THE WAITING IS OVER…
“All initial category C and D licence applications require a medical assessment by a registered medical practitioner (recorded on the D4 form, this does not need to be the applicant’s GP). The same assessment is required again at 45 years of age and on any subsequent reapplication.” This paragraph contradicts the first, by stating “once until the age of 45”, not every five years until the age of 45. It then becomes more puzzling by saying “and any subsequent renewal” which is every three years, how confusing, I feel an edit may be helpful to the guidance here.
6.13 Vehicle condition check “Drivers should be required to retain the vehicle checklist as proof that they have undertaken the required vehicle check.” Whilst we understand the importance of a daily check, a written record of such will achieve nothing in much the same way as hourly cleanliness charts in restaurant or pub toilets, which are clearly just ticked occasionally. We did include this in our submission. There are apps available now which maintain such a record, whilst verifying the check has genuinely taken place. It’s also worth noting that such evidence would be enough proof to submit a claim against a council for damage caused by poor road main- tenance, since you would have evidence to verify roadworthiness prior to damage. Suggesting a written record, crumpled up and shoved in a glovebox is worrying at best.
7.1 Sources of information “Checking open-source
information, cross-
checking information with bodies such as Companies House and the Office of the Traffic Commissioner, can help licensing authorities assure themselves a company is suitable to be licensed.”
Whilst some larger operators may be registered with the traffic commissioner, (although not many) and some that may be registered with Companies House as limited companies, (maybe more for the larger companies) these checks may not be relevant to smaller operators and the “one man band”.
8. Vehicle licensing Here we f ind a more detailed view than we saw in the 2010 guidance - the new guidance clearly suggests there should not be any 100% WAV policies.
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8.1 Specification of vehicle types that may be licensed “Normally, the best practice is for licensing authorities to adopt the principle of enabling as many different types of vehicles as possible to be licensed. Indeed, authorities should set down a range of general criteria, leaving it open to the taxi and PHV trades to put forward vehicles of their own choice which can be shown to meet those criteria. In that way, there can be flexibility for new vehicle types to be readily considered. Licensing authorities should give very careful consideration to a policy that automatically rules out particular types of vehicles or prescribes only one type or a small number of types of vehicles. For example, the department believes councils should be particularly cautious about specify- ing that only purpose-built taxis can be licensed, given the strict constraint on supply that implies. It may also be too restrictive to automatically rule out considering multi-purpose vehicles.”
8.4 Vehicle age limits “The setting of an arbitrary age limit may be inappropriate, counterproductive and result in higher costs to the trade and ultimately passengers. Licensing authorities should not impose age limits for the licensing of vehicles. Greater flexibility regarding the age of vehicles licensed can result in more rapid improvement in air quality than mandating new ‘clean’ internal combustion engine vehicles.”
Paraphrasing quite a lot here, but the view is to move away from age limits. This may change by the next issue of the Guidance, once the prices of vehicles has levelled out again, making vehicles more affordable.
8.8 Tinted windows “For most cars on the road today, the minimum light transmission for windscreens is 75% and 70% for front side windows. There are no rules for tinting the windows rear of the B-pillar and vehicles are often manufactured with glass in the rear that is darker than the front, especially in luxury, estate, and people carrier style vehicles. There is a significant cost and inconvenience associated with requiring drivers to replace the standard manufacturer or factory specifications for window glass, there is a lack of evidence to suggest that these are detrimental to public safety.
DECEMBER 2023 PHTM
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