleet.
• The level of investment in the cab fleet has fallenslightly between 2004 and 2008; 24.5 per cent of
the cab fleet was more than nine years old in 2008,
compared to 22.9 per cent of the fleet in 2004.

S e c t i o n 4 c o m p e t i t i o n a n d o v e r a l l m a r k e t s u p p ly

39

40

5
StRuCtuRe of Cab inDuStRy SuPPly

5.1 introduction

table 5.1
Estimated Profile of Dispatch Operators by Size, 2008

This Section of the Review discusses
the supply of cab services. It begins

Size of Dispatch

number of

Proportion

with an examination of the structure ofoperators in terms

Dispatchof Dispatchof vehicle numbers

operators

operators (%)

the industry. This is followed by analysis

1

72

16.8

of the level of supply and a profile of

2–5

148

34.5

the cab drivers that provide this supply,

6–10

67

15.6

in terms of their earnings and hours

11–15

24

5.6

of work.

16–20

22

5.1

21–50

53

12.4

51–100

20

4.7

100+

23

5.4

total

429

100

5.2 Structure of the Industry
Since the market was liberalised, the practice of ‘cosying’has greatly diminished and the vast majority of drivers
own and operate their cabs. While definitive data is notavailable, market intelligence suggests that only a small
minority of drivers are renting as opposed to owning alicensed vehicle.
Dispatch operators offer cab-booking services andindividual operators may choose to be affiliated todispatch companies with a view to securing businessin the telephone-booked market. It is estimated thatapproximately 40 per cent of drivers nationwide areaffiliated.23 Affiliation levels tend to be higher among
drivers working in urban areas.
There is evidence, however, that the level of affiliation
has declined in Dublin. In 2005, 51.2 per cent of Dublin
taxi drivers were affiliated as compared with 38.4 percent in 2008.
There are over 400 dispatch operators registered with
the Commission, with two-thirds of them operating
ten vehicles or fewer (See Table 5.1). Only five per centof dispatch operators have more than 100 affiliatedvehicles. In total, there are approximately 10,000
vehicles affiliated with dispatch operators in Ireland.

23 Based on the Goodbody Survey of Taxi Drivers.

Source: Commission for Taxi Regulation

Dispatch companies are important in creating economies
of scale in the industry. The fact that there are so few large
dispatch companies in Ireland limits the extent to which
economies of scale are being realised. The number andsize of dispatch operators in Ireland is adversely affectedby the small scale of many local cab markets and the recent
introduction of taxis to many of these smaller and morerural markets for the first time.
Achievement of economies of scale by dispatch operators
is dependent on:• Critical mass of drivers in the area willing to affiliate• Consumers recognising that larger dispatch companies
may offer higher levels of service• Incentives in place to encourage drivers to affiliate

41

S e c t i o n 5 s t r u c t u r e o f c a b i n d u s t r y s u p p ly

Table 5.2
Distribution of Annual Mileage by Licence TypeMiles/Year

Miles/Year

Miles/Year

Miles/Year

Miles/Year

Miles/Year

Miles/Year

Miles/Year<10k

10K–20K

20K–40K

40K–60K

60K–80K

80K+

Total

Average

(%)

(%)

(%)

(%)

(%)

(%)

(%)

Taxi

5.5

9.6

47.9

27.2

6.7

3.1

100

34,892

Hackney

3.9

11.6

37.1

29.9

13.4

4.1

100

37,828Limousine

23.1

15.6

19.8

23.5

18.0

0.0

100

30,320All Cabs

5.4

10.3

44.3

27.8

8.8

3.3

100

35,602

Source: Goodbody Survey of Drivers

5.3 Cab Industry Level of Supply

SPSVs undertake some 8.7 million work shifts perannum (2008), comprising an estimated 68.6 million
working hours.

The cab industry operated an estimated 986 million
vehicle miles in 2008 (1,585 million vehicle kilometres).
The average annual mileage of all cabs was approximately
36,000 (57,800 vehicle kilometres)24. This level of mileageis broadly unchanged from the levels reported in 200525(36,067 miles per annum).

Taken together with the demand analysis of Section
4, these data suggest that demand is very peaked aroundthe Thursday to Saturday period and particularly atnight time, but that while supply is also peaked aroundthose times, it is less peaked than demand.

Table 5.2 shows that taxis performed slightly lower
annual mileages than cabs as a whole. With regard tolimousines, some 23 per cent operated for less than
10,000 miles (16,000 kilometres) annually.
Figure 5.1
Distribution of Drivers Shifts by Day of Week, 2008

Taxi Drivers%
18.7% 19.0%

20

18.8%

Other Cab Drivers

17.7%
16.1%
15.0%

15

13.2%
12.2%

12.3%

13.7%

12.1%

11.1%

11.0%
9.2%

10

5

MondayTuesday

Wednesday

Source: Goodbody Survey of Cab Drivers 2008

24 Based on survey data and confirmed by National Car Testing Data.
25 As part of the National Review of Taxi, Hackney and Limousine Services, 2005.

ThursdayFridaySaturday

Sunday42

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 5.3
Distribution of Shifts by Time and Day of the Week, 2008

Taxi %

Others %All Drivers %Monday Daytime

8.1

8.5

8.2

Tuesday Daytime

8.7

6.9

8.1

Wednesday Daytime

8.9

8.4

8.7

Thursday Daytime

8.8

8.5

8.7

Friday Daytime

8.8

9.4

9.0

Saturday Daytime

6.8

8.0

7.2

Sunday Daytime

5.2

7.0

5.8

Monday Night

3.0

3.7

3.2

Tuesday Night

3.6

2.3

3.1

Wednesday Night

4.3

3.7

4.1

Thursday Night

7.3

5.1

6.6

Friday Night

9.9

9.6

9.8

Saturday Night

10.9

10.8

10.9

Sunday Night

5.8

7.9

6.5

Total

100

100

100

Source: Goodbody Survey of Cab Drivers, 2008

5.4 Temporal Pattern of Supply
In order to gauge the pattern of supply that cab operators
provide, the survey of cab drivers asked drivers to indicate
the days of the week on which they provided services
and whether they operated day or night shifts, or both.
Figure 5.1 depicts the distribution of shifts worked by dayof the week. For taxi drivers, Thursday, Friday and Saturday
are the busiest days of the week. Just over half of shifts
occurred on those three days. Hackney drivers have aslightly different pattern, with Sunday being slightly more
important than Thursday.
In Section 3, it was noted that demand for cabs is very
peaked and that over 85 per cent of cab trips took place
during the period Thursday to Saturday inclusive. Therefore
demand is apparently more peaked than supply.

Table 5.3 sets outs the proportions of cabs drivers
operating daytime and night time shifts in 2008. The
greatest proportion of shifts provided by both taxi drivers
and other cab drivers are on Friday and Saturday nights.
The data shows that 44.2 per cent of shifts are offeredat night time. Again this is somewhat lower than the
proportion of demand occurring at night time.
Taken together with the demand analysis of Section 3,
this data suggests that demand is very peaked aroundthe Thursday to Saturday period and particularly at nighttime, but that while supply is also peaked around thosetimes, it is less peaked than demand.

43

S e c t i o n 5 s t r u c t u r e o f c a b i n d u s t r y s u p p ly

5.5 The Earnings of Drivers
5.5.1 Gross Earnings
Based on survey data, there are a number of ways of
estimating gross fare revenue arising from cab driving.
The first approach is to use average weekly fare revenues
reported by cab drivers in the Cab Driver Survey. In 2008,
the reported average weekly earnings by all full-time
cab drivers were €704 per week, which is equivalentto €33,810 per annum.26
This estimate was based on the number of paid trips
and average fares as reported by cab drivers in October
2008. There is the likelihood that these estimates werebiased downwards. For example, the average reported
fare was a little over €9, which seems low when comparedwith the initial charge, at that time, of €3.80 or €4.10
and minimum per kilometre charges of €0.95 or €1.25
per kilometre.27 This is also lower than the average taxi fareof €15 reported in the Household Survey.
Table 5.4
Estimates of Cab Drivers’ Earnings Nationally, 2008

Estimation

Estimated

Estimated

MethodWeeklyAnnual

Gross

Gross

Earnings €Earnings €Based on Earnings
Reported by Drivers

704

33,810

Based on Fares
Estimated from theHousehold Survey

1,210

58,010Source: Goodbody Estimates

Another approach to estimating cab drivers’ earnings is
to estimate average fares for both standard and premium
rate journeys using data from the Household and Cab
Drivers surveys. This avoids direct use of average fareestimates. This alternative approach yielded an estimateof €1,210 per week or €58,010 per annum. The results ofthe two estimation methods are summarised in Table 5.4.
There is a substantial difference between the estimates,with the Household Survey based estimate being
substantially in excess of the cab driver estimate. A similar
divergence in cab driver earnings estimates emerged fromthe analysis undertaken at the time of the 2005 National
Review. If the earnings of taxi and hackney drivers are
separately analysed, the indications are that hackneydrivers on average have earnings some 20 to 30 per
cent above their counterparts in the taxi industry.
Table 5.5 compares the results contained in that review
for Dublin taxi drivers with a revised estimate for 2008.
As the survey took place a month before the 8 per centincrease in taxi fares introduced in November 2008, theadjusted drop in gross earnings is approximately 5 per centfrom 2008 to 2005 for Dublin taxi drivers.28
Table 5.5
Estimated Change in Dublin Taxi Drivers’
Annual Gross Earnings, 2005 and 2008

Estimation

2005

2008

€

€

Based on Fares
Reported by Drivers

38,30033,380

Based on Fares
Estimated from theHousehold Survey

54,60047,520

MethodSource: Goodbody Estimates

26 Full-time drivers are those working more than 30 hours per week; an annual working year of 48 weeks is assumed.
The estimates are prior to the 2008 fares increase; no gratuities are allowed for.
27 The survey of cab drivers was conducted in October 2008, prior to the introduction of the new taxi fare in November 2008.
28 2005 earnings data not available for drivers outside of Dublin.

44

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

Figure 5.2
Distribution of Cab Drivers Reported Gross Earnings 2008
%

33.2%

35

30

25
21.7%

20.6%

20

15

10

9.2%
6.7%

8.5%

5

<€20,000€21,000–€30,000€31,000–€40,000€41,000–€50,000€51,000–€60,000€60,000+

Source: Goodbody Survey of Cab Drivers 2008

5.5.3 Variability in Gross Earnings
The above estimates of gross earnings are averages.
However, individual cab drivers achieve different levelsof success in terms of earnings outcomes. Figure 5.2
shows the distribution of gross earnings as reported bycab drivers. This indicates that while the average reported
earnings are €33,810, one quarter of drivers reported
earnings of over €40,000 per annum.

5.5.2 Costs of Operation and Net Earnings
The above data refers to gross earnings. In this review, net
earnings denote earnings less the costs of operation but
before income tax has been deducted. A recent estimate(2008) of the costs of operating taxis put the standing costat €10,291 per annum and the running costs at €7,372
per annum, making a total of €17,663.29 The annual
costs of operating a hackney would be similar. Based onthese costs, the 2008 net earnings of cab drivers can be
estimated at approximately €16,147 per annum basedon the lower gross earnings estimate and €40,347 on
the higher estimate. This data suggests that nominal net
earnings of Dublin taxi drivers have declined somewhat
since 2005.30
Average hourly earnings in the manufacturing industry(referred to as the industrial wage) were €19.60 in mid2008 and the minimum wage was set at €8.65. As
full-time cab drivers work for an average 52 hours per
week, assuming net earnings are approximately mid-way
between the minimum levels reported by the industry andupper levels calculated based on fares estimated from theHousehold Survey, the net hourly earnings of cab drivers
in 2008 is approximately €11,31 which is below the averageindustrial wage and above the minimum wage.

29 PA Consulting. Review of the National Maximum Taxi Fare. October, 2008.
30 Operating costs in 2005 stood at approximately €17,749.
31 On the basis of a nine hour average working day, the daily rate suggested by taxi unions to insurance companies for loss of earnings of €90 would substantiate hourly earnings of €11.

45

S e c t i o n 5 s t r u c t u r e o f c a b i n d u s t r y s u p p ly

5.6 The Role of Part-Time Drivers

Table 5.7
Distribution of Drivers by Hours Worked, 2008

If part-time drivers are defined as working less than 30hours, then approximately 15.6 per cent of cab drivers
were working part-time in the industry in 2008, according
to the Cab Driver Survey.32 Part-time working is particularly
prevalent in the hackney (26.9 per cent) and limousine
trade (49.5 per cent). Part-time drivers tend to be older
than full-time – 12 per cent of all part-time drivers areover 65 years, compared to 4 per cent of their full-time
counterparts. However, part-time drivers are present
among all driver age groups. Approximately half ofpart-time drivers have another occupation.
Of taxi drivers that entered the industry over the last
five years, 12 per cent are part-time drivers. Among thedrivers that are in the industry for over five years, thecorresponding proportion is 8.7 per cent. When othercabs are analysed in the same manner (the majority ofwhich are hackneys) we see that approximately 40 per
cent of drivers that have entered the industry during thelast five years work part-time, compared to 21 per centof drivers who have been in the industry for periods
exceeding five years (See Table 5.6). Therefore, part-time
driving is becoming more prevalent.
Section 3 has confirmed that Fridays and Saturdays aredays of peak demand. Part-time drivers are much more
likely to supply services on those days than are their fulltime counterparts. Over 51 per cent of shifts operated bypart-time drivers occur on those two days as against 36
per cent by full-time drivers. Therefore, part-time drivers
make a valuable contribution to meeting peak demands.
Table 5.6
Distribution of Part-time and Full-time Drivers
by Years in the Industry, 2008

Years in

Part-time

Full-time

Total

Industry

(%)

(%)

(%)

Less than 5 Years

12.1

87.9

100

Over 5 Years

8.7

91.3

100

Less than 5 Years

38.9

61.1

100

Over 5 Years

21.0

79.0

100

Taxis

Hours

Taxis

Other Cabs

All Drivers

(%)

(%)

(%)

<20

5.6

14.6

8.6

21–30

4.6

12.3

7.0

31–40

15.1

14.5

14.8

41–50

13.8

19.5

15.5

51–60

34.1

17.8

28.9

61–70

16.6

8.1

14.0

>70

10.4

13.1

11.2

Total

100

100

100

Average Hours

54

47

52

Source: Goodbody Survey of Cab Drivers 2008

Table 5.8
Distribution of Dublin Taxi Drivers
by Hours Worked, 2005 and 2008

Hours

Dublin Taxi

Dublin Taxi

Drivers 2005 (%)

Drivers 2008 (%)

<20

4.8

7.3

21–30

6.4

2.4

31–40

17.6

13.4

41–50

22.4

17.1

51–60

28.0

37.8

61–70

16.8

12.2

>70

4.0

9.8

Total

100

100

Average Hours

50

54

Source: Goodbody Survey of Cab Drivers, 2005 and 2008

Other Cabs

Source: Goodbody Survey of Cab Drivers 2008

32 Because the 2008 cab driver survey was administered as a self-completion questionnaire, it is conceivable that the response rate was biased in favour of those with a greater vested
interest in the industry, namely full-time drivers. Based on consultations held with representatives in the industry during the course of this study, there may be a substantially higher
proportion of part-time drivers operating in the industry than the 2008 survey results would suggest.

46

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

for less than five years. The equivalent proportion of cab
drivers with no other occupation is 30.8 per cent.

Table 5.9
Distribution of Drivers with Two Occupations
by Total Hours Worked

Hours

Taxis

Other Cabs

All Cabs

(%)

(%)

(%)

<15

0.0

0.0

0.0

15–30

6.8

3.6

4.8

30–45

7.6

10.8

9.6

45–60

34.9

27.3

30.3

60–75

31.3

38.6

35.8

75+

19.3

19.6

19.5

Total

100

100

100

Source: Goodbody Survey of Cab Drivers 2008

5.7 The Role of Cab Drivers
with Another Occupation
Just over 14 per cent of cab drivers have anotheroccupation. From the point of view of cab operators who
have two occupations, benefits are incurred to the extent
that the income provided from cab operations permits
them to ensure adequate weekly levels of income.
Hackney drivers are much more likely to have anotheroccupation relative to their taxi driver counterparts: 25.1
per cent and 8.7 per cent respectively. Some 6 per cent offull-time drivers hold another occupation, which suggests
such individuals may be working very long hours.

5.8 Cab Drivers and Working Hours
Table 5.7 sets out the proportion of drivers by the hours
they work weekly as cab drivers. One in four of all cab
drivers (25.2 per cent) is currently working in excess of
60 hours weekly. The corresponding proportion of taxi
drivers is 27 per cent. A significant minority of cab drivers(11.2 per cent) are working long hours in excess of 70
hours per week.
When the results of the 2008 survey are compared to
the 2005 survey results (for Dublin taxi drivers only), it canbe seen that the proportion of drivers working in excess of
60 hours weekly has increased only marginally from 20.8
per cent to 22 per cent. The proportion of drivers working
in excess of 50 hours weekly, however, has increased
from 48.8 per cent to 59.8 per cent and the proportion
working more than 70 hours has doubled from 4 percent to 9.8 per cent.
Of taxi drivers who have another occupation,
approximately one third are working between 30–45
hours per week in that occupation. This increases to53.5 per cent among other cab drivers with anotheroccupation. The total hours worked in a week forindividuals with two occupations is also illustrated
Table 5.9. Approximately one in five cab drivers with
two occupations is working in excess of 75 hours per
week. This compares to only 8 per cent of all cab drivers(both those with and without another occupation)
working in excess of 75 hours per week.

In contrast to part-time cab drivers, cab drivers withanother occupation tend to be younger. They are mostover-represented in the 35–44 age group. A large
proportion of cab drivers with another occupation are in
the transport business (29.1 per cent) with building andconstruction (12.6 per cent) and agriculture (17.9 per cent)also being prevalent other occupations.

5.9 Conclusions

Cab drivers with another occupation are also more likely tobe providing services at peak times than other cab drivers.
However, their contribution to serving the Friday andSaturday peak is not as substantial as part-time cab drivers.

• Cabs undertake some 8.7 million work shifts perannum (2008), comprising an estimated 68.6 million
working hours.

There appears to be an upward trend in the proportionof cab drivers with another occupation; 48.2 per cent ofdrivers with another occupation are in the cab industry

Industry size
• The cab industry operated an estimated 986 million
vehicle miles in 2008 (1,585 million vehicle kilometres).
• The average annual mileage of all cabs wasapproximately 36,000 (57,800 vehicle kilometres).

47

S e c t i o n 5 s t r u c t u r e o f c a b i n d u s t r y s u p p ly

Market Structure
Operator Profile• Since the market was liberalised, the practice of‘cosying’ has greatly diminished and the vast majorityof drivers own and operate their cab.
• While definitive data is not available, market intelligencesuggests that only a small minority of drivers are renting
as opposed to owning a licensed SPSV.
Dispatch Operator Profile• There are over 400 dispatch operators in Ireland,with two thirds of them operating ten vehicles or fewer.
• Only five per cent of dispatch operators have morethan 100 affiliated vehicles. Dispatch companies areimportant in creating network economies of scale in
the industry.
• The fact that are so few large dispatch companies in
Ireland limits the extent to which economies of scale
are being realised.
• The achievement of economies of scale is dependent on
consumers recognising that larger dispatch companies
offer higher levels of service and incentives to encourage
drivers to affiliate.
• It is estimated that approximately 40 per cent of drivers
nationwide are affiliated to a dispatch company.
• There is evidence, however, that the level of affiliation
has declined in Dublin. In 2005, 51.2 per cent of Dublin
cab drivers were affiliated as compared with 38.4 percent in 2008.
Market Supply and Demand• The supply structure of the cab industry is undergoingsignificant change. This involves increased part-timeworking and an increased proportion of drivers withanother occupation.
• At a minimum 15.6 per cent of drivers are
part-time and 14.1 per cent have another job.
• Supply of cab services peaks in the period Thursday
to Saturday.
• Demand is even more peaked around the Thursday
to Saturday period and particularly at night time, sothat supply is less peaked than demand.
• Friday and Saturdays are days of peak demand.
• Part-time drivers are much more likely to supply
services on Friday and Saturday than full-time drivers.
Over 51 per cent of shifts operated by part-time drivers
occur on those two days as against 36 per cent by
full-time drivers.

• Therefore, part-time drivers make a valuable
contribution to meeting peak demands.
Driver working hours• Cab drivers are providing more work shifts andworking longer hours.
• The average working week of all cab drivers is
52 hours, with one in four drivers working in excess
of 60 hours a week.
• Between 2005 and 2008, the proportion of Dublin
taxi drivers working more than 70 hours has grownfrom 4 per cent to 9.8 per cent.
• Of taxi drivers who have another occupation,
approximately one third are working between
30–45 hours per week in that occupation.
• This increases to 53.5 per cent among other drivers.
• Approximately one in five individuals with two
occupations is working in excess of 75 hours per week.
• This compares to only 8 per cent of all drivers working
in excess of 75 hours per week.
• Drivers with another occupation are also more likely
to be providing services at peak times than other cab
drivers. However, their contribution to serving the
Friday and Saturday peak is not as substantial as
part-time drivers.
Driver Earnings• The average gross earnings of cab drivers is
independently estimated at €58,010 per annum;or €40,350 after costs but before tax• Reported earnings by cab drivers indicated averagegross earnings of €33,810, or €16,150 after costs but
before tax. These reports appear low on the basisof the average fare reported• There is evidence that hackney drivers on average
have earnings some 20 to 30 per cent above theircounterparts in the taxi industry.
• Data from the Dublin market indicate that bothgross and net earnings of taxi drivers have declined
somewhat in nominal terms. This reduction would havebeen mitigated significantly by the 8.3 per cent increasein fares implemented in late 2008. This adjusted drop
in gross earnings is approximately 5 per cent for Dublin
taxi drivers from 2005 to 2008.

48

6
Quality of Cab SeRviCeS

6.1 introduction

6.2 Waiting Times

This section looks in detail at the

Waiting times for cabs relate not only to the length oftime it takes to get a cab on the street, through either
hailing or at a rank, but also, in relation to pre-booked
services, the length of time consumers are waiting fora taxi over and above the specified arrival time.

quality of service offered by cabs.
Three broad aspects of quality ofservice are examined, namely:• The availability of cabs
• The quality of cab vehicles• Value for money
The various surveys undertaken
as part of this study recorded theperceptions of the quality of cab services
as experienced by general users, business6.2.1 Consumer waiting times
Table 6.1 presents data on cab waiting times in 2008,
based on consumers’ experiences in relation to the lastcab journey that they took. Over half (51.5 per cent) of
all consumers had to wait just five minutes or less for acab. The proportion of consumers who had to wait forten minutes or less was 81.1 per cent. Relative to 2005,
waiting times for cabs have reduced considerably.

table 6.1
Distribution of Consumers by Lengthof Wait Experienced, 2005 and 2008

users and people with disabilities. These
perceptions are reported in this section

waiting time2005 (%)

2008 (%)

of the report, as is the data available<5 minutes

34.6

51.5

on the complaints made by the public

5–10 minutes

32.1

29.6

to the Commission in relation to the cab

11–20 minutes

23.5

13.0

services provided to them. In addition,

21–30 minutes

6.0

5.1

waiting times are a key indicator of

31–60 minutes

2.7

0.9

>60 minutes

1.2

0.0

total

100

100

availability and the surveys also recorded
consumers’ experiences in that regard.

Source: Goodbody Survey of Households 2008

49

Sec tion 6 qualit y of c ab services

Table 6.2 sets out average waiting times reported byconsumers by the time of day their most recent cab
journey was taken. According to the results of theconsumer survey, average waiting times are greatest
between midnight and 09:00, and in particular between
the 03:00 and 06:00 when average waiting times total
12.1 minutes. Average waiting times are shortest between
18:00 and 21:00.

Table 6.2
Distribution of Cab Consumers by Average Waiting
Time and Time of Day, 2008

2008 AverageTime of Day

Waiting Time (Mins)

00.01–09.00

8.8

09.01–12.00

5.8

12.01–15.00

6.1

15.01–18.00

6.2

18.01–21.00

4.9

21.01–24.00

5.5

Similar data has been collected for Dublin consumers
over the period since 1997. This data shows sharp
reductions in waiting times post-liberalisation of themarket. Whereas prior to liberalisation 58 per cent ofconsumers had waiting times of less than 10 minutes,
this had risen to 86 per cent by 2008.
There are also continuing improvements in the reliabilityof cabs. In 1997, 5.9 per cent of respondents reported
a wait of over 30 minutes; this proportion had decreased
to 1.2 per cent in 2008.33
Table 6.4 sets out average waiting times reported byconsumers in Dublin by the time of day their most recent
cab journey was taken. According to the survey results,
average waiting times in Dublin are also greatest between
midnight and 09:00 and in particular between 03:00 and
06:00 when average waiting times total 14.5 minutes.
Average waiting times in Dublin broadly mirror national
waiting times, but exceed national waiting times during
the hours of 18:00 and midnight.

Source: Goodbody Survey of Household 2008

Table 6.3
Distribution of Dublin Cab Users by Waiting Times: 1997, 2001, 2005 and 2008

Waiting time1997 (%)

2001 (%)

2005 (%)

2008 (%)<5 minutes

23.0

47.5

40.2

50.3

5–10 minutes

35.3

22.7

33.9

35.4

11–20 minutes

29.4

17.4

18.0

11.2

21–30 minutes

5.9

6.4

5.8

1.9

31–60 minutes

5.9

4.6

1.1

1.2

>60 minutes

0.0

1.4

1.1

0.0

Total

100

100

100

100

Source: Goodbody Survey of Households, 1997, 2001, 2005 and 2008

33 In 1997 and 2001, this question was only asked of people who had telephoned for a cab immediately. In 2005 it was asked of all people who had telephoned for a cab immediately,
who had gone to a rank, or hailed a taxi on the street. In 2008 it was asked of all people who had telephoned for a cab immediately, who had gone to a rank, or hailed a taxi on thestreet or had to wait beyond the agreed time.

50

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 6.4
Distribution of Dublin Cab Consumers by

6.3 Availability of Cabs

Average Waiting Time and Time of Day, 2008

The section sets out the perceptions of cab users
with respect to the availability of cabs services.
2008 Average

Waiting Time (Mins)

00.01–09.00

7.9

09.01–12.00

5.9

12.01–15.00

5.1

15.01–18.00

6.2

18.01–21.00

5.7

21.01–24.00

5.7

Source: Goodbody Survey of Household 2008

6.2.2 Business Waiting Times
The distribution of businesses by their waiting time
experiences for cabs is set out in Table 6.5. In 2008 thevast majority of businesses (96.4 per cent) reported cabs
arriving always or most of the time within a reasonable
time. Relative to 2005, there has been a minor reductionin the proportion of businesses reporting cabs arriving
within a reasonable time, all of the time. There has beena corresponding increase in the proportion of businesses
reporting cabs arriving within a reasonable time, mostof the time.

Table 6.5
Frequency with which Cabs Ordered Arrive within
a Reasonable Time, 2005 and 2008

6.3.1 Availability of Cabs for Consumers
One in two adults (54.2 per cent) surveyed as part of
the Household Survey was of the opinion that cabs areeasily hired at busy periods. In total, 29.7 per cent of
adults felt that this was not the case.
There are significant regional variations in the perceptionsof cab availability levels. Whereas the proportion of
respondents who believe it easy enough to hire cab atbusy periods was 70.1 per cent in Dublin, it fell to 44.8
per cent in Munster and further to 34.2 per cent in
Leinster. Since 2005, the perception in ease of hiringa cab has remained the same in Munster but has fallen
by 17 percentage points in Leinster. This has occurred
despite the fact that cab numbers has increased byapproximately 40 per cent in both regions.
When respondents were asked if a taxi or dispatch
operator had ever refused to provide them with aservice, 7.7 per cent agreed that they had experienced
this. The most usual reason given by a company for notproviding a service was that they had no cars available,
and this was apparent across all areas. The next mostcommon reason given was the remoteness of thedestination.

Figure 6.1
Distribution of Adults by Reasons given by Dispatch
Operators for Refusing to Provide a Service, 2008
No cab available

2005 (%)

2008 (%)

All of the time

55.6

50.0

Remotenessof destination

Most of the time

40.8

46.4

Remotenessof pick-up

Some of the time

2.4

3.6

Rarely/never

1.2

0.0

Total

100

100

Other

15%
10%
40%

Source: Goodbody Survey of Business, 2005 and 2008

35%

Source: Goodbody Survey of Households 2008

51

Sec tion 6 qualit y of c ab services

Table 6.6
Distribution of Adults by Perception of Ease with which Cabs can be hired, 2005 and 2008

Taxis/hackneys are easily

All Adults

DublinRest of Leinster

Munster

Connaught/

(%)

(%)

(%)

(%)

Ulster (%)

hired at busy periods

2008

Agree strongly

10.6

15.0

5.7

3.7

18.3

Agree

43.6

55.1

28.5

41.1

46.3

Neither

16.1

12.0

24.4

19.6

7.3

Disagree

21.1

12.6

28.5

24.3

23.2

Disagree strongly

8.6

5.4

13.0

11.2

4.9

Total

100

100

100

100

100

2005

Agree strongly

4.8

4.9

8.2

2.0

4.0

Agree

41.4

42.9

43.3

40.6

35.2

Neither

16.7

15.1

16.8

22.3

9.6

Disagree

28.9

29.9

22.1

28.9

37.6

Disagree strongly

8.2

7.1

9.6

6.3

13.6

Total

100

100

100

100

100

Source: Goodbody Survey of Households 2008

6.3.2 Availability of Cabs for Businesses
Businesses were also asked their views regarding theavailability of cab services. In total, 44.4 per cent of thebusinesses surveyed in 2008 perceive that there areparticular times of day when they experience difficulties
or delays when booking a cab. This represented a
reduction from 52.8 per cent in 2005. The reduction in
the perception that there are times in the day when cabs
are difficult to obtain was experienced mainly in Dublin.

In all areas of the country the reported worst timeof the day in terms of difficulty in obtaining a cab was
between 16:00 and 18:00. However, businesses in Dublin
were twice as likely to perceive this time (between 16:00
and 18:00) as the most difficult time in obtaining a cab,
relative to their counterparts outside of the city.

52

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 6.7
Existence of Times of the Day when Cabs Difficult to Obtain, 2005 and 2008

2005

2008

Total Sample

DublinRest of Ireland

Total Sample

DublinRest of Ireland

(%)

(%)

(%)

(%)

(%)

(%)

Yes

52.8

56.0

49.2

44.4

42.8

46.9

No

47.2

44.0

50.8

55.6

57.2

53.1

Source: Goodbody Survey of Businesses, 2005 and 2008

6.3.3 Availability of Cabs for
People with Disabilities

When asked if they had ever been refused a cab
service, 26.1 per cent of people with disabilities indicatedthat they had been informed by dispatch operatorsthat they could not be provided with a service. This
proportion rose substantially to 44.4 per cent among
full-time wheelchair users, compared to 13.8 per centamong non full-time users.

As part of the survey of people with disabilities,
respondents were asked about the willingness of
dispatch operators to provide a service and the occurrenceof refusal of service. The majority of all respondents (68.7
per cent) find that dispatch operators are willing or very
willing to provide a service. Among full-time wheelchairusers this figure drops to 60 per cent. In total, 20 per
cent of full-time wheelchair users find dispatch operators
unwilling to provide a service, which is significantly higher
than non full-time users at 6.5 per cent.

The most common reason provided to people withdisabilities for service refusal was there being nowheelchair accessible cabs available at the time (63.4
per cent of respondents). An additional 22 per centof all respondents cited the absence of a wheelchair
accessible cab in the fleet.

Table 6.8
Distribution of Respondents by Perception of Dispatch Operators’ Willingness to Provide a Service, 2008
Category

Proportion %Proportion %Proportion %(Full-time users)(Non full-time)(All respondents)

Very willing

27.3

44.7

37.4

Willing

32.7

30.3

31.3

Neither willing or unwilling

20.0

18.4

19.1

Unwilling

7.3

3.9

5.3

Very unwilling

12.7

2.6

6.9

Total

100

100

100

Source: Goodbody Survey of People with Disabilities 2008

53

Sec tion 6 qualit y of c ab services

6.4 Vehicle and Driver Aspectsof Quality of Service

Figure 6.2:
Distribution of Respondents by Refusal of Service, 2008
%
100

No
Yes

80

55.6%

86.2%

73.9%

60

40

44.4%

26.1%

20

13.8%
Full-time
wheelchair users

Non full-time
wheelchair users

All respondents

6.4.1 Introduction
The perception of cab users, with respect to the vehicle
and driver aspects of the quality of service provided tothem, is set out here. With regard to vehicles, an aspectof the cab trade is that the vehicles used are generally
much older than the cars in use by the population as awhole. In 2008, just 728 taxi vehicles, or 3.4 per cent of
the total taxi fleet, were bought new during the year.
The equivalent proportion in 2004 was 3.5 per cent. Thislevel of investment lags significantly behind the level ofinvestment in the private passenger car fleet where newvehicles typically represent 10 per cent of the overall fleet.
The use of more aged vehicles by the cab trade raises
the possibility that some vehicles may be offering poorlevels of comfort to the consumer.

6.4.2 Perception of Quality of Service by Consumers
Source: Goodbody Survey of People with Disabilities, 2008

As part of the Household Survey consumers were asked
the extent to which they agreed or disagreed with anumber of statements relating to cab services.
The majority of adults are quite satisfied with the overalllevel of service provided, as well as vehicle quality, vehicle
cleanliness and the helpfulness of drivers. Therefore, in
general, consumers are happy with the quality of service
that cabs provide. See Table 6.9.

Table 6.9
Consumer Perception of Cab Services, 2008
Agree Strongly

Agree

Neither Agree

DisagreeDisagree(%)(%)

nor Disagree (%)(%)

Strongly (%)

Taxis/hackneys generally
provide a good service

20.6

67.1

8.5

3.3

0.4

Taxis/hackney vehicles are
generally clean and tidy

19.3

65.3

11.6

3.5

0.2

Taxis/hackney vehicles
are of good quality

20.1

64.8

10.8

4.1

0.2

Taxi/hackney drivers are
generally helpful and friendly

22.5

61.9

9.8

4.8

1.0

Source: Goodbody Survey of Households 2008

54

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

6.4.3 Perception of Quality of Service by Businesses
As part of the business survey businesses were asked
the extent to which they were satisfied with the dispatch
operator they used most often. Ninety per cent ofbusinesses were satisfied or very satisfied with the levelof service provided. Satisfaction levels were slightly
higher outside Dublin.

6.4.4 Perception of Quality of Service
by People with Disabilities
People with disabilities were also asked their views
regarding the level of cab service provided to them.
The reported perceptions were mixed. While between
65 and 72 per cent of respondents agreed that cabs
generally provide a good service, that cabs vehicles areof good quality and that the layout and seating of cabs
is satisfactory, between 10 and 17 per cent were not inagreement. People with disabilities were more favourable
in terms of their perception of the helpfulness of drivers.

Table 6.10
Distribution of Businesses by Level of Satisfaction with Dispatch Operator Used Most Often, 2008

2008
Country as a Whole (%)

Dublin (%)

Rest of Ireland (%)

Very satisfied

56.0

51.3

63.5

Satisfied

34.0

36.2

30.2

Neither

9.6

12.5

5.2

Dissatisfied

0.4

0.0

1.0

Very dissatisfied

0.0

0.0

0.0

Source: Goodbody Survey of Businesses 2008

Table 6.11
Distribution of Respondents’ Perceptions of Cab Services, 2008

Agree

Agree

Neither Agree

DisagreeDisagreeStrongly (%)(%)

nor Disagree (%)(%)

Strongly (%)

Cabs generally provide
a good service

21.8

50.0

18.5

7.3

2.4

Cab drivers are generally
helpful and friendly

22.0

61.8

9.8

4.9

1.6

Cab vehicles are of good quality

16.9

46.8

25.8

6.5

4.0

The seating arrangements
in wheelchair accessible
cabs are satisfactory

16.4

52.6

18.1

9.5

3.4

The physical layout of wheelchair
accessible cabs (ie. door width,
ceiling height etc) is satisfactory

15.5

50.0

17.2

12.9

4.3

Source: Goodbody Survey of People with Disabilities 2008

55

Sec tion 6 qualit y of c ab services

Table 6.12
Distribution of Adults by Perception of Value for Money, 2008

Taxis/hackneys offer

All Respondents

DublinRest of Leinster

Munster

Connaught/Ulster

good value for money

(%)

(%)

(%)

(%)

(%)

Agree strongly

12.2

13.7

4.0

11.9

22.0

Agree

50.4

57.1

33.6

59.6

50.0

Neither

15.1

10.7

24.0

14.7

11.0

Disagree

19.0

11.9

35.2

12.8

17.1

Disagree strongly

3.3

6.5

3.2

0.9

0.0

Total

100

100

100

100

100

Source: Goodbody Survey of Households 2008

6.5 Value for Money
In addition to waiting times, cab availability and qualityof service, cab users were also asked their views on thevalue for money associated with cab services.

Figure 6.3
Distribution of Full-Time Wheelchair Users
Perceptions on Cab Affordability, 2008

Agree strongly
Agree

6.5.1 Perception of Value for Money by Consumers
As Table 6.12 indicates, 62.6 per cent of all adultrespondents questioned as part of the household
survey agreed that cabs do offer good value for money,
compared to 22.3 per cent who disagreed. The proportionof respondents who disagreed increased to 38.4 per centin Leinster, but was lower in the other areas where it fell
to 18.4 per cent in Dublin and 17.1 and 13.7 per centin Connaught/Ulster and Munster respectively.

6.5.2 Perception of Value for Money
by People with Disabilities
As part of the survey of people with disabilities,
respondents were asked if they considered that taxi
fares were affordable. It is noteworthy that 47 per centof respondents consider cab fares not to be affordable.

Neither agree
nor disagree
Disagree

6.1%
20.4%
18.4%

Disagree strongly

26.5%
28.6%

Source: Goodbody Survey of People with Disabilities 2008

56

Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

6.6 Consumer Complaints
In September 2006, the Commission took over theprocessing and administration of Section 51 complaints
regarding cab services from An Garda Síochána. These
complaints are categorised according to whether they
relate to:• The condition and cleanliness of vehicles• The conduct and behaviour of operators/driver• Overcharging or other matters relating to fares• Matters relating to the hiring of a cab
The number of complaints received by the Commission
over the 2006–2008 period is set out in Table 6.13. A totalof 763 complaints were received by the Commission forthe year 2007 as a whole with 601 complaints received
in 2008. This is a very low level of complaints especiallyin view of the estimated 94 million34 cab trips madeannually by Irish residents. The most significant numberof complaints received by the Commission relates toovercharging or other fare-related matters as well as
the conduct of cab drivers.

6.7 Conclusions
Service levels for consumers:• The general perception of consumers is that theoverall level of cab service provided in Ireland, as
well as vehicle quality, vehicle cleanliness and thehelpfulness of drivers is good.
• Nationally, 62.6 per cent of consumers agree
that cabs do offer good value for money.
• Just over 20 per cent of consumers feel that cabs
do not offer good value for money. However, thisincreases to 38 per cent among consumers in thepart of Leinster outside Dublin.
Service for people with disabilities:• People with disabilities receive a significantly
poorer level of service relative to other cab users.
• Approximately 44 per cent of full-time wheelchairusers have had some experience of dispatch operators
reporting not being able to provide a service, comparedto just 7.7 per cent of the general population. The mostcommon reason given is that the dispatch operators do
not have any accessible vehicles available at the time
requested.
• Overall, 71.8 per cent of people with disabilities feelthat cab services are generally good and 83.8 per centfind drivers helpful and friendly.
• However, 47 per cent of people with disabilities
feel cab fares are not affordable.

Table 6.13
Complaints Received by the Commission, 2006–2008
2006 (%)35

2007 (%)

2008 (%)

Conditions and cleanliness of vehicle

13

6

11

Conduct of vehicle operator

27

45

29

Matters relating to hiring of vehicle

25

14

17

Overcharging or fare matters

35

35

43

Total number of complaints

145

763

601

Source: Commission for Taxi Regulation

34 This is an estimate based on Irish population levels, the proportion of adults using cabs and their estimated annual frequency of usage of cabs.
35 Data for 2006 relates to the months of October, November and December.

Sec tion 6 qualit y of c ab services

Waiting times for consumers:• Waiting times for cabs in Ireland have improved
significantly over recent years with 51.5 per cent ofconsumers reporting having to wait less than 5 minutes
for their most recent taken cab journey in 2008, an
increase of 16.9 percentage points on 2005.
• Data for Dublin alone also shows sharp reductions
in waiting times post-liberalisation of the market. In
particular, whereas prior to liberalisation, 58 per centof consumers had waiting times less than 10 minutes,
this had risen to 86 per cent by 2008.
• There are also continuing improvements in the reliabilityof cabs in Dublin. In 1997, 5.9 per cent of respondents
reported a wait of over 30 minutes and this proportion
had decreased to 1.2 per cent in 2008.36• One in two cab users in Ireland is of the opinion
that cabs are easily hired at busy periods. However,
29.7 per cent of adults feel that this is not the case.

36 In 1997 and 2001, this question was asked only of people who had telephoned for a cab immediately. In 2005 it was asked of all people who had telephoned for a cab immediately,
who had gone to a rank, or hailed a taxi on the street. In 2008 it was asked of all people who had telephoned for a cab immediately, who had gone to a rank, or hailed a taxi on thestreet or had to wait beyond the agreed time.

57

58

7
ReGulation of the SyStem

7.1 introduction

7.2 Background

The Commission for Taxi Regulation

Since its establishment in 2004, the Commission
for Taxi Regulation has engaged in extensive research
into the SPSV industry. In 2005, Goodbody Economic
Consultants was appointed by the Commission to carryout a national review of services provided by taxis,
hackneys, and limousines. The key objectives of the study
were to assess the extent and quality of services provided
and to make recommendations that would inform thedevelopment of quality consumer-orientated licensing
systems for SPSVs and their drivers. In the same year theCommission engaged the Dublin Institute of Technology(DIT) to undertake a national review of SPSV vehicle
standards. The principal aim of this study was to investigate
and analyse vehicle quality and safety regulations andto make recommendations that would inform the future
development of quality regulations. As part of boththe Goodbody and DIT reviews, extensive consultations
were carried out including public meetings throughout
the country, face-to-face meetings with a range ofstakeholders, and consultation with the Advisory
Council to the Commission. Written submissions
were also received and analysed.

has introduced a number of significant
reforms to the SPSV industry in recent
years, which are discussed in this section.
These take the form of the introductionof improved standards on the one handand administrative reforms on the other.
The Commission has adopted a planned
strategic approach to reform in this area
outlined in a series of publicly available
action plans and based on widespread
public consultation. This sectioncommences with an overview of thereform targets that the Commission set
itself. This is followed by an assessmentof the progress made. Finally, anevaluation of the impact of the reform
process on the cab market is set out.

On the basis of the research and consultation outlined
above, as well as three consultation papers issued by theCommission,37 the Commission developed its first action
plan in 2006 entitled Driving Forward, in which it set
out the reforms the Commission proposed to make tothe industry over the 2006–2007 period. This Plan
was superseded in 2007 by Always Driving Forward,
the Commission’s action plan covering the period
2008–2009.

37 One consultation document was issued as part of the National Review process. In response to the National Review, a second consultation document was issued by the Commission,
setting out areas where the Commission believed change was necessary in the industry. The third consultation document was issued in October 2005 in relation to taximeter areas andtaxi fares. The Taxi Regulation Act 2003 imposes a statutory obligation on the Commission to consult specified stakeholders before introducing certain changes.

59

S e c t i o n 7 r e g u l at i o n o f t h e s y s t e m

7.3 Agenda for Industry Reform

7.3.3 Service Quality

The reforms envisaged by the Commission, as set
out in its action plans, are summarised below under
the headings:

As part of its action plan the Commission made a numberof commitments related to the quality of service provided
in the SPSV industry.

• Driver quality

National Complaints System• Vehicle quality

The Commission stated it would be putting in place a
new national complaints system, so as to have one single
repository of complaints to assist with the monitoring ofcompliance with SPSV regulations. Under the system thatexisted at the time, complaints were administered throughregional PSV offices by the Gardaí and consequently,
depending on the SPSV region, the collating of information
on, and follow-up to, complaints differed across thecountry. There was no central record of complaints andno overview available of the number of complaints being
made annually.

• Service quality• Licensing and Administrative systems
Progress to date against each of these areas is outlined
below in Section 7.4.

7.3.1 Driver Quality
Skills Development Programme
When the Commission was established in September
2004 there was no consistent or comprehensive training
programme for SPSV drivers in Ireland. Rather, as part of
the application process for a SPSV driver licence, applicantsunderwent a test commonly referred to as a local area
knowledge test. The test generally included a local
area knowledge section and a section on the rules andregulations associated with the SPSV industry. However
it varied significantly across the country in its content
and complexity.
As part of Driving Forward the Commission committed
itself to the development of a mandatory Skills
Development Programme for all existing and new SPSV
drivers, as well as for dispatch operators. According to theCommission’s action plan, on successful completion of the
programme participants would be awarded a Commission
Skills Development Certificate for the SPSV industry.
The Skills Development Programme would replace theexisting Garda test and would represent the first uniform
approach to the training of SPSV operators in Ireland.

7.3.2 Vehicle Quality
National Vehicle Standards
As part of its action plan the Commission set out a numberof areas where improvements were to be implemented
in relation to the quality of the SPSV fleet. In particular,
the Commission stated it would be putting in place newvehicle standards covering a number of areas including
vehicle condition, basic vehicle specification, as well as
comfort and safety.

Enforcement
To ensure maximum compliance with all SPSV Regulations,the Commission stated it would be developing a system of
fixed-charge penalties. The Commission also committed
itself to appointing authorised officers for the purpose ofenforcement, whose job it would be both to work with
the Gardaí and other enforcement agencies and to work
independently to ensure compliance with regulations
within the industry.
In-vehicle Information
As part of its action plan the Commission committed
itself to developing a customer charter setting out
customer rights and responsibilities as well as othercustomer information to be displayed in all SPSVs.
Additional Industry Information
As part of its Action Plan the Commission also committed
itself to providing passengers and drivers with easy accessto a range of information regarding the industry on its
website: www.taxiregulator.ie. Consumers would be
provided with lo-call, text, email and fax options which
would provide easy access to a range of information on
customers’ rights and responsibilities, fares and systemsof redress. The Commission also committed itself toproviding consumer and industry information guides.

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Accessible Services
Regarding the quality of services available to wheelchairusers, the Commission stated that all actions across its
action plans would be examined to measure their impact
on the contribution to improved accessibility.
Operational Standards for Dispatch Operators
The Commission also stated that operational standards
for dispatch operators would be put in place whichamong other things, would require dispatch operators
to put in place a complaints process for their customers,a booking system, as well as training for staff. As partof the standards, it would also be a requirement for all
dispatch operators to ensure that they were registeredwith the Commission. Dispatch operators would also be
responsible for ensuring all affiliated drivers and vehicles
were properly licensed and compliant withSPSV Regulations.
Quality Assurance Scheme and a Quality Mark
Finally, the Commission committed itself to thedevelopment and implementation of a quality assurance
scheme and a quality mark, so as to encourage, recognise
and reward the provision of quality service within theindustry in the areas of vehicle standards, driver standards
and booking services provided.

7.3.4 Administration and Licensing Systems
Prior to the establishment of the Commission in 2004,
the vehicle and driver-licensing processes in operationin the country were fragmented. In addition, there wereno central sources of information regarding the numbersof licensed SPSV vehicles and drivers.
National Registers of SPSV Vehicles and Drivers
One of the commitments made by the Commission
in Driving Forward included the development andmaintenance of a national register of vehicle licences
as well as a national register of SPSV driver licences.
National Vehicle Licensing System
The Commission also committed itself to the developmentof a new national vehicle licensing system that would
be implemented in the SPSV industry. As part of the
new system, vehicle licensing would be carried out onbehalf of the Commission (the single licensing authority

in the country) by the National Car Testing Service Ltd(NCTS), thereby replacing the process under which over
80 local authorities were the licensing authorities.
The new system would represent a more efficient andconsistent approach to the licensing of SPSVs owing to
the fact that the number of organisations involved in thelicensing process would be reduced. The licensing process
would be available at all NCT centres throughout thecountry, at the time of the NCT test or another time of theapplicant’s choosing. The Commission also set out detailsof a new national vehicle licensing numbering system
under which each vehicle licence holder would be issued
with a new national five-digit licence number unique tothe vehicle and licence holder and which would be able
to uniquely identify the licence holder in the National
Register of Licences.
National Driver Licensing System
The Commission also committed itself to the developmentof a more streamlined SPSV driver licence application
process. The Commission would take responsibility forthe administration of the application process and the issueof driver licences, while the Gardaí would continue tomanage character vetting.
Driver and Vehicle Identification
As well as taking over responsibility for the administrationof driver licence applications, the Commission committed
itself to replacing the driver licence certificate and badge
with a smart card which would have enhanced security
features to allow it to be scanned for enforcement andwould be a form of ID for customers. In addition to thesmart card, the Commission committed itself to providing
each SPSV licence holder with an identification card toinclude a photograph of the driver, the driver licencenumber and expiry date of the licence for display on thedashboard of the vehicle. All licensed vehicles would also
be issued with a tamper-proof disc which would have tobe affixed to all vehicles, containing details of the vehicle’s
registration, the SPSV licence number, the expiry date andthe number of passengers the vehicle is licensed to carry.

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7.4 Progress in Implementing Change

The principal new requirements for a standard taxi
or hackney are that the vehicle must:

7.4.1 Driver Quality• Be less than 9 years old

Skills Development Programme
The Commission is currently finalising the developmentof a Skills Development Programme, the successful
completion of which will be a prerequisite for new
applications for SPSV driver licences from May 2009
and renewals of driver licences from 1st January 2012.
The learning materials are currently being finalised andare expected to be released at the end March 2009.
The Commission anticipates the first tests will begin
in May 2009. Once the Skills Development Programme
is operational, the Gardaí will cease administration of
the local area knowledge tests.
The new Skills Development Programme test will takethe form of a multiple choice exam in electronic format
with a touch-screen facility, of approximately one hourand forty five minutes in length38. It will incorporate botha general test relating to the SPSV industry, as well as arelevant local area knowledge test for a county. Questions
will be chosen randomly from a bank of questions.
The Skills Development Test, once implemented, will
represent the first consistent approach to the trainingof SPSV operators in Ireland.

7.4.2 Vehicle Quality
National Vehicle Standards
The Commission has developed a detailed set ofstandards that all vehicles operating in the SPSV industry
must comply with, which are set out in the document‘National Vehicle Standards’, published by the Commissionin November 2007. The Commission’s standards supersede
the standards previously set by the Department ofTransport. They apply to all standard taxi and hackneyvehicle licences from 1st January 2009, and, following aperiod of transition, to all new and renewed SPSV vehicle
licences from 1st January 2012. They include minimum
standards for capacity, accessibility, comfort, and safety.
The Commission has produced a model report for mostof the vehicles available on the Irish market. The model
report indicates compliance (or non-compliance) withthe basic vehicle parameters set out in National
Vehicle Standards, such as seating accommodationand luggage capacity.

• Have a luggage capacity of at least 420 litres• Have a rear shoulder width of at least 1,360mm
When fully operational, the vehicle standards will
ensure that only compliant vehicles will be licensed
and hence operational within the industry, thereby
guaranteeing a minimum level of vehicle quality within
the industry. The Commission has indicated that it
intends to review vehicle standards on an ongoing basis.

7.4.3 Service Quality
Since its establishment, the Commission has implemented
a number of reforms to improve the quality of service
provided in the industry.

National Information Line and Complaints System
One of those reforms relates to the putting in place of anational consumer information line providing informationon the hiring of SPSVs and advising callers on making acomplaint. The Commission has also put in place a national
central electronic complaints system,39 which deals withall complaints made in relation to the SPSV industry in aconsistent manner. All complaints are tracked electronicallywhich facilitates the speedy identification of drivers
against whom repeated complaints have been made.
The Commission monitors trends in complaint types andoutcomes on an area basis. The types of complaints theCommission is responsible for include:40• Complaints in relation to the condition andcleanliness of vehicles• Complaints in relation to the conduct
and behaviour of operators/drivers• Overcharging or other matters relating to fares• Matters relating to the hiring of a cab

38 Although some participants may prefer to attend an instructor-led course, there is no requirement for current or potential SPSV drivers to attend a training course.
The training material is designed to enable drivers to learn at home at their own pace.
39 Prior to this the only official means of making a formal complaint in relation to cab services was through the PSV Inspectorate of the Gardaí. In Dublin, the PSV Inspectorate
resided in the Carriage Office; elsewhere the function was carried out by individual officers. There were up to 30 inspectors in the Gardaí.
40 By virtue of Section 51 of the Taxi Regulation Act 2003.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yComplaints are investigated by the Commission’s
enforcement team and can result in:• Advice being issued• A formal warning• A prosecution• A fixed-charged penalty• No further action
Some complaints are referred to the Gardaí or otherrelevant agencies if the nature of the complaint is notwithin the remit of the Commission for Taxi Regulation.
Enforcement
Since February 2007, the Commission has also put
in place a team of nine enforcement officers whose role
is to enforce SPSV Regulations throughout the country.
The team is involved in investigating complaints, checking
compliance through nationwide operations, issuingon-the-spot penalties for fixed-charge offences, issuingformal warnings and pursuing prosecutions in theDistrict Court against persons not complying with SPSVRegulations. The enforcement team is in regular contact
with An Garda Síochana to seek assistance in investigations
and complaints, where appropriate. Local joint operations
with the Gardaí average two per month. Prior to each
enforcement operation, the responsible enforcement
officer submits a plan for the Head of Enforcement
providing details of the location, date and objectiveof the operation. The enforcement team also assists
SPSV drivers with the provision of information
regarding compliance.
In-Vehicle Information
The Commission has developed a customer charter ofrights and responsibilities of both the driver and passenger
which must be displayed in all SPSVs operating in theindustry. In addition, taxis are required to display thenational maximum taxi fare. Charters are supplied freeof charge to all SPSV licence holders.

Additional Industry Information
Information on all aspects of the SPSV industry is available
on the Commission’s website, www.taxiregulator.ie.
In December 2007 the Commission published a national
consumer information guide providing informationon the differences between hiring a taxi, wheelchair
accessible taxi, hackney and limousine; consumer rights
and responsibilities; as well as information on making acomplaint and locating lost property. The Commission
is currently finalising the Skills Development Programmemanual which is near completion at the time of writing.
The manual will provide a comprehensive outline of the
SPSV industry in Ireland, the role of each sector within
the industry and equip operators with the range of skills
necessary to operate an SPSV licence.
Accessible Services
The Commission has also issued a new vehicle specification
for wheelchair accessible vehicles as part of its National
Vehicle Standards document. These new specifications
include engineering-test-led requirements in anticipationof forthcoming vehicle legislation across the EU, which
for the first time will create an approval category forwheelchair accessible vehicles. Such improvements, likely tobe required of vehicle coachbuilders will undoubtedly add
to the already relatively high costs of accessible vehicles.
The Commission has always recognised this and has
made submissions to the Department of Transport seeking
financial assistance towards the costs associated withpurchasing, and providing a service, utilising wheelchair
accessible vehicles. In the absence of any such assistancepackage the existing fleet is likely to suffer from alack of replacement or upgrade investment and by
2012 could be significantly depleted.
The Commission has, in 2008, put in place a system
whereby all service providers licensed to provide wheelchair
accessible services are required to register their contact
details and hours of operation with the Commission. They
are required to give priority to the people with disabilities
in providing SPSV services. There is still a significant
proportion of unmet demand reported to the Commission
on a regular basis due to a limited supply of wheelchair
accessible taxi services.

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Registration and Licensing of Dispatch Operators

Quality Assurance Scheme and Quality MarkThe Commission has commenced the developmentof a national register of dispatch operators in 2008.
As of January 2009, 429 dispatch operators havereturned registration forms and are listed as active on
the Commission’s dispatch operator register. The
licensing of dispatch operators will commence in 2009.
Once licensing is complete the Commission will havea full breakdown of dispatch operators by size andarea in the country.

Finally, the Commission will in 2009 be implementing aquality assurance scheme and quality mark on a pilot basis
through dispatch operators 41. When fully implemented,
excellent services by both dispatch operators and service
providers will be eligible for the quality mark which will beawarded for vehicle quality, driver standards or quality ofbooking service provided. When introduced, the quality
mark is to be accompanied by a strong marketing andawareness campaign as well as innovative features, suchas, Dispatch Operator of the Year, Driver of the Year andMost Accessible Service.

In order to be licensed as a dispatch operator with theCommission the dispatch operator will have to among
other things ensure that at least one nominated personfrom the dispatch operator business holds the Commission
Skills Development Certificate. This person will thentrain other base operators in customer care, customer
complaints, fare structure and assisting persons withdisabilities.
Once licensed, the dispatch operators will have tocomply with the following requirements as laid out
by the Commission:• Maintain up-to-date records of bookings and drivers
affiliated to the dispatch operator. The dispatch
operators will be responsible for ensuring that vehicles
used as part of their operation are licensed and insured.
They will also be required to keep records of all of
their drivers’ contact details and licence and insurance
information. They will be required to make these records
available to the Commission on request.
• Keep the last six months of booking and complaints
records for inspection by the Commission.
• Maintain up-to-date driver and vehicle records
for the previous six months.
• Develop a staff training plan and maintain staff
training records for base operators.
The Commission’s enforcement team will conduct
on-site spot checks of licensed dispatch operators.
Repeated serious complaints against dispatch operators
will potentially lead to suspension or revocation of adispatch operator’s licence. Once the initial licensing
period has been completed, the Commission willprosecute any unlicensed dispatch operators foundto be providing dispatch operator services.

41 Subsequent to their licensing.

7.4.4 Licensing and Administration Systems
Since 2004, the Commission has put in place a seriesof reforms to streamline and improve the licensing andadministration processes associated with the SPSV industry.
National Register of Vehicle Licences
In September 2006, the Commission commenced thedevelopment of a national register, in electronic database
form, of all SPSVs licensed in the country. The register
permits the Commission to provide up-to-date statistics
on the number of active licences in any given region at
any time. An online version of the national register iswell advanced and will provide instant public access tothe status of all SPSV vehicle licences. The public form of
the register will not contain contact details of licensed
operators for the protection of the driver.
National SPSV Vehicle Licensing System
In 2006, the Commission became the sole SPSV vehicle
licensing authority for the country, replacing the various
local authorities who were previously responsible for therole. Since September 2006, the Commission has operated
a national licensing system for SPSV vehicles. The system
is administered on the Commission’s behalf by the NCTS
using the NCT test centre network (43 centres throughout
the country).

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The vehicle licensing system is more streamlined thanpreviously, owing to the fact that the NCTS also provides(at the time of writing):• The general roadworthiness test (which is requiredby all road vehicles, including SPSVs)• A suitability inspection that ensures that vehicles
are suitable for use as SPSVs• Taximeter verification from a selected numberof NCTS centres
The first two of these tests are operated under contractfrom the Road Safety Authority. The third is operated
under contract from NSAI/Legal Metrology. A suitability
inspection is currently a requirement of any first application
to have a vehicle licensed as an SPSV, including situations
where an existing SPSV vehicle licence is being transferred
to a vehicle which is being licensed as an SPSV for the firsttime. From 1st January 2010, a suitability inspection, to be
known as the licence renewal assessment, will be required
every year, as part of the vehicle licensing renewal process.
All SPSV licences must be renewed annually. Licences are
renewed on production of a valid NCT road worthinesscertificate; a valid SPSV insurance certificate; a valid tax
clearance certificate; and the appropriate licence renewal
fee. Each current vehicle licence holder receives a reminderfrom the Commission 12 weeks in advance of the renewal
date of the licence. A further reminder is issued six weeks
in advance, if the licence has not been renewed in theintervening period.
As part of the national vehicle licensing system, theCommission has introduced a new five-digit national
vehicle licensing numbering system in 2006, replacing theold numbering system under which there was replicationof numbers across local authorities and therefore no
unique identifier.
National Register of Driver Licences
During 2007, in close co-operation with the Gardaí, theCommission developed a national SPSV driver licenceregister. At the end of 2008 there were 46,845 active
SPSV driver licences on this register.

National SPSV Driver Licensing System
The Commission will in the future take over the processingof applications for SPSV driver licences from An Garda
Síochána. The Commission and the Gardaí have agreed
in principle that their responsibilities will transfer, but theCommission has not yet received sanction for additional
staff to assume the responsibility currently undertaken byapproximately 25 Garda personnel nationally. Transitional
stages from the current position are in place that will aid
the migration to the total takeover of the driver licensing
process by the Commission. The full takeover is dependent
on a sanction for extra staff for the Commission.
The system in operation by An Garda Síochána varies
slightly from region to region, however it can be broadly
outlined as follows. The licence fee, which amounts to a
total of €15, is payable to the Motor Tax Office. As partof the process, an application form is completed by theapplicant, and in most cases, the applicant submits theirapplication to their local Garda station and the applicant isthen vetted. The application is forwarded to the regional
PSV office. Some regions accept applications on a monthly
basis and others on a quarterly basis. If an application
is in order and the candidate passes vetting, they areinvited to undergo a test commonly referred to as a local
area knowledge test. The test generally includes a local
area knowledge section and a section on the rules andregulations associated with the SPSV industry. There isvariation across the country in relation to the content
and complexity of this test. After successful completionof the test, applicants are issued with a SPSV drivercertificate and badge.
When the Commission takes over the driver licensing
process, it will be streamlined. There will be one
centralised, consistent application and appeals processacross the country. All applications will be made to
the Commission. Under the new system, the Commission
will forward vetting forms to one single location, namely
the Garda Vetting Office in Thurles. In addition, thecurrent local area knowledge test will be replaced
by a Skills Development Certificate which will bemandatory nationwide.

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New Driver and Vehicle Identification System
A new driver identification system was introduced in 2007
by the Commission which, for the first time, created aconsistent national SPSV driver ID card. The card, whichis required to be displayed on the dashboard of all SPSV
vehicles, provides passengers inside the vehicles witha picture of the driver, their licence number and thecorresponding licence expiry date. Facing towards thewindscreen is information on where the driver is licensed
to ply or stand for hire as a taxi. The Commission has also
provided SPSV drivers with smart cards which they mustcarry with them when operating as SPSV drivers. This card
can be requested by enforcement officers and checkedwith hand-held devices and is a form of ID for customers.
In addition to the driver ID, the Commission also
introduced for the first time a requirement to display adisc on the front and rear windows of the licensed SPSVs.
On successful completion of the licence application or
renewal process, NCT staff members affix tamper-proof
licence discs with:• Details of the vehicle registration• The SPSV licence number• The expiry date of the SPSV licence• The number of passengers for which the vehicle
is licensed to carryRoll-out of new colour coded discs will be completed in
April 2009. The discs are required to remain in place in the
SPSV for the duration of the SPSV licence. The discs arevisible to passengers and enforcement agencies from insideand outside the front and back of the vehicle. They
contain a hologram and advanced security features
making transfer, replication or forgery very difficult.

7.5 Cost and Benefits ofRegulatory Changes
From the perspective of SPSV drivers, the reforms
introduced by the Commission and the improvements instandards will increase the professionalism of the industry
owing to a national consistent approach to training thatis shortly to be implemented. The phasing out of older
vehicles will also improve the image of the industry, which
is important from the viewpoint of promoting the cab
market. In the future, the introduction of the quality markwill increase the capacity of dedicated SPSV drivers to
attract more business. It is notable that these initiatives
will be achieved at little cost to the cab industry.
In November 2007, Fitzpatrick Associates Economic
Consultants prepared a Regulatory Impact Analysis 42(RIA) of the Commission’s proposed43 vehicle standards
for SPSVs.44 The proposed standards published by theCommission in a consultation paper45 included:• New standards for all SPSVs, including standards
on vehicle condition, communication aids, cabintemperature, safety equipment, interior lighting,spare wheels and in-vehicle information.
• Specific new standards for taxis and hackneys, including
standards on general vehicle requirements, luggage
capacity, interior size and seats, vehicle age, transparent
windows, audible taximeters, use of roof signs, use ofmeters and use of advertising.
The most significant aspect of the proposed new standards
for taxis and hackneys related to vehicle age, whereby all
vehicles would be no more than nine years old, from thedate of first registration.46
As part of the RIA, Fitzpatrick estimated the costs thatwere likely to be associated with the Commission’s
proposed vehicle standards. The cost estimates it prepared
were based on a number of assumptions including theextent to which the SPSV fleet already complied with theproposed standards; the current and future age profile ofthe taxi and hackney fleet; the likely future growth levelsin the fleet; typical vehicle types purchased; depreciationlevels; and the initial and ongoing costs associated withmeeting the required standards. Assuming the age limit ofnine years was introduced for new entrants to the market
in 2008 and existing licence holders in 2012, Fitzpatrick
estimated that the cost of introducing the new standards
would be just under €4.4 million annually, which is minimal
given the size of the fleet.

42 Regulatory Impact Analysis: Vehicle Standards’ Final Report, Fitzpatrick Associates Economic Consultants, November 2007.
43 The actual vehicle standards outlined by the Commission in November 2007 differ only marginally to those used by Fitzpatricks as part of the RIA.
44 The proposed standards for wheelchair accessible vehicles and limousines were excluded from the RIA because the issue of a subsidy regarding wheelchair accessible vehicles had notbeen finalised, and also the Commission was considering further changes to the vehicle standards for limousines.
45 ‘Vehicle Standards’ Consultation Paper No. 4, Commission for Taxi Regulation, December 2006.
46 A series of other options were also considered, including the colour coding of vehicles. However, as part of the National Review of Taxi, Hackney and Limousine Services in 2005 it wasdetermined that the recognition of cabs was not a particular problem among the domestic cab using population. Just 2 per cent of cab users stated they found cabs non-distinguishable.
As such the problem was considered not of a scale to warrant standardising the colour of vehicles.

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Cab operators have also benefited from the administrativereforms that have been put in place. The streamlined
vehicle licensing system has reduced the complexity ofthe system for operators and has led to reduced down-time
as licensing can now be accomplished in a shorter period.
Section 6 of this report indicated that consumers havegenerally positive views of the quality of cab services. Fromthe perspective of these consumers, the improvements instandards introduced by the Commission have resulted
in better educated and more aware consumers andbetter and more consistent systems of redress. In future,
consumers stand to benefit from:• a more professional service• a more consistent vehicle quality• safer vehicles• More environmentally-friendly cabs

7.6 Future Needs and Actions
In Section 8 of this report, it is recognised that theprovision of quality services constituted a form of market
failure in so far as it is not easy for persons using cabs tomake informed decisions regarding their quality before
using them. This is because consumers cannot exercise
effective choice based on the quality of the service
offered. Section 8 of this review also establishes thatin other jurisdictions where entry to the market wasliberalised, there was a heavy emphasis, either at the timeof liberalisation or thereafter, on ensuring that standards
were maintained and enhanced. The active and substantial
programme of reform that the Commission has embarked
on is therefore to be welcomed and will help to ensure thesuccess of the current regulatory approach.
In implementing its strategy to improve standards,
the Commission has two main options. The first is toestablish stringent and mandatory standards. Such an
approach would be likely to impose substantial costs on
the trade. To date the Commission, guided by regulatory
impact assessments it has commissioned as well as formalindustry representations, has not taken this approach.
The second approach is to adopt a lighter touch interms of mandatory requirements and to seek toincentivise the industry to adopt higher standards.

The costs imposed from the lighter regulations
implemented by the Commission have not been
substantial.
In this regard, it is noted that although consumers arebroadly happy with the overall quality of the current
service, the market failure in respect of service quality
arises because drivers cannot signal in advance thatthey are providing a quality service and consumers
cannot therefore exercise choice. If quality could besignalled then drivers could derive a commercial gainfrom their investments in providing a quality service.
In this regard, the quality mark would appear to be avaluable device for signalling quality and obtaining acommercial return. When the quality mark is in place, as
well as signalling to potential customers, it will open up
opportunities to provide a number of other rewards for
quality. Examples that could perhaps be considered include
preference for quality mark services or when the public
sector is procuring cab services. This would also allow
those operators who invest more in their vehicles andservices to gain a competitive advantage and differentiatethemselves in a challenging marketplace.

7.7 Conclusions
Reform in the Industry• The Commission has embarked on an ambitious
programme aimed at enhancing cab industry
standards and reforming the administration of
the system, and is making substantial progress in
implementing this programme.
• The emphasis on highlighting quality anddifferentiating those operators who meet a higher
set of standards addresses the fact that the market does
not automatically reward the industry for improvements
in quality, ie. consumers generally cannot distinguishin advance between the comparative quality ofcompeting services.
• In pursuing further improvements the Commission
should continue to adopt a light approach in termsof mandatory requirements and to seek to incentivise
the industry to adopt higher standards.

S e c t i o n 7 r e g u l at i o n o f t h e s y s t e m

Effects of Industry Reform• The streamlining of administration of the system
has been of benefit to operators.
• Consumers have already benefited from a more
coherent system of redress and will in future benefit
from the higher standards that the industry will adopt.
• Future planned reforms will continue to benefit theindustry and will be implemented at relatively low
cost to cab operators.
• The quality mark would appear to be a valuabledevice for signalling quality.
• When the quality mark is in place, as well as signalling
to potential customers, it will open up opportunities toprovide a number of other rewards for quality.
• Initiatives that could perhaps be considered include
preference for quality mark services when the public
sector is procuring cab services.

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8

eConomiC Rationale foR ReGulationof the Cab maRKet

8.1 introduction
It is generally recognised that if there
is free entry to the cab market, it willtend to deliver substantial benefits to theconsumer and potential entrants to thecab trade. However, there has been andcontinues to be a debate internationallyon the appropriate degree of regulationin the taxi industry. It is commonly
accepted that some form of regulation

Regulation of the industry normally relates to three
aspects: market entry, fares, and driver and vehicle quality
standards. Each of these aspects can be regulated todifferent degrees. At one extreme, a heavily regulated
market will encompass restrictive entry, fare and quality
standards, while a lightly regulated market will haveunrestricted entry, free fare setting and minimal quality
standards. Different jurisdictions across the world adopt
different positions on this regulatory continuum.
Regulation of the industry can also be extended to thehackney (private hire) market. However, in general, thisis normally a more lightly regulated market, with both
unrestricted entry and unregulated fare setting being
the norm, although relatively stringent vehicle and driver
quality standards are normally applied to this segmentof the market.

of the taxi component of the industry is
required, although views on the extent
and nature of that regulation vary. Most
jurisdictions tend to regulate the industry
to a certain degree, so that the market
in any one jurisdiction cannot be
precisely defined as wholly regulated
or non-regulated.

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8.2 Economic Theory and Market Regulation
Economic theory suggests that if certain conditions
are fulfilled, then free or unregulated markets for goods
and services rather than heavily regulated markets will
be most likely to increase economic welfare. Free markets
are said to be perfectly competitive, if the following
conditions obtain:• Both service providers and consumers are numerous• Service providers produce a homogeneous product• Both service providers and consumers have perfect
information about the market place• Entry into and exit from the market is free for both
service providers and consumers
The benefits of a perfectly competitive market in thecase of services are lower prices, and a wider choice for
consumers. In this way, consumer welfare is maximised
under perfect competition. An additional benefit ofcompetition is that it has the dynamic effect of stimulating
innovation as competitors strive to produce new and better
products for consumers. From the point of view of the

47 In describing markets, it might be more accurate to refer to degree of market liberalisation. However, in this Section we refer to regulation and non-regulation, as this is the way inwhich discussion of this topic has been characterised.

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S e c t i o n 8 e c o n o m i c r at i o n a l e f o r r e g u l at i o n o f t h e c a b m a r k e tservice provider, a competitive market in which there is
free entry benefits those providers who would otherwise
be unable to enter the market. They benefit from the factthat they have the opportunity to engage in economic
activity which increases their welfare over and above
alternative activities.

Market failure due to imperfect information arises inan unregulated cab trade in a number of situations:

A cab market is characterised by large numbers of bothconsumers and suppliers and a relatively homogeneous
product. This means, other things being equal, that thecab market could be expected to be perfectly competitive
and that no intervention by regulatory authorities in themarket should be needed. In practice, however, there are
a number of reasons why cab markets fail to be perfectlycompetitive. These potential market failures relate toimperfect and asymmetric information on the one
hand and external costs or benefits on the other.

• Consumers face considerable transaction costs inexercising choice. For example, the stopping of taxis on
the street in order to seek an economical fare would
be time consuming, and consumers with urgent travelneeds could not afford to undertake this practice.

Information problems arise where consumers have either
insufficient information to make an informed choice, orthey have an information deficit relative to suppliers ofcab services. Similarly, suppliers may have insufficient
information regarding earnings within the industry.
External costs arise where the supply of cab services gives
rise to costs to society as a whole (typically congestion,
environmental costs, and road safety impacts) for which
suppliers are not charged.
External benefits arise from network externalities. In
the cab market, this occurs in the telephone dispatch
market in particular. The larger the dispatch operator, thegreater the level of service to consumers, as the probability
that there are available cabs close to the requested pick-up
location rises. The linking of an additional cab operator
to a dispatch operator increases the value of dispatch
affiliation to all operators, as consumers choose thatcompany more frequently because of its greater size.
Without intervention to support affiliation to dispatch
companies, such companies will fail to achieve optimum
size. The benefits of incentivising affiliation to dispatch
companies are particularly significant where entry to themarket is restricted. This is because any measure that
increases cab utilisation rates in such circumstances ishighly prized. Some jurisdictions in Canada and theUSA, where entry is restricted, have made affiliation
to a dispatch operator mandatory.

• Consumers suffer from a lack of price information in
the on-street market. For example, in the absence offare control, they would often not be aware whether
the fare quoted is fair and reasonable.

• If, nevertheless, consumers were to engage in thispractice, it would give rise to increased congestion
for other road users, as stopping taxis would hinder
the flow of traffic.
• Tourists would be at a particular disadvantage as they
have little knowledge of the local environs and would
not be in a position to assess whether the proposed
fare is reasonable.
• Cab users cannot easily ascertain in advance thequality, safety and security of cab services on offer.
These potential market failure problems mainly referto information on fares and in relation to the hiring oftaxis on the street. This suggests, in turn, that there is astrong economic case for fare regulation of the taxi (street)market. In contrast, the argument for fare regulation of
the hackney market is much weaker. Hackneys are normally
hired by telephone, and consumers have an opportunity
to shop around to compare prices.
The second observation is that as the quality, safety andsecurity information gap applies to all cabs, regulation ofthese attributes of cab services as a whole is warranted.
However, such regulation should directly address theseelements and there is no reason to believe that controllingthe numbers of entrants would redress these potential
market failures.

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8.3 Entry Regulation
8.3.1 Introduction
The case for control on numbers of entrants must reston evidence that two potential market failures outweighthe benefits of competition. The first failure refers to any
external costs or societal loss arising from large-scale
entry to the market. The second derives from a lack ofmarket information on the part of suppliers. This is where
potential entrants to the cab market have either imperfect
information about the earnings potential in the cab market,
or choose to discount such information even when they
do have it.

8.3.2 External Costs
The argument in relation to potential external costs isthat, if cab numbers grow rapidly, they may contributeto road congestion as they go about their business.
In so far as they add to traffic volumes while picking
up or carrying their passengers, they are performing an
economic service that is arguably more valuable thanother categories of road users (for example leisure car
users) and constraints on the latter’s road use would
be more appropriate. Therefore, this externality is
only an argument for controlling taxis that may add
to congestion by standing at ranks or plying for hire.
Even here, the argument has to be tempered by thebenefits of such vehicles in alleviating congestion byencouraging commuters to leave their cars at home.  

8.3.3 Early Exit or Excessive ‘Churning’
Liberalised markets are usually characterised by significant
entry and exit. This is not a problem provided it does
not become excessive. The fact that incumbent cab
drivers’ average earnings are driven down by large-scale
entry to the market is regarded as a normal effect ofcompetition and is not an argument for control of cab
numbers. Therefore, while there can be sympathy forincumbent drivers who have seen their incomes decline
or who have to work longer hours, this not an issue thatshould influence policy on control of numbers of entrants.
Moreover, any such decline in incomes for incumbents
must be set against the additional incomes earned
by new entrants.

From the point of view of economic theory, excessiveor negative churning could occur if new entrants madedecisions to enter based on poor information as to market
conditions and or poor decision-making.48 For those
who enter the market in this way, the risk of an earlyexit is considerable. Where entrants to the market stayfor a short period only, the market is said to exhibit
excessive churning.
However, even if entry and exit rates for cabs werehigher than norms for other industries, it does not followthat churning is contributing to losses in economic
welfare that warrant entry restriction. New entrants toany market bring benefits to consumers in the form of
additional competition in the market place, a wider rangeof products, and technical innovations that can spill overto other market participants. In the context of the cab
market, new entrants could lead to higher levels of service
especially at unsocial hours, fare reductions, enhanced
service provision to people with disabilities, or innovative
services through market segmentation. If irrational entry
is taking place (in that entrants are overestimating theirpotential earnings), these benefits must be set against thenegative consequences of entry, which are the losses toirrational entrants and the squeezing out of the market ofother rational potential entrants. A recent survey of theissue of churning has concluded that entry restrictions in
response to churning run the risk of diminishing economic
welfare, particularly because a general restriction on entry
bars rational as well as irrational entrants.49 It is further
argued that other measures aimed at addressing irrational
entry behaviour directly, such as education and training,are more appropriate.
Once again, it should be emphasised that the existence ofchurning – or the possibility that it would arise – is not anargument for entry restriction as an ongoing policy. This isbecause if entry were permanently restricted, the financial
returns in the industry would be such that churning would
not arise. Consideration would also have to be given to theuse of qualitative controls on entry or other measures that
could constitute a more effective response.

48 That is, potential entrants exhibit ‘bounded rationality’.
49 A Tor. The Fable of Entry: Bounded Rationality, Market Discipline, and Legal Policy. Michigan Law Review. Volume 101, 2002.

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8.3.4 Difficulties in Identifying
Optimal Entry Restriction
Even in the event that entry restriction was deemed tobe economically justified, there remains the problemof establishing and enforcing the optimal degree ofrestriction. For example, if the scale of external costs
were to justify a restriction, a decision on the extent ofthat restriction would require knowledge of both therelationship between cab numbers and external costson the one hand and cab numbers and the benefits ofcompetitive pressures on the other. Other jurisdictions havefound it difficult to determine the appropriate number oftaxis so as to match supply to demand. Entry restrictions
are also deemed anti-competitive under current legislation.
The Competition Authority in Ireland has emphasised thisposition in recent policy discussions on the matter.50

8.4 Implications of Economic
Theory for Market Regulation
The above analysis provides a set of strong conclusions
with regard to market regulation:• Regulation of quality, safety and security aspectsof market supply is warranted in respect of bothtaxis and hackneys.
• Fare regulation in the taxi market but not in thehackney market is strongly supported.
• Permanent entry regulation in either the taxi or
hackney markets is not warranted.
• There may be arguments for moratoria on entry to
the taxi market if external costs such as congestion or
churning are excessive, but the case for such a courseof action requires careful evaluation. Protection of cab
driver’s earnings is not an argument for such a policy.
• There are practical difficulties in identifying andimplementing optimal entry restrictions.
It is noteworthy that recent analyses carried out for
the OECD and the World Bank broadly support these
conclusions.

The OECD conclusion was:“Restrictions on entry to the taxi industry constitutean unjustified restriction on competition.”51
With regard to the World Bank analysis, it concluded that:“In the cruising market, neither total regulation (fareand entry) nor total deregulation is likely to be aseffective as partial regulation involving fare control
accompanied by quality-controlled free entry.”52
The current regulatory framework in Ireland is in keepingwith the conclusions derived from economic theory in that:• Strong regulation of quality, safety and security
standards is being put in place for all cab vehicles
and their drivers.
• The hackney market is only controlled in relation
to quality standards and is neither entry nor farecontrolled.
• The taxi market is fare controlled, but has
unrestricted entry.

8.5 The Irish Regulatory Framework
in a Comparative Context
8.5.1 Overview
A review of taxi regulation in other jurisdictions reveals
that the regulatory approach adopted in Ireland is
replicated in a number of other jurisdictions. Three
countries – Austria, Netherlands and Japan – havebroadly the same regulatory structure as Ireland, as well
as approximately half of the local authorities in the UK.
Sweden and New Zealand operate a more liberal structurein which fares are also deregulated. Switzerland employs
a number of models, with some cantons (local regions)operating deregulated entry and fares. Norway is unique inthat it has entry restrictions but free fare setting.
Many countries continue to control both entry and fares.
These include Belgium, Denmark, France, Finland, Portugal,
Spain and Italy. Most jurisdictions in Germany and the
USA operate a similar system, although the full rangeof regulatory approaches exists in the latter country.
Figure 8.1 on the next page provides an overview of taxi
regulatory structures abroad.

50 For example, its presentation to the Joint Oireachtas Committee on Transport, 21st May 2008.  
51 OECD. Taxi Services: Competition and Regulation, 2007.
52 KM Gwilliam. Regulation of Taxi Markets in Developing Countries: Issues and Options. Transport Note No. TRN-3. The World Bank, 2005.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

Figure 8.1
Overview of Taxi Regulating Structures Abroad

Freedomto EnterHigh

IrelandNetherlands
AustriaJapan

MediumUK
USA
Germany

Low

Belgium
Denmark
FranceFinland

Switzerland

Portugal
Spain
Italy

Low

NorwayMediumHigh

Freedomto Set Fares

8.5.2 Experience of Countries
with No Entry Restriction• A diversification in service supply occurs, with greater
specialisation on the part of dispatch companies.

Two types of experience are of particular use in
informing this review:• The increase in supply is concentrated in the on-street
market.

• The experience of countries which, like Ireland,
have recently deregulated.

• There is usually an increased emphasis on ensuringthat service quality does not decrease and compliancewith the regulations is enforced.

• Countries where control of entry varies acrossdifferent local jurisdictions.53
With regard to the first group of countries, the OECD
notes that the impact depends on the deregulation
position. Where entry was controlled but supply wasmaintained close to free entry equilibrium, then significant
new entry does not occur. For example, in the Netherlands
the numbers of taxis increased by 25 per cent in the four
years after deregulation in 2000, while in Japan a ten
per cent increase took place in a five year period. The
OECD suggests that the very large increase in taxi numbers
in Ireland and New Zealand post-liberalisation indicatesthat there were severe restrictions on supply prior
to deregulation. Other aspects associated withentry deregulation abroad include:• The introduction of heavier penalties for noncompliance, for example the revoking of drivers’
licences.
With regard to the UK the experience of local jurisdictions
is noteworthy.54 In the UK, local authority areas without
control on numbers of entrants have on average 30 per
cent more taxis per head of the population. These areas
have consumer waiting times that are up to 10 per centbelow those in entry-restricted areas. In entry-deregulatedareas, there has been an immediate increase in street workat the expense of telephone-booked work. Overcrowding
at ranks has been observed in deregulated areas, but
this problem dissipates over time as drivers concentrateon other areas, such as residential areas. There is little
evidence that the quality of service has decreased inareas that have deregulated.55

53 Unless otherwise indicated, the data and information in this sub-section is from the OECD report to which reference was made above.
54 The USA also has a variety of experience with regard to entry regulation; however, there are apparently no information sources
which review the comparative performance of cities with different regimes.
55 Office of Fair Trading. The Regulation of Licensed Taxi Services and PHVs in the UK, 2003.

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8.5.3 Experience of Countries with
Entry Restriction
The OECD survey of countries that have restrictedentry indicates that:• Taxi numbers tend to remain relatively staticand to decline on a per capita basis• Licences or plates acquire a substantial value• Excess demand becomes evident.
However, jurisdictions with entry restrictions tend tovary in the extent to which these impacts arise. Thisis the result primarily of fact that:• Complete entry restriction is often not possible• Different economic circumstances prevail• The nature of the cab market, particularly thedemand for street services differs• The capacity of private hire to make good any
supply shortfall varies.
The OECD notes that there is an increasing, although
not universal, trend towards regulatory reform in countries
that have traditionally restricted entry. The OECD favours
this trend but recommends that it be accompanied bystrong quality regulation measures to ensure high vehicle
and driver standards.
An interesting point of comparison in light of the above isthe case of New York City and Washington. Section 9.4.2
outlines the differing experience of these two states.

8.6 Conclusions• The benefits of a competitive market in which there
is free entry are lower prices, better products, and awider choice for consumers. From the point of viewof the producer, free entry benefits those producers
who would otherwise be unable to enter the market;• The regulatory structure for the cab industry in Irelandclosely follows that suggested by economic principles
in that there is free entry to the market, but maximum
fare control in respect of taxis.
• Economic theory suggests that affiliation to dispatch
companies yields substantial economic benefits.
• The emphasis by the Commission on enhancing vehicle
and driver standards addresses a potential market failurethat is particularly valuable in an entry-deregulated
market and is being followed in other jurisdictions.
• Other countries that have adopted regulatorymodels close to that in Ireland have experienced
greatly improved supply, while (in the main) retaining
quality standards.
• The OECD favours the approach to regulation adopted
in Ireland and emphasises the value of quality regulation
combined with entry-deregulation.
• Departures from the current regulatory structures must
be based on the view that there are potential market
failures that can be addressed by regulatory change.
• The fact that incumbent cab drivers’ earnings are driven
down by large-scale entry to the market is regarded asa normal effect of competition and is not an economic
argument for control of numbers.
• The potential market failures that might require
correction are those relating to the external effects oflarge-scale market entry and the possibility of ‘churning’.
• Even in the event that entry restriction was deemed tobe economically justified, there remains the problemof establishing and enforcing the optimal degree ofrestriction. It is also deemed to be anti-competitive,
which is in direct conflict with legislation in that area.

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9evaluation of the iSSueS

9.1 introduction
This section of the report evaluates

9.2 Impact and Benefits of theCurrent Regulatory Structure

the issues that have arisen from the

9.2.1 the Regulatory Structure

data collection and the consultations

The regulatory structure for the cab industry in Irelandclosely follows that suggested by economic principles
in that there is free entry to the market, but maximum
fare control in respect of taxis. Other countries that haveadopted regulatory models close to that in Ireland haveexperienced greatly improved supply, while (in the main)
retaining quality standards. The regulatory structure in
Ireland is that favoured by both the World Bank andthe OECD.

in so far as they impact on theeconomics of the cab market. It begins
with a summary of the findings inrelation to liberalisation of the market.
The issues raised during the courseof the study are then considered,

9.2.2 Performance of the Cab industry

concluding with a consideration

Since the new regulatory structure was introduced
consequent to liberalisation of the market in 2000, thenumber of cabs in the country has more than doubled.
Taxi numbers have increased particularly rapidly. Thissuggests that prior to liberalisation, there was a substantial
imbalance between cabs serving the street and call-out
markets, with the former being under supplied. This view
is borne out by the sharp decline post-liberalisation inhackney numbers in Dublin, where a strong street
market exists.

of a moratorium.

An estimated minimum of approximately 100 million cab
trips were made nationwide in 2008. This represents anincrease of over one-quarter compared with 2005. One
in two adults has made a trip by cab in the last six months.
Demand for cabs is high relative to demand for othermodes of transport. Based on an average trip value of€15 as indicated by the Household Survey, the valueof the industry is estimated at €1.5 billion in 2008.

9.2.3 benefits to Consumers
Liberalisation of the market has resulted in significant
benefits to consumers. This is most evident in a very
substantial reduction in waiting times. Over half of cab
journeys now involve a waiting time of less than five

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S e c t i o n 9 e va l uat i o n o f t h e i s s u e sminutes. There is waiting time data for the Dublin market
both prior to and after liberalisation. These show sharp
reductions in waiting times and improvements in thereliability of cab services post-liberalisation of the market.
The value of the post-liberalisation reduction in waitingtimes to Dublin cab users is €300 million at a minimum.56
On a proportionate basis, the benefit of waiting time
reductions to consumers throughout the country is
estimated at €780 million. The estimates do not fully
capture the benefits that arose from the increase in taxis
offering street-hire services. Given the very substantial
increase in taxi numbers that has occurred, these benefits
are likely to be considerable, especially in Dublin and otherurban areas.
These benefits have been achieved without any significant
reduction in the quality of services. The general perceptionof consumers is that the overall level of service provided,
as well as vehicle quality, vehicle cleanliness and thehelpfulness of drivers is good.

9.3 Issues Raised by the Cab Industry
9.3.1 Introduction
Despite the huge benefits that have arisen for consumers,
the cab industry has raised a number of impacts ofliberalisation that in its view argue for a change in current
regulatory policies. These are discussed below.

9.3.2 Impact on Cab Driver Earnings
Precise data on cab drivers is difficult to obtain.
Analysis indicates that full-time cab drivers report net
earnings of approximately €16,150 per annum, whereas amore independent estimate, based on Household Survey
data, suggests a net figure of €40,350. The reported
earnings by drivers is unduly low, as it is based on very
low reported average fares.
Comparison of estimated earnings over time indicatethat full-time Dublin taxi drivers experienced a decline innominal earnings in the period 2005 to 2008, but this has
been mitigated to a degree by the fares increase granted
in late 2008. It is clear, therefore, that drivers’ earnings are
not collapsing as some industry sources would suggest.
Section 5.5 provides specific figures in relation to this.
However, this is not to deny that cab drivers have to work
long hours to achieve their income targets and that on

an hourly basis they are earning well below the averageindustrial wage rate.
However, even a very substantial fall in real earnings forincumbent drivers would not in itself be a reason for
Government to intervene.57 Many sectors of the economy
experience step changes in competition from time to time,with negative implications for the earning capacity of thosein the sector. However, this is usually regarded as a normal
economic process, not requiring specific intervention
from Government.

9.3.3 Supply of Cabs
Cab industry representatives argue that the market iscurrently oversupplied. On the one hand, it is argued that,
because drivers have to work long hours to make theirtarget income, this is an indication of oversupply. However,this is simply a reflection of the degree of competitionin the cab market and the tendency for drivers to have atarget income that they seek to attain. The impact of new
entrants on the degree of competition is further amplified
by the particular structure of the Irish cab market, wheremost operators are self-employed and so do not share theirvehicle with other operators to maximise the hours thatvehicles are utilised for cab services.
A further argument that is made is that the number ofcabs in Ireland is excessive on a per head of populationbasis. At present, there are 6.4 cabs per thousand of the
population in Ireland, with a low of 2.5 cabs per thousandin County Monaghan, with a high of more than 11 cabs
per thousand persons in County Dublin.58 As entry to themarket is not restricted on a quantitative basis in Ireland,
this variability across counties shows that there is no basis
for establishing a target per head cab level above which
cab supply could be said to be excessive. Supply is likely torespond to local demand conditions and adjust accordingly.
Using international comparisons as a basis for determining
an appropriate level of supply is especially difficult. Firstly,
where entry to the market is restricted on a quantitativebasis, cab levels per head simply reflect the severity of therestrictions involved and can in no way be held to reflect
underlying demand levels. For example, New York City,
where entry to the taxi market is severely restricted, hasa cab ratio of 6.3 per thousand of the population. On theother hand, Washington DC, with unrestricted entry on aquantitative basis, has a ratio in excess of 12 per thousand,which is on a par with the ratio for Dublin County.59

56 See Appendix 2.
57 This discussion assumes that legislation to restrict entry to the market would survive legal challenges.
There are divided opinions on this matter in light of the High Court to which reference was made in Section 2.
58 Estimated by Goodbody based on VRU data and Census of Population.
59 See: The New York City Taxicab Fact Book. Schaller Consulting, 2006.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r ySecondly, such comparisons say little about the quality ofthe service provided. Where supply is restricted, the qualityof service may be poor, with long customer waiting times
and poor availability of cabs. Again in New York, there isa high level of consumer dissatisfaction with cab services.
Consumers consider cab services to be lower in quality
than public transport modes and cited availability of cabs
as the worst aspect of cab services.60
In practice, the demand for cab services and therefore thenumber of licences needed in any area is a functionof a large range of issues including:• Personal incomes of consumers• Car ownership levels• Availability of public transport modes• Degree of car restraint in urban areas• Scale of the tourism industry• Extent of drink-driving laws
• Land use settlement patterns• Cultural preferences
While some studies have attempted to estimate theappropriate level of cab supply, they have generally
failed to take account of the majority of these factors
and are therefore relatively useless as a guide.61
From the viewpoint of economic theory, over-supply
could be said to occur in a number of situations. The firstis where there is insufficient demand for goods that aredelivered to a market, with the result that there is no
point at which the market clears. Inventories then build
up and this is a signal to producers to reduce supply. This
type of effect cannot occur in the cab market as it is aservice that cannot be stored. In effect, in the cab market,
the operators will continue to offer their services if their
expected marginal revenue exceeds their costs. If the
opposite is true, they will withdraw services.
A second situation could occur where there is a lag in
supply. This is where the period required to adjust supply
is long and market conditions change in the interim.
This result is a supply cycle in which demand rises andproducers plan to increase production. However, individual
producers ignore the production of others with the resultthat the market is over-supplied and inventories build up
rapidly and prices fall. Producers cannot react by reducing
supply because they have already embarked on the processof providing increased supply. In the second part of thecycle, the fall in prices causes production to be cut sharply
with the result that prices rise sharply again. Such a market

is characterised by significant swings in supply levels andprices. The Irish cab market has not exhibited this feature.
Rather, there has been a steady rise in the supply of cabs asevidenced in Section 4.
The final situation in which over-supply occurs is whereindividual operators misguidedly enter the market andleave again rapidly. This issue of irrational ‘churning’ isconsidered separately in Section 9.4.2 below.

9.3.4 Unfair Competition
The allegation that cab drivers are subject to unfair
competition is usually made on three grounds, namely that:• Some new entrants are receiving State support
to enter the industry.
• Drivers with another occupation are engaging
in unfair competition.
• Some drivers are not complying fully with the law
in respect of having the appropriate licences andinsurances, using fully compliant vehicles at all times,
operating within the area designated on their SPSV
driver licence and complying with income taxation
requirements.
The Back to Work Enterprise Allowance allows participants
to retain a proportion of their social welfare entitlement
provided that they take up full-time self employment. It isa condition of the scheme that the enterprise undertaken
should not displace an existing enterprise. This scheme
is one of a number of employment supports that are inplace to encourage the transition to work by social welfare
recipients. It has been established that approximately
11 per cent of recipients of the scheme are engaged inbusinesses involving the carriage of goods or people,
although not necessarily in the cab industry.62 A rangeof other businesses are affected by entry supportedby the scheme.
The key concern in relation to this issue is that ofdisplacement. If these supports cause incumbents towithdraw from the businesses affected, then not only are
the employment objectives of the scheme not being met
but the State is also incurring unnecessary costs. In thecontext of the cab industry, displacement would occur
if the industry was subject to ‘churning’. If ‘churning’ isfound to be substantial or happening on an irrational basis,then there would be a strong case to discontinue suchsupports to persons entering the cab industry.

60 Op.cit.
61 See for example: B.Schaller. A Regression model of the Number of Taxicabs in US Cities. Journal of Public Transportation, Volume 8, Number 5, 2005.
62 Dáil Debates, 11th May 2004.

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S e c t i o n 9 e va l uat i o n o f t h e i s s u e sWith regard to the second issue, it is clear that drivers
with another occupation face the same costs of entry
and operation in the industry as others. Under the current
regulatory structures, the cost of entry to the market isrelatively low and the market is very contestable. Thisis the same for all entrants irrespective of whether they
have another occupation or not. A second thread of theargument is that entrants with another occupation are able
to fund the use of better vehicles by virtue of the incomesthat they have in their non-taxi occupation. However, it
is also true that the income and wealth status of all thoseentering the industry varies and is accepted as a normal
element in the operation of the market. In addition, even if
drivers with another occupation were able to afford bettercars, this is not necessarily an advantage in a market wheresuch quality improvements cannot be signalled to theconsumer or used to market advantage. It should be noted
also, that in certain rural areas the incidence of drivers withanother occupation may suit both drivers and consumers,
as it affords drivers the opportunity to earn supplementary
income while guaranteeing consumers the part-time levelof service they require.
With regard to the third issue – non-compliance with legal
requirements – this is dealt with in Section 9.4 below.

9.3.5 Fare Competition
There is evidence that reduced taxi fares are being offered
to consumers, particularly outside of the Dublin market.
This is taking the form of:• Fixed flat rate fares for short journeys• The waiving of booking fees
• Long journey discounts
Again, some cab industry representatives view thisphenomenon as a negative consequence of liberalisationof the market.
However, the national fare structure provides for
maximum taxi fares and discounts can be legitimately
offered to consumers. Indeed, this has been a featureof the taxi industry for many years prior to liberalisation.
It is not a matter for concern except where fixed flat-ratefares exceed the metered fare and therefore contravene thenational maximum taxi fare Regulations.

63 That is, potential entrants exhibit ‘bounded rationality’.

9.4 Other Issues
9.4.1 Introduction
Section 3 of this report identified a number of potential
market failures and aspects of a liberalised market that
could cause concern. These include the fact that excessive‘churning’ might occur, that external costs, such ascongestion might arise, and that network economies ofscale might not be achieved. It also identified the fact that
other jurisdictions that liberalised their markets had to be
vigilant in terms of ensuring compliance with the legal
requirements governing the licensing and operating of
cabs. These and other issues are discussed below.

9.4.2 Economic Losses Due to Excessive ‘Churning’
Liberalised markets are usually characterised by significant
entry and exit. This is not a problem provided it does not
become excessive. Irrational entry and early exit could
occur if new entrants made decisions to enter based onpoor information as to market conditions and/or poor
decision-making.63 If this were found to be the case, theninitiatives to alter entry patterns to the industry would
have to be considered.
Table 9.1 presents an analysis of entry to and exit fromthe cab market for 2007–2008, in terms of the numberof persons taking up cab licences. This shows that in theyear 2008, a total of 5,029 persons took up licences,
representing 18.3 per cent of the total number of licencesin that year. With regard to those relinquishing licences,
only those transferring licences are likely to be leaving
the industry. Lapsed licences largely represent persons
who have yet to renew, while surrendered licences largely
involve hackney drivers transferring to taxi operation.
Therefore, 1,993 persons are estimated to have left theindustry in 2008. This is a 7.3 per cent exit rate. It is notpossible to determine what proportion of exits is due todecisions to retire or change profession against early exits.
The evidence is that the entry rate has declined and theexit rate increased since 2007.  
The level of exit from the industry does not appear to be
excessively high, given retirements and illness as well as thenormal process of job-changing that would occur in any
industry. Evidence from New York, for example, indicatesthat an 8.8 per cent exit rate was experienced in the
1990s, declining to 6.2 per cent in 2005.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yTable 9.1
Number of Persons Entering the Cab Market, 2007–2008

Category

2007

2008

1 With New Licence

4,439

3,036

2 With Transferred Taxi Licence

1,328

1,993

3 Total

5,767

5,029

4 Transfer of Taxi Licence

1,328

1,993

5 Total Numberof Licensed Cabs

25,69527,429Obviously, if the entry rate were to remain high and theearly exit rate were to increase, this would give rise toconcerns that significant ‘churning’ was taking place.
At the time of writing, the expectations are that economic
growth will be negative in both 2009 and 2010 and thatunemployment rates will rise throughout the period. Thereis, therefore, a danger that persons made redundant during
these years will enter the cab market in some numbers.
At the same time, the demand for cab services could fall,as the lack of discretionary income impacts on cab trips
for leisure purposes, which as has been demonstrated
is a major source of demand for cabs. This would be amatter of concern if economic conditions gave rise tohigh levels of entry and exit.

Acquisition of Licences

Relinquishing of Licences

Entry Rate per
Licensed Cab (3÷5)

22.4%

18.3%

Exit Rate per
Licensed Cab (4÷5)

5.2%

7.3%

To date (early 2009), however, the worsening economic
conditions have not given rise to increased entry to thecab market. Figure 9.1 shows that the number of newlicences issued was declining throughout 2008, and wasless than half the equivalent 2007 number by December
2008. The figures for 2009 to date indicate that the
downward trend has accelerated, with 92 licences being
issued in January, and 89 in February – this comparesto 188 in December 2008.

Source: Goodbody Estimates derived from Commission Data

Figure 9.1
New Licences Issued, January 2007–February 2009
New
Licences

2007

2008

2009

September OctoberNovember

500

400

300

200

100

0

January

February

March

April

Source: Commission for Taxi Regulation

May

June

July

AugustDecember

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S e c t i o n 9 e va l uat i o n o f t h e i s s u e s

In the context of the cab market, new entrants could leadto higher levels of service especially at unsocial hours,
fare reductions, and innovative services through market
segmentation. If irrational entry is taking place (in thatentrants are overestimating their potential earnings), thesebenefits must be set against the negative consequencesof entry control, which are the losses to irrational
entrants and the squeezing out of the market of otherrational potential entrants. A recent survey of the issue of‘churning’ has concluded that entry restrictions in responseto ‘churning’ run the risk of diminishing economic welfare,particularly because a general restriction on entry bars
rational as well as irrational entrants.64 It is further argued
that other measures aimed at addressing irrational entry
behaviour directly, such as education and training, aremore appropriate.
If a policy of restraining or cutting cab numbers were to
be introduced, the major gains in the quality of service tothe consumer, which were identified above, would unravel
as cab numbers diminished.
Therefore, while it is possible to empathise with incumbent
drivers who have suffered a loss of income, a policy ofentry restriction would be a risky policy, especially as
there are signs that the market is stabilising. Such a
policy would, in all probability, diminish the service
supply to the consumer.
With the continuing downward pressure on earnings
capacity, lack of market knowledge may give rise toincreased ‘churning’, with consequent economic losses.
In this context, the provision of information on thefinancial return to cab driving to potential entrants isimportant. The Skills Development Programme that theCommission intends to implement will make a contribution
in this regard as it provides business planning advice
to would-be entrants.

9.4.3 Congestion and Environmental
Pollution Effects

road congestion and environmental pollution. The Dublinarea, where the number of taxis has risen particularly
strongly, is usually cited as being affected by cab-induced
congestion and environmental pollution.
Survey results suggest that cab drivers operate an averageof approximately 60,000 kilometres annually, taking into
account both full and part-time operators. There are
13,200 cabs in the Dublin area, so that cabs contribute 792
million vehicle kilometres to the total Dublin area traffic.
In contrast, there are over 470,000 private cars licensed in
the Dublin area and while precise figures are not available,cars in Ireland typically complete some 18,500 kilometresannually. This indicates a total of 8,695 million annual car
vehicle kilometres. On this basis, cabs contribute some 9
per cent of the total ‘car’ kilometres in the Dublin area.65
It is clear therefore that the number of cabs is such as topotentially contribute to congestion and environmental
effects in the major urban areas in the State. Additionally,
even casual observation confirms that, at times on Friday
and Saturday nights, taxis can dominate the traffic volumes
on parts of the urban network, due in part to the lack oftaxi ranks and peaked demand.
It must be recognised, on the other hand, that cabs also
contribute to reducing traffic congestion by encouraging
car owners not to use their vehicles so that the net increasein ‘car’ traffic volumes would be a more relevant indicatorof the scale of the problem. Similarly, the contributionof taxis to traffic volumes will vary by time of day. For
example, if the major contribution is at night time when
non-taxi volumes are low then the congestion impacts are
reduced.
Therefore the scale of this issue would need to be more
fully assessed though a comprehensive cost-benefit
analysis. Moreover, it is clear that there are a number ofsteps that could be taken to address this problem thatstop short of restricting the number of cabs. These include
measures to secure greater affiliation of cabs to dispatch
companies to reduce cruising for hire and the provision of
additional taxi stands or holding areas.66

Background
Like other vehicles, cabs contribute to road congestionand environmental pollution. It has been argued thatthe increases in the number of cabs subsequent toliberalisation have resulted in a significant increase in

64 A. Tor. The Fable of Entry: Bounded Rationality, Market Discipline, and Legal Policy. Michigan Law Review. Volume 101, 2002.
65 It is recognised that this calculation is somewhat imprecise due, for example, to the use of the Dublin area network by cars and cabs registered outside the area.
66 A ‘first best’ solution would involve congestion pricing; however, this is not in prospect in the short term. Additionally, the use of the fare structure to address this problem is madedifficult by the national nature of the fare structure and the local nature of negative external effects.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

Figure 9.2
Contribution of SPSVs to Traffic Congestion arising from car use in Dublin

Private cars

SPSVs

91% 9%

MeasuresIf larger numbers of cabs were affiliated to dispatch
companies, then not only would the level of service toconsumers be enhanced but there would be a reductionin the numbers plying for hire. At present, it would
appear that dispatch companies have insufficient businessto accommodate additional drivers. This is presumably
because with the increase in the number of taxis,
consumers find it more convenient and cheaper tohire taxis in-street.
Some countries require all drivers to affiliate to dispatch
companies. In the Irish context, this would weigh heavily
on part-time operators and would not be feasible in all
markets in Ireland, due to the lack of dispatch companies.
As an alternative approach, the Commission should
consider a number of initiatives to incentivise consumers
to use dispatch companies and drivers to affiliate. These
could include:• Continued advertising focussed on the advantages
to the consumer of pre-booking cabs
• Use of dispatch operators to promote the quality
mark scheme
It is clear that there is inadequate provision of rank spaces
in some Irish cities and towns. It is apparent that there
are two types of problems with respect to rank spaces.
Some towns, especially those that were not previously
designated as taximeter areas, never introduced taxi
ranks, or introduced a small number of spaces only. The

second problem has arisen more in major urban areas
where the large number of cabs supplying street services
has put pressure on rank spaces. Responsibility for thismatter resides with the local authorities and not with theCommission. However, the Commission has separately
commenced a study of this issue.
Without wanting to pre-empt the findings of thatstudy, it is worth making the following observations.
Extra capacity may not be warranted in all areas owing toa lack of or falling demand for on-street hire. In the smallerurban centres particularly, there are few incentives for local
authorities to expand the number of ranks. This is because
the provision of ranks may take up valuable road space,
may be opposed by local businesses, or may reduce income
to the local authority from parking charges. Because of
these factors, a solution to the problem will most likely
entail the following:• Identification of quantity standards for the provisionof permanent rank spaces in urban areas• Guidelines as to conditions under which temporaryranks should be established• A legislative onus on the local authorities to plan
to meet these rank requirements, especially in thecontext of local development plans

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9.4.4 Road Safety Impacts
Working hours
The increased competition within the cab industry in
Ireland has resulted in a situation where drivers are working
increasingly long hours. According to Section 6 of thisstudy, one in four cab drivers in the country (25.2 per cent)is currently working in excess of 60 hours weekly, while
11.2 per cent are working in excess of 70 hours weekly.
When cab drivers who also have another occupation wereanalysed separately, the corresponding proportions were
found to be 55 per cent and 22.4 per cent respectively.
Accident Rates and Driver Fatigue
Driver fatigue is widely accepted as a major cause of roadaccidents. Fatigue is the physical and mental impairment
brought about by inadequate rest over a period of time.
According to the Road Safety Authority (RSA), if a driverpersists in fighting sleep while driving, the impairment
level is the same as driving while over the drink-drive limit.
A driver suffering from fatigue will drift in and out of
consciousness and experience ‘micro sleeps’ which can lastfor up to 10 seconds. If a driver has a ‘micro sleep’ for justfour seconds while travelling at a speed of 100 km/h the
car will travel 111 metres without any driver control.
Research in the UK has found that up to 20 per cent ofserious accidents on motorways and monotonous roads
are accounted for by fatigue. The UK Government’s Road
Safety Strategy ‘Tomorrow’s Roads: Safer for Everyone’has identified driver fatigue as one of the main areas ofdriver behaviour that needs to be addressed if their target
for reducing the number of people killed and seriously
injured on UK roads is to be achieved. The European
Transport Safety Council (ETSC) states that driver fatigue isconservatively estimated to be a factor in about 20 per centof road crashes in Europe. In Australia, VicRoads, the roadsafety organisation in Victoria, has estimated that 25 percent of road crashes are fatigue-related.
The long hours of work and the fact that fatigue is acontributory factor to road-related accidents, raises
concerns about the impact of the cab industry on roadsafety. However, the evidence for this effect is not strong:
a comparative study of regulated and deregulated markets
in the UK revealed that taxi accident rates were not higher
in jurisdictions where the market was deregulated andlong working hours were the norm.67 There are a numberof possible reasons for this including the nature of cab

work with its absence of continuous driving, and theexperience and skills of the drivers themselves. Research oncommercial drivers, for example, shows that drivers withmore than ten years’ experience have a consistently lower
accident risk, and that it takes about 10 hours of driving or
11 hours of work before accident risks start to rise.68
Similarly, if cab accident rates were high, then it would
be expected that this would be reflected in very highinsurance premia. Typical annual insurance costs for a fulltime taxi driver were of the order of €1,700 in 2008.69 As
full-time taxi drivers have an annual usage of their vehicle
that is some four times that of the average motorist, thelevel of insurance costs does not indicate a serious problem
in relation to cab accident rates.
Existing Legislation
EU-derived working time legislation does not apply to
self-employed workers. Therefore, as the vast majority of
SPSV drivers are self-employed, there is no Working Time
Directive restriction in relation to their work practices.
Regulation 32 of the Road Traffic (Public Service Vehicles)
Regulations 1963 (SI No 191 of 1963), as amended,70
requires the applicant for an SPSV driver licence toprovide a written undertaking to the licensing authoritythat he/she “shall not drive a public service vehicle formore than 11 hours in any one day in any period of threeconsecutive days”.
Possible Measures
Existing legislation does not fully restrict the hours worked
by cab drivers in Ireland. If specific initiatives were to beconsidered, then it would have to be clear that there is infact a real problem in this regard and that the benefits ofany measure are commensurate with the costs.
As drivers with other occupations work the longest hours,
one option would be to require that cab operators do
not have a second job. This approach would have thedisadvantage that persons working part-time in anotherjob and wished to supplement their earnings by parttime cab working would be barred from the cab industry.
This would be inequitable and could be found to beunconstitutional. It could also deprive certain parts ofthe country of an SPSV service if there is only a part-timeneed for the service.

67 OFT. Op.Cit.
68 The Role of Driver Fatigue in Commercial Road Transport Crashes. European Transport Safety Council. 2001.
69 PA Consulting. Op.Cit.
70 Regulation 11 of SI No 111 of 1977.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

It would seem that a direct restriction on cab working
hours is required. Such a restriction would have to takeaccount of hours worked elsewhere, as otherwise only
full-time cab drivers and not drivers with anotheroccupation would be restricted.
One direct approach would be to require that all cabs befitted with tachographs71 or similar measuring devices
and set associated maximum working hour limits in theindustry. These limits would be higher for full-time drivers
than for those with another occupation. Under such asystem, cab drivers would be required to self-declaretheir status as either full-time, part-time with anotheroccupation or part-time without another occupation. The
implementation of tachographs or other measuring devices
would need to be supported by additional monitoringand enforcement activities to ensure the maximum hourthresholds would not be surpassed. The co-operation of
the Revenue Commissioners would also be required toenable the verification of the self-declared status of drivers.
This approach would be a significant and costly step.
Before implementing such an approach, there would need
to be clear evidence that long cab working hours arecontributing to high accident rates. It would also need
to be subject to a cost-benefit analysis that would analyse
the extent of the fatigue problem, identify a maximum
hours of work threshold, and examine whether the cost
to industry would be outweighed by reduced accident
rates and other benefits.

9.4.5 People with Disabilities
Section 4 established that cab use among people withdisabilities is low in Ireland relative to usage among
the general population. Almost half of all people withdisabilities use cabs less than once a month. The level ofusage has also fallen since 2005 for full-time wheelchairusers with 55.2 per cent now using cabs less than oncea month compared with 40.4 per cent in 2005.
Price and availability of cabs are the two main factors
inhibiting use of cabs by people with disability.
As of 2009, there are 1,600 wheelchair accessible taxis(WATs) in Ireland. The numbers are increasing only
marginally each year, so that WATs are in decline as aproportion of all cabs. Ireland has 0.36 WATs per thousandpeople. This is similar to the ratio for the Netherlands andabove those for many other European countries.72 Only the

UK is a significantly better performer in this regard at 1.89
per thousand. In nearly every country surveyed, there were
fiscal incentives and or grants available for the purchaseof WATs.
At present, apart from the reduced initial SPSV licence feesfor WATs, there are no other incentives for the purchaseof WATs in Ireland. In January 2007, the Commission
submitted an application to the Department of Transport
for a subsidy to assist with the purchase of accessible taxis
and hackneys. The subsidy sought is for a maximum of 40
per cent of the open market price of the WAT, subject to aceiling of €20,000.73 If this subsidy were to be granted, itwould serve as a spur to increase the penetration of WATs.
However, even then, a high level of service for people withdisabilities will not necessarily ensue. This is because, whena WAT is requested, the vehicles in the fleet in any one
dispatch centre are likely to be involved in servicing theroutine cab market and may or may not be in the vicinity.
At the same time, other dispatch companies could havea WAT available, but the consumer cannot be expected
to trawl through a range of dispatch companies seeking
WAT services. The Commission intends to require dispatch
companies to provide a minimum level of service for people
with disabilities.
Additionally, once the number of WATs reached amoderately high level, consideration could be given toproviding in major urban areas a publicly-funded callcentre for people with disabilities linked to individual
dispatch companies. This would ensure maximum useof WATs in the fleet.
In many European countries, the State provides special
contracted transport services for people with disabilities,
using Large Public Service Vehicles (LPSVs) as well as SPSVs.
Sweden and Finland are examples of where significant
services of this nature are provided by the State.
In Ireland, there are two types of contracted service
for people with disabilities:• The Rural Transport Programme, which provides
subsidised transport services for a range of target groups
including people with disabilities. These are usuallyprovided by community-based organisations and involve
minibus and to some extent SPSVs.

71 Tachographs are instruments fitted in vehicles to record the driving times, breaks and rest periods of individual drivers.
In Ireland, the Road Safety Authority is the legal body responsible for issuing digital tachographs.
72 See: Improving Access to Taxis. OECD, 2007.
73 An additional subsidy was later sought.

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S e c t i o n 9 e va l uat i o n o f t h e i s s u e s• Other contracted public service transport, which
includes transport provided through the Health Service
Executive (HSE), schools transport or transport provided
by charitable bodies for specific target groups.
Improving the level of service to people with disabilities
will require action in respect of these two types of services
also. Firstly, with regard to the Rural Transport Programme,
although this is outside the remit of the Commission, it
is clear that the more resources that are applied by thisprogramme, the better the level of service that will be
provided to people with disabilities.
Also, it would be desirable, within the Rural Transport
Programme and the HSE, that decisions on whether to
use SPSVs or LPSVs to provide services would be basedon an assessment of operating economics and not on theassumption that SPSVs are necessarily the more expensive
option. This will ensure that there is a market for services
provided by WATs, which will be further encouragingof their use. In addition, public bodies, when procuring
cab services, could be encouraged to give preference todispatch companies that have high numbers of WATs.

9.4.6 Enforcement
Enforcement of the Regulations is a vital element inensuring the provision of quality cab services andmaintaining a level playing field for cab drivers. The
degree to which illegal operation is a feature of the cab
market is very difficult to gauge. However, Gardaí andCommission enforcement activities such as spot checks
have indicated low levels of non-compliance.
It has become more difficult to earn a living from cab
services and this trend may well continue in the near future
as economic conditions deteriorate. In such circumstances,
there may be an increased tendency for some drivers
to flout the regulations so as to avoid costs and boost
revenue. Actions such as failure to comply with vehicle
and driver-licensing requirements, driving while uninsured,and poor maintenance of vehicles all result in lower
costs for illegal operators.
While the Gardaí have in place a structured approachto SPSV enforcement, with specific resources devoted
to annual SPSV operations around the country, theexistence and scale of the dedicated inspectorate within
the Commission is of the utmost importance. The
administrative reforms introduced by the Commission
have established a sound basis for enforcement activities.
The Commission has acknowledged that it needs more
enforcement officers and has requested the additional

resources from Government. In view of the scale of theindustry, which is now valued at €1.5 billion, and itschanging nature, the Commission needs to be given theopportunity to leverage the administrative advances madethrough additional resourcing of its dedicated enforcement
function.
Finally, to the extent that cab drivers operate in ageographic area for which they do not hold an SPSV driver
licence, this constitutes unfair competition. At present,
drivers are required to display their driver ID on thedashboard so that their area of operation is visible from theexterior of the vehicle. Where this requirement is complied
with, it is often done by affixing the ID to the dashboard
with poor external visibility. Consideration should be given
to requiring the driver ID to be displayed on the windscreen
so that the geographic area details are clearly visible fromthe exterior of the vehicle.

9.5 A Moratorium on the Issue of Licences
Representatives of the cab industry have called for a
moratorium on cab licences. A moratorium is a temporary
cessation in the issue of licences.74
This report has shown that free entry to the cab industry
has yielded large benefits for consumers in terms ofhigher levels of service without compromising the qualityof service on offer. For a moratorium to be acceptable, it
has to be demonstrated that there are continuing market
failures that would warrant such an approach. The factthat drivers’ incomes are falling in real terms or that they
are working longer hours is insufficient to justify the
introduction of a moratorium.
There are however two conditions that would be reasonsfor consideration of a moratorium: the existence of a highdegree of ‘churning’ and/or significant external societal
costs associated with the cab industry such as congestion.
Evidence of any increase in churning or significant externalcosts would not even then represent a sufficient condition
in its own right for the introduction of a moratorium,
as the full costs and benefits of such a policy would need
to be assessed.  
The existence of excessive churning would be supported
if there proved to be high levels of both irrational entry
to and early exit from the industry. The evidence is thatexits from the industry, although increasing, are not athigh levels. Also, the rate of entry is in decline, so that the
numbers of cabs in the market may stabilise in the near

74 It should be noted that it is not within the Commission’s powers to introduce such a change, which would require legislation.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r yfuture, provided deteriorating economic conditions do
not upset this trend.
With regard to external costs, the scale of the cab
industry indicates that congestion and environmental
impacts associated with the cab industry could become
significant if the market continued to grow. However,controlling the numbers of SPSVs is not a recommended
solution to congestion on its own given the importanceof this sector in the overall public transport network. The
peaked demand and supply in the sector, and its particular
contribution to reducing reliance on private transport atnight time, also mitigate the impact of SPSV operations on
overall traffic congestion. A more relevant focus might bemeasures to minimise cruising by taxis looking for businesssuch as the provision of additional taxi ranks or holding
areas and the promotion of affiliation to dispatch centres.
A moratorium could have some unintended negative
consequences that would have to be considered in any
assessment of costs and benefits. The first of these derives
from the fact that cab markets are local with the resultthat the extent of churning and external costs varies fromlocation to location. Therefore, the general problems that
restrictions on entry would bring would be exacerbatedin certain markets. This would be very damaging to theefficient operation of cab markets in the State.
Secondly, apart from the impact of a moratorium oncompetition in the market place, such a policy may haveunintended consequences such as concerted industry
resistance to any lifting of the moratorium or inflationin the value of licences. The extension of a moratorium
would, in turn, cause supply to reduce over time.
Thirdly, a moratorium could apply to all cab licences or on
taxis only. With regard to a moratorium on cab licences,
this would have a severe impact on supply over time.
Finally, those who support a moratorium as a means
to raise drivers’ incomes should note that of itself, a
moratorium will not raise the earnings of incumbent
drivers, unless licences cease to be transferable, which inturn would result in a reduction of supply from the current
level. Even then, any increase in the earnings of taxi drivers
generally would be limited by the tendency for increased
entry by hackney drivers and a possible return to thepractice of hiring cosies by some existing drivers.
It is concluded, therefore, that the introduction of a
moratorium is not justified at present. However, the key
issues of churning and external costs should continue to bemonitored.   

It may be noted in this regard that Washington DC, ajurisdiction that operates a similar regulatory framework
to Ireland, recently decided not to introduce a moratorium
because of the benefits of competition and the evidence
that the rate of entry to the market was slowing down.75

9.6 Conclusions
Cab Industry• An estimated minimum of approximately 100 million cab
trips were made nationwide in 2008. This represents anincrease of over one-quarter compared with 2005. The
value of the industry is estimated at €1.5 billion in 2008.
• Liberalisation of the market has resulted in significant
benefits to consumers. This is most evident in a very
substantial reduction in waiting times. The value ofthe post-liberalisation reduction in waiting times to
Dublin cab users is €300 million at a minimum. On
a proportionate basis, the benefit of waiting time
reductions to consumers throughout the country is
estimated at €780 million. The estimates do not fully
capture the benefits that arise from the increase intaxis offering on-street hire services.
• These benefits have been achieved without any
reduction in the quality of services. The generalperception of consumers is that the overall level ofservice provided, as well as vehicle quality, vehicle
cleanliness and the helpfulness of drivers is good.
Cab Drivers’ Earnings• Comparison of estimated earnings over time indicatesthat full-time cab drivers experienced no increasein nominal earnings in the period 2005 to 2008, but
did incur a small reduction in real earnings that has
been mitigated to a degree by the taxi fares increase
granted in late 2008. It is clear, therefore, that drivers’
earnings are not collapsing as some industry sources
would suggest.
• This is not to deny that, on average, cab drivers haveto work longer hours to achieve their income targets
and that on an hourly basis they are earning well below
the average industrial wage rate.
• While it is possible to empathise with incumbent drivers
who have suffered a loss of income, a policy of entry
restriction would be a risky policy, especially as there aresigns that the market is stabilising. Such a policy would,
in all probability, diminish the welfare of consumers andblock entry of rational entrants.

75 See: Task Force on Taxicab and Limousine Industry Study Report, District of Columbia Taxicab Commission, November 2008.

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Excessive ‘churning’• With the continuing downward pressure on earnings
capacity, lack of market knowledge may give riseto increased ‘churning’ in the cab industry, withconsequent economic losses. In this context, theprovision of information on the financial return to cab
driving to potential entrants is important. The Skills
Development Programme that the Commission intends
to implement will make a contribution in this regard as itprovides business planning advice to would-be entrants.
• However, the level of exit from the industry at 7.3 percent does not appear to be excessively high, given
retirements and illness as well as the normal process ofjob changing that would occur in any industry. Evidence
from New York, for example, indicates that an 8.8 percent exit rate was experienced in the 1990s, declining
to 6.2 per cent in 2005. Also, the level of entry to thecab market in Ireland is in decline.
Road Safety• Increased competition within the cab industry has
resulted in cab drivers working increasingly long hours,with potential concerns for road safety.
• With regard to restricting cab drivers’ hour of work,
there would need to be clear evidence that long cab
working hours are contributing to high accident rates.
• It would also need to be subject to a cost-benefit
analysis that would analyse the extent of the fatigue
problem, identify a maximum hours-of-work threshold,and examine whether the cost to industry would
be outweighed by reduced accident rates and otherbenefits.
Services for People with Disabilities• Ireland has 0.36 wheelchair accessible taxis (WATs) per
thousand population. This rate is above that in manyother European countries. In nearly every country
surveyed, there were fiscal incentives and/or grants
available for the purchase of WATs. The Commission has
submitted an application to the Department of Transport
for an operator subsidy to assist with the purchase ofaccessible taxis and hackneys.
• The Commission intends to require dispatch companies
to provide minimum level of service for people withdisabilities. Once the number of WATs reached amoderately high level, consideration could be given toproviding in major urban areas a publicly-funded callcentre for people with disability linked to individual

dispatch companies. This would ensure maximum
use of the WATs that are in the fleet.
• It would be desirable within the Rural Transport
Programme and the HSE that decisions on whether
to use SPSVs or LPSVs to provide services would bebased on an assessment of operating economics andnot on the assumption that SPSVs are necessarily themore expensive option. In addition, public bodies,when procuring cab services, could be encouraged togive preference to dispatch companies that have highnumbers of WATs.
Enforcement• Enforcement of the regulations is a vital element inensuring the provision of quality cab services andmaintaining a level playing field for cab drivers.
• In view of the scale of the industry, which is now valuedat €1.5 billion, and its changing nature, the Commission
needs to be given the opportunity to leverage theadministrative advances made, through additional
resourcing of its dedicated enforcement function.
• The degree to which illegal operation is a featureof the cab market is very difficult to gauge.
• However, Gardaí and Commission enforcement
activities such as spot checks have indicated very
low levels of non-compliance.
Introduction of a Moratorium• The existence of excessive ‘churning’ and large externalcosts associated with the cab industry would be
the basis for consideration of the introduction of a
moratorium. The evidence is that exits from the industry,
although increasing, are not at extremely high levels.
Also, the rate of entry is in decline, so that the numberof cabs in the market may stabilise in the near future,provided deteriorating economic conditions do not
upset this trend.
• With regard to external costs, the scale of the cab
industry indicates that congestion and environmental
impacts associated with the cab industry could become
significant. However, there are a number of initiatives,
such as the provision of additional taxi ranks and thepromotion of affiliation to dispatch centre that would
help alleviate the problem.
• It is concluded, therefore, that a moratorium is notjustified at present. However, the key issues of excessive
churning and external costs should continue to bemonitored.

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10ConCluSionS anD ReCommenDationS10.1 introduction

10.2 Trends in the Industry

The key objectives of this study were to:10.2.1 Scale of the Cab market in ireland• Undertake a review of the trends
shaping the general environment inwhich the industry operates• Assess the economic impact ofliberalisation of the SPSV sector, inparticular on supply, demand andindustry earnings.
Some particular areas of emphasis
emerged during the course of thereview which are considered in thissection, namely:– The impact of the particularregulatory model in place in Irelandon the industry overall, and how thiscompares to international experience– An assessment of how the cab market
is functioning from the point of viewof service providers and service users– The degree to which supply
matches demand– The impact of competition for existing
entrants (earnings and working hours)
and new entrants (barriers to entry).

A minimum of approximately 100 million cab trips weremade nationwide in 2008. This represents an increase ofover one quarter compared with 2005. The value of theindustry is estimated at €1.5 billion in 2008.
In meeting this demand, the cab industry operated an
estimated 1.6 billion vehicle kilometres in 2008. Cabs
undertook some 8.7 million work shifts during the year,
comprising an estimated 69 million working hours.

10.2.2 Demand for and use of Cabs
Cabs are used predominately for social and recreational
purposes. However, approximately 60 per cent ofbusinesses held one or more accounts with cab
companies in 2008, up from 50 per cent in 2005.
Some 77 per cent of national demand for cabs in2008 was for taxi services with 23 per cent for hackneyservices. This compares with an equivalent share in 2005
of 72 per cent for taxis, so the demand for taxis is rising
proportionately over time. However, hackney operations
are predominant in 10 counties.
Nationally, 63 per cent of trips are arranged by phone in2008, with 37 per cent hired on-street. These proportions
have remained relatively static since 2005. With regard
to the Dublin market, in 2008, 58 per cent of trips were
telephone booked, with 42 per cent street-hired. The data
indicates that immediately after liberalisation, the demand
for street services increased as a proportion of the total,
but that telephone-booked services are now preferred.
The demand for cab services is a peaked demand. Demand
peaks on Fridays and Saturdays, which together accountfor 73 per cent of all trips. This reflects the demand forcabs for social and recreational purposes. The evidence
is that this peakedness in demand is increasing.

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S e c t i o n 10 c o n c l u s i o n s a n d r e c o m m e n dat i o n s

There is evidence also that demand is peaked by time ofday. Over 50 per cent of demand arises between 18.00 and
03:00 hours and the period between midnight and 03.00
accounts for 22 per cent of demand.  
Cab use by people with disabilities is lower than thegeneral population with approximately 50 per cent using
them less often than once a month. The level of usage forfull-time wheelchair users has fallen since 2005 with 55
per cent now using cabs less than once a month comparedwith 40 per cent in 2005.

10.2.3 Supply of Cab Services
The supply of cab services peaks in the period fromThursday to Saturday. However, in this regard, supply
is not as peaked as demand.
In 2008, cab drivers worked more shifts and worked
longer hours than three years previously. The average
working week of all cab drivers is 52 hours, with one
in four drivers working in excess of 60 hours a week.
Between 2005 and 2008, the proportion of Dublin taxi
drivers working more than 70 hours has more thandoubled from 4 per cent to 9.8 per cent.
The supply structure of the cab industry is undergoingsignificant change. This involves increased part-timeworking and an increased proportion of drivers with asecond job. At a minimum, 15.6 per cent of cab drivers
are part-time and 14.1 per cent have another job.
Part-time drivers are much more likely to supply
services on days of peak demand than are their full-time
counterparts. Over 51 per cent of shifts operated by parttime drivers occur on those two days as against 36 percent by full-time drivers. Therefore, part-time drivers makea valuable contribution to meeting peak demands.
Of taxi drivers who have another occupation,
approximately one-third are working between 30 and 45
hours per week in that occupation. Approximately one infive cab drivers with two occupations is working in excessof 75 hours per week in total. This compares to only 8 percent of all drivers working in excess of 75 hours per week.
Cab drivers with another occupation are also more likely tobe providing services at peak times than other cab drivers.
However, their contribution to serving the Friday andSaturday peak is not as substantial as part-time drivers.
It is estimated that approximately 40 per cent of cab
vehicles nationwide are affiliated to a dispatch operator.
There is evidence, however, that the level of affiliation has

declined in Dublin. In 2005, 51.2 per cent of Dublin taxi
drivers were affiliated as compared with 38.4 per centin 2008.
There are over 400 dispatch operators in Ireland currently
registered with the Commission, with two-thirds of them
operating ten vehicles or less. Only five per cent of dispatch
operators have more than 100 affiliated vehicles. Dispatch
companies are important in creating economies of scale in
the industry. The fact that there are so few large dispatch
companies in Ireland limits the extent to which economies
of scale are being realised. The achievement of economies
of scale is dependent on consumers recognising that many
dispatch companies offer higher levels of service andincentives to encourage drivers to affiliate.

10.2.4 Earnings and Hours Worked
Precise data on cab drivers is difficult to obtain.
Analysis indicates that full-time cab drivers report average
net earnings (after all costs) of approximately €16,150
per annum, whereas a more independent estimate
suggests a figure of €40,350. The first reported earnings
figure is unduly low, as it is based on very low reported
average fares.
Comparison of estimated earnings over time indicate thatfull-time Dublin taxi drivers experienced a reduction in
nominal earnings in the period 2005 to 2008. This has
been mitigated to a degree by the fares increase granted inlate 2008. It is clear, therefore, that industry earnings are
not collapsing as some industry sources would suggest.
However, this is not to deny that cab drivers have to work
longer hours to achieve their income targets and that on
an hourly basis they are earning well below the averageindustrial wage rate.

10.3 Impact of Market
Liberalisation and Reform
10.3.1 Regulatory Structures
The regulatory structure for the cab industry in Irelandclosely follows that suggested by economic principles
in that there is free entry to the market, but maximum
fare control in respect of taxis. Other countries that haveadopted regulatory models close to that in Ireland haveexperienced greatly improved supply, while (in the main)
retaining quality standards.

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The emphasis by the Commission on enhancing vehicle anddriver standards is a means of addressing a market failurethat is particularly valuable in an entry-deregulated market
and is being followed in other jurisdictions. The OECD andWorld Bank favour the approach to regulation adopted
in Ireland and the former emphasises the value of quality
regulation combined with entry deregulation.

10.3.2 Impact of Liberalisation
As a result of liberalisation, the cab market in Ireland ishighly competitive and has no significant barriers to entry
or exit.
Liberalisation of the cab industry has brought profoundchanges in the relative market share of hackneys and taxis
in Ireland. Since liberalisation, taxi numbers have increased
rapidly. This suggests that prior to liberalisation there was asubstantial imbalance between cabs serving the street andcall-out markets, with the former being undersupplied. Thisview is borne out by the sharp decline in hackney numbers
in Dublin, where a strong street market exists.
Estimates for cab trips by residents of the Dublin areasuggest that, since liberalisation of the market, demandin the Dublin market has increased from 22 million trips in1997 to 40 million in 2008, or by some 82 per cent.
Liberalisation of the market has resulted in significant
benefits to consumers. This is most evident in a very
substantial reduction in waiting times. Data for the Dublinarea shows that whereas prior to liberalisation, 58 per centof consumers had waiting times less than 10 minutes, thishad risen to 86 per cent by 2008. There are also continuing
improvements in the reliability of cabs: in 1997, 5.9 percent of respondents reported a wait of over 30 minutes
and this proportion had decreased to 1.2 per cent in 2008.
The value of the post-liberalisation reduction in waitingtimes to Dublin cab users is €300 million at a minimum.
On a proportionate basis, the benefit of waiting time
reductions to consumers throughout the country is
estimated at €780 million.
There is no evidence that the increase in cab use andreductions in waiting times has been at the expense of thequality of the services provided. The general perception of
consumers is that the overall level of cab service provided
in Ireland, as well as vehicle quality, vehicle cleanliness andthe helpfulness of drivers is good.

The fact that incumbent cab drivers’ earnings have declined
in real terms is regarded as a normal effect of competition
and is not an economic argument for control of numbers.
The evidence is that exits from the industry, although
increasing, are not at problematically high levels. Also, therate of entry is in sharp decline, so that the number of cabsin the market may stabilise in the near future, provided
deteriorating economic conditions do not upset this trend.

10.3.3 Commission’s Reform Process
Since its establishment in 2004, the Commission has
embarked on an ambitious programme of reform of thecab industry. The reforms implemented by the Commission
relate to vehicle quality, service quality, cab licensing andadministrative systems.
The Commission has made substantial progress in
implementing its reform programme. This programme
will benefit the cab industry and will be implemented
at relatively low cost to cab operators.
In 2006, the Commission introduced a uniform national
maximum fare structure. This change in fare structures has
been broadly accepted by the consumer. There is evidence
that consumers find the fare structure easier to understandand believe that the current structure is providing better
value for money. Consumers have also benefited from amore coherent system of redress and will in future benefit
from the higher standards that the industry will adopt. The
streamlining of administration of the cab licensing system
has been of benefit to operators.
The increased emphasis the Commission is placing on
industry standards is addressing a market failure in thatthe market left alone will not automatically reward theindustry for improvements in quality.

10.3.4 Summary of the Current
Regulatory and Reform Model
The current regulatory approach of free entry to the cab
market combined with controlled taxi fares has facilitateda significant increase in cab use and service levels with
substantial benefits to the consumer. New entrants to thecab market have also benefited from the opportunity toearn a livelihood through participation in the industry. The
reform process, which the Commission has embarked on,
will increasingly benefit consumers and cab operators alike.
There are therefore strong arguments for retaining the

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S e c t i o n 10 c o n c l u s i o n s a n d r e c o m m e n dat i o n spresent regulatory structure and continuing to pursue
the Commission’s reform agenda.

10.4 Recommendations
10.4.1 The Regulatory Structure
The present regulatory structure has worked well andshould be retained. There is an insufficient justification
at present for an adjustment to the regulatory structure
through the introduction of a moratorium.76 Rather, freeentry to the cab industry has yielded large benefits for
consumers in terms of higher levels of service withoutcompromising the quality of service on offer. For a
moratorium to be acceptable, it has to be demonstrated
that there are continuing market failures that would
warrant such an approach. The fact that drivers’ incomesare falling in real terms or that they are working longer
hours is insufficient to justify the introduction of a
moratorium. The existence of excessive ‘churning’ andlarge external costs associated with the cab industry
would be reasons for consideration of such an approach,however, they are not considered sufficiently problematic
at present to justify the introduction of a moratorium. Thisis particularly the case because the rate of entry to themarket has declined sharply during 2008 and early 2009.

10.4.2 Strategic Approach
Given the positive performance of the current regulatory
structures, the Commission should now focus, within theseregulatory structures, on consolidating the reform processthat it has commenced. This consolidation process shouldhave a number of themes:• The further improvement in quality standards throughinitiatives that are of low cost to the cab trade• The further enhancement of enforcement measures
so as to maximise compliance with legislation on
the part of both the operator and consumer• The adoption of measures to research and counteract
potential market failures• The implementation of measures to promote industry
competitiveness and innovation and address supply
deficiencies in particular market segments• The further development of consumer awareness andunderstanding of the cab industry

76 As mentioned previously, the Commission does not have the authority to make such a change.

On the basis of consultation with the industry, theCommission has set the reform period to run until 2012
to allow individual operators sufficient time to arrange
financial investment or other planning to meet the newstandards. Given the support throughout the industry
for ensuring quality standards and in light of theimportance of maintaining high standards in a liberalised
market, it is advised that the Commission revisit thesetimelines to see if any fast-tracking of individual reforms
could be agreed. These would have to be cognisant offinancial impact.

10.4.3 Quality Standards
The Commission has an ambitious programme in place
aimed at improving quality standards. it is recommended
that the Commission consider the following measures:• Firstly, bringing forward from 2012, the date at which
completion of the Skills Development Programme
for existing entrants is required.
• Secondly, using the Quality Mark to promote highquality cab services through such initiatives as:– The promotion of preference for Quality MarkServices when the public sector is procuring
cab services– Promoting dedicated booking systems for Quality
Mark Cabs– Investigating other financial incentives suchas reduced insurance premia.

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Ec o n o m i c R e v i e w o f t h e S m a l l P u b l i c S e r v i c e V e h i c l e I n d u s t r y

10.4.4 Enforcement Measures
Enforcement of the Regulations is vital to ensuring theprovision of quality cab services and maintaining a levelplaying field for cab drivers. In view of the scale of theindustry, which is now valued at €1.5 billion, and itschanging nature, the Commission needs to be given theopportunity to leverage the administrative advances madethrough additional resourcing of its dedicated enforcement
function. It is also recommended that the Commission
continue to collaborate with other relevant bodies,including the Gardaí, the Revenue Commissioners andthe Department of Social and Family Affairs to promotemaximum compliance with Regulations across the industry.

collaboration with wider transport policy developmenton the issue.
The long working hours of some cab drivers could
create a negative spillover in terms of road safety impacts.
As there are no easy or cheap solutions to this issue,
there would need to be clear evidence that long cab
working hours are contributing to high accident rates,
before any radical ameliorative measures could beconsidered. It is recommended that some basic research
be conducted to establish whether there is a link between
cab driver working hours and road safety. Additionally,
the Commission should explore methods of recording
hours worked, through the use of the recording capacityof the taximeter or other devices.

10.4.5 Market Failures
Market failures associated with excessive ‘churning’ in
the Irish cab industry are not yet evident. However, it isrecommended that the Commission develop a formal andtransparent process to ensure that early exit is measured
separately as part of the overall monitoring of churning.
This could be based on an independent calculation of what
would be considered a reasonable time period to signify
early exit (or irrational entry). It is also recommended thatmeasures such as education and training be engaged inby the Commission to ensure persons entering the industry
are aware of the market conditions and potential earnings
capacity within the industry. Information on the level ofentry and exit in local markets should also be made publicly
available to assist would-be entrants to conduct more
informed research into market opportunities.
With regard to external costs, the scale of the cab
industry indicates that congestion and environmental
impacts associated with the cab industry could become
significant, albeit as a relatively small proportion of thecontribution of cars overall. However, there are a numberof initiatives, such as measures to secure greater affiliationof cabs to dispatch companies to reduce cruising for hire
and the provision of additional taxi stands in areas withdemonstrable unmet demand for street hire that would
help alleviate the problem. However, the debate about
the extent of external congestion costs is taking place
in a relative information vacuum. It is recommended that
the Commission research the extent to which external
congestion costs are arising in practice and the costbenefit of mitigating measures. This should be done in

10.4.6 Industry Competitivenessand Supply Deficiencies
The cab industry is a highly competitive one. The key
to driving further efficiencies is increasing the number
and scale of dispatch centres, especially in urban areas.
If increased affiliation were to occur then the external
congestion costs associated with the street market could
be reduced. The key role of dispatch centres has beenrecognised by the Commission. At present, consumers
do not fully understand the role of dispatch companies
and benefits arising from purchasing cab services throughthem. It is recommended that the Commission continues toengage in developing consumer awareness of cab services
and dispatch centre services in particular. Additionally, it isrecommended that the Commission explore opportunities
to incentivise cab operators to affiliate to dispatch centres
through measures such as reduced licence fees.
It is also recommended that the Commission should
investigate innovative ways through the use of technology
to contribute to integration between the booking systemsof other transport options and cabs, the potential roleof information systems at street level etc. A number ofother countries have experimented successfully with suchtechnology, including the Netherlands.
The major supply deficiency facing the industry is that ofsupply for people with disabilities. There is no one policy
initiative that will remedy this situation. Other countries
have addressed this problem not only through the cab
industry, but also through supports for other communityand private hire bus services. The current policy of seeking

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S e c t i o n 10 c o n c l u s i o n s a n d r e c o m m e n dat i o n s

to provide financial support for the purchase of wheelchair
accessible cabs and ensuring that minimum levels of service
are provided to people with disabilities is the correct
approach. It is recommended that the Commission engage
with a number of other stakeholders in the provision oftransport services for people with disabilities with a viewto establishing the role for cab services relative to othertransport services, so as to support a more integrated
and comprehensive response to the transport needsof this user group.

10.5 Overview of the Review’s Findings
The Irish cab industry has undergone substantialchange since the 1990s. Three periods in the recent
development of the industry may be discerned. The
Pre-Liberalisation Period existed up to the year 2000 and
was characterised by restricted entry to the taxi market,
a fragmented administrative structure, and diversity intaxi fare structures and levels across the country. The
Post-Liberalisation Period, commencing in 2000, saw
the complete liberalisation of entry to the market, but
the fragmented administrative and fare structures wereretained. The Reform Period, prefaced by the establishmentof the Commission for Taxi Regulation in late 2004, beganwith the introduction by the Commission of a national
taximeter area and national fare structure and otherreforms in 2006. This period of major reform is
continuing apace.
The current regulatory model, which was adopted
when the market was liberalised in the year 2000,
has solid foundations in economic theory and is that
advocated by the OECD and the World Bank. It hasbrought substantial benefits to consumers and to thoseservice providers who have entered the cab market.
The cab market is working well, with high levels ofsatisfaction expressed by consumers.
The liberalisation of the market has resulted in a muchbetter matching of supply to demand. The previous
deficiency in the provision of taxi services has been
removed and the increased involvement of part-time
service providers has helped ensure that peakdemands for cab services are better met.

There are therefore strong arguments for retaining thepresent regulatory structure. Furthermore, an adjustment
to the regulatory structure through the introduction of a
moratorium is not warranted at present. The evidence isthat exits from the industry, although increasing, do notindicate a problematic level of irrational churning. Also,
the rate of entry is in sharp decline, so that the numbersof cab in the market may stabilise in the near future,provided deteriorating economic conditions do not
upset this trend.  The Commission should monitor
industry exits to identify any emerging patterns ofexcessive churning.  
The reform process, on which the Commission has
embarked, will increasingly benefit consumers andcab operators alike. The challenge for the Commission
is to consolidate the gains already made, throughthe active pursuit of its current reform agenda.  

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eConomiC Review of the Small PubliC SeRviCe vehiCle inDuStRy

aPPenDiX 1
liSt of ConSulteeS

The following key stakeholders and interested parties andbodies were contacted during the course of this study:• An Garda Síochána• National Disability Authority• Athlone Taxi Association• National Limousine Association of Ireland• Ballina Taxi Association• National Private Hire & Taxi Association• Carlow & County Taxi Association• National Radio Cabs

• Cavan Town Taxi Owners/Operators Group• National Taxi Drivers’ Union• Commission for Taxi Regulation• Newbridge and District Taxi Association• Competition Authority• Representatives of Limerick Taxi Drivers• Consumer Association of Ireland• Road Safety Authority• Cork Taxi Association• Roscommon Hackney Cabs Association• Drogheda Taxi Owners’ Association• Rural Taxi Alliance• Dublin Airport Authority• SGS Ireland• Ennis Taxi Drivers’ Association• SIPTU• Fáilte Ireland• Sligo Taxi Association• Health and Safety Authority• Taxi Company Owners’ Association• Independent Workers Union• The Allied Taxi Association• Irish Taxi Drivers’ Federation• Thurles Taxi Drivers’ Association• Kilkenny Taxi Association• Tralee Taxi Association• Laois Taxis Limited• Tullamore Taxi Drivers’ Association• Legal Metrology Service• Waterford Taxi Association• Letterkenny Taxi Owners’ Association• West Coast Wexford Rural Transport• Naas Taxi Owners’ Association• Westport Hackney Association

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aPPenDiX 2
eStimatinG the value of ConSumeR
benefitS PoSt-libeRaliSation

Time Savings to Cab Users

Value of Time

Since deregulation in 2000, consumers have benefited
from reduced waiting times for cabs. These reduced
waiting times were recorded in the various household
surveys undertaken in the period 2000 to 2008 for the
Dublin area. The relevant data is set out in Table A2.1.
This indicates that the average waiting time in 2008 was
6.2 minutes, representing a saving of 5.3 minutes on
pre-liberalisation waiting times. The total number of cab
trips for the same dates is also available. This indicates anincrease in cab trips from 22.3 in 1997 to 40 in 2008.

It is normal practice to ascribe values to travel time
for the purpose of evaluating transport investments.
The Department of Transport has mandated a set ofsuch values.77

table a2.1
Estimated Time Savings and Cab Trips

Based on the mandated values, an estimate of thevalue of time in 2008 prices can be made. This value differs
as between journeys in the course of work andnon-work journeys. It also differs as to whether the timesavings are in respect of time spent in the vehicle or in
waiting for a transport service. Waiting time is valued
at 2.5 times in-vehicle time.
Based on the above considerations, the following
2008 values of time were used:average

Cumulative

Cab trips

waitingtime Saving

in Dublinyear

time (mins)(mins)

(m)

1997

11.5

N/A

22.3

2001

9.2

2.3

26.7

2005

8.3

3.2

27.5

2008

6.2

5.3

40.0

Work time: €24.10 per hour
Non-work time: €21.75 per hour
It was further assumed that 7 per cent of cab trips
are in work time.

This data was used as a basis for estimating the annual
value of time savings that had accrued to cab users sinceliberalisation. This was done by interpolating the data foryears for which surveys were not undertaken

77 See: Parameter Values for Use in Cost-Benefit Analysis of Transport Projects. Goodbody Economic Consultants for the Department of Transport, 2004.

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eConomiC Review of the Small PubliC SeRviCe vehiCle inDuStRy

Estimate of Consumer Benefits
The first estimate of the value of consumer timesavings was obtained by simply multiplying the annual
time savings by the number of journeys and applying theappropriate value of time. This yielded an accumulated
value of time savings of €313 million for the Dublin area.
The second approach to estimating the value of timesavings to consumers took account of the possibility thatthe reduction in waiting times might itself have contributed
to the increase in cab trips since liberalisation. If additionalcab trips are a result of the reduction in waiting times,
then not all of the additional cab users will receive a value
equivalent to the time saving. This is because some of theadditional trip-makers would not have required the full
reduction in waiting times in order to be attracted to makean additional trip. This situation is depicted in Figure A2.1,
which shows how cab trips vary with the level of service
as indicated by waiting times.
If the waiting time falls from P0 to P1, then the number oftrips increases from Q0 to Q1. The value of the time savings
to existing users is (P0 – P1) Q0, while that to the additionalcab users is 0.5 (P0 – P1)(Q0 – Q1). This Consumer’s Surplus
calculation indicates that the value of the reduction in
waiting times is given by the area P0ABP or (P0 – P1) Q0 +
0.5 (P0 – P1)(Q0 – Q1). Applying this formula yields a lower
estimate of the accumulated consumer time savingsof €284 million.

Figure: a2.1
Valuing Consumer Time Savings

Waiting Times (mins)

D

P0

A

B
P1
D

Cab Trips

Q0

Q1

Commission For Taxi Regulation
35 Fitzwilliam Square, Dublin 2, Ireland

Tel +353 1 659 3800
Fax +353 1 659 3801

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