Taxi Services for People with Disabilities: Model Regulations Proposed to the International Community

Kéroul is taking a position on the draft model regulations published by the International Association of Transportation Regulators (IATR) on September 11. The draft regulations provide taxi service regulators with a framework for ensuring that taxi services are available to individuals with disabilities.

Kéroul welcomes the original approach taken by the IATR, which is inviting the international community to comment on the draft regulations. An international public consultation will take place at the IATR’s annual conference in New Orleans, which is being held from September 21 to 24, 2014. Papers may be submitted to the IATR until year-end.

The IATR’s approach is of special interest to Montréal, which recently tabled its policy on taxi transportation. In its policy, the Ville de Montréal undertakes to significantly increase the number of taxis able to carry passengers who use a wheelchair.

Based on its review of the regulations in effect in jurisdictions around the world, the IATR’s proposal comprises the following measures:

1)   A detailed definition of the standards applicable to accessible taxis;

2)   Training for taxi drivers;

3)   The introduction of “equivalent service” for handicapped passengers, namely 24/7 availability, wait times equivalent to those experienced by all clients and, of course, equivalent rates.

To meet the desired level of service, the IATR is proposing an Accessible Dispatch Program—a dispatch centre for accessible taxis—which would be funded by a surcharge applied to all taxi trips made in the transportation authority’s territory.

Kéroul wishes to commend the IATR on this initiative and make the following comments.

1)   A more stringent definition of the standards applicable to accessible vehicles is a valid goal, but it must not exclude accessible vehicles that are already on the market and in use.

2)   Training on transporting people with disabilities must be provided to all taxi drivers, not just those who operate an accessible vehicle; every driver may be asked to pick up passengers with functional limitations, including intellectual impairments. In addition, adapted vehicle drivers should receive training of a more technical nature on handling wheelchairs and fastening systems.

3)   In our view, funding an adapted transportation dispatch system by means of a surcharge on all taxi trips would not appear to be the optimal solution for the following reasons:

1. In many jurisdictions, taxi fares are already very high;
2. Services for people with disabilities would be identified as the cause of the increase, which all clients would be forced to pay;
3. As with the imposition of a new tax on services, it is clear that taxi drivers would be responsible for collecting the surcharge; however, it is not as clear that they would remit those monies to the proper funding mechanism;
4. Implementation of this mechanism with its many facets (the rate increase, collection and remittance of the surcharge by drivers, the creation of an administrative body to collect the funds and transfer them to the dispatch centre, etc.) would take considerable time, during which the service provided by accessible taxis would not be available.

“Think globally, act locally.”

“Think long-term, act now. But act!”

This is the foreword to the brief submitted by Kéroul to the Board of Directors of the Bureau du taxi de Montréal in June 2014.

In a nutshell, Kéroul is recommending that responsibility for providing accessible taxi transportation services be assigned to every dispatch company operating in Montréal. They are the gateways to taxi services, therefore it is their responsibility to make adapted taxis available and to provide this public-interest service. It is also up to them to organize their operations as they see fit and secure the necessary funding for accessible taxi services.

For Montréal, the service standard that Kéroul is proposing is a maximum response time of 30 minutes—24 hours a day, seven days a week. Accessible taxi services must be equivalent to those provided to other clients in the same territory.

Kéroul’s position is in keeping with the recommendation made exactly 20 years ago by the European Conference of Ministers of Transport (ECMT):

“[…] In areas where a significant proportion of taxi use is through on-street hailing […], there is a strong case for all taxis to be capable of carrying a person in a wheelchair; […]  in areas where taxi hire is predominantly by means of telephone booking or at taxi ranks, the needs of wheelchair users may be met by a proportion of the taxi fleet (to be determined in the light of local circumstances) […].[1]

Kéroul believes that providing accessible taxi services should be an integral part of the operations of every call dispatch company and is opposed to limiting this service to “specialized transportation” companies. In this way, intermediaries who use mobile applications to assign calls to taxi drivers (such as Uber, Sidecar and Lyft) would be required to provide equivalent services to people with disabilities.

As a result, taxi system regulators must establish this public service obligation for intermediaries that dispatch taxi trips and provide the means for those intermediaries to fulfil this obligation, even if it means issuing new permits to these companies.

Kéroul will submit its views at the international consultation spearheaded by the IATR. It has been invited to present its position at the association’s annual conference being held in New Orleans.