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Taxi Talk magazine October 2016

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TAXI VOICE OF THE TAXI INDUSTRY Australia’s premier independent taxi industry magazine celebra TALK October 2016 ISSUE NO 580 VOICE OF THE TAXI INDUSTRY TAXI MAGAZINE ON THE RANKS SINCE 1966 PROUDLY PUBLISHED AND PRINTED IN MELBOURNE Print Post Approved number 100004912 ting YEARS THE VOICE OF THE VICTORIAN TAXI INDUSTRY MELBOURNE FESTIVAL 6-23 October 2016 - in and around Melbourne From contemporary dance on ice, to fireworks, percussion and CBD street takeovers, to some of the world’s greatest theatre makers locally and internationally, the Melbourne Festival program presents an irresistible assortment of familiar and unknown, local and far-flung, large-scale and intimate productions.

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TALK TO US FOR Quick and Easy SOLUTIONS FOR YOUR Accident Cover Needs PROVIDING COVER TO THE TAXI & LIMOUSINE INDUSTRY SINCE 1998 CALL TODAY FOR AN OBLIGATION FREE QUOTE 6 | September 2016 VICTORIA TAXI CLUB 128 Errol Street, North Melbourne tel 9326 3808 | fax 9326 4808 | email vTaixci .Ttaalkx- iV@oicbe iogf tpheoTanxidIn.dcuostmry YEARS

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Contents 6 PROBLEMS & SOLUTIONS Simples problems requiring complex solutions. 20 14 INDUSTRY CHANGE VHCA is disappointed with derisory payment offer. 22 VOICE OF THE TAXI INDUSTRY TAXI MAGAZINE ON THE RANKS SINCE 1966 MAGAZINE EDITOR Toni F. Peters FOUNDER Stanley F. White PUBLISHER Trade Promotions Pty Ltd ADVERTISING ENQUIRIES Mrs Toni Peters Trade Promotions Pty Ltd PO Box 2345, Mt Waverley VIC 3149 Phone: ....................................... 0400 137 866 Email: ............................. info@taxitalk.com.au Website: .......................... www.taxitalk.com.au RESTRAIN ANIMALS Travelling animals should be restrained. 24 FROM VIC TAXI & HIRE CAR FAMILIES A look at what’s been happening this month within the industry. HAVE YOUR SAY Our readers’ opinions, thoughts and comments. 30 RULES & REGULATIONS An update on rules and regulations affecting the Victorian taxi industry. Views expressed in any article in Taxi Talk magazine are those of the individual contributor and not necessarily those of the publisher. The publisher cannot accept any responsibility for any opinions, information, errors or omissions in this publication. To the extent permitted by law, the publisher will not be liable for any damages including special, exemplary, punitive or consequential damages (including but not limited to economic loss or loss of profit or revenue or loss of opportunity) or indirect loss or damage of any kind arising from the contract, tort or otherwise, even if advised of the possibility of such loss of profits or damage. Advertisements must comply with the relevant provisions of the Competition and Consumer Act 2010. Responsibility for compliance with the Act rests with the person, company or advertising agency submitting the advertisement. Taxi Talk magazine has agreed to advertise taxi clubs because those clubs have stated that they and their products comply with all applicable laws and regulations relating to insurance for taxi operators. Taxi Talk magazine has not independently verified these taxi clubs’ compliance, and give no warranty and make no representation as to whether the taxi clubs are compliant. Operators should satisfy themselves as to a taxi club’s compliance with laws and regulations through their own enquiries. These advertisements do not constitute recommendations by Taxi Talk magazine that operators purchase insurance products from taxi clubs. Taxi Talk magazine does not accept any liability or responsibility for any loss or damage suffered or incurred by any operator because a taxi club or its product or service is non-compliant. Taxi Talk magazine is wholly owned by Trade Promotions Pty Ltd. COPYRIGHT © Trade Promotions Pty Ltd 2015. All rights reserved. The “Taxi Talk – Voice of the taxi industry” heading and logos are trademarks of Stanley F. White. Copyright of articles and photographs of Taxi Talk magazine remain with the individual contributors and may not be reproduced without permission. DISPLAY ADS All copy, editorial and artwork must be submitted by the 15th of the month prior to publication date. Advertisement sizes and costs can be downloaded at www.taxitalk.com.au. CLASSIFIED ADS $35 for 40 words, $70 for 80 words, etc. Email or Mail your classified advertisement by the 15th of the month prior to publication date, together with your payment. SUBSCRIPTION DETAILS 1 year = $40 PAYMENT OPTIONS • Via PAYPAL to info@taxitalk.com.au • Direct Deposit to Trade Promotions Pty Ltd BSB 033065 A/c 312786 • Mail Cheque to Trade Promotions Pty Ltd PO Box 2345, Mt Waverley VIC 3149 proudly supporting these organisations since inception..... October 2016 | 3

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editFoROrM’TsHE desk What was the Taxi Services Commission (TSC) thinking last month when they advertised on their website that annual WAT licences are available for only $538.40? Really! The TSC couldn’t possibly expect a WAT vehicle to drop down in price to nothing overnight - could they? It was pleasing to learn that due to consistent lobbying from the VTHF and the VTA to revisit this decision, the Victorian government has back tracked on this decision. At this stage, there will be no shortterm changes to WAT licensing. But you all have to be very vigilant. If you see something, hear something, check it out. And if it doesn’t seem right - let us know and we will pass it on to the right people. I wonder if the Victorian government actually realises that they are violating the human rights of those who own Victorian Taxi Plate Licences by their unconscionable conduct in the deregulation of the taxi industry. Perhaps they don’t really care who they hurt, what businesses go bankrupt or which people lose all their livelihood, by the government’s actions. They state that a perpetual metro licence will be bought back by the Victorian government for $100,000. But the meaning of perpetual is everlasting, never-ending, eternal, permanent, unending, endless, without end, lasting, constant, etc. So, why are they offering to buy back the licence at all? The licence was sold to business people, investors, the average guy trying to make a living, as an perpetual investment. The licence should still have a value - reflective of the investment people have made to their business - their taxi business. I do hope you all realise that the $2 per ride levy is being placed on the Network Service Provider who can, if they chose, pass this cost on to the taxi driver. But how is it going to be collected? Who is going to monitor this? Don’t think the government has fully thought this one through. Now, why can’t the Victorian government spend some of the funds they have recently gained from the lease of Melbourne Ports, on the taxi industry? That would be quite sensible. Sell one part of our transportation infrastructure and put the funds towards another transportation sector. 4 | October 2016 YEARS Taxi Talk - Voice of the Taxi Industry

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VOICE OF THE TAXI INDUSTRY TAXI MAGAZINE ON THE RANKS SINCE 1966 proudly published and printed in Melbourne Michael Gunner, the newly elected Chief Minister of the Northern Territory, is creating a working group consisting of the NT Taxi Council, Uber, disability groups and other interested parties. This group will advise the government on the framework for ride-sharing laws in NT and hope to make a level-playing field for all NT point-to-point transport. Good luck! From 1 November taxi drivers will be out-of-pocket 88 cents when picking up passengers from Melbourne Airport, via the Holding Bay, as Melbourne Airport Corporation (MAC) is increasing their fees to the driver from $2.70 to $3.58. MAC claim that the recent passenger growth has increased the demand for taxis by 5% and therefore this has required them to put a significant investment into ensuring that service levels don’t decrease. MAC submitted a request to the Essential Services Commission in June 2016 seeking permission for the taxi drivers to fully pass on this cost to their passengers - but this has not been granted. So, at this stage, the drivers are only allowed to charge passengers a collection fee of $2.70 instead of $3.58. In Quebec, Canada, UberX has been given the go ahead by government to operate ‘legally’ for 12 months. There will be 300 new permits issued to UberX. The government has applied certain restrictions to these new permits (see page 45 in this issue). But, what they have failed to do is offer any compensation to the current taxi permit holders. The only ones winning out of this deal is the government (they’re going to receive more revenue) and UberX (whose service is now legal). No wonder the Quebec taxi drivers are regularly striking at present! Over in New York City they have recently dropped the compulsory English test for Yellow Cab drivers, primarily because Uber doesn’t require proficiency in English, therefore neither should the taxis. So watch out if you are catching a taxi over there. You had better make sure you have a good translation app on your phone. It’s been reported that Uber and TripGo (an app that allows users to synchronise tram, train or bus trips with Uber rides) are joining forces. This will enable prospective customers to order an Uber vehicle to meet them at their appropriate tram, train or bus stop. Now this is just going to further take away work from the taxis. Many taxi ranks are positioned at public transport hubs (eg major train and bus stations). Wake up taxi companies, Network Service Providers and taxi apps providers! You need to get your skates on if you wish to be an effective competitor in the race to be the best point-to-point small motor vehicle public transport provider in Victoria. Toni Peters Editor TT Advertise in TAXI TALK DO YOU HAVE... • something to sell? • a service to offer? • a new product? Voice of the Victorian Taxi Industry Contact Toni Peters on M 0400 137 866 | E tonipeters@taxitalk.com.au Taxi Talk - Voice of the Taxi Industry YEARS October 2016 | 5

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Simple problems complex solutions Uber an American high tech company operates in Australia in the point to point transport industry by making its own rules and regulations. The Company ignores both our laws and regulations. 6 | October 2016 The Uber business model is brilliant, when you are able to ignore the laws of the country or if you are able to get the laws changed by the use of money, advertising and an army of lawyers. Uber uses the cars of private citizens and takes about 25% of the fare (at the moment) for arranging the trip via a smartphone app. Uber avoids vehicle costs, maintenance expenses, insurance and all other associated running expenses. But one of the worst actions is the misclassification of its workforce. No Australian company would be allowed to classify its workforce as contractors when they engage its workers under the same rules and conditions as Uber does. So, it is not only State law that Uber treats with disdain but also Federal Law. The business model of Uber is so flawed, that Uber would find it impossible to operate profitably if it had to comply with Australian laws and regulations. So Uber simply states that our laws are wrong. They claim that our laws and regulations do not apply to them because they provide a totally new service and should be allowed to do whatever they want and our laws and regulations should be changed to accommodate them. Our Governments would laugh at most companies that would be so arrogant to propose something like this, but not in the case of Uber. Uber has money and influence all over the world. If one looks at the people and organisations that back Uber, we talk about the two percent of this world that want to make the rest of this world their slaves. YEARS Taxi Talk - Voice of the Taxi Industry

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Our Government and many people in the media claim that Uber is here to stay and that we have to accommodate them. I have no problem with Uber doing business in Australia and providing a service to the Australian consumer. But I do have a problem with the fact that our Government throws its own regulations and laws out of the window in order to favour an American bully over its own hard working citizens. Are our politicians so ignorant or unobservant that they do not see that Uber fights court cases all over the world for ignoring laws and misclassification of their workforce? Are they ignorant of the fact that the major European countries have banned Uber X from operating? Why does our Victorian Government destroy an industry that obeyed and complied with the law? Why and for what are those Victorians, who provided a service to the Public under the regulation and laws of the Government, being punished? The Government and many in the media claim that our Taxi Service needed to be reformed in the interest of the public. Yet they did not, and still do not, know that many of the reasons for reform were introduced by Government and big business over the last one and a half decades. Most do not know that the Victorian Taxi Industry is made up of thousands of small businesses that obeyed the Victorian law and are now punished, by not only taking their businesses away from them, but also their hard earned assets. Our present Government wants to compensate the taxi industry for allowing Uber to disrupt and destroy our industry unlawfully. They want to compensate people on a discriminatory basis. During all my years in the Taxi Industry (over 40) the value of a Taxi Licence in the Metropolitan area of Melbourne was always comparable with the price of an average Australian home. This valuation had its ups and downs that did not always correlate perfectly in time, but was a good approximation. In the early 1970s the Victorian Government allowed banks to put a lien on a Taxi Licence and use it as security on a loan. In about 2002 the Government issued the so-called Peak Service Licences for a yearly lease fee and only a few years ago the Government sold the use of Licences for ten years for an upfront fee of $180,000 and others for a yearly fee of over $30,000. This clearly shows that progressive Governments did acknowledge that Taxi Licences had an intrinsic value. If we look at a valuation using $32,000 per year we come to a valuation in excess of $320,000. Looking at the economic value of an $180,000 up-front payment the valuation would be in excess of $360,000 and by using the average house price as a comparison we find a valuation in excess of $450,000. So it becomes quite clear that the Government is willing to hand the assets of hard working Australians to big business but not willing to compensate at an appropriate level. Mr Andrews finds it acceptable to compensate big business at the rate of over $1 billion for not building the East West Link but he wants to compensate the Taxi Industry with a pittance. Mr Premier Daniel Andrews, if you feel you have to deregulate the Taxi Industry then at least compensate all Taxi Licence Holders appropriately and remember what Mr Nardella (member for Melton) said when your Government was in opposition. “How dare those opposite call themselves liberals! How dare these people come into this house and say they are representing small business when they are destroying families, destroying wealth, destroying the businesses that these small businesses, these families, have built up over a generation!” “How dare they come in here with the view that they are representing the philosophy of Robert Menzies in this house, when Robert Menzies was a member of this Parliament those many decades ago.” And he concluded, “these people are frauds. They are defrauding small business people and families who have built up their businesses over many decades of hard work.” Hans Altoff Taxi Owner / Operator TT Taxi Talk - Voice of the Taxi Industry YEARS October 2016 | 7

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Compensation for goodwill The announcement by the government seems to have not been thought through. What the government should be thinking is that they are going against all principles of business. Every single person who has bought licences or the business (which includes goodwill and licences) have bought it with an approval from the Taxi Services Commission (TSC) (formally Victorian Taxi Directorate, VTD). The buyer of licences had to declare at all times to the VTD/TSC the cost of each licence. Up until 2012 when Prof Alan Fels’ study of the taxi industry was completed, it was accepted by government that all his recommendations be implemented to the extent of reducing the share of owners income in business to 45%. This was done even though the owner had to pay for all expenses including cost of vehicles, depreciation, repairs, petrol, gas and oils, radio fees and other office expenses (like rates, rent, water, electricity, advertising, wages etc) When the drivers income share was increased to 55% a disparity of 10% was created, even though the driver did not have to pay for any expenses. Even at that point it was accepted that it is the efforts of the investors in business which are serving the community with this good service and creating employment for the drivers. Coming back to the point, even after 2012, the rules remained the same. Everybody had to report to the TSC and get permission to buy licences and the business. Now the government has decided that they will only pay $50,000 for the first regional taxi licence and $25,000 for the second regional taxi licence and nothing for the rest of the licences. It seems very odd that even though the government knows what prices have been paid for each licence and business, that they only want to compensate a very small amount for the first licence and the second licence and would like to forget that there are other licences too. If the government was fair about it, they would pay the amounts which the owner paid for each licence with an increase of 5% every year that licences were held. Secondly the government should pay for the goodwill, advertising and efforts of the owner in running this service in the regional and country areas. The government intends to diminish all licences in regional areas which will create a hole in the transport industry because the service will disappear for the elderly people. 8 | October 2016 YEARS Taxi Talk - Voice of the Taxi Industry

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Uber will not be interested in doing small jobs, they are only interested in long jobs. The authorities, like TSC, will have no authority over Uber or any other service working in the area to ensure service for the poor and elderly people and wheelchair passengers. Lastly the government would like all Network Service Providers (NSPs) to collect $2 per fare from all passengers, this would be disastrous. This will further damage the industry to increase the fares. This will be hidden taxation by the government and would effect businesses and people’s standard of living. If anything this should only apply to the newcomers in the industry like Uber. If the taxi industry has to pay in regional and country areas it should be used to compensate for the goodwill and hard work that owners have put into creating this good service for poor and elderly over the years. Lastly I would like to suggest some solutions. Preferably all licences in regional and country areas should remain intact. There should be no change. If changes have to be done then the regional and country areas should be treated differently as compared to metro taxis which is as follows:- 1. The value of all licences in regional and country areas should be paid at the same value as city if they have to be cancelled. 2. The $2 per fare should be used by NSP for cost of their goodwill and compensation for their effort in providing good service over the years. 3. If Uber or other services come in these areas they charge $2 and hand it to the government. A Zafar TT Are you a taxi licence holder ? Are you in Financial Hardship ? Are you making a Hardship Application to the Government’s Fairness Fund ? WEstjustice can provide eligible licence holders with free legal advice and assistance with your application. For more information about our service, or to make an appointment call 9749 7720 Taxi Talk - Voice of the Taxi Industry YEARS October 2016 | 9

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ALLEN LANG 2/11/1934 - 17/9/2016 Father of the Victorian Taxi Industry died last month after losing his battle with cancer. A stalwart of the Taxi Industry and generally a great man. He passed away quietly and with dignity at Cabrini Prahan. Many of the industry’s “old timers” will recall Allen Lang as operator of US (Motors) Taxis and more particularly his long years of service as President of the Taxicab Division of the Victorian Road Transport Association which, in 1963 changed its identity to the Victorian Taxi Association (VTA). Allen achieved an incredible 22 consecutive years as President of the VTA. The taxi industry in Victoria, and indeed the regulators, which encompassed several Transport Regulation Board chairmen in that period, can be thankful that a person of Allen’s calibre had made himself available for such an important and difficult volunteer post for so many years. For those few who did not have the pleasure of meeting Allen Lang since he commenced driving taxis in 1958, and who had never left the industry scene, you can be assured that our industry was under the control of a leader who was a master diplomat and an untiring administrator of the highest level. Allen Lang was blessed with the qualities of impeccable judgement, fairness, diligence and most importantly a reputation for being a straight guy. He will be remembered in high esteem for over 30 years of leadership during which time he gave unstintingly of his time and effort in the interests of the Taxi Industry. Allen was also a competitive cyclist, trained with Tour de France riders and rode with Kensington Amateur Cycling Club. Your trip on the ranks lasted 81 years Your memories will last a lifetime (Goodbye Pal) 10 | October 2016 YEARS Taxi Talk - Voice of the Taxi Industry

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One of the very best! Taxi Talk - Voice of the Taxi Industry YEARS

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Tributes to Allen Lang Last month our friend, confidante and adviser lost his fight against cancer and has left us. He was an advocate of a clean, successfully run Victorian taxi industry, an avid cyclist and had a passion for dogs. He was a great leader and was also the first Victorian Boy Scout to receive the Queen’s Scout Award. Allen also enjoyed the simple pleasures of life too, from the colourful flowers he grew on his balcony to the home-made shortbread he looked forward to every Christmas. When leaving The Scots Church on 22 September, he was escorted for two blocks by a Scottish Piper playing Amazing Grace. What a great send off! We will miss his smile, quick wit, unfinished sentences, cryptic answers and contagious laugh. Goodbye dear friend. RIP Allen. Isobel, Toni and Donna Allen’s commitment to doing the right thing for his sons, his family, friends and colleagues was what made him the man he was. Always looking to help somebody get a start, get back on their feet or get through a tough time. With a unique brand of political incorrectness, a booming voice, an amazing collection of wisdom and phrases, he was a man that could make a lunch with friends go on and on and on….. and on. Allen’s courage in his last days was both amazing and a thing of true inspiration. No complaints, no anger, no resentment and no backward steps either. Facing into everything that approached without fear or hesitation. Dad, I’m so proud of you, I’m so proud to be your son. I love you. Robert Lang My dear friend Allen Lang passed away on Saturday 17/9/2016. He will be missed by all of us at Vermont Autogas. Rest in peace my friend. Hans Altoff I regret the passing of long-time friend Allen Lang who I had known for 56 years. Frank Hart Allen was a life member of the Australian Taxi Industry Association (ATIA) and highly respected for his knowledge, advice and insight. My friend and colleague for many years. He will be sincerely missed. John Bowe Allen, my dad, my best friend, was a man I looked to for support; I looked to for strength; I looked to for advice. Not the answer, he would NEVER give you the answer, he would say “you have to work that out yourself kid”. As you get older in life things get taken from you - that’s life. Allen would say “You never truly know what confidence is until you’ve lost it” and on Saturday 17 September 2016 myself, the Lang family and many, many others lost a little confidence. But, we will all bounce back, as we are all better for knowing Allen Lang….my Dad. David Lang 12 | October 2016 YEARS Taxi Talk - Voice of the Taxi Industry

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Schmidt G5 Taximeter Schmidt G5 SN 123456 01 $48.50 TARIFF Tap to Pause or Hold to Total FARE $5.10 $2.00 TOLLS CITYLINK Tap to Add EXTRAS DAY • HIRED Day View Keep control of your business • Fully automatic self-calibration - World’s first self-calibrating taximeter. - Recalibrates itself automatically whenever required e.g. when you change tyres. - No need to visit a dealer for calibration, saving you time and money. • Eliminates off-meter fares and could pay for itself many times over every year - World’s first taximeter with optional ultrasonic passenger detection - Keeps the fare running whenever a passenger is riding in your taxi • Prevent other parties from owning your confidential income data and putting your privacy at risk • Control your taximeter via secure website log-in Schmidt Electronic Laboratories Pty Ltd Trusted by thousands of taxi operators & drivers for more than 35 years Taxi TPalhk o- nVoeice(0o3f)th9Ae5d4Tda6xri6eI9nsd9su0s1ot5rry31O30sb0o1r3n2e 422 | Email info@schmidt.com.au Avenue, ClaytonYESAoRSuth, VIC 3169 | A| BWNeb2s0it0e05w6w3w1 .7s1cSh0emptiedmt.bceorm20.a1u6 | 7

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Industry change The Victorian Hire Car Association is deeply disappointed with the derisory offer of ‘assistance payments’ made by the Andrews Government to hire-car licence holders. Let us make no mistake about what this really is. It is not ‘assistance’; nor is it anything to do with Uber (or any other ride-sharing platform), or the level of ‘competition’ within the industry. It is about COMPENSATION for the compulsory acquisition of privately owned assets. The Andrews Government has abandoned a long-held principle of previous governments (of both persuasion) to compensate those affected fairly in situations where governments have compulsorily acquired private assets. The Government’s offer represents a total failure to compensate licence holders ‘fairly’ and in good faith. For those who believe that compensation for taxi and hirecar licence holders is not justified, allow us to provide some context: The Victorian Government has recently announced the compulsory acquisition of some homes and businesses to facilitate the removal of two level crossings in Cheltenham. The Spriggs family owns one such property that the government will be purchasing. On 6 September 2016, The Age reported: “Owners will be compensated by the government if their homes are taken; for the Spriggs this likely means around $1million plus any other costs. Under the Land Acquisition and Compensation Act they would also be eligible for up to 10% more for the inconvenience they will suffer… Public Transport Minister Jacinta Allan said removing the level crossings was “a complex task”, and that the government would deal respectfully with people whose homes will be affected.” Why are taxi or hire-car licence holders being treated differently? A privately owned asset is a privately owned asset; be it a house or a hire car licence it makes no difference! These houses in Cheltenham are being acquired at market value plus additional compensation; yet the taxi and hire car industries are being treated with contempt. Our industry is being decimated; our businesses are being damaged and our lives are being disrupted; yet somehow we are less worthy? The Government has an obligation to compensate fairly and their conduct so far has been nothing short of unconscionable. 14 | October 2016 YEARS Taxi Talk - Voice of the Taxi Industry

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$2 TAXI TAX The VHCA does not support the ‘taxi tax’ of $2.00 being added to all fares from ‘Network Service Providers’ when the proposed legislation comes into effect in 2018. We anticipate there will be noncompliance on a wide scale; not to mention the added administrative burden will add further costs to business, which will ultimately be passed on to the public. To put it simply, this is just more bureaucratic red tape that the industry could do without! The VHCA made a number of alternative suggestions in our policy submission to the Andrews Government Ministerial Forum back in November 2015 (available on www.vhca.com.au). We strongly believe the public should not be made to pay for a new entrant (rideshare) to the market. VHCA NEWS In other news, VHCA Board Member Tony Sheridan resigned from his position on the Board, on 9 September effective immediately. We thank Tony for his valuable contribution to the re-forming of the VHCA and his voluntary work on behalf of the VHCA members over the last 18 months. Andre Baruch will add Tony’s role as Treasurer to his existing role as Vice President for the short term. The Board intends to replace Tony’s role plus create an additional Board position; to be decided by members at the next AGM. So to those members who are interested in joining the next VHCA Board, please make yourself known to any of the current Board members. Stay in touch with VHCA updates via our Facebook page www.facebook.com/thevhca Rod Barton President VHCA TT Attention ! ALL HIRE CAR OPERATORS & DRIVERS everyone is welcome - you do not have to be a VHCA member to attend Please make an effort to be there; it is your livelihood! Wednesday October 5 from 10:30am @ Veneto Club 191 Bulleen Road, Bulleen This meeting is very important to the future direction of our industry. • Aaron de Rosario (CEO, Taxi Services Commission) will be in attendance to help explain some of the changes which our industry is facing. • We will also discuss legal advice that we have received and other upcoming matters that will need decisions as we move forward. Taxi Talk - Voice of the Taxi Industry YEARS October 2016 | 15

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