ALL THINGS LICENSING
see several hundred licensed vehicles / drivers licensed elsewhere working in our area every day it is clear to see why there has been this reduction. The reduction in numbers has led to a
operators, which hopefully would be considered by all local authorities as well as the Department for Transport as they analyse the responses received to the Best Practice Guidance consultation in order for this important matter to be addressed.
JOINT AUTHORISATION
Much is made of joint authorisation as a way to address vehicles working between areas and it remains a good idea. However, this usually develops between neighbouring authorities, and does not address the issue of the larger authorities which have vehicles working some distance away where no local arrangements are in place. Even when (or if, considering the speed at which the Government responds to taxi matters) authorities are given “national enforcement” powers against other taxis / PHVs in their area, there remains the problem of the smaller authorities having the staff available to carry out any enforcement work.
If a local authority is responsible for licensing large numbers of drivers / vehicles which then go on to work elsewhere, then this authority must take steps to address the issue. The role of the licensing authority is to protect the public, not to license as many vehicles or drivers as it can, and authorities which knowingly allow their licence holders to work in other areas need to consider the impact this practice has on other authorities and members of the trade who want to serve their residents.
If a local authority such as Guildford, where I work, has large numbers of vehicles / drivers from elsewhere, this reduces our ability to protect our residents as our standards are not upheld and our efforts are undermined by the lack of powers and resources we have to deal with the issue.
Guildford’s taxi / PH application numbers have dropped by 40% over the past five years and when we
PHTM DECEMBER 2022
It would also be unfair and counterproductive for us to raise our fees from existing licence holders so that we could provide more resource to enforce against those we do not license with new powers, as this would only serve to drive current licence holders to the cheaper authorities and reduce numbers further.
As such, in addition to joint authorisation arrangements, there absolutely must be a system of those bigger licensing authorities providing a recharge to the smaller local authorities which are impacted by out-of-area working. It is also perhaps worth noting that while joint authorisation was recommended in the statutory standards, Guildford has not had the licensing authority responsible for the hundreds of drivers and vehicles working in our area knocking on our door to authorise us to respond to their licence holders in our borough, nor has it approached us with an offer for its officers to undertake some enforcement in our area.
THE FIT AND PROPER PRIVATE HIRE OPERATOR
While the issue of a driver’s “right to roam” was considered in 2018 in the Knowsley case, how a vehicle proprietor or a private hire operator manages the roaming issue could be considered by authorities in their decision making.
Operators, like licensing authorities as discussed above, have an important role in negating the potential effects of out-of-area working and the fit and proper test noted in the draft Best Practice Guidance would be the ideal opportunity to set reasonable expectations of operators.
71
corresponding reduction in licensing officers and the issue is therefore that we do not have the resource any longer to undertake enforcement under a joint authorisation as we only have sufficient resource to respond reactively to complaints, among our many other duties.
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88
