Accident Towing Regulation. 28 November 2014

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1 Accident Towing Regulation 28 November

2 2 Contents Executive Summary... 3 Summary of VACC recommendations VACC Introduction Price Regulation Accident Allocation Boundaries and Zones Accident Allocation Schemes Summary of Costs and Benefits Role of the regulator VACC Contacts Gary Cowen Division Manager Towing Operators Victorian Automobile Chamber of Commerce (VACC) 464 St Kilda Road Melbourne VIC 3004 P E gcowen@vacc.com.au Brian Savage General Manager Policy & Government Relations Victorian Automobile Chamber of Commerce (VACC) 464 St Kilda Road Melbourne VIC 3004 P E bsavage@vacc.com.au 2

3 Executive Summary The VACC welcomes the opportunity to make a submission to the Essential Services Commission s (ESC) review of accident towing regulation. The VACC represents most accident tow truck operators in Victoria. The objective of regulating the accident towing industry is to promote the safe, efficient and timely provision of accident towing services. The VACC believes these objectives are being met by accident tow operators and notes that the ESC has acknowledged in its periodic pricing reviews that accident tow operators have provided a safe, efficient and timely accident towing service. The introduction of the accident allocation scheme for the Melbourne Controlled area in 1983 and the Geelong self-management area has provided a world class and unique accident towing service to Victorian motorists. The National Competition Council and the Industry Commission (Productivity Commission) have acknowledged the benefits of the allocation schemes in previous reviews. The level of non-compliance by accident tow truck operators and their drivers is negligible. Victoria Police issued only 10 infringement notices in 2012/13 and this represents % of the 45,000 accident tow jobs in the Melbourne Controlled area. Over the past four years, Victoria Police have not issued any infringement notices to operators for failing to arrive at an accident scene within 30 minutes of receiving the tow job from the RACV accident allocation centre. A compelling evidence-based case needs to be made for any regulatory change and the VACC expects any issues of concern raised during the course of the review are subjected to detailed analysis to determine the extent of the problem (number of incidents and associated costs) relative to the size of the market (number of accident tows). As the ESC would be aware, accident towing is a heavily regulated sector, and the VACC does not want additional regulation introduced to address isolated incidents that ends up punishing the majority of accident tow operators that comply with the existing regulatory framework. Notwithstanding this, the VACC acknowledges there is always scope for improvement that delivers a more efficient and higher quality service to Victorian motorists. In this respect, the VACC notes that two of the three key areas being examined in this review were the subject of ESC recommendations directed at VicRoads in its previous periodic price reviews. As the ESC is obviously aware, VicRoads has not adopted these recommendations. The VACC believes the ESC should investigate why VicRoads has not adopted these recommendations and include the reasons in its Draft Report. Our submission addresses the three key areas raised in the Issues Paper: the regulation of fees the necessity for and location of boundaries which set up different regulatory approaches; and, the allocation of accident towing jobs 3

4 Price Regulation Melbourne Controlled Area The VACC would like to point out price regulation already exists across Victoria as well as for heavy vehicle towing. The Melbourne Controlled area is the only area that has prescribed towing fees. The other parts of the State and heavy vehicle towing are required to charge reasonable towing fees. Price regulation exists in most jurisdictions and exists to address the vulnerability of motorists involved in an accident and the fact that they are often traumatised or distressed, have a poor knowledge of towing services and the associated costs, invariably do not have a choice of towing service, and for insured motorists are not interested in negotiating given that their insurance company will pay for the tow. These problems and the need for price regulation has been accepted as necessary in previous reviews and assessments undertaken by the Industry Commission (now Productivity Commission), National Competition Council and other state government agencies such as the New South Wales Independent Pricing and Regulatory Tribunal (IPART) The VACC believes the ESC needs to adopt the methodology used by NSW IPART to ensure a fair and reasonable return for accident tow truck operators. If the recent IPART recommendations are adopted by the NSW Government, the NSW towing base fee will be about $40 higher together with higher per km and storage fees compared with the Melbourne Controlled area. Yet New South Wales and Victorian accident tow truck operators share identical labor and capital costs with the only material difference being higher leasing costs particularly in Sydney. However, IPART has correctly apportioned most of this cost to mostly higher storage fees rather than the base fee. Accordingly, the VACC believes accident tow truck operators in the Melbourne Controlled area are being disadvantaged by the current ESC pricing methodology and would urge it to reconsider. The VACC does not support alternative pricing arrangements such as bidding or auction price systems for the Melbourne Controlled area. The requirement that accident tow truck operators to arrive at the accident scene within 30 minutes of accepting the allocation prevents all of the accident tow truck operators from competing for all of the accident tows across Melbourne. Bidding or auctioning tow jobs would result in a considerable variation in towing fees, with lower fees in the inner suburbs where there are more tow truck operators, higher fees in fringe areas without many operators and higher fees than the current regulated fees for after-hours towing and on public holidays. The VACC considers the bidding or auctioning option does not address the problems of motorist vulnerability. In addition, a bidding or auctioning system would be confined to accident tow truck operators competing against each other without any input from motorists. Motorists cannot determine when they have an accident and it would be unfair if 4

5 motorists were charged significantly higher fees than the current regulated arrangements if there was only one accident tow truck operator bidding for a tow job at 3.00 am. Regional Victoria and the Geelong Self-Management Area In respect to accident towing in other parts of Victoria including the self-management area of Geelong, the requirement to charge reasonable fees reflects the lower volume of accident towing in these areas and hence the lower tow truck utilization that leads to a wide variation in the hourly costs experienced by different operators. Accordingly, prescribed average towing fees are not supported as this would lead to significant under-recovery for some operators in small regional towns, and possibly over-recovery for some operators in regional centers. Most accident tow truck operators also operate a smash repair business and it is the latter business that would, in most cases, provide the greatest turnover for the business. Insurance companies purchase both the accident towing and the smash repair services usually from the same business. As a result, the insurance companies are able to keep a check on accident towing fees as the smash repair division of the business would not jeopardise its smash repair revenues by charging unreasonable or exorbitant accident towing fees. If on the other hand, accident tow truck operators solely provided towing services, the insurance companies would not have any leverage on them in terms of ensuring reasonable fees were being charged. If the market structure comprised accident tow truck operators providing only towing services and no smash repair business, there would be a greater case for price regulation. Heavy Vehicle Towing The heavy vehicle towing market is different to the light vehicle towing market. The problems associated with motorist vulnerability at the scene of the accident are unlikely to occur with heavy vehicle accidents. In most cases, freight transport companies and major insurance companies such as National Transport Insurance have contractual arrangements with licensed accident towing businesses to tow their trucks in the event of an accident, and in some cases, also to provide break-down towing and repair services. In most cases, heavy vehicle tow truck operators are not dealing with the driver at the scene of the accident but with the transport or insurance company. Unlike the light vehicle market, freight transport companies have an incentive to invest time and resources in developing an understanding of the heavy vehicle towing industry to ensure that they receive a reliable and high quality service at the least cost. In view of the different characteristics of the heavy vehicle accident towing market and in particular the commercial arrangements that currently exist between operators and freight transport/insurance companies, the VACC strongly recommends the current requirement that operators charge reasonable fees remain to provide suitable flexibility to operators and protections to freight transport and insurance companies. 5

6 Accident Allocation Boundaries and Zones There have been recent documented problems of VicRoads exercising administrative discretion (including at a junior level) changes to zone boundaries and co-location of depots that have had a significant impact on adjacent accident towing zones and consequently to accident tow allocations. The ESC is clearly aware of these incidents given that it raised them in its previous periodic pricing reviews. It is not necessary to detail in this submission the actual problems that have arisen in recent years. In response to these problems, the ESC recommended the establishment of Guidelines to determine accident towing zones and allocation boundaries. The VACC supports the ESC for the development of these Guidelines together with an open and transparent process with appropriate independent appeal processes for aggrieved applicants and/or other affected licensees. The ESC has suggested the criteria could include population density, traffic flow information, the number of accidents and the number of customer complaints and infringements by operators. The VACC is supportive of the aforementioned criteria other than the number of customer complaints and infringements by operators. The VACC considers other forms of sanctions should be applied rather than tampering with zone boundaries based on complaints and infringements. Accident Allocation Schemes Melbourne Controlled Area and Geelong Self-Management Area The accident allocation system for light vehicles was introduced in the Melbourne Controlled Area in 1983 to prevent multiple tow truck operators racing to an accident scene that often led to some tow truck drivers harassing and intimidating traumatized drivers to forcibly authorize them to tow their smashed motor vehicle and/or intimidating and assaulting other tow truck drivers to leave the accident scene. The attendance of multiple tow trucks at an accident scene caused further distress to accident victims, increased difficulty for Police and other emergency services to manage the accident scene, increased traffic hazards and unnecessary traffic congestion to other motorists. It would appear that the key drivers for smash chasing by tow truck operators are found in areas with high volumes of accidents and an oversupply of tow truck operators. Since the introduction of the accident allocation system in 1983, the previous smash chasing by multiple tow truck operators to the scene of an accident has disappeared as only the licensed accident tow operator that has been allocated a job number from the RACV Accident Allocation Centre can attend the accident. 6

7 Costs and benefits of the allocation schemes Accident allocation schemes have additional costs and benefits relative to accident towing markets without allocation schemes such as in Sydney and Brisbane. Additional costs include the administration of the scheme and freedom of choice and competition. In respect to additional benefits, accident allocation schemes have service standards and sanctions similar to contractual arrangements that ensure licensed accident tow truck operators deliver a high quality towing service to insured and uninsured motorists involved in an accident. Administration In 1995, the Industry Commission noted that the cost of the accident allocation scheme for the Melbourne Controlled area cost $340,000. The cost increased to $882,000 by 2005 (some of this may be attributable to the expansion of the Melbourne Controlled area boundaries to include the Mornington Peninsula, Melton and Longwarry in 2002). The VACC is unaware of the exact cost of the current RACV AAC contract. Using the 2005 cost and the 41,000 accident allocations for that year, the unit cost of allocating each tow job in 2005 was $ While this does not appear to be a significant cost, the actual time taken to receive a call and take basic particulars and dispatch (allocate) a tow job to a licensed accident tow truck operator is about 5 minutes in real time. Obviously, the actual cost is higher due to the standby nature of the accident towing. However, these costs could be mitigated with a call-centre that has sufficient scale and high capacity utilisation over a 24 hour 7 day period. The ESC should investigate whether the current cost to administer the accident allocation centre offers value for money to the government by benchmarking costs charged by the call-centre industry for comparable services. Freedom of Choice & Competition It could be argued that allocation schemes reduce the freedom of choice, price and service competition at the scene of the accident. However, the reality is that in most accident towing markets without an allocation scheme, there is minimal choice, price or service competition. The Industry Commission 1995) acknowledged this in respect to the NSW accident towing market, There is some information to suggest that in New South Wales, where no allocation system applies, there is frequently little choice anyway. A survey conducted for the New South Wales Government (Ernst and Young 1993, p. 8) found that, in around half the number of accidents, the number of tow trucks equaled the number of vehicles requiring towing. Accident allocation schemes also prevent accident tow truck operators combining to provide a network service for a particular region (as occurs with taxis). Insurers are also unable to pursue/support the development of such networks for their clients. Some insurers have established contractual arrangements with some individual accident tow truck 7

8 operators in Sydney to tow their clients involved in an accident. In this respect, the insurer s network excludes accident tow truck operators that do not meet their price and service requirements. A reasonable amount of guaranteed accident towing work would also need to be offered by the insurers to make it financially worthwhile for the contracted accident tow truck operators. Both accident allocation schemes with restricted licences and open towing markets that allow insurers to develop networks limit the number of accident tow truck operators, which in effect ensures that these accident tow truck operators remain viable and profitable to provide an ongoing accident towing service. An advantage of the open market is that it enables insurers to competitively tender and replace non-performing tow truck operators. However, the accident allocation scheme for the Melbourne Controlled area also has similar sanctions that can be exercised at any time, not just at the end of the contractual period as in the case with insurers. Service standards and sanctions Accident allocation schemes have contractual type service standards and sanctions that ensure licensed accident tow truck operators deliver a high quality towing service to insured and uninsured motorists involved in an accident. The advantages of accident allocation schemes are the orderly allocation of one truck per smash vehicle and contractual type features such as minimum service standards that licensed tow truck operators must adhere to in order to remain eligible for continued allocations. A key minimum service standard is to arrive at the accident scene within 30 minutes after accepting a tow job from the RACV AAC. A range of other sanctions and rewards exist such as loss of position on the top of the roster if a tow job is rejected. In these cases, the licensed accident tow truck operator returns to the bottom of the roster. The licensed accident tow truck operator next in line on the roster that accepts the rejected tow job still is entitled to its normal allocations. Importantly, the accident allocation scheme excludes organisations and individuals with a criminal history (whether licensed or unlicensed). This is complemented with the regulatory requirement that repairers are required to record the accident allocation job number in its correspondence with insurers. Accordingly, insurers are not obligated to pay for an accident tow if the invoice does not have the accident allocation job number issued by the RACV AAC. The design of the accident allocation scheme makes it extraordinarily difficult for organised crime to infiltrate accident towing when the source of work is allocated from a single organisation. Regulators in jurisdiction without an accident allocation scheme must rely on their limited enforcement resources to randomly inspect road accidents to detect organised crime infiltration, unlicensed accident towing activity and breaches of any minimum service standards. 8

9 Conclusions The accident allocation schemes would appear to have achieved their objective of reducing smash chasing and the associated problems to accident victims, tow truck drivers and the general motoring public. The accident allocation schemes do not reduce freedom of choice and competition given that this does not really occur in open accident towing markets due to the nature of first in, best dressed approach of signing up a tow and the fact that insured drivers do not pay for the tow directly, rather their insurance company. The minimum service standards prescribed in the accident allocation schemes together with the various sanctions for non-performance and the effective exclusion of organised crime and/or persons with a criminal history provides a superior public benefit to the open accident towing market that requires adequate and regular enforcement of licensed accident tow truck operators/drivers at accident scenes. While open accident towing markets enable insurers to develop networks with individual accident tow truck operators, the accident allocation schemes benefit the insured and the uninsured. However, there may be scope to reduce the administrative cost of accident allocation schemes. Improvements to the Current Allocation Schemes Melbourne Controlled Area Data analysis of allocations reveals inequitable distribution of allocations relative to licence entitlements. Each licence is entitled to an allocation of about 107 tow jobs or 8.97 per month. The allocation data analysis reveals that 19 or 36% of 52 licensees in 2012 received allocation jobs below the average allocation of 8.97 per month. 8 of the 19 operators were large accident towing operators (>10 licences); 4 were medium sized (6 to 9 licences) and 7 were small (1 to 5 licences). Currently, the RACV AAC seeks to achieve partial equalisation. However, full equalisation occurred about a decade ago but subsequent changes to zone boundaries and the colocation of multiple depots within zones has undermined the ability of the RACV AAC and resulted in partial equalisation where attempts are made to provide comparable average allocations with neighbouring accident zones. This is achieved by providing allocations to a licensed accident tow truck operator that is down on their entitlements by allowing them to be offered allocations in an adjacent zone. While this smoothes the averages, it still invariably leads to lower overall allocations compared with the average allocation. Greater flexibility is required to provide a fair and equitable system that enables allocations that match licence entitlements but also provides a high quality service to the public. Greater flexibility in the accident allocation scheme needs to be achieved so that every 9

10 licensed accident tow truck operator is given the opportunity to match their entitlements with the average number of accident allocations per licence. A performance-based arrangement could provide a solution such as offering tow jobs in any zone provided the licensed accident tow truck operator is able to meet the minimum service standard of arriving at the accident scene within the designated 30 minutes. To some extent, the RACV AAC already undertakes this with partial equalisation. Other possible solutions could include allowing a licensed accident tow truck to tow more than one smash vehicle. This already occurs at the discretion of the RACV AAC in circumstances where the location and time of day prevents multiple licensed accident tow truck operators attending a collision involving 2 or more motor vehicles within the 30 minute response service standard. Given that most smash vehicles return to the licensed accident tow truck operator s depot, with almost 100% returning to the depot after business hours, it would seem efficient and help to reduce the cost of towing, to allow as a general rule a tow truck to tow more than one vehicle. This could facilitate full equalisation and provide productivity benefits to licensed accident tow truck operators. VACC members believe the RACV AAC s IT system and the rules governing the allocation scheme are antiquated and in need of significant improvements to facilitate full equalization and better customer service. Geelong Self-Management Area The Geelong self-management allocation scheme enables the licensed accident tow truck operators to know at any point their position on the roster and to have the ability to swap allocation positions with other. This provides greater flexibility in planning, capacity tow truck capacity utilisation without the loss of accident towing work. While the accident allocation scheme is independent of the 5 licensed accident tow truck operators, they have considerable input into the design of the rules of the scheme to ensure a fair, equitable and transparent accident allocation scheme is operated that provides a high quality service but also provides flexibility without loss of licence allocation entitlements. In addition, VicRoads audits the Geelong accident allocation centre to ensure it meets minimum service standards. Due to the input and ongoing review of the allocation scheme, the Geelong operators do not believe any improvements are required. Extension of Allocation Schemes Regional Victoria Most rural and regional areas (other than Ballarat and Bendigo) across the State have a wide distribution of licensed accident tow truck operators. This reflects the low volume of accidents in most areas. As discussed previously, the key drivers for the establishment of an accident allocation scheme is high volumes of accidents and an over-supply of tow truck operators competing for work that leads to aggressive behaviour towards accident victims and other tow truck drivers. These key drivers do not exist for most of the State and hence should remain unregulated. 10

11 Regional centres such as Ballarat and Bendigo each have about 5 licensed accident tow truck businesses. This is similar to the number of operators in the Geelong self-management area. On the surface, Ballarat and Bendigo would appear to be candidates for a selfmanagement accident allocation scheme. However, the VACC believes the ESC would need to firstly demonstrate that a problem exists in these regional centres in terms of an oversupply of licensed operators and the extent of any aggressive behaviour. Secondly, the ESC would need to demonstrate that the additional costs imposed on these licensed accident tow truck operators to fund a self -management accident allocation scheme would outweigh the perceived benefits of reduced smash chasing and aggressive behaviour (if this actually exists). As the ESC would be aware, the costs of funding a self-management accident allocation scheme, such as one that operates in the Geelong region, is ultimately borne by insurance companies and uninsured drivers. Another issue that needs to be considered is the current contractual relationships insurance companies have with licensed accident tow truck operators across rural and regional areas in the State. In view of the above, the VACC does not believe there is a case for change and that allocation schemes should not be extended to regional Victoria. Heavy vehicle towing As previously discussed, the heavy vehicle towing market is different to the light vehicle towing market. There are four licensed heavy vehicle tow truck operators in the Melbourne Controlled Area with depots in Laverton, Campbellfield and Ringwood. Given that most heavy vehicle towing is undertaken on a contractual basis, there is less opportunity for these operators to indulge in smash chasing for truck accidents. 11

12 Summary of VACC recommendations Price Regulation The VACC strongly supports the continuation of the current price regulation regime that operates in the Melbourne Controlled Area and the less prescriptive price regulation of reasonable accident towing fees for other parts of Victoria and for heavy vehicle accident towing in all parts of Victoria. Boundaries and Zones The VACC supports the ESC s previous recommendations for the development of guidelines for the determination of the Melbourne Controlled area and the Geelong self-management area accident allocation boundaries and also for accident towing zones on the grounds of decision-making transparency and accountability, fairness, efficiency and service quality. Allocation Schemes VACC supports the continuation of the accident allocation system for the Melbourne Controlled area and the Geelong self-management area accident allocation schemes but does not support any proposal to merge the Melbourne and Geelong accident allocation schemes, or to extend the accident allocation scheme to rural and regional Victoria. The VACC has presented the advantages and disadvantages of an accident allocation scheme for heavy vehicle towing for the ESC s consideration. The VACC believes the RACV s accident allocation center s IT software needs to be upgraded to ensure each accident towing operator is offered allocations in accordance with their licence entitlements. The VACC believes an IT software upgrade together with some rule changes should ensure an equitable distribution of allocations without any impact on the timeliness of service and also deliver long-term cost savings to Victorian taxpayers. The VACC recommends that the ESC should benchmark private call-centre costs to determine whether the current accident allocation costs provide value for money to the Victorian Government and investigate towing software options that could deliver a more customer based service at a lower cost. Role and Responsibilities of the Accident Towing Regulator The VACC recommends that the ESC should investigate the effectiveness of VicRoads administration and enforcement of the Accident Towing Services Act 2007 and scope for efficiency improvements. 12

13 VACC The Victorian Automobile Chamber of Commerce (VACC) is Victoria s peak retail automotive industry association, representing the interests of 5,500 members in over 20 retail automotive sectors (including towing) that employ over 50,000 Victorians. 1. Introduction The objective of regulating the accident towing industry is to promote the safe, efficient and timely provision of accident towing services. The VACC believes these objectives are being met by accident tow operators and notes that the ESC has acknowledged in its periodic pricing reviews that accident tow operators have provided a safe, efficient and timely accident towing service. The introduction of the accident allocation scheme for the Melbourne Controlled area in 1983 and the Geelong self-management area has provided a world class and unique accident towing service to Victorian motorists. The National Competition Council and the Industry Commission (Productivity Commission) have acknowledged the benefits of the allocation schemes in previous reviews. The number of infringement notices issued to accident tow truck operators/drivers by Victoria Police has substantially declined from 47 in 1998/99 to 10 in 2012/13. The 10 infringement notices issued in 2012/13 represent % of the 45,000 accident tow jobs in the Melbourne Controlled area. Failing to attend an accident scene within 30 minutes of being given an allocation comprised about 30% of infringement notices in the late 1990s. However, no infringement notices have been issued for this offence over the past four years. 2. Price Regulation The Issues Paper has asked several questions in relation to price regulation. Firstly, in relation to the Melbourne Controlled Area, should price regulation exist or should accident tow operators compete on price. Secondly, should price regulation as it currently operates in the Melbourne Controlled Area be extended to rural and regional Victoria? Thirdly, should price regulation be extended to heavy vehicle accident towing? Our submission addresses each of these questions below. The Need for Price Regulation Most regulatory reviews of accident towing have noted the market failures that prevent prices being set to reflect efficient costs and the need for price regulation of light vehicle accident towing. The Industry Commission (1995) observed; 13

14 In the accident towing market, consumers are usually in a poor position to negotiate. They are frequently in trauma, often under pressure to have their vehicle removed from the accident scene and/or inexperienced about the towing market. Few consumers have a preferred tower and, even if they did, that tower might not be available in the area where the accident has occurred. Moreover, with insurance covering towing fees, insured drivers have little or no incentive to negotiate at the scene of the accident. 1 It is important to recognize that price regulation exists in most State and Territory jurisdictions for the aforementioned reasons; most of which do not have an accident allocation scheme. Current Price Regulatory Arrangements The Melbourne Controlled Area is the only area in Victoria subject to prescriptive price regulation: accident towing base fees, per km fee and storage fees. In the self-management area of Geelong, regional Victoria and for heavy vehicle towing, the charges for accident towing are regulated. While the fees are not prescribed, the Accident Towing Services Act 2007 requires the fee charged must be reasonable. VicRoads provides some guidance on some of the factors that may be taken into account to determine whether the fee charged is reasonable: the nature of the service provided; the day and time that the service is provided; any administrative costs incurred; the amount charged for a similar towing service, such as a car breakdown; and the amount charged for the same or similar service by another accident towing operator in the same or similar area. In view of the above, the VACC considers that price regulation currently exists for light and heavy vehicle towing in all parts of Victoria. Melbourne Controlled Area The Melbourne Controlled area should continue to have prescriptive price regulation to provide certainty to insured and uninsured motorists, and to protect them from any untoward pricing behaviour that may occur in an unregulated market as acknowledged by the ESC; Regulated fees in the Controlled Area work to protect consumers from being overcharged as a result of the monopoly entitlement of the accident granted to tow truck operators through the allocation scheme. 2 We understand the ESC has had difficulties in the past developing the appropriate fee level for accident towing in the Melbourne Controlled Area. This is not surprising given that previous reviews such as Industry Commission review of Vehicle and Recreational Marine 1 Industry Commission, Vehicle and Recreational Marine Craft Repair and Insurance Industries, Report No. 43, 15 March 1995, Australian Government Publishing Service, Canberra, p Essential Services Commission, Review of Accident Towing and Storage Fees: Draft Report- Volume 2: Detailed Reasons and Methodology, March 2010, p 54 14

15 Craft Repair and Insurance Industries (1995) have noted the difficulty for governments to assess costs and set fees; Where fee regulation is used, it will be difficult for governments to assess the appropriate level of fees because a range of factors need to be taken into account (e.g. cost structures, capacity utilisation and warranted levels of return). Ideally, fees would be set to achieve that level of investment which was optimal from the community s perspective. However, as the fee that would achieve this level, and the level itself, would be extremely difficult to determine, there is a danger that fee regulation could lead to inappropriate levels of investment. 3 The ESC has previously acknowledged a single fee should be viewed as an average within the Controlled Area that will under-recover the costs for some operators and over-recover for others 4 Despite the inherent difficulty in striking a regulated fee that meets the needs of all accident tow truck operators and setting it at an optimal level from the public perspective, the current regulated fees are within the ball-park given the ESC s previous reviews that have led to some fee increases. Accordingly, there is unlikely to be a significant variation from the average hourly cost for most licensed accident tow truck operators. This is not the case for other unregulated parts of the State. Unlike other parts of the State and including heavy vehicle towing, the Melbourne controlled area provides about 45,000 accident tow jobs per annum. This permits most licensed tow truck operators to generate reasonable scale and tow truck utilisation provided they also avail themselves to breakdown, trade, police and local council clearway towing market that has even greater volumes. Increased tow truck utilisation enables hourly operating costs to decline. Some governments have adopted superior methodologies to assess accident towing costs that take into account capacity utilization, opportunity cost of the standby nature of accident towing, levels of return etc. The VACC strongly recommends that the ESC adopts the cost methodology used by the NSW Government s Independent Pricing and Regulatory Tribunal s (IPART) in its recent review of Tow Truck Fees and Licensing in NSW (2014). Comparable states such as NSW and QLD prescribe base, per km and storage fees for all accident towing operators. In the case of New South Wales, IPART has recommended a base fee of $ (GST inclusive), compared with the Melbourne Controlled area base fee of $ (GST inclusive). This is a $51.20 gross differential or $39.98 net differential (after adjusting for the different km allowances provided in the base fee). IPART has also recommended significantly higher per km and storage fees. Yet New South Wales and Victorian accident tow truck operators have almost identical labour and capital 3 Industry Commission, Vehicle and Recreational Marine Craft Repair and Insurance Industries, Report No. 43, 15 March 1995, Australian Government Publishing Service, Canberra, p Essential Services Commission, Review of Accident Towing and Storage Fees: Draft Report- Volume 2: Detailed Reasons and Methodology, March 2010, p 9 15

16 costs. Leasing is the only material cost difference between New South Wales and Victoria. While Sydney in particular has higher leasing costs compared with Melbourne, this overhead cost represents a small cost component of an accident tow truck operator, particularly where the operator has a reasonable sized fleet of tow trucks combined with high tow truck utilisation. IPART has also correctly apportioned most of the leasing costs that are relevant to smash vehicle storage in their recommended storage fees rather than the base fee. Bidding or Auctioning Allocations The ESC has previously suggested that bidding or auctioning accident allocations may be an alternative to prescriptive price regulation. 5 The requirement to arrive at the accident scene within 30 minutes after receiving an allocation limits the number of licensed accident tow truck operators that are available in the different zones across the Melbourne Controlled Area. The number of operators in each of the zones varies considerably; with inner Melbourne suburbs having more operators and some of the fringe areas having only one operator. Accordingly, the 30 minute response requirement effectively creates a number of markets within the Melbourne Controlled area. A bidding or auction system with the current distribution of tow depots would result in lower towing fees for inner Melbourne and higher towing fees for fringe areas with minimal competition. In fringe areas and also during the off-peak time (late night and early hours of the morning) towing fees could be considerably more than the current regulated fee. Most accident tows occur during business hours and some operators under a bidding and auction system that obtained a higher number of overall tow jobs during this period may well withdraw from bidding for after-hours work due to the lower volumes and higher costs. This would reduce the number of operators bidding in the different areas across Melbourne and result in higher fees. A bidding or auction system would be similar to the wholesale electricity market where generators sell to distributors based on expected demand from consumers. However, electricity consumers can affect demand and hence prices by using energy efficient appliances and/or reducing their consumption. However, a bidding or auction system would be between accident tow truck operators without any input from consumers (insurance companies and motorists). Motorists cannot predict when they are likely to have an accident and hence cannot influence price. The towing fee would be determined by the number of accident tow truck operators competing for a specific job, at a particular time and location. During business hours, the towing fee may not substantially differ from the current regulated fee. However, towing fees could substantially increase above the regulated fees for accidents that occur after-hours, on weekends and public holidays. The restricted number of licensed accident two truck operators together with the zone and 30 minute response times prevents a deep pool of bidders across all parts of the Melbourne Controlled area. 5 ibid, p 54 16

17 It would seem unfair for a motorist, particularly the uninsured that has an accident afterhours to be subject to significant accident towing fees. This could have a flow-on effect for insurance premiums for young drivers, given that most after-hours accidents involve young drivers. The current price regulatory framework provides certainty to all motorists and addresses the problem motorists face in terms of being traumatised or distressed after having had an accident, poor information about the costs for towing service and the inability to choose a tow truck operator. Self-Management area of Geelong and Regional Victoria A survey of our regional members was undertaken to ascertain the key features of their accident towing business. The survey revealed that 31 regional accident tow truck operators conducted less than 100 accident tows per annum. A further 16 operators conducted from 100 to 200 accident tows per annum. 5 operators conducted from 200 to 300 accident tows per annum. With an average tow time of 1.5 hours, most of these tow truck operators are conducting from 150 to 300 hours of accident towing per annum, with several up to 450 hours per annum. The low volume of accident towing provided by our members in the survey would appear consistent with the Emergency Services Telecommunications Authority s (ESTA) accident towing data that shows 1,911 accident tow allocations and 7,716 non-accident towing allocations across regional Victoria from October 2013 to September The 1,911 accident tows represent about 4 percent of the Melbourne Controlled area allocations. It is unlikely that the ESTA data represents the total number of accident tows in regional Victoria but it still provides an insight into the lower volumes experienced in regional Victoria relative to the Melbourne Controlled area. The key operating costs of the tow truck and running costs are at least $61,000 per annum with an hourly cost of $406 plus $30 for the driver; a total of $436 for a tow truck operator conducting 150 hours of accident towing. For 300 hours of accident towing, the hourly cost declines to $203 plus $30 for the driver; a total of $233. For 450 hours of accident towing, the cost declines to $136 plus $30 for the driver; a total of $166. The costs are GST exclusive and obviously do not include overheads (rent, administrative support and outgoings). The above hourly costs are solely based on accident towing and do not include other types of towing. Of course, it would be expected that where accident tow truck operators conduct other types of towing, their hourly costs and the towing fees charged would decline accordingly. The above hourly costs are provided solely to illustrate the significant costs incurred by regional accident tow truck operators that have low tow truck utilisation. Accident tow truck operators based in small towns such as Ouyen are likely to have a low tow truck utilisation rate and high hourly costs compared with an operator based in a large regional centre such as Ballarat or Geelong. Accordingly, prescribed average towing fees are not supported as this would lead to significant under-recovery for some operators in small regional towns, and possibly over-recovery for some operators in regional centres. 17

18 However, while no data exists on the number of breakdown, trade and police towing work in regional Victoria, it is reasonable to conclude that there would be limited opportunities to significantly reduce hourly costs compared with the Melbourne controlled area due to the different size in the markets. The number of tow trucks owned by accident tow truck operators in regional Victoria provides a useful proxy for market demand for all towing services. Our survey revealed that 27 accident tow truck operators had only one tow truck. A further 26 operators had 2 to 3 tow trucks. Turnover can also provide some indication of market opportunities. 30 accident tow truck operators estimated their turnover was less than $100,000. This is again consistent with the low volume of accident tow jobs provided by our members and by ESTA. Similarly, in the Geelong self-management area, the accident towing volumes are greater than most regional centres throughout Victoria but still low relative to the Melbourne controlled area. In addition, the Geelong accident tow truck operators fund the independent accident allocation centre. These costs are included in the base fee. Most accident tow truck operators also operate a smash repair business and it is the latter business that would, in most cases, provide the greatest turnover for the business. Insurance companies purchase both the accident towing and the smash repair services usually from the same business. As a result, the insurance companies are able to keep a check on accident towing fees as the smash repair division of the business would not jeopardise its smash repair revenues by charging unreasonable or exorbitant accident towing fees. If on the other hand, accident tow truck operators solely provided towing services, the insurance companies would not have any leverage on them in terms of ensuring reasonable fees were being charged. If the market structure comprised accident tow truck operators providing only towing services and no smash repair business, there would be a greater case for price regulation. In view of the above, the VACC considers that the current price regulation of reasonable fees for regional Victoria and the self-management area of Geelong should remain. Heavy vehicle towing Heavy vehicle accident towing is currently subject to the same reasonable charges provision. NSW currently prescribes prescriptive price regulation for heavy vehicle accident towing. As part of the IPART review, it has recommended price deregulation on the grounds that accident towing in the heavy vehicle market is different to the light vehicle market. As discussed previously, price regulation addresses the vulnerability of motorists involved in an accident and the fact that they are often traumatised or distressed, have a poor knowledge of towing services and the associated costs, invariably do not have a choice of towing service, and for insured motorists are not interested in negotiating given that their insurance company will pay for the tow. 18

19 However, these problems are unlikely to occur with heavy vehicle accidents. In most cases, freight transport companies and major insurance companies such as National Transport Insurance have contractual arrangements with licensed accident towing businesses to tow their trucks in the event of an accident, and in some cases, also to provide break-down towing and repair services. In most cases, heavy vehicle tow truck operators are not dealing with the driver at the scene of the accident but with the transport or insurance company. Unlike the light vehicle market, freight transport companies have an incentive to invest time and resources in developing an understanding of the heavy vehicle towing industry to ensure that they receive a reliable and high quality service at the least cost. In view of the different characteristics of the heavy vehicle accident towing market and in particular the commercial arrangements that currently exist between operators and freight transport/insurance companies, the VACC strongly recommends the current requirement that operators charge reasonable fees remain to provide suitable flexibility to operators and protections to freight transport and insurance companies. 3. Accident Allocation Boundaries and Zones There have been recent documented problems of VicRoads exercising administrative discretion (including at a junior level) changes to zone boundaries and co-location of depots that have had a significant impact on adjacent accident towing zones and consequently to accident tow allocations. The ESC is clearly aware of these incidents given that it raised them in its previous periodic pricing reviews. It is not necessary to detail in this submission the actual problems that have arisen in recent years. In response to these problems, the ESC recommended the establishment of Guidelines to determine accident towing zones and allocation boundaries. The VACC supports the ESC for the development of these Guidelines together with an open and transparent process with appropriate independent appeal processes for aggrieved applicants and/or other affected licensees. The ESC has suggested the criteria could include population density, traffic flow information, the number of accidents and the number of customer complaints and infringements by operators. The VACC is supportive of the aforementioned criteria other than the number of customer complaints and infringements by operators. The VACC considers that other sanctions such as suspension from accident allocations would be a more appropriate response to a serial offending operator. The ESC needs to be mindful that an operator can sell/transfer their licences to another operator and any future operator should not be disadvantaged by the previous operator s level of compliance and infringement history. 19

20 4. Accident Allocation Schemes The Issues Paper seeks views on whether accident allocation schemes should continue in the controlled and self-management areas, and whether the accident allocation schemes should be extended to unregulated parts of the State and also to heavy vehicle accidents. In asking these questions, the VACC understands that the ESC is seeking to develop regulatory design principles as to when an accident allocation scheme is appropriate for a particular accident towing market and is likely to deliver a net benefit to the community. Rationale for Allocation Schemes Firstly, it is important to understand the reasons for the establishment of the accident allocation scheme and the type of market failures it seeks to address. The accident allocation system for light vehicles was introduced in the Melbourne Controlled Area in 1983 to prevent multiple tow truck operators racing to an accident scene that often led to some tow truck drivers harassing and intimidating traumatized drivers to forcibly authorize them to tow their smashed motor vehicle and/or intimidating and assaulting other tow truck drivers to leave the accident scene. The attendance of multiple tow trucks at an accident scene caused further distress to accident victims, increased difficulty for Police and other emergency services to manage the accident scene, increased traffic hazards and unnecessary traffic congestion to other motorists. It would appear that the key drivers for smash chasing by tow truck operators are found in areas with high volumes of accidents and an oversupply of tow truck operators. This would appear a reasonable assessment given that rural areas that have a wide distribution of tow truck operators and low volumes of motor vehicle accidents have not experienced anywhere near the extent of the smash chasing that occurred in the Melbourne Controlled Area pre Hence, it would be reasonable to identify and quantify the number of smash chasing and aggressive incidents relative to the total number of accident tow jobs and the associated costs of these incidents in any given market to determine the extent of the problem and whether an accident allocation scheme is warranted. 20

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