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THE LATEST CAMPAIGN


changed as a matter of urgency including many officers working from home, many licensing departments having closed to the public, and many regimes having moved online.


However, this is such an urgent matter but it must be addressed very soon, since there are very few modern vehicles that have a clear glass option, and with the push for newer vehicles, this could very well result in there being very few vehicles to license.


Is this really such a problem?


Yes - since in most cases there is no clear glass option at all. Changing glass in this way is a vehicle modification which could void the vehicle warranty, and potentially void the insurance too since the vehicle is no longer adhering to manufacturers’ specifications.


Add to that the costs incurred, which can be as extreme as costing over £1,000 per vehicle, based on nothing more than local opinion, or the difficulty in sourcing a new enough vehicle which is Euro6 without tinted rear windows.


Do tinted window restrictions affect passenger safety or reduce risk?


As a part of our Judicial Review on this topic, we made use of a national FOI request sent to all UK police forces which asked this question very clearly.


“Has the fact that a vehicle has tinted windows ever been considered to be a factor in any taxi or private hire related incident?”


The answer from every single police force in the UK was a resounding: “No, tinted windows have never been considered to have any bearing at all in any taxi or private hire related incidents.”


What does the Regulators’ Code state?


1. Regulators should carry out their activities in a way that supports those they regulate to comply and grow.


1.1 Regulators should avoid imposing unnecessary burdens through their activities and should assess whether similar social, environmental and economic outcomes could be achieved by less burdensome means.


Regulators should choose proportionate approaches to those they regulate.


1.2 When reviewing policies, operational procedures and practices, regulators should consider how they might support or enable economic growth for compliant busi- nesses, for example, by considering how they can best:


AUGUST 2021


• understand and minimise negative economic impacts of their regulatory activities.


• minimise the costs of compliance for those they regulate. • improve confidence in compliance for those they regulate, by providing greater certainty.


Evidence based?


As mentioned, there is not one scrap of evidence to suggest that any wrongdoings or crimes within any licensed vehicle – against passengers or drivers - have taken place in a taxi or private hire vehicle, where the presence of tinted windows was considered a factor, nor was the result of bad visibility through the rear glass, in fact the opposite is true.


Justification?


Think about it: during the night when our drivers are at their busiest, and most vulnerable, a police or council officer would not be able to see inside most licensed vehicles anyway whilst driving past whether they had tinted glass or not: it’s too dark!


It’s decision time!


Now more than ever due to the changes that have taken place over the last eighteen months including: the effects of Covid- 19; the financial impact; the lack of financial support across the entire industry; the new requirements including newer, cleaner, greener vehicles; entry age reductions; and the intro- duction of Clean Air Zones in many regions, all of which affect the taxi and private hire industry… isn’t it logical to have a sen- sible approach, to wake up and smell the coffee and to have a look at the current vehicle market and see what is actually available?


Please, we implore you all to do something to support the licensed trade and put measures in place to help. We’re asking for policies in line with the current structure of the law (i.e., Construction and Use regulations, in place since 1986) and not the whim of local authorities; policies and conditions must be supported by national regulation.


Forward planning – future proofing licensing


Consideration must be given to the availability of new vehicles into the future – which will be difficult enough as is, with emissions caps, CAZ charging, lack of electric charge points and new vehicle price tags that are prohibitive to the extreme - without the further constraint of clear glass on top.


The phrase “reasonably necessary”, which pops up just about everywhere in the LGMPA 1976, should be applied to tinted glass in licensed vehicles. Come on!


ACT NOW – BEFORE IT IS TOO LATE! 7


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