Alan Kelly (Tipperary North, Labour) | Oireachtas source

The regulation of the SPSV industry, including the operation of the area knowledge test and SPSV skills development programme, is a matter for the NTA under the provisions of the Taxi Regulation Act 2013. My role relates to the overall policy for the sector. There have been many changes to the SPSV policy framework in recent years through the implementation of the recommendations of the taxi regulation review report 2011 and the introduction of the Taxi Regulation Act 2013. These initiatives provide a foundation for a better quality taxi industry.

The SPSV entry test is designed to confirm the candidates understanding of the SPSV regulations, industry and consumer service standards, as well as knowledge of the county in which the candidate intends to operate. The test includes two modules: the industry knowledge module and the area knowledge module. Both must be passed before an application can be granted by An Garda Síochána.

The area knowledge module consists of 36 questions in the SPSV entry test. Each county in the State comprises a separate area for the purposes of SPSV driver licensing. In the case of taxi drivers, the taxi driver can only stand or ply for hire in a county in which he or she is authorised to operate. For recent and new entrants to the SPSV industry, that authorisation means successfully completing the area knowledge test related to the particular county. Within a county, the candidate may be asked questions on various locations, routes in the county or key destinations immediately adjoining the county boundary. This reflects the fact that, if successful, the licenceholder will be entitled to provide taxi services at any location in that county.

The rationale for the area knowledge module of the SPSV entry test is the establishment of a suitable standard of area knowledge for drivers of small public service vehicles in order to ensure an appropriate quality of service to passengers. This is an approach used in many jurisdictions throughout the world, not only in Ireland.

For many years, the area authorisation arrangements have been based on the county system, with a specific area knowledge test for each county in Ireland. For an applicant intending to operate a taxi, he or she is then required to place his or her authorised county designation on his or her roof sign. It would be possible to subdivide county designations to smaller geographic areas and to tailor area knowledge tests to relate to those smaller area designations. However, there are issues that arise with such an approach. Taxis are only allowed to stand at ranks or pick up on-street in areas in respect of which they are authorised under their licence. For all recent entrants to the industry, that has meant passing the relevant area knowledge test.

While not claiming that the county system is perfect - know it is not - it has the benefit of simplicity and clarity. Alternative systems could prove to provide even more issues. The boundary of a county is a recognisable concept that is understood by everybody. Operating a system of multiple areas within a county creates the challenge of defining clearly the area authorised in each case and making that clearly and intuitively understandable. While defining boundaries based on maps can be developed, it is difficult to make this easily understandable in a simple intuitive way, and to communicate that clearly on the vehicle.

A further concern would arise in regard to enforcement issues. Arising from the issue of clarity of operational areas, the enforcement of a sub-divided area system would become much more complex and difficult than it is at present. The simplicity of finding a person standing for hire in a taxi in county A when he or she only has an authorisation for county B would be removed. Clarity would need to be obtained by the relevant Garda or compliance officer suspecting this as to the actual area designation for which the driver is authorised - it would no longer be governed by the simple, definable county boundaries. It is likely to require map-based information to fully inform of the county sub-division areas. For a Garda involved in small public service vehicle prosecutions on an infrequent intermittent basis, this lack of simplicity and clarity will be a disincentive to detection and prosecution.

There would also be cost implications in having tests for smaller areas. Currently the cost of an area knowledge test is €90 per test, reflecting the cost to the National Transport Authority of carrying out the test. If successfully passed, it authorises the successful person to stand or ply for hire at any location within the county of authorisation. As identified earlier, many taxi operators are unlikely to wish to pick up passengers on-street at several locations in a county and, under the suggested alternative system, would have to pay and take several additional area knowledge tests to achieve this, thereby increasing their costs.

While I acknowledge that the current area knowledge test has limitations, it represents a reasonable mechanism to establish an appropriate standard of geographic knowledge to be attained by drivers of small public service vehicles. The sub-division of the current county structure into smaller zones would undoubtedly make it easier to pass the revised and more localised test. However, it has several disadvantages associated with it, including enforcement challenges, lack of clarity on area knowledge, signage for taxis, cost burden and potential passenger perception issues. Overall, it is considered that the division of operational areas into a sub-county structure would create significant difficulties which would greatly out-weigh the benefits of such an approach.

See this speech in context