CabBerra 31

PLEASE LEAVE ME IN THE CAR FOR OTHERS TO READ.

The Official Newsletter of Aerial Capital Group LtdIssue Thirty-One June/July 2015

CANBERRA TAXI INDUSTRY:

A COMMENT ON THE HARPER REVIEW PAGE 10

Email all enquiries to

[email protected] or call 0433 398 097

29 Morrow St Dunlop ACT 2615

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Call Ashok Chhabra for an expert advice

FROM THE CHAIRMAN 2

FROM THE MD 2

FLEET Q&A 4

TRAINING ROOM 5

CONCERN FOR PUBLIC SAFETY 6

UBER AND GST 7

TAXI CAMERAS IN A DEREGULATED MARKET 9

COMMENT ON THE HARPER REVIEW 10

NEW RANK: KINGSTON FORESHORE 13

CTIA NEWS 14

EVENTS 16

DRIVER POINTS 17

AMBASSADOR DRIVERS 18

DRIVERS OUT & ABOUT 19

NEW TAXI FARES FROM JULY 2015 21

For any enquiries regarding the CabBerra magazine, please call

02 6126 1696 or email [email protected]

TABLE OFCONTENTS

ISSUE #31 JUNE/JULY 2015

AERIAL NEWS

This issue of CabBerra has a special focus and responds to the Taxi Innovation Review Discussion Paper. Aerial and CTIA have prepared and submitted detailed submissions, copies of which are available on the respective web sites.

For those interested in a greater understanding on the national competition policy issues, which have been discussed in both the above submissions, I would recommend perusals of a book recently sponsored by Senator Xenophon – Supermarket Monsters by Malcolm Knox. Of particular interest is the reference to a PhD thesis from 2012 by ex Greens Senator Dee Margetts (Review of National Competition Policy).

A point resounding in this current debate on Innovation and made strongly in the book “Supermarket Monsters”, is the impact of pricing discounts on a business’ capability to innovate. Price discounting means declining profits, which means lesser capital investment, which leads to little or no innovation and fewer jobs. The Victoria taxi market has had two taxi fare increases in the past 16 years. Little wonder there is so much concern for the taxi industry in Victoria and such an opportunity for foreign disrupters. Whose real fault is this?

Aerial’s base fee cost equates to 9% of the average taxi fare in Canberra. Aerial is investing capital and there are many examples of innovation. The TNC apps (e.g. Uber) propose taking 20% of a taxi fare, their profit, some processing these transactions offshore and not paying GST, with little effective Government control. If all these profits, leaving no taxes, go offshore how can there be long-term beneficial capital investment

I have written a letter to the Chief Minister, concerning Uber’s recently released privacy policy. We have included it in our CabBerra magazine (see page 3) because the topic is very important. There needs to be a wider understanding and debate of this issue.

Having personal credit card information, smartphone contact addresses, SMS history and other such data held off shore, taken and stored without prior approval is not what we commonly understand to be acceptable. When it is used for unsolicited marketing we call it spam and there are very strong privacy rules and social mores that are being broken.

How far can this go (Privacy, GST, Road Transport Rules, FWA industrial Relations) – What is next?

Kim Hancock

in Australia and any long-term innovation? It looks like jobs will grow in Singapore, Europe and the US and part time casual, low skilled, lowly paid, itinerant workers will be the norm in Australia. If these arguments are accurate it starts to explain why jobs and the lack of innovation are such topical issues throughout Australia. It also helps explain, as is highlighted by the CTIA submission, why the Harper review has said there is little or no productivity benefit in deregulating the taxi industry.

To me it looks like it is about time for Government to stop focusing on hindering small business by pushing the neoliberal deregulation agenda and international uncontrollable disrupters and find ways to grow Australian local capital investment. Local meaningfully skilled jobs depend on it.

Some suggestions offered on how to control a Corporation, including international ones, who are breaking the laws – • Tax legislation• Industrial Relations law• Federal Telecommunications Interception and Access Laws (Privacy)• ACMA – Australian Communication and Media Authority.• Good old fashioned solid Policing.• Chain of Responsibility legislation.

Only offered because Government appears to be indicating that they don’t know how to do their job.

Mark Bramston

FROM THE CHAIRMAN

From the MD’S desk

02 - CABBERRA THIRTY-ONE facebook.com/AerialCG

http://www.facebook.com/AerialCG

AERIAL NEWS

3rd July 2015

Andrew BarrACT Chief Minister Member for MolongloLegislative Assembly for the ACT GPO Box 1020Canberra ACT 2601

CC Hon Jeremy Hanson Hon Shane RattenburyThe Project Officer - Taxi Innovation Review

Dear Chief Minister,I write to request consideration be given to comments published in the Channel 9 Live Stream (Perth) News program of June 30 2015.

http://www.9news.com.au/national/2015/06/30/17/57/uber-slammed-over-privacy-policy-changes

This news article specifically refers to the new privacy policy adopted by Uber applicable to the Uber Ride Hailing App, which includes:

1. Tracking their location 24/7 through the Uber app, even if it’s minimised, as well as their IP address.

2. Collecting data about passengers’ journeys.

3. Accessing address books on customers’ devices as well as calls and SMS messages between drivers and users.

4. Collecting information from passengers’ social media accounts linked with Uber.

A comment published in the news article from Mr. Mark Gregory of RMIT that – “It’s a corporation trying to justify practices that are one step too far” should be very relevant to the Taxi Innovation Review. I.e There is no opt out option or right to choose privacy.

Aerial’s submission in response to the Taxi Industry Innovation Review Discussion Paper, presented by our Managing Director, Mr Mark Bramston (page 7, What role can new technology play?) emphasizes the importance of privacy associated with all data collected with taxi bookings in the ACT. Compliance with the PCI-DSS (Payment Card Industry Data Security Standards) in Australia to Australian licensed service providers is both vital and mandatory. How can this be guaranteed for data held offshore?

I do not understand the evident conflict in the ACT Government’s acceptance of Uber when the above privacy policy contradicts the ACT’s strong support of the basic human right to privacy.

Yours sincerely,

Kim Hancock

Chairman

CAPITAL GROUP LIMITED

Aerial Capital Group LtdABN 85 116 825 248

‘Ken Lambert House’ 24 Kembla St. Fyshwick ACT 2609PO Box 1233, Fyshwick ACT 2609 www.aerialcapitalgroup.com.au

Tel: +61 2 6126 1500Fax: +61 2 6126 1549

CABBERRA THIRTY-ONE - 03facebook.com/AerialCG


FLEET NEWS

FLEET Q & A

What do you think about UBER trying to enter the Canberra market place?

I think if UBER is coming into the market it would not be good for so many reasons. As an industry we need to prepare ourselves to defeat them in the same field.This would not be very hard for us because we have a very good taxi network here in Canberra which has been working here for many years. I think we are quite happy with Canberra Elite and we as operators have joined Canberra Elite because they have a good reputation with customers in Australia’s capital city.

We must remember that UBER only has an application on a phone. They don’t have manpower in Canberra and I think that without an office they will have problems in running a viable opposition to the taxi industry. The main thing is that the Canberra market has many quality customers. They are educated people in the majority and they think about the safety and standard of the taxis. I think we also have well educated drivers here as well to meet the needs of these customers and they have a great reputation.

What do you think about the ACT Chief Ministers public support of UBER before the conclusion of the taxi review?

Recently we met with Mr Shane Rattenbury the current Transport Minister. I said to him that I think people like to shop for bargains without realising the consequences of abandoning the well known brands. The ACT Government first of all needs to think about the safety of the people and consider every groups point of view before making any statements to the media or the general public. They need to bring their laws and regulations in front of the general public before they recognise UBER in the market.

How do you think the taxi industry could stop customers from wanting to use UBER?

They have made themselves very strong in the social media space. If the taxi industry wants to stop customers from going to UBER we need to use social media and advertising to sell the taxi industry. It’s important to remember that in Canberra we have 307 taxi plates and lots of people have paid nearly $300,000 for their plate. So who is thinking about how much they have paid and who is looking out for their future. We raised this matter with Shane Rattenbury as well.In your submission to the Taxi Innovation Review you mentioned that UBER being able to compete for taxi hiring’s was unfair, can you detail why?We are paying Registration costs which are the most expensive in Australia.

Through insurance, registration, plate lease fees, maintenance, inspections

Aerial Fleet Manager Jason Shields sits down to talk with Jagjit Singh from Sikh Taxi Drivers Association about the Canberra Taxi Review

and base fees it costs roughly $80,000 a year to keep a taxi on the road. We are happy to do the maintenance and the upkeep on the taxis because often we receive compliments about our vehicles but with all the expenses how are we expected to challenge UBER on price if they don’t have to meet the same requirements.

It has recently been revealed that UBER processes their credit card transactions offshore and that its privacy policy allows it to share customers credit card information with other companies.

As an Operator/Driver how do you think your customers would feel if they knew their credit card information was not secure when the fare was being processed?

I think that this one of the many reasons why countries like Canada has been so quick to ban UBER and other ride sharing applications. When you live in a country like Australia which has a history of being able to trust that your privacy is being protected you expect that your private information is secure. So if UBER does this with customers private information it would be very bad for them. If the ACT Government was to change regulations to legalise UBER what do you think it would do for the financial viability of local taxi operators?

Once again we raised this with Mr Rattenbury. We explained to him that there are 1200 families in the ACT whose well-being relies on the Canberra taxi industry. If the ACT Government approves UBER they will be taking much needed money away from local families and sending money out of both the local and Australian economies. An example is that if a UBER fare is $20.00, they will send $4.00 of this amount back overseas. This is valuable money being taken from the families of ACT taxi drivers and paid into a Multinational offshore account.

This will ultimately lead to higher unemployment locally and put financial pressure on the Federal Government to provide basic human services. We cannot forget about the financial viability of the drivers as well. As operators we want to educate our drivers about why they won’t make more money driving for UBER and how their financial viability lies in driving taxis as well.



FLEET NEWS

At a time when the Canberra taxi industry is facing a challenge from the introduction of the ride sharing apps like ‘Uber’ a solid training framework has never been so important. This app service will be opening up the door for untrained private vehicle owners to enter the

passenger transport industry.

Whilst this service is being marketed towards young adults as an alternative transport option to taxis and hire cars, it falls a long way short of the service provided by taxis (users must be 18+ years old, have access to the application and accept Ubers privacy policy). In addition the established taxi networks commitment to security and training procedures will be difficult to replicate without the dedicated equipment installed in the taxis.

So how do we ensure customers continue to use taxis as their service of choice? We must ensure our customers are satisfied with the service they are provided. Drivers must be prompt, reliable and knowledgeable of the local area.

This begins with the training provided to new drivers.Our training course revolves around three principles: Knowledge, Skills and Attitude. The knowledge of the local area including identifying major landmarks, shortest routes, rank locations, services and attractions. The skills to operate the dispatch and security equipment, to drive the taxi in a safe and professional manner and to handle unexpected situations.

TRAINING ROOMAnd lastly, the correct attitude for providing service to a wide range of customers, including our special needs community.From the day our new drivers get a PIN on our system, we hope they continue to apply these principles every time they get behind the wheel of a taxi and continue to build their knowledge.Most existing drivers have an excellent grasp of both the knowledge and skills of a taxi driver, but has their attitude remained intact?

Think about the last time you had a bad day. Was your mood affecting your driving and your interactions with your passengers? Did you find that you had more difficulties whilst interacting with your customers? Are you still familiar with the security equipment in your taxi and the procedures for handling a difficult or aggressive customers?

If not, feel free to contact the training school and we will be more than happy to arrange for a refresher. Through our nationally recognized training we want to ensure that all taxi drivers can demonstrate use of such safety equipment when required.

Remember: no matter if it is a good day or a bad day, keep smiling! Continue to provide excellent service and you will be surprised how many customers will continue to use our taxis.

Cheers,JAMES BETTS

The ACT Taxi industry was the first taxi organisation in Australia to:

• Adopt swivel seating for disabled passengers in taxis in 1976,

• Adopt stretched vehicles for wheelchair accessibility (early 1980) services,

• Adopt the first ever Australian digital dispatch system in taxis (Motorola) in 1992,

• Adopt taxi camera technology in 2002 (unassisted by Government regulation, funding or regulation),

• Adopt quarterly vehicle inspection in support of annual RTA inspection (Regulatory cost saving to Gov.),

• Adopt MTData digital dispatch in 2005,

• Adopt digital telephony automation IVR and pioneer the use of natural language automation for taxi bookings in 2006,

• Adopt the transfer of all finance transaction commissions to Taxi Operators in 2006,

• Develop and adopt Apple, Android and Blackberry booking Apps in 2010

• Adopt the first fully integrated web payment model integrated into a hire car dispatch system in June 2015. Migration to taxis is under development.

Aerial innovating since 1957

AERIAL NEWS

A Concern for Public Safety

Currently Aerial Capital Group is approached by the Australian Federal Police (AFP) on average more than 3 times per week for information. This information assists the AFP in investigating not just taxi related incidents but also incidents that occur in public places where taxis may have been in the vicinity.

As part of Aerial’s community service obligation, information is made available to the AFP 7 days a week with no attempt to reclaim costs. Aerial is called on to provide witness statements, booking details, vehicle camera footage and GPS tracking data. Aerial’s local presence in Canberra assists the AFP in moving forward with their investigations in a timely manner.

Aerial Taxi Safety Measures compared:

• Taxis are required by law to include GPS tracking of every vehicle. Only hardwired GPS tracking is admissible in a court of law. Mobile phones do provide GPS data but there can always be doubt as to whether a mobile device is actually located within a vehicle.

• Camera surveillance is provided above the door and within a taxi for both driver and passenger safety. Taxi camera footage may only be viewed by the AFP and without it a complaint about inappropriate behaviour is difficult to prove. No Cameras are available for the safety of drivers or passengers within private vehicles used by rideshare services.

• All taxi drivers are expected to complete a Health test and attain a Police Character Check. No Health tests are required by rideshare services.• Each taxi driver has a unique login in order for the taxi to operate. This provides a link between the driver and the vehicle. Camera footage confirms their identity.

• A duress alarm is located in every taxi.

• Every taxi is officially inspected on a quarterly basis to ensure regulation standards are met. How can ridesharing apps ensure that the vehicles they inspected when signing up a driver is the actual car being used? Continual checks should be required to ensure the vehicle continues to meet safety standards, and insurance and servicing requirements.

• Passenger personal details are not shared with taxi drivers. The Taxi Base maintains these and makes contact with the passenger on the driver’s behalf. Ridesharing apps provide all passenger contact details to the driver.

In a recent article in the Canberra Times, How one driver is helping rip off Uber in China (29/6/15), the validity of Uber bookings is raised, “It is well-known that Uber has the problem of false bookings.”

“Fraud accounts for less than 10 per cent of bookings in China, Uber said, “much lower” than competitors and similar to other markets in the initial

phase of service. Uber expects to manage fraud down to “sustainable levels below 0.5 per cent in short order,” according to an email response from the company”. (Canberra Times, 29/6/15)

With a population the size of China, 0.5% of bookings would still be a considerable number. How can police enforcement rely on booking data, if the data may be fraudulent and there aren’t other admissible sources of information for them to fall back on?

Based on how ridesharing services operate, how can the AFP ensure that the driver logged into the Uber app is actually providing the service? How can they look at booking details and even be sure it took place? There is no absolute way to link the GPS data to a vehicle. No Camera footage to confirm identity and events. No locally based central body to help provide witness statements.

With Ridesharing Apps it looks like a Police Officer’s job has been made harder and a potential criminal’s all the easier.

Smartphone tracking less reliable (subject to fraud) than fixed taxi GPS hardware.During an Uber trip, the location of the car is subject to the

physical location of the phone, if the phone is not in the car or the driver has turned the GPS off on that phone tracking of that job is impossible.

No Camera video surveillance in a ride-sharing car.Ridesharing jobs are completed in private cars, which have no safety mechanisms. Any complaint made by a passenger

about an inappropriate action of a driver “Assault etc” will be almost impossible to prove.

Uber insurance – will it cover all the claims?If any driver does an Uber job whether in a private car or in a Taxi the insurance for that vehicle is nonexistent because

commercial ridesharing at this time is an illegal act.This also includes third party property. In the case of an accident whether at fault or not the driver would be liable for all costs involved for the car he or she is driving and the car or property they damaged, which could in some cases equate to ten’s of thousands of dollars.



Uber Drivers To Pay All The GSTThe ATO recently announced (20th May 2015) that Uber Drivers meet the definition of a taxi service and must therefore register for GST.

Under GST law, if you carry on an enterprise and reach a turnover of $75,000 per annum you must register for GST from the first dollar that you earn. However, taxi transport has always been treated differently than other industries under the GST Act, requiring registration for GST regardless of how much is earned.

Is Uber a Taxi?

Taxi Travel is defined in the GST Act to mean “travel that involves transporting passengers, by taxi or limousine, for fares”. As ‘Taxi’ is not defined in this instance, the ATO has stated that “the word taxi takes on its broad ordinary meaning of a car made available for hire that is used to transport passengers for fares”. An Uber driver provides the same service as that provided by a conventional taxi driver and should be held to the same GST requirements.

Uber drivers must now register for GST by August 1st 2015, lodge quarterly Business Activity Statement’s (BAS) and pay 1/11th of gross fares to the ATO in addition to paying income tax on the net amount.

The Uber driver is the one supplying the service to the passenger with the transaction directly between the driver and passenger. Uber has deliberately structured itself as an overseas third party, who arranges bookings, which the Uber driver pays them a commission for. This commission is a supply by a foreign company, so the commission the Uber driver pays them is GST free. GST credits cannot be claimed.

When GST is lodged you provide GST collected minus any GST paid. This means that an Uber driver from a total fare of $110 inc gst. pays a commission of 20% on the gross fare i.e. $22. The driver collects the GST on the fare of $10. This means that the driver earned $88 on the job and paid 11.36% in GST.

Uber’s Australian head, David Rohrsheim told The Australian, that this recent ruling is unfair, “We expect our driver partners to meet their tax obligations like everyone else but they should be treated no differently to any other independently-operated micro or small businesses, and other sharing economy participants. (Red light for Uber as tax office puts ride-sharing in taxi class, 20/5/2015)

It has already been established that Uber Drivers are providing a service, which is the same as a conventional taxi driver, whether they classify themselves as ridesharing is irrelevant unless they plan to make themselves a non-commercial car-pooling/car-sharing arrangement. Uber drivers must pay GST just like Taxi Drivers. But what of Uber?

AERIAL NEWS

Uber has been in the media internationally for its tax avoidance strategies. As part of its rapid expansion into new markets, Uber has established a network of limited partnerships and holding companies around the world in what critics say is a strategy designed to dramatically minimize its taxes.

The San Francisco based online newspaper 48hills, posted the investigative article, Uber’s tax-avoidance strategy costs government millions. How’s that for “sharing?” http://www.48hills.org/2014/07/10/ubers-tax-avoidance-strategy-costs-government-millions/ (10/7/2015). The article highlights how Uber has found weaknesses in government’s regulatory or tax policies and focuses on making that a core part of their business strategy. Uber’s considerable income and ability to reduce its effective tax rate costs governments worldwide millions of dollars.

“Uber appears to have put in place the same sort of tax minimizing structure that a lot of bigger public companies have established,” said Matt Gardner of the Institute for Taxation and Economic Policy in the USA. The London Taxi Driver’s Association stated that “Uber in London, take their bookings through and issue a receipt from Uber BV (Holland) whilst maintaining that they are licensed in London and legal. In contrast, the UK taxi drivers maintain that they pay significant taxes to the city of London and the U.K. (48hills.org)It is no different here in Australia, Taxi companies must be registered for income tax, GST and meet regulation costs. This goes towards the government being able to provide infrastructure and public safety.Uber is an Australian registered company and does not pay GST on its Australian fare commissions. We all have to pay more, when large companies find ways to avoid their taxes. Thanks for sharing.

Uber Pricing - Drivers to pay the GSTAny driver should be aware that when you carry out an Uber Job you pay the full GST on that job and Uber pay no

GST. For example: From a $110 fare, Uber takes a $22 commission. The driver pays $10 GST but earnt $88.



OPERATORS

Taxi Operators Receive 0% Baillee - Bailor payment from Uber drivers.This means when a driver receives a job while driving a taxi from Uber

there is no record of that job and the payment for that job goes directly into the drivers bank account leaving the option for the driver not to disclose to the operator that he has in fact carried out that fare.

Who will pay for price discounting – the Operator or the Driver?Uber discount fares without notice at any given time. If an Uber

job is carried out in a taxi, does the Operator or the Driver bare the cost of this discount? It will most likely fall to the Operator who has never been consulted or agreed to the discount.

Ride sharing = No CashAnyone carrying out Uber fares in a taxi can never collect cash for those fares. A Credit Card is the only method of payment, which is put

directly into the drivers bank account. The Operator has to get his share out of the driver provided that the driver tells the operator he did the fare.

No PMR radio or call centre backup in a ride-sharing carIn the case of ridesharing in a private car, if the Carrier service, “Telstra,Optus etc”, is unavailable there is no backup and work

ceases.

DRIVERS

More Ride Sharing cars = More Drivers = Less jobs per car.One can assume fares taken by ridesharing private cars would previously have been taken by Taxis. This means the average amount

of fares carried out by a Taxi will drop and there will be less income for drivers and operators.

Surge pricing = drivers handle the customer backlashIn extremely busy times Uber uses surge pricing which can sometimes be 800% more than the normal fare. Not only does this not offer a

level playing field for a necessary service like transport, it also leads to aggravated complaints.

Mobile and Credit Card data is stored outside AustraliaAre you covered by Australian law? – The answer is a definite NO.Uber’s privacy policy states they can use your Mobile Phone contacts

and your sms messages for any reason, such as marketing etc and this is without your knowledge.

King Cabbie’s Tips

“Revertar ad suas securitate” This is latin for “Safety and security will return all to their families”

So far in 2015 Aerial has completed 44 taxi camera footage downloads for the ACT

Police. We have also supplied the ACT Police with GPS tracking information which has led to the capture and conviction of dangerous criminals within the ACT.

“...In a submission to the ACT’s taxi industry innovation review, CEO Rob Whelan says ICA supports “competitive neutrality” and expects taxi and ride-sharing services to be subject to the same requirements. The current CTP premium for a taxi in the ACT is more than $9500, compared with a maximum of $644 for a class-one passenger vehicle (business use)...If ride-sharing vehicles remain class-one passenger vehicles, this could lead to higher premiums across the board, creating

“significant cross-subsidy” in their favour, ICA warns.”

InsuranceNEWS.com.au, Ride-sharing Drivers Should Pay More: ICA, 6/7/2015

AERIAL NEWS

http://www.insurancenews.com.au/regulatory-government/ride-sharing-drivers-should-pay-more-ica

9 July 2015

Hon Steven JoyceMinister of Economic Development Parliament BuildingsWellington

Dear Minister

I write on behalf of Barrie White (General Manager Auckland Cooperative Taxi Society Ltd), Colin Sampson (CEO Corporate Cabs Ltd), Robert van Heiningen (CEO Alert Group) and myself (former Executive Director, NZ Taxi Federation and Life Member). We are making contact in the hope you will see fit to provide sensible advice to your more junior Cabinet colleagues whom we are concerned may be influenced by poor recommendations regarding the current Small Passenger Service Vehicle Review.

The review is being undertaken by the Ministry of Transport at the request of Associate Minister Foss. Based on comments Minister Bridges has made in the media, your two colleagues appear ready to ease the entry conditions for new smartphone app providers joining the small passenger market.

Among the options being discussed are proposals to do away with security cameras and associated duress alarms and 24/7 duress alarm monitoring systems. Although the taxi industry has provided a robust submission to all items covered by the review, it is this proposal that most deeply concerns us from a driver safety perspective.

By way of background you may recall that following the murder of Auckland taxi driver Hiren Mohini, we met with you on at least two occasions in the lead-up to your decision to make security cameras and panic alarms in taxis compulsory. We all remember your genuine concern at the vulnerability of taxi drivers working alone, and your determination to implement a package of safety measures for the benefit of both drivers and passengers. As industry leaders we were impressed by your ability to override sceptical officials and the speed with which you were able to implement these critically important safety measures.

The proof of the effectiveness of these measures is demonstrated by the fact that no taxi driver has been murdered since; that the incidents of serious assaults on taxi drivers has fallen dramatically; and that the cameras’ deterrent effect has modified aggressive/intoxicated passenger behaviour. At the same time, the New Zealand Police have been provided with a powerful evidential tool that has helped them to achieve many successful prosecutions.

Clearly it would be a retrograde step with potentially serious consequences for both drivers and passengers if new entrants into the small passenger service vehicle sector are not legally required to have these safety measures installed. We feel you passionately believed in the need for these security measures and we hope that, like us, you believe they are still absolutely necessary. In closing, we note that your ministerial responsibilities have changed and that this matter may not directly require your attention, and for that reason we appreciate we may not receive a reply. All we ask is that you use your influence and intimate knowledge of why the current legislation was introduced to guide and inform your caucus colleagues in making the right decisions to ensure the ongoing safety of drivers and their passengers.

Yours sincerely

Tim Reddish

AERIAL NEWS

(Printed within approval of the New Zealand Taxi Federation and Mr Tim Reddish)

Listening to experienceTaxi Camera Regulations are Vital Even In A Deregulated Taxi Market



Why, after 10 ACT Taxi Governmental reviews since 1985 have the ACT NOT adopted National Competition Policy (NCP) reform recommendations for the taxi industry?

Aerial’s comment: the ACT reviews found numerous community benefits in regulation and insufficient justification for the neoliberal deregulation view of NCP.

The Harper Review separates the components of a regulated taxi model, [i.e. - Community Service Obligations (CSO’s), license quantity and type limits, quality aspects and minimum service standards (MSS)] and comments on these individually from a competition perspective.

Aerial’s comment: This is overly simplistic and unmeritorious because it overlooks the behavioral imperatives of the CSO’s. By definition a CSO is an obligation accepted but unfunded and conditional upon a licensed advantage awarded to the licensee who accepts the CSO. If the advantage is removed then the CSO ceases to be serviced. For example in the USA, without regulations only the Honey Pots (high volume areas) get serviced. Outer suburbs are abandoned.

An alternative behavioral rather than dry economic assessment of taxi regulation aptly should ask “Is the CSO’s benefit to the community sufficient to justify the licensing benefits that accrue to the licensee?” The answer to this question is just the outcome that a Regulatory Impact Assessment (RIA) should provide before any changes are made to ACT taxi regulations. Aerial has written to the ACT Innovation Review recommending that this RIA be completed and published before any changes are made to the current regulated ACT taxi model.

The Harper Review continues with “most service industries face variable demand, and that businesses are able to operate without regulation limiting the number of operators”

Aerial’s comment: Again this is an oversimplified generalization that ignores both specific and unique market aspects in Canberra and the more than 30 years of experience applied to balancing real service solutions in CSO’s.

The Harper Reviews comments about licence resource rents and taxi plate values adding to fares.

Aerial’s comment: This position from the Harper Review is archaic and uninformed with respect to the ACT market. The many reforms made in the ACT, where approximately 40% of taxi plates are assets owned by the ACT Government with lease fees set by the Government and with release rules managed by Government, make these comments from the Harper Review not relevant.

Government’s taxi licences are assets; these lease fees are justifiably a benefit to the community and as such should be annually indexed to inflation.

Harper Review – Technological change … with ride-sharing apps, such as Uber, is connecting passengers with private drivers. Traditional booking methods are also being challenged by the emergence of apps such as Go-Catch and Ingogo. Aerial’s comment: The view that traditional taxi booking methods are being challenged by unlicensed app providers is correct and no objection is offered by the taxi industry to the competition other than that it is illegal. There must be competition on a level licensed playing field. By this we mean acceptance of all current CSO’s and their costs and the provision of a complete taxi service. The taxi industry offers an equal booking service technology (i.e. apps) and has accepted this challenge. Every major taxi service provider in Australia (in Canberra since 2010) and in NZ offers app booking technologies. Why should these new one-mode opportunists get a free ride?

Aerial unequivocally refutes Uber’s stated view that it does not offer a taxi service. Uber, Go-Catch, Ingogo and all the rest offer e-hailing services that are TAXI SERVICES. Uber does not offer a job to a car unless it is within 5 minutes travel of the pickup point. Where is the CSO that requires the customers that are beyond 5 minutes travel to be picked up on time? How does Uber manage lost property, privacy, driver-safety, reporting of data, etc?

ARE SOCIAL COSTS TO BE THE OUTCOME OF THE REVIEW? A COMMENT ON THE HARPER REVIEW OF TAXI REGULATION

(COMPETITION POLICY REVIEW FINAL REPORT MARCH 2015 SECTION 10.2)

AERIAL’S POINT OF VIEW



The Harper Review further comments that “The regulatory framework for taxi regulation could be enhanced considerably through independent regulators having the power to make determinations (rather than recommendations), including on the number and type of taxi licences to be issued”.

Aerial’s comment: The CTIA has at considerable cost obtained advice from Professor Nicholls ANU College of Business and Economics, to prepare a model, based on the 2010 ACT Taxi review, to use market mechanisms to release more taxi leased plates. The model meets the Harper Reviews recommendation of enhancing regulations and making determinations. All that is needed is a will to act and use this advice. It has the support of the ACT taxi industry.

Harper Review - Mobile technologies are emerging that competes with traditional taxi booking services and support the emergence of innovative passenger transport services. Any regulation of such services should be consumer-focused, flexible enough to accommodate technical solutions to the problem being regulated and not inhibit innovation or protect existing business models.

Aerial’s comment: We disagree with the view that such regulations for apps need to be considered differently to current technologies used within existing business models. App technologies are already in use within the taxi industry. These so called new app technologies do not offer anything new and as such are unworthy of any special treatment that creates an unleveled playing field. We find the Harper Review’s recommendation to favour a technology preferentially as being overly simplistic and void of customer impact and real market feedback.

AERIAL’S POINT OF VIEW

The Harper Review comment, “Further regulatory review of the industry is necessary to take account of the impact of new technologies”

Aerial’s comment: Unnecessary in the ACT as there is no justification for the review. No lack of competition, no lack of service, few customer complaints, no lack of adoption for new technologies, no community safety impacts and no lack of cooperation between the industry and the regulator. Further reform in the ACT must be justified, as the review process is a cost that neither Government nor the industry can afford in the current market.

Harper Review comment “Although taxi reform is not expected to make a major contribution to national productivity, the sector is an important component of metropolitan transport and can be particularly important for the mobility of the elderly and those with a disability. More affordable and convenient taxi services give consumers options. Significantly, reduced barriers to entry could see more services operate at peak times, without needing to operate at off-peak times.

Aerial’s comment: A taxi industry is a vital part of public passenger transport so much so that every major city in the world has and needs this service. The ACT has an affordable service that gives consumers more options, many more than those offered by the app providers. Submissions made by Aerial and the CTIA rule out the “could” in the last sentence, in context to the ACT market. The “could” cannot because in this small and highly variable Canberra market it will destroy small taxi business viability and services will decline.

Cont’d



AERIAL’S POINT OF VIEW | A COMMENT ON THE HARPER REVIEW OF TAXI REGULATION

Why does the CSO exist?

Aerial’s comment: It exists for the Community because it is expected and needed. The CSO protects the people least able to fund the market’s ability to preference the wealthy (surge pricing, premium service model). This community need makes the CSO relevant in the sharing economy.The Taxi Industry CSO in Canberra has evolved over 30 plus years, to serve ALL Canberrans.

The CSO puts the obligation of safe service on a license holder. Remove the license and the obligation and then what will the market yield? A race to the bottom, profit overcomes equality? Who benefits most? Not those who most need the CSO.

The ACT Taxi Industry, after 10 Government taxi reviews, is justifiably and willingly the custodian of this CSO. How can there be a valid argument made to remove the CSO or allow any new entrant to avoid these obligations? The regulatory rewards offered in return for the CSO are needed and accepted by an ACT Community majority. Clearly the Harper Review has not made an evidence based argument justifying a decision on the part of the ACT Government to change current ACT Taxi Regulations.

Concluding the Harper Review Panel recommended – “Further regulatory review of the industry is necessary to take account of the impact of new technologies”. But the Harper Review Panel validly makes the point “that the panel’s primary concern is to ensure that the regulations respond to changes in technology in a way that allows new entrants to meet consumer demand, while continuing to ensure the health and safety of consumers”.

Aerial’s comment: It is no surprise that Aerial and the Canberra Taxi Industry rejects the Harper Review Panel’s recommendation for further regulatory reform in the ACT. This recommendation is a generalization not applicable to the ACT market.

The new app technologies already exist in the Canberra market and any move to give new technologies offered by international or local free-riders unrestricted entry, such as removing the CSO and licensing, will only lead to real community harm, poorer service, less protection of privacy, price gouging, insurance and tax scams and exploitation of workers. The Harper Review panel clearly and justly makes the point that the heath and safety of consumers is important. Yet it makes recommendations that will have an opposite impact in the ACT. Aerial agrees that health and safety of consumers is vitally important and willing accepts the CSO. Competition demands that these CSO’s be borne and met by ALL..

In summary Aerial’s view is that the Harper Review offers no justification for change to current regulation governing the taxi industry in Canberra. We make the point, above, that the only question worth asking and answering, via RIA, is that relating to the CSO.

The CSO placed on Taxis in Canberra is the only thing that protects services in off-peak periods. Aerial holds the following activities to be CSO’s:

• Provide a reliable, safe, and (regulated) reasonably priced taxi service to the whole Canberra market (city, suburbs and airport), 7 days per week, 24 hours per days and every day of the year,

• Equally service booking and hail work,

• Accept ALL taxi jobs without preference subject to safety issues (e.g. alcohol consumption),

• Take bookings from ALL customers using ALL media (phone, web, apps etc.) forms,

• Accept ALL forms of payment including CASH,

• Privacy (personal and credit card) is part of the service not just a legal requirement,

• Offer an equal and nondiscriminatory service to everyone,

• To charge no more that the Government regulated fare at any time, regardless of market demand,

• Return Lost Property, promptly as part of the service,

• Respond to all complaints and prove this to the regulator,

• Regularly report independently audited performance statistics to Government.

CAPITAL GROUP LIMITED



INTRODUCING The Kingston Forshore

Taxi Rank

A taxi rank for 2 vehicles is now located on Eastlake Parade at the Kingston Foreshore.The rank is within view of the Walt & Burley and not far from other popular restaurants and bars.

AERIAL NEWS: NEW TAXI RANK

Imagery ©2015 Aerometrex, CNES/Astrium, DigitalGlobe, Map data ©2015 Google.



CANBERRA TAXI INDUSTRY ASSOCIATION

CTIA NEWSThe ACT Taxi Innovation Review. What is it about?

The current ACT taxi review, announced 28th January this year, is not about innovation in the taxi industry, but about how to get the industry to agree to destroy itself. The plan is not to argue about whether or not the American based, facilitator of illegal taxi services, Uber, should be allowed to operate in Canberra to compete with taxis, but to negotiate with the taxi industry to establish a ‘level playing field’ so that UberX can compete ‘fairly’ with the taxi industry. Allowing Uber into the ACT would open the door for other such services.

The level playing field is to be brought about, not by insisting that Uber complies with the same regulations with which taxis comply, but by expecting the taxi industry to accept a new definition of booked taxi work. (They say) It is really hire car work.

Senior government people have been seduced by Uber into thinking that they (Uber) have a brand new way to move people: a five minute service, with fares cheaper than taxi fares, and as they do not do rank and hail work, they are really a form of hire car, that taxis need competition, and that they (Uber) can provide choice and value. The fact is, Uber does do hail work, electronic hail work. It is all hail work. Instead of seeing a taxi on the street and signaling it to stop beside him/her, the passenger summons’ the driver to the pick-up point via an app. Uber has five minute pick-ups because it does not accept trips outside the five minute radius. Uber has fooled these people into believing that this “brand new model” is part of the “sharing economy” which has gained favour in many places because of cheaper rates for such services as accommodation, car parking and equipment hire.

The “sharing” economy is causing hardship for many legitimate businesses because its participants manage to avoid regulatory costs common to business. Their defence is that they are using excess capacity.Uber is not using excess capacity. It is using no more excess capacity than the driver of a private car who pulls onto a taxi rank and picks up fares.Uber has acknowledged it is running a political campaign, and typical of political campaigns uses half-truths and an exaggeration to promote its campaign. The aim is to throw mud at the taxi industry and promote itself as a white knight. Besides the first deception of calling itself a ‘rideshare’ company, Uber claimed earlier this year it was going to create twenty thousand new jobs in Australia (not mentioning the twenty thousand taxi driving jobs it would destroy and the harm it would cause to twenty thousand families). Uber claims its accident insurance policies adequately cover Uber drivers. The facts say otherwise. In April, in the US, Uber was fighting over thirty court cases in various disputes. On 2 July (Canberra Times), it clamed it could be an important link in the Canberra light rail network. So would taxis. Uber claims that only 30-40% of taxi hirings are booked work. This is another deception. In Canberra, booked hirings are more than 50%.Uber claims to give people choice. What choice? There is no choice in

booking methods. A potential user may use only an app to hail a car. Taxis networks provide at least five methods of booking a taxi. Uber gives Wheelchair users no choice. They are not into community obligations but they are into skimming at least 20% from their drivers’ takings and sending it back to America through an as yet unknown taxation structure. Uber has objected to the ATO’s ruling that Uber drivers must register for an ABN and pay GST on the fares they collect and has threatened to challenge the ruling.

Uber also claims to be cheaper. The same newspaper article said UberX fares were “typically costing 30-50% less than a standard taxi fare”. This is a serious distortion. Uber sometimes promises Uber X drivers a minimum rate of pay and reduces fares just to get drivers to start and to get a toehold in the taxi market (if Coles or Woolies did the same, the ACCC would fine them millions). What the drivers actually receive has been a source of dispute in many cases. The newspaper item did not mention Uber’s surge pricing. During busy periods, Uber charges automatically rise by up to anything between 325% and 825%.

Before commencing in Canberra, Uber has agreed to hold off until after the review. Who thinks this is out of courtesy to the ACT Government? Uber has shown no respect for any governments anywhere, anytime. The reason it is holding off is because it hopes to gain some concessions from the ACT Government that it might be able to use as leverage in other jurisdictions. If it does not get what it wants from the review, it will start on its own terms anyway. If it does get some concessions, it will only demand more.

What is the ACT taxi industry doing?

The CTIA and Aerial have made submissions to the inquiry, and its outlook is presented below. Taxi regulations have evolved over the years with the main emphasis on safety for clients and drivers, adequate training and adequate vehicle standards and compliance to the Disability Discrimination Act.The CTIA believes that regardless of any creative re-defining of realities, any new entrants to the taxi world should comply with the same regulations as those in the taxi industry.

The Government’s desire to provide a level playing field will be an interesting exercise.

The CTIA has been assured that Uber drivers will be required to demonstrate a satisfactory level of competence to carry fee paying passengers. The establishment of any level of competence will need to be measured against regulatory standards. Like the GST, Uber will not be happy with this. Uber claims its drivers might only drive 20 hours per week, so they should not need to go through the same training process as taxi drivers. Some taxi drivers are restricted by visa conditions to work only twenty hours per week. They still need to do the full training. UberX drivers should do the full taxi driver training program.



Uber X drivers undergo a ‘mickey mouse’ police check, which has proved to be inadequate. They should undergo the same police check as taxi drivers.Uber claims its UberX drivers carry adequate insurance, but the Insurance Council of Australia has issued a warning to UberX drivers and potential passengers that they may suffer heavy losses in the event of an accident. Any level playing field adjustment imposed on UberX drivers will put pressure on Uber to raise it fares. For the purpose of insurances Uber driver/operators should be catergorised at the same level as taxi operators.

UberX cars in other states may be up to nine years old and may never have been through an inspection station. Taxis doing the same work are inspected annually.

UberX vehicles should be subject to annual roadworthiness checks and random checks by roving inspectors. They should also be clearly identifiable.

Uber claims its fares are lower than taxi fares, but surge pricing is only mentioned when a passenger reacts to an unexpected shock. Surge pricing cross-subsidises its off-peak rates to the disadvantage of unsuspecting customers and taxi drivers. UberX cars should be subject to capped maximum prices.

Because the outcome of the review is so important the CTIA has involved Mr Blair Davies, CEO of the Australian Taxi Industry Association in its negotiations with the Government and will continue to do so. Mr Davies has a vast knowledge of the taxi industry in Australia and overseas, and also of

the workings of Uber.

The review team has told the CTIA that debating the pros and cons of Uber with them is a waste of breath as they have been told to simply build the level playing field, so the CTIA will continue to insist that the points above and others must be part of the package.

Operators, Drivers and Owners, what else needs to be done?Uber has acknowledged their campaign is a political one and so the taxi industry needs to engage in the political fight too.The CTIA and Aerial have or soon will have approached members of the Legislative Assembly, pointing out the damage that could be done to public transport in Canberra if Uber is not resisted.Aerial and the CTIA might produce very good arguments to the politicians, but we are only a few people. We have one thousand drivers, operators and owners; and to have an impact in a political fight, numbers beat logic any time. We urge all taxi drivers, operators and owners to become involved. The Aerial and CTIA submissions are on their respective websites and are there to be used by our colleagues. Your involvement is critical.

The taxi industry is in the greatest fight of its life, so we need make our politicians aware of the risks to effective public transport if Uber and the like get a toehold in our industry.

BY JOHN MCKEOUGH

CANBERRA TAXI INDUSTRY ASSOCIATION



EVENTS


Ink Remix: Contemporary art from mainland China, Taiwan and Hong Kong 01/07/2015 to 18/07/2015 Canberra Museum and Gallery

Reality in flames: modern Australian art and the Second World War 03/07/2015 to 06/07/2015 Australian War Memorial

School Holidays at the Australian War Memorial: Discovery Zone 03/07/2015 to 19/07/2015 Australian War Memorial

Yangupala Tjuta Waakarinyi: Ceramics from Ernabella Australia 04/07/2015 to 12/07/2015 Australian National Botanic Gardens Visitor Centre Gallery

Rockabilly by Day, Swing by Night 04/07/2015 Albert Hall

Protean 04/07/2015 to 19/07/2015 Nishi Gallery

Walking and falling 04/07/2015 to 12/07/2015 National Portrait Gallery

Australian Animation 06/07/2015 to 17/07/2015 National Film and Sound Archive of Australia

Stepping Up: The Australian Ceramics Triennale 2015 08/07/2015 to 12/07/2015 CraftACT

Story Time 08/07/2015 to 15/07/2015 National Portrait Gallery

Lore 09/07/2015 to 11/07/2015 Canberra Theatre Centre

Canberra Raiders vs Newcastle Knights 10/07/2015 GIO Stadium Canberra

NAIDOC Week: Curator talk 10/07/2015 Australian War Memorial

World Curry Festival in the City 11/07/2015 to 12/07/2015 City Walk

Old Bus Depot Markets - Creative Fibre 12/07/2015 Old Bus Depot Markets

Wicked Winter Drama Holiday Workshop!y | Second Contact 13/07/2015 to 17/07/2015 C Block Theatre

ANU School of Art Photography Workshop 14/07/2015 ANU School of Art

Escape and Australian Prisoners in Germany, 1916–18 15/07/2015 Australian War Memorial

Flying Fruit Circus - Circus under my bed 16/07/2015 to 18/07/2015 Canberra Theatre

"A most miserable hotchpotch": Charles Bean and the First World War film collection 16/07/2015 Australian War Memorial

Distortion 16/07/2015 National Portrait Gallery

Damien Leith: The Parting Glass - An Irish Journey 18/07/2015 The Street Theatre

Canberra Raiders vs Cronulla Sharks 18/07/2015 GIO Stadium Canberra

Task Force 72 scale model ship display 18/07/2015 to 19/07/2015 Australian War Memorial

A Pooch Affair 18/07/2015 Exhibition Park in Canberra

Three Sixty Fashion Market - Winter 19/07/2015 Fitters Workshop

In The Spotlight 19/07/2015 National Portrait Gallery

Dylan Thomas: Return Journey 21/07/2015 to 25/07/2015 The Street Theatre

Stripey - The Eggscellent Adventures of an Emu Chick 23/07/2015 to 25/07/2015 Canberra Theatre

A literary portrait 23/07/2015 National Portrait Gallery

Behind-the-scenes art tour: Girl operatives: women's war work 23/07/2015 Australian War Memorial

Mt Stromlo Observatory July Public Night 24/07/2015 Mt. Stromlo Observatory

We May Never Meet Again 24/07/2015 The Street Theatre

GIANTS vs Geelong 25/07/2015 StarTrack Oval

Brazilian 'Festa Julina' 25/07/2015 Embassy of Brazil

Reckless Valour: contemporary dance by Quantum Leap 29/07/2015 to 01/08/2015 Canberra Playhouse

Two Wheels to the Front Line: Australian Corps Cycling Battalions 30/07/2015 Australian War Memorial

JULY 2015


DRIVER POINTS SYSTEM

AERIAL DRIVER POINTS

ERNEST JOHN BERRY

RIPPAN THAKUR

PETER STAVROPOULOS

MIRCO MATEVSKI

CHANH NGOC HA

HARWINDER SINGH

KHURRAM SHAHZAD

RANJEET SINGH

HUU QUANG LY

SAMUEL GRAHAM

ABDUL BASIT

JAI SINGH

How to earn points?Pickup within 6 minutes = 1 Point | Reject a Job = Minus 1 Point | Recall a Job = Minus 1 Point



AMBASSADOR DRIVERS

MALIK SHAHZADA customer called to thank you for your professionalism and assistance through what had been a trying week for him. You let him use your phone when his phone was broken and he really appreciated the gesture.

HARWINDER SINGHI would like to thank the taxi driver driving at roughly 3:30am on the 27th of May. I had lost my key card and he drove me back to the address he originally picked me up from with the most helpful and positive attitude. He even double checked that I hadn’t dropped my card in the cab. Clearly I had been drinking and he did everything to make sure I felt safe. He offered to drive me back to my address but I knew I couldn’t pay for it so I politely refused. He’s one of the kindest taxi drivers I have encountered and I hope this email makes him realise people like him are the reason I am comfortable catching a taxi alone.

GRAHAME O’NEILOne of your customers called to say thank you. She was not having a good day and had to go to the Canberra Eye Hospital, and you could tell that she was having trouble with her eyes/sight. You assisted her from the car and walked her into the building. She was very touched by your concern kindness. Well done Grahame.

KHOA DINH QUACHAerial would like to say well done. As a new taxi driver, many staff within the network have noticed your positive attitude and professionalism towards taxi driving.

WELL DONE! AMBASSADOR DRIVERS



PAUL SUTHERLAND

HARPREET KAHLON

MAZHAR IHTISHAM BAQIRRANJIT SINGH CHAHAL RAJESH KUMAR MALHI

RAMANDEEP SINGH & MANISH GUPTA

GURJEET SINGH & GURVINDER SINGH

july out & about

OUT AND ABOUT | FLEET INSPECTIONS



OUT AND ABOUT | FLEET INSPECTIONS

TAKAYA

RIPPAN THAKUR

ARSHDEEP SINGH GILL

HARMEET SINGH GILL SUKHJINDER SINGH

SHIVRAJDEEP SANDHUAND, SUMEET SINGH & BALWINDER SINGH

GURJIT SINGH

MALKIAT



Authorised by the ACT Parliamentary Counsel—also accessible at www.legislation.act.gov.au

Road Transport (Public Passenger Services) Maximum Fares for Taxi Services Determination 2015 (No 1)

Schedule

Section of the Road Transport (Public Passenger Services) Act 2001

Fare Rate

Description of matter in respect of which fare is payable

Maximum fare

payable ($)

Section 60 (1) Radio Bookings $0.00

Booking Fee for Canberra Silver Service Taxis (operated by Aerial Capital Group Limited)

$13.80

1

2

Standard Taxi (single hiring) Flagfall

Kilometre Rate

- For a journey commencing between 6 am and 9 pm on a day other than a Saturday, Sunday or public holiday

- For a journey commencing before 6 am or after 9 pm Monday to Friday and all day on a Saturday, Sunday or public holiday

$5.00

$2.06

$2.37

3

4

Standard Taxi – (multiple hiring) Flagfall

Kilometre Rate

- For a journey commencing between 6 am and 9 pm on a day other than a Saturday, Sunday or public holiday

- For a journey commencing before 6 am or after 9 pm Monday to Friday and all day on a Saturday, Sunday or public holiday

$3.75

$1.55

$1.78

5

High Occupancy Taxi (5, 6 or 7 passengers) $7.50 Flagfall

Kilometre Rate

- For a journey commencing between 6 am and 9 pm on a $3.09 day other than a Saturday, Sunday or public holiday

6 - For a journey commencing before 6 am or after 9 pm Monday to Friday and all day on a Saturday, Sunday or $3.55

public holiday

7

High Occupancy Taxi (8 or more passengers) $7.50 Flagfall

Kilometre Rate

- For a journey commencing between 6 am and 9 pm on a $3.91 day other than a Saturday, Sunday or public holiday

8 - For a journey commencing before 6 am or after 9 pm Monday to Friday and all day on a Saturday, Sunday or $4.50

public holiday

ROAD TRANSPORT (PUBLIC PASSENGER SERVICES) MAXIMUM FARES FOR TAXI SERVICES DETERMINATION 2015 (NO1)

NEW TAXI FARES | JULY 2015

“It’s not realwithout the seal”

An Australian Taxi Industry Association initiative.

www.grabacab.net.au

Protect the future of our industry and fight back against illegal

ride-sharing! Join the ‘Grab a Cab!’ campaign and display the

seal of approval on your cab to inform your passengers that

their journey will be safe and in accordance with all government

regulations.

Documents

CabBerra 31