This Submission is provided by the NSW

Taxi Council and NSW Country Taxi

Operators Association in response to the

Independent Pricing and Regulatory

Tribunal’s Draft Report for the Review of

Taxi Cab Fares outside the Sydney

Metropolitan Area

NSW Taxi Council

and NSW Country

Taxi Operators

Association

Submission Country Taxi Cab Fare Review Draft

Report

1

Contents EXECUTIVE SUMMARY ............................................................................................................................ 2

INTRODUCTION ....................................................................................................................................... 4

RESPONSE TO THE DRAFT REPORT ......................................................................................................... 7

Taxi Licence Values ............................................................................................................................. 7

Taxi Licence Policy ............................................................................................................................... 9

Taxi Industry Performance .................................................................................................................. 9

Newcastle Taxis ................................................................................................................................. 10

Competitive Pressure – An Uneven Playing Field ............................................................................. 11

Illegal Hire Cars ............................................................................................................................. 12

Community Transport ................................................................................................................... 13

Courtesy Transport ....................................................................................................................... 14

Illegal Ridesharing ......................................................................................................................... 15

Taxi Industry Costs ............................................................................................................................ 15

CONCLUSION ..................................................................................................................................... 18

2

EXECUTIVE SUMMARY The NSW Taxi Council and Country Taxi Operators Association (CTOA) welcome the opportunity to provide a response to the Independent Pricing & Regulatory Tribunal’s (IPART) Draft Report on its Review of Fares Outside of Sydney (Draft Report). Country taxis play a vital role in providing public transport services to people who live in rural and regional NSW. Taxi services in these areas are often the only form of public transport available to the community and are therefore integral to the economic and social fabric of these towns. Privately funded, country taxis work hard to provide a universal service to all members of the community, and a strong and growing taxi business, like other small businesses, is reflective of the economic health of a rural and regional town. Fares for taxi cabs outside of Sydney are critical in promoting the health and viability of the rural and regional taxi industry. Both the NSW Taxi Council and the NSW CTOA are acutely aware of the need to strike the correct balance between price competitiveness and the viability of the industry. It has been clear through this IPART review process that taxi operators outside of Sydney are facing significant challenges, and in some cases, a potential crisis. Demand for taxi services has not grown, particularly since the GFC, and in a number of cases has declined significantly1. It is likely that before too long, a number of towns could be without a taxi service and therefore denying those towns the essential transport services that the NSW Taxi Industry provide. This situation is reflected in the number of taxi licences on hold in NSW2 as well as the number of taxi businesses that have been for sale but have not yet been sold.3 Contrary to the position taken by IPART, the challenges facing taxis in NSW are not as a consequence of licence costs. They are a manifestation of an ever increasing uneven competitive playing field where taxi businesses, which are privately funded, are trying to compete with free or low costs services, a number of which are funded by the State. There are significant issues regarding a lack of competitive neutrality and this is directly compounding the ability of private sector taxis to provide viable quality transport services to communities in rural and regional NSW. As outlined by many stakeholders at the public hearings for this review process, the NSW Taxi Industry can effectively compete when there is a level playing field, but it cannot compete against heavily subsidised and/or free transport. Furthermore there have been significant increases in other cost items that impact the NSW Taxi Industry and therefore there has been real downward pressure on taxi revenue over

1 NSW Taxi Networks, Taxi Booking Statistics, 2010 - 2014

2 NSW RMS, Taxi Statistics Report, May 2015

3 http://www.131008.com/cgi-

bin/cart/trader.cgi?view_all_old=1&state=New+South+Wales&cat=&view_all_old=Search , May 2015

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recent years. This has been exacerbated by taxi fares being frozen and thereby failing to keep pace with costs. It is important to note that taxi licence values and costs have also declined in real over this period. It is for these reasons that the NSW Taxi Council and NSW CTOA do not support the proposed fare freeze as recommended by IPART. The NSW Taxi Industry had a fare freeze placed upon it during 2013/2014, with a CPI (2.5%) increase in 2014/2015. During the corresponding period, taxi costs have increased by in excess of 7%, thereby representing a significant reduction in taxi driver, operator and owner earnings. The NSW Taxi Council and CTOA are also concerned that IPART has selectively represented performance data in the Draft Report, and potentially misleading the public in terms of the true picture in rural and regional NSW. This is particularly the case for the reporting in relation to the Newcastle Region which, contrary to the perception created in the Draft Report, has consistently improved its performance over the last three years. As outlined in our response to the IPART Issues Paper and reaffirmed in our representations at the public forums associated with this review, the NSW Taxi Council and NSW CTOA firmly reject the recommendation that the determination of taxi-cab fares is based on dealing with the apparent presence of economic rent in taxi licences. Taxi licences are not a constrained commodity outside of Sydney and therefore their values are a reflection of what the market is prepared to pay for this type of business. In this context, buying a taxi licence is the same as buying a small business in rural and regional NSW. As such, the variability in licence values around NSW are a reflection of how the market has valued those businesses relative to their respective markets. The approach outlined by IPART in its Draft Report is considered narrow and myopic and also disregards the importance of taxi licences to taxi owners and operators. It fails to acknowledge the long established government policies associated with taxi licences that have led many thousands of people to invest in the taxi industry in good faith. The NSW Taxi Council and NSW CTOA consider this recommendation as unreasonable and therefore inconsistent with the statutory requirements as set out in the Passenger Transport Act, 2014.

4

INTRODUCTION The NSW taxi industry is a major contributor to the State’s public transport system. It provides approximately 170 million passenger journeys each year and it meets customer travel needs right across NSW. It functions as a door to door transport service that operates 24 hours a day 7 days a week. The NSW taxi industry also provides services at times when other forms of public transport either significantly reduce service levels or cease operations altogether. Taxis are often the only form of public transport for some members of the community, and they provide essential transport services to some of the most disadvantaged people in the State. The NSW taxi industry is also a significant contributor to the State’s economy, providing employment opportunities for tens of thousands of drivers, operators, and network management staff as well as for other industries which rely on economic activity that the NSW taxi industry generates. The taxi industry contributes to the economic generation of the State by connecting people efficiently and effectively for business, education, tourism and essential lifestyle activities. The highly respected international accounting firm Deloitte Access Economics has undertaken an independent assessment of the economic contribution of the NSW Taxi Industry and has estimated the annual contribution of the industry to the NSW economy to be in the order of $1.15 billion per annum. The NSW Taxi Industry is made up of a complex array of providers, ranging from the licence owners (the licence being the principal legal instrument to provide a taxi service), through to operators and drivers. A licence owner may own, operate and drive a taxi, where as some elect only to own and be the operator of the vehicle. Some licence owners have chosen to invest in a licence and then subsequently lease the licence to an operator. Authorised taxi networks are the principal means through which taxi services are coordinated. They provide direct booking services to the public and a range of safety and other services to operators and drivers. The NSW Government does not, unlike other forms of public transport, procure taxi services from the NSW Taxi Industry. Whilst some financial support is provided to assist disadvantaged members of the community to access taxi services, on the whole the taxi transport system has been created and continues to operate as a consequence of the many people and organisations that have committed capital to invest in the industry. The NSW Taxi Industry also generates revenue for the NSW Government through the sale of licences and stamp duty on third party licence sales. It also generates other revenue through authorisation fees and indirect taxes. Taxi services in areas outside of Sydney are being provided to a high standard, as is evidenced by the negligible level of complaints received through the Government’s independent customer feedback management system (CFMS), and generally taxi operators and drivers are living on modest means. Furthermore, increasing competition from the illegal activities of some hire car operators, Courtesy Transport as well as tax payer funded Community Transport has been having a negative impact on a number of taxi operators in

5

rural and regional NSW, to the extent that some are now only marginal and are considering exiting the industry. The issue of illegal hire car activities has prompted Transport for NSW, amongst other reasons, to review the regulations that control the Private Hire Car industry and to specifically look at the issue or pre-booking times4. The issue of Community Transport is more complex and in some cases problematic. Community Transport generally provides services to the frail and aged and is funded through extensive Commonwealth, State and Local Government grants. This therefore provides a competitive advantage to Community Transport in the provision of transport services, and strong anecdotal evidence suggests that this is having a material negative impact on the earnings of taxi operators and drivers, particularly in rural and regional NSW. This issue raises questions about competitive neutrality and is a matter that is being reviewed separately by the NSW Taxi Council given the impact Community Transport is having on the taxi industry, particularly in Country NSW. Further competitive challenges are posed by Courtesy Transport. There are increasing pressures being placed on clubs and pubs to provide free transport for their clients, yet it is a false economy as the service comes at a significant cost to the relevant establishment, and indirectly to the community overall. In many instances, towns in rural and regional areas are ‘over-cabbed’ and as a consequence, there are currently in excess of 50 licences, or approximately 5% of the NSW Country taxi fleet currently on hold. There are also other key externalities that are affecting rural and regional NSW that have flow-on impacts to country taxis. Rural and regional NSW generally suffers from lower economic growth than major urban centres, higher unemployment5 and also have a faster ageing population. In some instances, rural and regional towns suffer population decline, particularly where a major industry that is critical to a rural centre closes The impending closure of the Electrolux factory in Orange, where 544 jobs will be lost, is key example of such economic and social pressures.. The situation facing rural and regional centres generally, including those in NSW, has been well summarised by Mr Paul Collits, an Adjunct Senior Lecturer at the University of NSW and a manager of policy in the former NSW Department of State and Regional Development. Mr Collits states:

A number of regional problems have surfaced over recent decades that have demanded the attention of policy makers and generated calls by regional interests for ameliorative action by governments. These problems include the sudden economic shocks caused by downturns in “one industry towns” as a result of economic restructuring; the continued emptying of the inland; the ongoing (and increasing) domination of State economies by their capital cities as a result of the processes of globalisation; increasing disparities within and between regions

4 Transport for NSW, Request for Feedback – Hire Car Pre-Booking Times, www.transport.nsw.gov.au

5 For example, Wollongong’s unemployment rate is generally 1.5% higher than the national average – Source:

Wollongong City Council, Economic Profile, www.economicprofile.com.au/Wollongong, 6 February 2014.

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across a wide range of social and economic indicators; and environmental pressures and high unemployment in rapidly growing coastal regions6

This is why the NSW Government has developed a range of investment subsidy programs for rural and regional development to help stimulate economic growth, improve employment conditions and respond to key policy challenges such as the rapid ageing of the population, particularly in coastal towns7. There are also complex cross border issues that the NSW Government and the NSW Taxi Industry is seeking to resolve; issues which are having potentially negative financial impacts for country taxi operators, and unilaterally adding more licences to these situations will only exacerbate these problems. Furthermore, under the current arrangements of the Passenger Transport Act, 2014, there is no statutory limit on the number of taxis in rural and regional NSW, and an application for a licence in areas outside of Sydney can be made at any time. The price for the licence is determined by the market based on the value set by transactions of taxi licences in the relevant region. Where there are insufficient transaction details, the NSW Government determines market value through an open and transparent tender process. In addition, there are significant subsidies for WAT’s in country areas, which are available at no cost to the applicant, and financial support by way of interest free loans are available to applicants for assistance with the establishment costs associated with a WAT. It is therefore considered inappropriate for IPART to determine that taxi services in NSW rural and regional centres are inefficient in terms of cost. Given that rural and regional NSW is more sensitive to cost movements and the recent price increases for LPG and CTP have been greater in the country than for the city, it is very important that the cost based model used to determine taxi fares in rural and regional NSW be reinstated as soon as possible.

6 P.Collits, Small Town Decline and Survival, Success Factors and Policy Issues, The Regional Institute Ltd,

www.regional.org.au, downloaded on 6 February 2012 7 For example, the Commonwealth Department of Infrastructure and Regional Development manages the

Regional Development Australia Fund. The NSW Government also has similar regional economic development programs.

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RESPONSE TO THE DRAFT REPORT The following comments are made in response to the IPART Issues Paper on the Review of Taxi Fares Outside Of Sydney

Taxi Licence Values The central argument used by IPART to support its recommendations is the cost of licences In its Issues Paper, IPART presents an argument that taxi fares in country areas (and in Sydney) are inefficient due to the apparent presence of economic rent. IPART goes on to outline in the Draft Report how it believes that fare setting policy must be focussed on removing this economic rent by putting downward pressure on licence lease costs where it is considered to exist. It is therefore considered important in response to IPART’s Draft Report that some context is provided in relation to taxi licence values and the importance of this value to those who have in good faith entered into the taxi industry through the purchase of a taxi licence. Investment in taxi licences in NSW, either as an owner operator or a third party investor, is a discretionary activity based on the purchasers’ assessment of risk and return. As identified in a number of previous submissions to IPART, an investment in a taxi licence carries a range of risks that are not necessarily relevant to other financial instruments. In this regard, a taxi licence carries a risk premium that responds to this environment. As outlined in the previous IPART reports, a key component to this risk environment for a taxi licence is ‘sovereign risk’. For many decades successive governments have implemented taxi polices that have attributed a value to a taxi plate. By way of example, in the post Second World War period, taxi plates were issued to returned servicemen as means for them establishing a business to earn a living and provide an opportunity of re-entering the community as contributors to the economy. Through the latter part of the 20th century successive governments have continued to recognise the value of a taxi plate and have continued to institute policies to support this. In the early 1980’s, government policy was broadened to allow third party investment in taxi plates, thereby allowing for greater level of investment in the industry thus contributing to growth in the number of taxis in NSW and the value of this business. In 2003 through to 2006, the then NSW Government used the capital value of a taxi plate as a means of compensating members of the hire car industry when that industry was partially deregulated at that time. Over 200 taxi licences were issued to holders of hire car licences in an explicit recognition that a taxi plate had a value that was capable of providing a reasonable return into the future, and that this value would therefore compensate owners of

8

a hire car business who had been adversely affected by government policy, i.e sovereign risk.8 As a consequence of the implementation of these policies by many governments for more than half a century, there has been a significant number of community members who have entered the NSW taxi industry as either owner operators or as third party investors. Based on current licence values, the combined value of this investment in the Sydney area alone is in excess of $2 billion. For the vast majority of licence owners (more than 80% of licence holders own only one plate), this investment represents their small/family business, a significant portion of their life savings and/or a means of funding their retirement into the future. This is particularly the case in rural and regional NSW where taxi licences are mostly operated by the owner. This ongoing investment in the industry by these people is critical to the future sustainability and viability of the taxi industry, which ultimately is central to providing an effective taxi transport service to the people of NSW. The combined economic and social impact of the proposed fare policy, as proposed by IPART, is therefore significant in this context. The NSW Taxi Council has repeatedly responded to IPART’s many reports on the matter that artificial downward pressure on taxi licence values is unreasonable particularly given the historic context of taxi licence policy. This approach to taxi fares and licence policy, without adequate compensation to effected owners, has recently been acknowledged as inappropriate by the newly elected Victorian Government which has established a compensation fund for taxi licence owners who have been adversely affected by the former Victorian Government reforms of its taxi industry. It should also be noted that there has generally been a decline in licence values in areas outside of Sydney for a number of years. Submissions from industry stakeholders have identified that taxi licence values are less than what they were when they purchased them over two decades ago9. This is a common situation right throughout NSW. It is also important to understand the marginal impact on the price of fares by what is being proposed by IPART. The Draft Report identified taxi licence costs being in the order of 12% of total taxi costs. Assuming this is correct, the removal of this cost (setting aside the negative social and economic outcomes of this) would equate to less than $2.00 on the average fare in the country, all other things being equal. Given the extent of the subsidised and/or free competition that confronts the taxi industry today in rural and regional NSW this will have a negligible impact on the competitive position of the industry, yet it would have devastating economic and social consequences for industry participants and the community more broadly. The NSW Taxi Council and NSW CTOA therefore rejects any fare policy that seeks to put artificial downward pressure on taxi licence values and we do not support the setting of fares policy based on the apparent presence of economic rent in taxi licences. 8 The submission by R.Palmer to the IPART Draft Report reflects some of the concerns these former hire car

operators have in relation to this process. 9 Fiona Richards, Submission to IPART Draft Report on the Review of Taxi-Cab Fares Outside of Sydney, 15

May 2015

9

The NSW Taxi Council and NSW CTOA presses for the return to a proper cost index model for determining taxi-cab fares, and that a review of heavily subsidised forms of transport in rural and regional NSW be undertaken to assess their collective impact on the privately funded taxi industry.

Taxi Licence Policy There is no statutory limit on the number of licences outside of Sydney. Licences are available on application from the NSW Government. The price of the licence is based on a determination of the current market value. Consistent with the international standards for assessing current market value, the price is set in accordance with the recent transactions of licences, ie a reflection of what the market is prepared to pay for a taxi licence in the relevant region. Where there is insufficient transactional data to determine a reliable current market value, then the NSW Government determines the licence value an open and transparent expression of interest process. Again this is consistent with international standards for setting current market value. This process has been undertaken by the NSW Government on many occasions and has resulted in the fair and equitable sale of licences to applicants. This has most recently occurred in Port Macquarie and Muswellbrook. IPART stated in its Draft Report that there is a lack of transparency in relation to this process. Which creates a potential barrier to entering the taxi industry10 This is generally not supported, however if there is a requirement for Transport for NSW and/or RMS to provide further information to the market on how this process is managed, then this would be welcomed by the NSW Taxi Council and NSW CTOA. Given that taxis from part of the overall public transport network, the NSW Taxi Council and NSW CTOA would also welcome an examination of this process to consider issues such as the potential oversupply of taxis in a region. For example, the application for Muswellbrook was undertaken despite there being up to six taxi licences being placed on hold in that town. Without wishing to fetter with the market response, the process should take into account the efficient use of the existing fleet and how existing taxis on hold can be better utilised. Consideration of first right of refusal and demonstrative evidence of business acumen of the applicant may be useful steps that could yield greater efficiency of this essential service asset.

Taxi Industry Performance Taxi services in areas outside of Sydney provide a very high level of service. Waiting times across country NSW are very short. In general there is an oversupply of taxis in regional NSW with a large number of towns having too many taxis to sustain efficient productive utilisation of the entire fleet across each entire week.

10

IPART, Draft Report on the Review of Taxi-Cab Fares Outside of Sydney, April 2015, pp

10

Furthermore, complaints regarding taxis services in country areas are very low. In the period 2003 to 2013, complaints in country areas averaged approximately 150 per year11 which, when considered against total number of journeys provided, represents a very high level of customer satisfaction.

Country Area Complaints 2003 to 2013 (inclusive)

An appropriate analysis of service performance is to assess compliance with mandated service standards and to measure this against other relevant inputs such as customer feedback. To this end, the NSW Taxi Council and CTOA is not aware of, nor has it been informed of, any systemic service performance issues in relations to taxis outside of Sydney. On the contrary, in two recent independent customer surveys carried out by Transport for NSW, the performance of taxis, including WAT taxis, rated highly12. This, combined with the absence of any other data to the contrary, strongly indicates that the performance of the taxi industry is well above the required standard. This level of performance was also supported by the Tavenor Research which identified that services across rural and regional NSW are generally better than those in Sydney.13 In the context that taxi services are funded directly by the private sector and the industry does not receive any subsidies from the State, this performance is all the more significant.

Newcastle Taxis In the Draft Report, Newcastle Taxis were singled out for performance issues, specifically with the No Car Available (NCA) being identified as a reason for more taxis needing to be placed on the road. 11

NSW RMS, Complaints Feedback Management System 2014 12

Transport for NSW, NSW Transport Customer Satisfactions Index 2013 and 2014, and the Transport for NSW WAT Users Survey of 1,100 Taxi Transport Subsidy Scheme users carried out in 2013. 13

Tavenor Research, Survey of Taxi use, December 2014

050

100150200250

CountryComplaints

11

The Draft Report did not however put these statistics in context and therefore potentially it misleads the reader in relation to the true performance of Newcastle Taxis. Specifically, the NCA performance of Newcastle Taxis represents 1% of total bookings. This is substantially less than the 3% statutory maximum set by the NSW Government. Moreover, the proportion of NCA’s to the total number of bookings has decreased by over 40% over the last three years. This improved performance is reflected in a reduction in complaints which have reduced by 16% over the corresponding period. The performance also needs to be considered in the context of other public transport providers. The vast majority of the NCA’s recorded were at peak times, ie Friday and Saturday nights. It is therefore instructive to note that Sydney Trains, which receives over $1 billion in Government funding each year to operate its services, had over 420 train cancellations during peak periods in 201314. This would impact upon up to 500,000 passengers. Similarly, Sydney Buses, which also receives significant State funding, did not operate over 80 timetabled services for the year 2013/2014, reflecting a potential negative impact on in excess of 3,500 passengers15. Newcastle Taxis, like all other taxi networks in rural and regional NSW, does not receive any Government funding, but is striving to provide an excellent level of customer service. Newcastle Taxis is exceeding its statutory obligations in terms of customer performance and that performance is improving. The implication arising out of the IPART Draft is therefore misleading and should be revised to properly reflect the correct situation.

Competitive Pressure – An Uneven Playing Field The biggest issue facing rural and regional taxis is the extent of uneven competition that exists in small markets outside of Sydney. Whilst taxis compete daily with other form of public transport, as well as private motor vehicles, there is an increasing level of uneven or unfair competition emerging in the market place. This includes (but is not limited to:

Illegal hire car operators Illegal Tourist Vehicle (TV) operators Courtesy Transport Government funded Community Transport (CT) Government Funded special transport, eg Summer Buses Illegal Ridesharing

14

https://au.news.yahoo.com/nsw/a/19640430/most-delayed-sydney-rail-lines-revealed/ 1 November 2013 15

NSW State Transit, Quarterly Performance Information July – September 2014 and Quarterly Performance Information April – June 2014

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Illegal Hire Cars

There is clear evidence that some hire car operators are acting illegally as taxis. In Port Macquarie a hire car operator was found guilty of operating hire cars illegally as taxis.16 In the Southern Highlands and in Griffith there are ongoing investigations of hire cars being used illegally. Some of these hire cars are using booking systems that challenge the requirement of the regulation to be pre-booked. The NSW private hire car industry is regulated under the Passenger Transport Act, 2014 (the Act) and the Passenger Transport Regulation, 2007 (the Regulation). These legal instruments set out the minimum requirements for attaining and operating a hire car business.

In the context of the consultation being undertaken by Transport for NSW, the Passenger Transport Regulation, 2007 states the following:

189 No plying or standing for hire

The driver of a private hire vehicle must not:

(a) ply, stand or park the vehicle for hire on any road or road related area, or

(b) use the vehicle to carry out a hiring other than a pre-booked hiring, or

(c) if the licence for the private hire vehicle specifies an area of operation for the

vehicle-use the vehicle to carry out a hiring to convey a passenger from a place

outside the vehicle’s area of operation to a place other than a place inside that area.

Maximum penalty: 50 penalty units.

It is therefore the intent of the Act and the Regulation that a private hire car cannot act as a taxi and must be pre-booked. As can be seen from the above clause, no minimum pre-booking time is stipulated and therefore it is largely open to the market and the approach of the private hire car operator to determine what ‘pre-booked’ means. Given the increasing competition among private hire car operators arising from the partial deregulation of private hire car licences in the early 2000’s, as well as the advent of new technology such as Apps, this definition has become increasingly ambiguous and it is potentially open to interpretation that pre-booked may only mean a number of minutes, if anything at all. The NSW Taxi Council and the NSW CTOA do not agree that hire cars represent an alternate to taxis. Taxis are distinct from private hire cars and the two industries service very different market segments. Private hire cars are not part of the NSW public transport system as they provide a specific luxury service for passengers on a pre-arranged basis that

16

http://www.portnews.com.au/story/1197670/taxi-ruling-demands-silver-service-cease-in-port-on-february-27/ dated December 2012

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usually align with high end business needs, major/special events and VIP’s. Private hire cars do not have the same strict requirements for safety, service performance and vehicle standards as the NSW Taxi Industry and therefore have less regulatory obligations in this regard. As a consequence of this, private hire cars have lower fixed and variable costs as they do not require the same level of safety systems to be in the vehicle, including alarm systems, security cameras, taxi meters and distinct livery. Recurrent costs such as insurance are also heavily weighted in the favour of private hire cars. This therefore gives private hire car operators a distinct competitive advantage, particularly if they seek to illegally compete with taxis. It is therefore in the public interest that the regulatory framework for private hire cars ensures that there is a clear and unambiguous distinction between them and taxis. This includes a range of measures including but not limited to:

Minimum pre-booking periods

Minimum hiring charges

Stronger vehicle standards

Improved Livery restrictions

Stronger restrictions on meter devices

Improved training requirements

Clearer requirements for false advertising The negative impact of illegal hire car operations on the rural and regional taxi industry has been significant and regulatory reform is required to strengthen the regulations to aid compliance and give clear direction to the market on the differences between the two modes of transport. Community Transport

Community Transport in NSW is provided by the not-for-profit sector for a specific purpose under funding agreements. They provide transport for the frail aged and transport disadvantaged where there is no viable alternate public transport. Community Transport is funded by the Commonwealth and NSW Governments, and there are competitive neutrality issues where Community Transport competes with the private sector, specifically taxis. Community Transport is charged to the Government on a per passenger basis as opposed to a per kilometre basis. This means that Community Transport services are not as efficient or as productive as taxis and therefore represent less value for money to the State and Commonwealth Governments.

14

As Community Transport is heavily subsidised, it offers services at significantly reduced prices or often at no charge at all. This does however represent a false economy to both levels of Government as this funding is unsustainable into the future, particularly as demand grows. The NSW Taxi Council and the NSW CTOA therefore believe that the NSW and Commonwealth Governments need to look to more efficient means of providing transport for community purposes. This is subject to a separate review process that the NSW Taxi Council and NSW CTOA is undertaking. The NSW Taxi Council and CTOA do however acknowledge the need for Community Transport and works closely with many Community Transport providers in providing sub-contracted services. Community Transport cannot however be considered as a substitute for taxi services which are provided by the private sector on a least cost basis. Furthermore, Community Transport is, rightly, limited in its scope of services to the frail aged and transport disadvantaged. The expansion of Community Transport services is negatively impacting upon the viability of taxis in rural and regional NSW. In some cases they will force taxi businesses to close. The NSW Taxi Council and the NSW CTOA therefore believe that this issue needs to be examined as a matter of priority.

Courtesy Transport

Courtesy Transport is often associated with pubs and clubs. There is little regulatory oversight of this form of transport although they cannot collect fares and pick up passengers off the street as hails. Given the lack of regulatory oversight, there is significant anecdotal evidence that some Courtesy Transport operators are using their vehicles as taxis and/or charter services to offset the cost of the vehicle. This is particularly the case when there are major events occurring in regional centres and these operators seek to take advantage of increased demand. Again, the regulatory costs associated with Courtesy Transport are significantly less than those for taxis and therefore these services significantly lower demand. In a number of smaller towns where fluctuations on demands are highly sensitive to small taxi operators, these impacts can lead to the closure of the business. This was highlighted at the IPART Round Table in Wagga on 12 May 201517, and is also a risk in towns such as Bermagui where the recent commencement of yet another Courtesy Transport service has made the taxi service potentially unviable.

17

Ian Favero, IPART – Draft Report, 12 May 2015

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Illegal Ridesharing

Whilst not prevalent in other areas outside of Sydney other than Newcastle, illegal ridesharing is a considerable challenge to the NSW Taxi Industry and the NSW Government more broadly. Ride-sharing apps like Uber X service are seeking to undercut taxis by operating outside of government regulation, whereas taxis are required to meet strict criteria in order to operate safely and legally Ride-sharing services, are seeking to generate a sentiment that any person equipped with a car and a smartphone can ‘make $1000’ a week; however, the reality of providing public passenger transport is that it is all about the public interest and not what best suits the commercial interests of the entity delivering the service. The NSW Taxi industry has a high cost of compliance. This is because the provision of passenger transport services is not a ‘fast money’ industry but a core public service that carries with it obligations and responsibilities that the taxi industry has upheld for many years, including safety, quality and knowledge based on training and standards, as well as obligations to vulnerable sections of the community. While the taxi industry is responding to, and in many ways leading in new technologies, these fundamental obligations and responsibilities can’t be held as mandatory for one group (taxis) and dispensable for others (ride sharing).

The lack of an even competitive playing field is the most critical issue facing the taxis in rural and regional NSW. It is in this context that the NSW Taxi Council and NSW CTOA would welcome a review on this matter. The risks to country communities are significant if these issues are not properly examined and addressed.

Taxi Industry Costs IPART acknowledges in its Draft Report that the costs of operating a taxi business have increased. IPART further states however that these costs can be absorbed by the industry through reduced licenced costs. This recommendation is not supported. There is a much higher proportion of owner operators in areas outside of Sydney and therefore there would be little or no offsetting cost reductions as put forward by IPART. Owner operators would suffer the multiple effects of diminished licence values, reduced revenue and increased costs. This will place significant pressure on already marginal businesses throughout NSW. The NSW Taxi Council has conducted independent research on the costs associated with owning, operating and driving a taxi (Attachment B)18. The research has outlined that costs have increased by in excess of 3.5%. Given the retrospective nature of fare determinations, ie that they compensate drivers and operators for costs already incurred, and also that the industry experienced a fare freeze only 12 months ago, the negative impact of a further fare freeze will be significant.

18

This research was conducted for operating a taxi in Sydney however the relativities are reflective of the costs for operating a taxi in areas outside of Sydney, particularly for Newcastle and Wollongong.

16

As outlined in repeated representations at the IPART Round Table meetings conducted as part of this review process, taxi drivers, operators and owners advised that they could accept a fare freeze as long as all other costs were frozen, (although it was noted that this was an unrealistic expectation). This was the strong sentiment of industry stakeholders at these meetings. By way of example of the impact of increasing costs affecting the NSW Taxi Industry, the cost of CTP insurance has increased at a rate well in advance of the Consumer Price Index (CPI). This rate of increase has been consistent in relative terms across NSW in both T and TC plated areas. This is illustrated in the graphs below.

Premiums for T-Plated Taxis

Premiums for TC-Plated Taxis As previously outlined to IPART, there needs to be a rigorous and transparent process for the setting of fares.

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

$4,000

$4,500

Mar-08 Mar-09 Mar-10 Mar-11 Mar-12 Mar-13 Mar-14

Premium Cost

Premium Cost

17

The Taxi Cost Index (TCI) is an industry based cost index that had been used by IPART since 2002 to make annual recommendations to the NSW Government on the movement of taxi fares. Prior to this, the TCI was developed and presented to IPART by the NSW Taxi Industry to compensate operators for costs incurred in providing taxi services19. The TCI measures, in percentage terms, how much the overall cost of providing taxi services in NSW has changed. As outlined in previous submissions to IPART by the NSW Taxi Council, the TCI is well regarded and provides for a transparent and rigorous process for examining the movements in costs and therefore the flow on effects to taxi fares. It has been subject to a number of reviews and the process has been simplified and inputs and associated weightings assessed for relativity and accuracy20. As the TCI is industry based and requires inputs from both independent sources as well as industry data, it is not as broad a reflection of the movements in costs generally in society. It doesn’t serve this purpose and is therefore likely to result in different outcomes when compared to broader based measure such as the consumer price index (CPI) or other living cost indexes. The cost items in the TCI are also likely to be less volatile than broader based measures such as the CPI, and the trend for most of the cost items has generally been upward, whereas some CPI inputs have been downward. This is has been particularly relevant for housing, household goods and technology items in the CPI which have softened in the post GFC period and in a number of cases reduced in real terms. There have also been regulatory changes that have resulted in step changes to taxi industry costs, most notably the introduction of an excise for LPG, which has placed upward pressure on taxi fares. The importance of the relativity in the increase in fares when compared to the increases in CPI need to be considered in their context. The average difference per annum is 0.8%. On fares around $20.00 this represents an increase of $0.16 cents. Even at higher fares, the comparative increase between the TCI and CPI is considered not to be that significant for the customer. It needs to be noted however, that as the TCI reflects the actual movements in costs for owners and operators, this difference is important to the industry’s ongoing viability and sustainability as it reflects the movement in actual costs incurred. It is also important to note that the inflator for the cost of taxi licence leases has been set at zero. This was done to remove the circulatory relationship between fares and licence costs. This change was supported by the NSW Taxi Council at the time. This adjustment to the TCI has meant that movements in licence costs, both up and down, as not reflected in the change in fare prices as recommended by IPART. This therefore removes the concern expressed by IPART that the cost of licence leases continues to put upward pressure on fares.

19

NSW Taxi Council Submission to IPART 2012 Fare Review dated February 2012 20

ibid

18

As outlined earlier in this submission in NSW there has been downward pressure on licence values and associated lease costs, particularly where there has economic and social decline in specific regions. By setting the licence lease cost inflator to zero, and then abandoning the TCI altogether, IPART has in effect lost the opportunity to assess this downward pressure in lease costs as part of the overall fare review. Whilst the NSW Taxi Council and NSW CTOA are not seeking to reset the inflator for licence lease costs as part of the fare review, both entities are seeking that IPART return to using the TCI as the means of reviewing and recommending fare adjustments in both the Country and the City in the future.

CONCLUSION The NSW Taxi Council and the NSW CTOA strongly believe the challenges affecting taxis in rural and regional issue go well beyond the single issue of taxi licences. To consider fare setting policy on this issue alone is neither appropriate nor fair. Given that this is a review on taxi cab fares outside of Sydney, it is considered that the IPART should revert to the TCI, assessed at approximately 3.5% or in the absence of this approach, recommend and increase in line with CPI. A fare freeze will only add pressure to the viability of existing taxi owners, operators and drivers, particularly in light of the recent fare freeze and increased costs, and it will not materially improve the competitive position of the industry due to increasing levels of inequitable competition arising from illegal operations of other providers or the increased subsidies from the State. It is also considered important that IPART recommend that the Government revert to the structure of urban and country fares, particularly given that IPART has not recommended a change to the fare structure. The recent determination for Sydney (as opposed to urban fares) has confused the industry and will potentially confuse passengers as well. . Finally, it is critical tha the issue of country taxi viability be closely examined as a priority. Communities in rural and regional NSW are at risk of losing their taxi services and this will negative economic and social consequences for not only the NSW Taxi Industry but thos towns as well.

IPART - Draft Report As an owner operator of 42 years experience I have grave concerns for some of the recommendations. The views expressed here are honest and factual. My concerns are as follows:

1. Competition: Is IPART aware of the following competitors

a) Community Transport b) Club and Pub Courtesy Buses c) Town Bus Services d) Rogue Hire Cars e) Backpackers Hostels operating Free travel for Workers f) Airport Shuttle Buses in some towns g) Cheap 2nd hand cars

All the above are genuine service providers and do impact on the viability of regional taxis particularly in small towns. There is a place for Community Transport but it must be per their stated guidelines not as a defacto taxi service funded by tax payers money. Since RBT came in 1982 clubs and pubs have put on courtesy buses and lately Bus Companies have been compelled to do town bus runs as per their accreditation.

2. Demand Rise and Lack of Taxis: Generally there has been a downturn in our Region. The only time demand exceeds supply is for 2 hours on Saturday and Sunday mornings between 2am - 4am. That leaves 164 hours of oversupply of taxis. No town or city in our Region has had an increase in Plate values. They have certainly gone down and will continue to do so as my figures attached will show. To qualify my remarks in the past 42 years the following towns have closed their Taxi Service completely: Ardlethan 1 Cab 1976 Hillston 1 Cab 1977 Lake Cargellico 1 Cab 1977 Moama 1 Cab 2007 Gundagai 1 Cab 2007 Tocumwal 1 Cab 2007 Balranald 1 Cab 2005 Hay 6 Cabs 2006 (now have 1 Hire Car) As stated above competition plus population decrease have caused their closure. A typical example is Hay which has gone from 6 Taxis in the 60's and 70's to 1 only Hire Car.

3. Future Closures: I see that in 5 to 10 years the following towns will be impacted unless something changes. Narrandera currently 3 Licences 2 on hold Leeton " 5 Licences Tumut " 5 Licences West Wyalong " 3 Licences 1 transferred 1998 Dareton " 1 Licence Wentworth " 1 Licence Coomella " 1 Licence The above towns are surviving under extreme pressure and only holding on by Government Contracts e.g. Department of Veterans Affairs and Education. As a matter of fact the above towns have 200% more community transport cars than taxis and only operate 8 to 5 weekdays.

4. Taxi Values: Taxi values peaked about 2010 and have steadily declined across the region. In some towns the value has been stagnant for 40 years, and they are very hard to sell at present.

5. Fares: I note IPART is recommending a freeze. Over the past 5 years I have been coaxed into doing private fares and bookings. It has been a very rewarding experience in that customers are happy to wait sometimes for me and the surprising outcome is that 90% of them pay well above the metered fare. This tells me that the fare price is not a deterrent to using a Taxi. The most important issue is customer service, time and time again.

6. Demand Decline: Over the past 15 years I have kept records of the performance of my Cab in Griffith.

In 1999 my cab did 15,548 jobs and 105,000 km In 2004 “ “ 14,149 jobs and 98,000 km In 2009 “ “ 15,663 jobs and 99,768 km In 2014 “ “ 11,970 jobs and 88,425 km

Equally my hired rate (hired to vacant) has gone from 50.1% in 1999 to 47.2% in 2014. Overall we need more taxi users during the daytime, especially to help our business. I hope the above information assists IPART in its Fare Determination.

Yours faithfully Ian Favero Griffith NSW

Grant Thornton Australia Limited ABN 41 127 556 389 ACN 127 556 389

Grant Thornton Australia Limited is a member firm within Grant Thornton International Ltd. Grant Thornton International Ltd and the member firms are not a worldwide partnership. Grant Thornton

Australia Limited, together with its subsidiaries and related entities, delivers its services independently in Australia.

Liability limited by a scheme approved under Professional Standards Legislation

Dear Sir / Madam

REPORT OF FACTUAL FINDINGS IN RELATION TO THE COMPILIATION OF A

2014 TAXI COST INDEX MODEL

1. Introduction

1.1. In accordance with your instructions provided on 28 January 2015 as outlined in the

Section 3 of this letter, we have performed certain procedures with respect to

calculating the cost of operating a taxi in the NSW Metropolitan Transport District in

2014 (as compared to 2013) utilising the Taxi Cost Index (“TCI”) previously utilised by

the Independent Pricing and Regulatory Tribunal of NSW (“IPART”). This report is

compiled for the purpose of assisting the NSW Taxi Industry Association (“TIA”), in

assessing the cost of operating a taxi in the NSW Metropolitan Transport District in

2014 (as compared to 2013) assuming the continued use of the TCI.

1.2. Our engagement was undertaken in accordance with the Standard on Related Services

ASRS 4400 Agreed-Upon Procedures Engagements to Report Factual Findings issued by the

Auditing and Assurance Standards Board. The responsibility for determining the adequacy

or otherwise of the procedures agreed to be performed is that of TIA.

1.3. TIA is responsible for determining whether the factual findings provided below, in

combination with any other information obtained by TIA, provide a reasonable basis

for any conclusions which TIA wishes to draw on the subject matter.

2. Findings

2.1. Having regard to the scope and limitations of our procedures as set out in the paragraphs “Scope of Work” and “Limitations of Scope” below, we report our findings as follows, noting the exceptions / clarification of assumptions provided below, and the effects these may have on the 2014 Model:

a) We have confirmed the model used to calculate the cost of operating a taxi in the NSW Metropolitan Transport District in 2014 (as compared to 2013) (“the 2014 Model”) is materially the same in structure as the “Taxi Cost Index – Fare Review 2012” model prepared and published by IPART (“the 2012 IPART Model”);

NSW Taxi Industry Association 152 Riley Street EAST SYDNEY NSW 2010 29 January 2015 PRIVATE AND CONFIDENTIAL

2

b) We have confirmed the assumptions used in the 2014 Model are consistent in nature with that used by IPART in its compilation of the TCI in 2012 and 2013 (other than those exceptions / clarification of assumptions provided below);

c) We have verified the assumptions used in the 2014 Model against the primary source (other than those exceptions / clarification of assumptions provided below), specifically inputs relating to:

i The 2013 base taxi operating costs and weightings;

ii The 2013 base fare components;

iii 2014 inflator values for:

− Driver labour costs;

− Operator administration labour costs;

− LPG fuel costs;

− Maintenance costs;

− Plate lease costs;

− Insurance costs;

− Vehicle lease payments;

− Network fees;

− Cleaning costs; and

− Productivity adjustment

d) We confirmed that all assumptions and input data flow logically through the 2014 Model noting we have not verified the suitability of these assumptions for calculating the TCI for 2014.

e) In accordance with the above findings, the outputs from the 2014 Model are summarised as follows and detailed further in Annexure 2:

Figure 1: 2014 Model Output

Urban Fares

% increase

01-Jul-14

3.7%

4.1.2 Rounded fares - urban

Fare components 01-Jul-13 01-Jul-14

Flagfall $ $3.50 $3.60

Distance charge (Tariff I) $/km $2.14 $2.22

Waiting time charge $/hr $55.30 $57.35

Booking fee $ $2.40 $2.50

Night-time surcharge (on distance rate) % 20% 20%

Maxi taxi surcharge (on total fare) % 50% 50%

Waiting time threshold km/hr 26 26

3

3. Scope of Work

3.1. Grant Thornton Australia Limited (“Grant Thornton” or “We”) have performed the

following procedures as agreed with you:

a) Obtained the “Taxi Cost Index – Fare Review 2012” model prepared and published by the Independent Pricing and Regulatory Tribunal of NSW (“IPART”)(“the 2012 IPART Model”);

b) Updated the inputs in the 2012 IPART Model with data relevant to the 2014 indexation of taxi operating costs, utilising assumptions used by IPART in its compilation of the TCI in 2012 and 2013, obtained from the relevant primary source (other than those exceptions / clarification of assumptions provided below). Specifically, these inputs relate to:

i The 2013 base taxi operating costs and weightings;

ii The 2013 base fare components;

iii 2014 inflator values for:

− Driver labour costs;

− Operator administration labour costs;

− LPG fuel costs;

− Maintenance costs;

− Plate lease costs;

− Insurance costs;

− Vehicle lease payments;

− Network fees;

− Cleaning costs; and

− Productivity adjustment

c) Confirmed that all assumptions and input data flow logically through the 2014 Model.

4. Limitations of Scope

4.1. Our scope has been limited to the procedures set out above, because the above

procedures do not constitute either an audit in accordance with Australian Auditing

Standards or a review in accordance with Australian Standards on Review

Engagements, we do not express any assurance on the 2014 Model.

4.2. Had we performed additional procedures or had we performed an audit in accordance

with Australian Auditing Standards or a review in accordance with Australian Standards

on Review Engagements, other matters might have come to our attention that would

have been reported to you.

4.3. We note the following specific procedures were not undertaken:

a) no verification of the appropriateness of using the underlying assumption sources contained within the 2014 Model has been conducted in our procedures.

b) we note that our procedures conducted as set out above do not include verifying whether the use of the TCI model is appropriate for assessing the change in the costs of operating a taxi in the Metropolitan Transport District.

4

4.4. Except as required by law, TIA acknowledges that Grant Thornton makes no representation or warranty as to the accuracy or completeness of the 2014 Model and Grant Thornton, its related bodies corporate, directors, officers and agents do not assume responsibility to the Recipients or to any other person for loss or damage of any kind whatsoever arising as a result of TIA use or misuse of the 2014 Model or for any opinion, advice recommendation, representation or information, expressly or impliedly contained therein.

5. Outputs

5.1. A copy of the 2014 Model’s outputs is attached as Annexure A. 5.2. We make provide no comments regarding the calculated outcomes provided in the

model apart from the observations provided above.

6. Exceptions / Clarification of Assumptions

6.1. We advise of the following exceptions / clarification of assumptions to our findings

from the completion of the above procedures:

Input / Assumptions

2012 IPART Model Instructions / Notes

2014 Model Assumptions Utilised

LPG fuel costs Fuel costs are inflated by the annual change in urban LPG prices provided by FUELtrac

We have been unable to source the 2013 average LPG price from FUELtrac. Accordingly, we have calculated the 2013 average by increasing the 2012 average LPG price (obtained from IPART's 2012 Model) by the fuel inflator used in IPART's 2013 report. We note that the fuel excise was used in IPART’s 2012 model as part of the fuel cost inflation. We are unable to ascertain whether the fuel excise was used by IPART in its 2013 model (nor the value). We have assumed no fuel excise in our fuel cost growth data.

Insurance costs Insurance costs are inflated by the annual change in the Insurance Services sub group of the CPI

Unable to locate the "Insurance Services" sub group of the CPI, we utilised the "Insurance" sub group of the CPI (series ID: A3602793W). We note that the insurance cost inflator used in IPART's 2013 report was the "Insurance" sub group of the CPI.

Productivity adjustment

Calculated by IPART in its 2012 and 2013 model to be -0.2%

We have assumed a -0.2% productivity adjustment in the 2014 Model in line with the previous 2 periods.

2013 base fare components

No reference to where the fare components to be sourced from

We understand that no increase to the 2012 base fare components were provided during 2013. As such, we have used the fare component output from IPART's 2012 model as the base fare components.

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7. Professional Qualifications

7.1. Attached as Annexure B are details of the formal qualifications and experience of the personnel undertaking the “Scope of Work”.

8. About Grant Thornton

8.1. Grant Thornton is one of the world's leading organisations of independent assurance,

tax and advisory firms. Grant Thornton Australia has more than 1,040 people working

in offices in Adelaide, Brisbane, Cairns, Melbourne, Perth and Sydney. We combine

service breadth, depth of expertise and industry insight with an approachable “client

first” mindset and a broad commercial perspective.

8.2. More than 38,500 Grant Thornton people, across over 120 countries, are focused on

making a difference to clients, colleagues and the communities in which we live and

work. Through this membership, we access global resources and methodologies that

enable us to deliver consistently high quality outcomes for owners and key executives in

our clients

9. Disclosure

9.1. Grant Thornton does not have any interest in the outcome of its agreed upon procedures the subject of this report other than normal professional fees that will be received.

9.2. This letter is for the sole purpose of assisting the TIA with its assessment of the cost of

operating a taxi in the NSW Metropolitan Transport District in 2014 (as compared to

2013) assuming the continued use of the TCI and is not to be used for any other

purpose without the prior written consent of Grant Thornton. .

9.3. Our report is solely for the purpose set forth in the Scope of Work and Limitations section of this report and is not to be used for any other purpose.

Yours faithfully GRANT THORNTON AUSTRALIA LIMITED

Paul Gooley Partner - Corporate Finance

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ANNEXURE A

2014 MODEL OUTPUTS

7

1.3

Urb

an

Taxi C

ost

Ind

ex

Co

st

ite

m2013 C

ost

2013 W

eig

ht

Infl

ato

rV

alu

eC

ost

in

cre

ase

2014 C

ost

2014 W

eig

ht

Dri

ver

co

sts

Dri

ver

lab

ou

r co

sts

66,1

49

41.2

%C

PI

2.5

%1.0

%67,6

84

40.6

%

LP

G F

ue

l18,0

15

11.2

%F

ueltra

c L

PG

cost

18.7

%2.1

%21,3

34

12.8

%

Cle

an

ing

3,4

05

2.1

%C

PI

2.5

%0.1

%3,4

84

2.1

%

To

tal

dri

ve

r co

sts

87,5

68

54.5

%5.6

%3.2

%92,5

02

55.5

%

Op

era

tor

co

sts

Op

era

tor

ad

min

istr

atio

n9,8

46

6.1

%C

PI

2.5

%0.2

%10,0

74

6.0

%

Main

tenance C

osts

8,0

10

5.0

%C

PI R

epair a

nd S

erv

icin

g0.8

%0.0

%8,0

62

4.8

%

Pla

te L

ea

se

Co

sts

25,8

36

16.1

%Tribunal decis

ion

0.0

%0.0

%25,7

85

15.5

%

Ins

ura

nce

15,4

50

9.6

%C

PI In

sura

nce

5.4

%0.5

%16,2

49

9.7

%

Ve

hic

le L

ea

se

Pa

yme

nts

6,2

13

3.9

%C

PI M

oto

r V

ehic

les

-2.2

%-0

.1%

6,0

67

3.6

%

Ne

two

rk F

ee

s7,7

98

4.9

%C

PI

2.5

%0.1

%7,9

79

4.8

%

To

tal

op

era

tor

co

sts

73,1

53

45.5

%1.5

%0.8

%74,2

16

44.5

%

Pro

du

cti

vit

y A

dju

stm

en

t-0

.2%

TO

TA

L -

AN

NU

AL

CH

AN

GE

IN T

CI

160,7

21

100.0

%3.7

%166,7

19

100.0

%

8

Urban Fares

% increase

01-Jul-14

3.7%

4.1.1 Master fare schedule - urban fares

Fare components 01-Jul-13 01-Jul-14

Flagfall $ $3.50 $3.63

Distance charge (Tariff I) $/km $2.14 $2.22

Waiting time charge $/hr $55.30 $57.35

Booking fee $ $2.40 $2.49

Night-time surcharge (on distance rate) % 20% 20%

Maxi taxi surcharge (on total fare) % 50% 50%

Waiting time threshold km/hr 26 26

4.1.2 Rounded fares - urban

Fare components 01-Jul-13 01-Jul-14

Flagfall $ $3.50 $3.60

Distance charge (Tariff I) $/km $2.14 $2.22

Waiting time charge $/hr $55.30 $57.35

Booking fee $ $2.40 $2.50

Night-time surcharge (on distance rate) % 20% 20%

Maxi taxi surcharge (on total fare) % 50% 50%

Waiting time threshold km/hr 26 26

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ANNEXURE B

QUALIFICATIONS & EXPERTISE

10