SUBMISSION BY
THE NSW TAXI
COUNCIL
Proposed Standards for Training
Providers and VET Regulators
This submission is provided to detail the NSW Taxi Council comments on the proposed
Standards for Registered Training Organisations (RTOs) 2014.
30 July 2014
EXECUTIVE SUMMARY
The NSW Taxi Council welcomes the opportunity to provide a submission to the Australian
Government, Department of Industry on the proposed Standards for Registered Training
Organisations (RTOs) 2014.
The NSW Taxi Council is the peak operational body representing two industry associations,
The NSW Taxi Industry Association and the NSW Country Taxi Operators’ Association. The
NSW Taxi Council is also a Registered Training Organisation (RTO) delivery accredited
industry courses for Wheelchair Accessible Taxi Drivers and Taxi Operators. In addition, the
NSW Taxi Council is the owner of a course approved by the NSW Government for the
training of taxi drivers and is responsible for the design and update of the course materials.
The NSW Taxi Council has been involved in the early consultation on this matter attending
the VET Reform Stakeholder Engagement Workshop on 7 March 2014. The NSW Taxi
Council representative raised the following issues as key concerns for the NSW Taxi
Council:

Regulator seen in terms of compliance focused rather than an education function for
RTOs. Assistance in understanding how to meet the standards in a practical sense
would be appreciated by RTOs.

Significant compliance burden on RTOs, with associated costs to meet regulation.

Funding opportunities are difficult to access and when accessed for program
development, have been later withdrawn (ie. Workplace English Language WELL
funding, which results in short term programs that are halted due to lack of ongoing
funding.

Challenges for industry where language and literacy is an issue for workers.

Ad hoc consultation from Industry Skills Councils on changes to training packages
and unit changes.
The NSW Taxi Council has reviewed the draft standards and the associated documentation
and provides comments as detailed below.
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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 seven 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 and operators, network
management staff as well as for other industries who 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 NSW Taxi Industry is made up of a complex array of providers, ranging from the licence
owner (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 revenues through
authorisation fees and indirect taxes.
The NSW Taxi Industry has a strong commitment to customer service excellence through its
training and compliance regimes. Unfortunately, a minority of drivers and operators let these
standards fall and the customer experience is diminished as a consequence. This is why the
NSW Taxi Council remedial training program is critical as it provides an opportunity for reskilling and influencing behaviour, particularly amongst taxi drivers.
The following points are made with the ultimate aim of improving the accredited training
outcomes for the NSW Taxi Industry.
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PROPOSED STANDARDS FOR TRAINING PROVIDERS AND VET
REGULATORS
Standard 1. The RTO’s training and assessment strategies and practices are
responsive to industry and learner needs and meet the requirements of
Training Packages and VET Accredited Courses
The NSW Taxi Council supports the requirements for RTO’s to be more responsive, more
closely engaged and be meaningfully informed by industry.
It is believed that this will strengthen the outcomes for learners to be work ready and
appropriately trained to meet the job requirements and to meet the needs of industry.
Consideration should be given to mechanisms for consulting with industry, and the role that
peak bodies and industry associations play in the representation of industry in a holistic
manner should be focused on. In industry, where there are many RTO’s the consultation
process may place burden on smaller industry participants and industry bodies are well
placed to be the first port of call in streamlining this process.
In relation to appropriately skilled trainers and assessors, the removal of the equivalence of
competence may prove difficult in some areas where access to achieving formal
qualifications for trainers and assessors may be limited, such as remote country areas. In
this respect an appropriate time period for implementation could be applied; for example a
12 month transition period.
Standard 2.
The Operations of the RTO are quality assured.
The NSW Taxi Council supports standards that result in high quality training outcomes,
subject to further advice/implementation and consultation.
Standard 3.
The RTO issues, maintains and accepts AQF certification
documentation in accordance with these Standards and provides
access to learner records.
The NSW Taxi Council supports standards which maintain the integrity of AQF qualifications,
subject to further advice/implementation and consultation
Standard 4.
Accurate and accessible information about an RTO, its training and
assessment and related services and performance is available to inform
current and prospective learners and clients.
It is supported that transparent and accurate information regarding course offerings be
presented to students. It is recommendation that this includes information regarding the
bona fides of the RTO for student consideration. Principles of ethical marketing of RTOs,
course and qualifications is strongly supported.
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It is agreed that the manner of presenting information to students should not be prescribed,
rather guidelines detailing the minimum standards for information requirements be provided
to RTOs for interpretation and distribution.
The requirements for RTO’s to implement the student identifier as Student Identifiers Act
2014, for small RTOs has placed onerous time and economic burden, especially for those
RTOs that are industry specific.
In addition, the core focus of any RTO should be the quality of training and the student
outcomes that ensure that graduates are work ready. Any move to cut red tape in the
administration of an RTO is strongly supported, as often this compliance burden detracts
from its core focus. A more balanced approach to regulation and compliance would be
welcomed.
Standard 5.
Each learner is properly informed and protected.
This standard is supported. It is agreed that the communication method be determined by
the RTO to best meet the needs of the learner. The NSW Taxi Council supports the new
standard requirements that apply to sub-contracting, acknowledging that in some
circumstances it is not possible, due to the third party trainers, to ensure compliance at a
subcontracting level, however it is recommended that wording be such that rather than
ensure that the RTO be required to take all reasonable steps to ensure compliance.
Standard 6
Complaints and appeals are recorded, acknowledged and dealt with
fairly, efficiently and effectively.
The NSW Taxi Council supports the requirement for RTOs to have a transparent complaint
policy and procedures.
Standard 7
The RTO has effective governance and administration arrangements in
place.
It is noted that the requirement for financial viability checks for existing RTOs has not been
included in the new standards. The NSW Taxi Council supports ongoing financial viability
checks and recommends, that at a minimum, a robust and transparent system for financial
viability be maintained.
Standard 8
The RTO cooperates with the VET Regulator and is legally compliant at
all times.
The NSW Taxi Council supports the requirement for RTOs to be compliant at all times.
Notwithstanding, given the complexity of the regulations, appropriate instruction and advice
should be provided by the regulator to assist RTOs to achieve and maintain compliance.
The role of the regulator, therefore should be both compliance and education, to inform and
assist and where necessary, carry out enforcement. Furthermore, the regulations should be
accessible to RTO’s and particular attention be paid to clarity and interpretation to avoid
ambiguity.
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CONCLUSION
The NSW Taxi Council acknowledges the role of the Department of Industry and the
regulators for Registered Training Organisations and strongly supports a robust system for
workplace training and assessment, meeting the needs of workers and industry.
The core focus of RTOs should be on high quality training delivery and outcomes for
learners. In this regard, the NSW Taxi Council supports the initiatives to lessen the red tape
burden, whilst enhancing training outcomes.
We are keen to work with the regulator to introduce the new standards, and request that a
suitable transition period be afforded for RTOs and industry to adapt to the new
requirements.
Ends.
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