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Institute for Transportation Research and Education
North Carolina State University
Centennial Campus
Box 8601
Raleigh, NC, USA 27695-8601
(919) 515-8899


ITRE
Institute for Transportation Research and Education
North Carolina State University

Final Report

Study of Taxicab and Wrecker
Licensing for the Metropolitan
Government of Nashville and
Davidson County


Prepared by

Institute for Transportation Research and Education
North Carolina State University

February 6, 1996

Study of Taxicab and Wrecker Licensing
for
The Metropolitan Government of Nashville and Davidson County


Table of Contents


1.0 INTRODUCTION
1.1 Problem Statement
1.2 Data Collection and Analysis
1.3 Organization and Scope of Report

2.0 FINDINGS
2.1 Regulatory Structure
2.2 Organization
2.3 Policy-Setting
2.4 Licensing
2.5 Enforcement
2.6 Adjudication, Fines, Appeals Process
2.7 Staffing Levels and Training







3.0 RECOMMENDATIONS
3.1 Regulatory Structure
3.2 Organization
3.3 Policy-setting
3.4 Licensing
3.5 Enforcement
3.6 Adjudication, Fines, Appeals Process
3.7 Staffing and Training

4.0 RESPONSES TO STUDY QUESTIONS
4.1 How Do Taxis and Wreckers Fit Into the Current Transportation System?
4.2 How Can the Current Organization and Functions of the Board Be Improved?
4.3 What Should Be the Staffing Levels?
4.4 What Are the Staff Training Requirements?

APPENDICES


1. INTRODUCTION

1.1. Problem Statement

The Institute for Transportation Research and Education at North Carolina State University (ITRE) has been contracted by the Metropolitan Government of Nashville and Davidson County to study its regulation of taxicab and wrecker services. Specifically, ITRE has been asked to analyze, evaluate, and make recommendations on the following elements of this regulation as performed by the Metropolitan Government's Taxicab and Wrecker Licensing Board (Board):

  1. How do taxicabs and wreckers fit into the current transportation systems in the Nashville Metropolitan area?
  2. How can the current organization and functions of the Taxicab and Wrecker Licensing Board be improved?
  3. What should be the staffing levels, qualifications, and administrative accountability of the Board and its staff?
  4. What are the training requirements for the Board's taxicab and wrecker regulatory staff?

It is important to emphasize that this study focuses on the above questions. ITRE was not asked to perform an analysis of the quality or quantity of taxi and wrecker services but rather to focus on the role of the Board in regulating these services. To the extent that specific regulations--such as taxi inspection requirements--impact the work load of the Board, we did include them in our analysis. However, our study is not an assessment of the performance of either the taxi or the wrecker industries.

1.2. Data Collection and Analysis

To best respond to the above questions, ITRE gathered information from individuals and groups involved in providing, regulating, and using taxicab and wrecker services in Nashville. Taxicab and wrecker regulation in five other cities of comparable size that are also tourist destinations were examined, for comparative purposes. Data collection and analysis involved three primary activities: collecting information from individuals and organizations in Nashville; collecting information from five comparable cities; and analyzing, comparing and synthesizing that information as well as other relevant information on taxicab and wrecker regulation. This information was used to formulate findings and recommendations.

1.2.1. Nashville and Davidson County

Information gathering in Nashville involved a series of interviews with individuals and groups involved in the regulatory process, a review of the local taxicab and wrecker ordinances, a compilation of the forms used in the taxicab and wrecker regulatory process, and follow-up telephone calls.

Dr. Gorman Gilbert, Anna Nalevanko, and Thomas Cook conducted interviews in Nashville October 21-23, 1996. Individuals and groups with whom personal interviews were conducted included the following:

Telephone interviews were conducted with Mr. Larry Ennis, Wrecker Inspector, Mr. Gene Ward, Assistant Director of Parking, Department of Public Works, Dr. Bob Babbitt, Metropolitan Transit Authority, and staff of the Metropolitan Beer Board. Questionnaires were sent to taxicab company owners who were not able to attend our meeting in Nashville.

Interviews with government officials and policy-makers addressed issues regarding policy setting, administration and enforcement of the taxicab and wrecker ordinances, staff levels and training, and the organization of regulatory authorities. A broad spectrum of regulatory issues was discussed, from opinions on the most appropriate location of regulation of taxicabs and wreckers within the metropolitan government to appropriate vehicle age requirements for taxicabs.

Interviews with members of the taxicab and wrecker industries focused on the current regulatory structure. Taxicab and wrecker company owners and taxicab drivers provided input on problems with the current regulatory structure and ordinance and were asked for suggestions as to how metropolitan authorities could best respond to those concerns.

Interviews with representatives from the business community, the tourism industry, and the airport centered on issues regarding vehicle operations, driver training, and positive/negative aspects of job performance by those in the taxicab and wrecker industries.

1.2.2. Other Cities

Interviews were also conducted with inspectors and other individuals involved in taxicab and wrecker regulation in Birmingham, Alabama, Charlotte, North Carolina, Louisville, Kentucky, Memphis, Tennessee, and Tulsa, Oklahoma. Copies of current taxicab and wrecker ordinances and of forms used for permit applications, vehicle inspections, and other aspects of the regulatory process were procured from each city.

One member of the project team conducted on-site interviews with the taxicab and wrecker inspectors for each of the five comparable cities. In many cases, discussions were held with other individuals involved in the regulation of taxicabs and wreckers. Those individuals included members of the taxicab and wrecker licensing or advisory boards, local government officials, and members of the taxicab and wrecker industries. While the range of individuals from whom information was procured in the other cities was not as extensive as that in Nashville and Davidson County, those with a sign)ficant role in taxicab and wrecker regulation in each city were contacted.

1.2.3. Analvsis

Current regulatory practices in Nashville and the other five cities were then compared. Areas of investigation included:

These data items were then compiled into a chart (refer to Appendix) to allow comparison of Nashville and the other five cities. Comparison data was used in developing the findings and recommendations contained herein.

1.2.4 Draft Report

A draft report was presented to members of the Taxicab and Wrecker Licensing Board, the Metropolitan Clerk, the Taxicab and Wrecker Inspectors, and taxicab company owners during a series of meetings in Nashville on December 17, 1996. Meeting participants raised questions concerning the following topics:

  1. Regulation through a minimum standards approach.
  2. A maximum vehicle age standard.
  3. An appropriate maximum number of taxicabs to be licensed to operate.
  4. Taxicab/wrecker industry representation on Board.
  5. Type of vehicle inspection to be recommended.
  6. Mandatory driver training not recommended.
  7. Adoption of stringent dress code for taxicab drivers.
  8. Adoption of licensing deadlines so that process is not impeded by clerk's absence due to illness or vacation.
  9. Behaviors constituting sexual harassment.
  10. Recommend allowing practice of hailing taxicabs.
  11. Inspectors now carry firearrns.

Those topics are addressed both in this final report and in a separate written response.

1.3 Organization and Scope of Report

The four questions that we were asked to address in this study illustrate the range of regulatory responsibilities of the Board. They do not, however, represent all the regulatory steps that the Board is asked to perform or that any regulatory body would be asked to perform. Thus, to clarify the overall regulatory responsibilities, we have elected to address separately each regulatory step in presenting our findings and recommendations. These regulatory steps, beginning with the most general, are:

  1. regulatory structure
  2. organization
  3. policy-setting
  4. licensing
  5. enforcement
  6. adjudication, fines, and appeals process
  7. staffing levels and training

By breaking down the regulatory functions into these seven elements, we are able not only to address all four questions posed in this study but also to clarify how these elements might be grouped and possibly performed by different organizations.

The remainder of this report is organized in three parts. Section 2 details the findings of the study team. These findings are organized functionally; that is, they address each of the seven regulatory functions listed above. Likewise, Section 3 presents the recommendations for each of these seven regulatory functions. In Section 4 we address the four questions posed for this study.

2. FINDINGS

2.1 Regulatory Structure

This regulatory element pertains to the overall approach used in Nashville to regulate taxis and wreckers in as much as this overall approach affects the regulatory workload of the Metropolitan Government.

2.2 Organization

By "organization" we refer to the delegation of responsibility for regulatory functions.

2.3 Policy-Setting

Policy-setting refers to how regulations and rules affecting the taxi and wrecker industries are promulgated.

2.4 Licensing

An important element in the overall regulation of taxis and wreckers is the licensing of drivers and owners, including testing and recordkeeping.

2.5 Enforcement

Enforcement refers to the issuance of citations or summonses to industry drivers or owners for infractions of the taxi or wrecker ordinances.

2.6 Adjudication, Fines, Appeals Process

This regulatory function refers to the setting of fine levels, the issuing of fines, the appeals process available to industry persons receiving citations, and the process for penalizing persons who refuse to pay their fines.

2.7 Staffing Levels and Training

3. RECOMMENDATIONS

Given the findings in Section 2, there are specific recommendations that ITRE offers as means to address the questions posed by the Metropolitan Government in this study. Recommended actions are specified in this section.

3.1. Regulatory Structure

3.2 Organization

3.3 Policy-Setting

3.4 Licensing

3.5 Enforcement

3.6 Adjudication, Fines, Appeals Process

3.7 Staffing and Training

4. RESPONSES TO STUDY QUESTIONS

In performing this study ITRE was asked to address the four questions listed in Section 1.1. We now specifically address these questions in terms of our recommendations.

4.1 How Do Taxis and Wreckers Fit Into the Current Transportation System?

Taxis and wreckers play important roles in the overall transportation system in Nashville and Davidson County. Moreover, as the region becomes more attractive to tourism and business visitors, the importance of these two services, especially taxis, becomes ever greater. Furthermore, there are now new modes of transportation services, such as horsedrawn carriages and Metro Shuttle, which compete with taxis, and one can predict that executive sedan services, which are operating in other cities, will soon appear in Nashville. The result is that there is an increasing need for Metro Council to regulate all such services in an effective and efficient manpower.

We are making several recommendations that relate to the overall regulatory approach which we believe that Metropolitan Government should follow. These are primarily cited in Section 3.1 where we suggest how the taxi services should be regulated. There are, however, in other sections, such as Section 3.4, additional recommendations that relate to taxi service quality. All of these recommendations, particularly the changes in the five year rule and the imposition and enforcement of meaningful service standards, are meant to enhance the attractiveness of taxi services and hence the attractiveness of the region.

4.2 How Can the Current Organization and Functions of the Board Be Improved?

Primarily, we address this question in Section 3.2. We urge the Metropolitan Government to continue to delegate taxi and wrecker regulation to the Taxicab and Wrecker Licensing Board, but we further urge major changes in how the Board operates. We recommend that the Board be given an administrative staff that reports to a staff director, who reports to the Board. We recommend that two member positions on the Board be reserved for representatives of the taxicab and wrecker industry and of the tourism industry.

4.3 What Should Be the Staffing Levels?

We recommend that one new position, the staff director, be created. We further recommend that a clerical position be established with the Board and that the current clerical and administrative duties associated with taxis and wreckers in the Clerk's Office be moved to the Board. These recommendations appear in Sections 3.2 and 3.7.

4.4 What Are the Staff Training Requirements?

We recommend that the new staff director be given the ffrearms training equivalent to that currently provided to the taxicab and wrecker inspectors. We do not recommend that this person be armed or have authority outside of matters pertaining to taxicab and wrecker regulation. We expect that the director will participate in typical professional development and training activities.


Appendix: Summary of Nashville and Comparable Cities


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