technical, or even public safety understanding, with even less foundation of substance in any lawful or legal terms.


These then range from allowing any manufactured specifi- cation glass to be allowed - realising that those specifications must follow the national standards, other- wise they would not obtain M1 type approval, and would therefore not be available to sell to the UK market - to those who introduce their own arbitrary window light- transmission percentages, based on nothing more than personal desire and whim of the policy writers at the time.


VEHICLE LICENSING – TINTED WINDOWS


We agree that there should be no requirement for darkened glass rearward of the B-pillar (front driver and passenger seat) to be removed, given that there is no evidence that this is a public safety issue. We agree that enforcement officers could ask for a door or even a window to be opened in order to see how many passengers are inside (or anything else which may give them cause for concern).


TINTED WINDOWS


The subject of tinted window restrictions has for a very long time been a bone of contention within the taxi and private hire industry, with such a widespread variation of what is and what is not ‘allowed.’


Some local authorities simply refuse to follow and observe nationally set standards by the regulatory bodies which for this purpose is VOSA and the DVSA. This standard is very clear and reads that for the windscreen the glass must allow a minimum of 75% of light to pass through the glass, whilst the front passenger seats must allow a minimum of 70% of light to pass through the glass.


This is to remove the risk of objects not being clearly seen at junctions and from the direct line of sight and is to enhance road traffic safety.


The national standards go further to state that for all windows rear of the B-Pillar (back windows) there are no restrictions at all. This caters for vans and vehicles with solid bulkheads behind the front seats, so is actually quite an obvious and sensible stipulation to make.


We then look at local authorities, and their local opinions as to what this means for licensed vehicles, bearing in mind of course that this is quite literally all that this is, local opinions, with little to no actual understanding of mechanical,


JULY 2022


Herein lies a problem: by the very nature of the mix and match of conditions and policies, due to the lack of national standards, since this means that whilst a vehicle may be perfectly suitable for licensing by one authority, such as Liverpool, it would not be suitable to be licensed by a neighbouring authority, such as Sefton.


This has led to a number of approaches being taken based on nothing more than perceived common sense, which resulted in those authorities being challenged at various levels, including a judicial review on this subject taken against Rossendale Borough Council. This resulted in a consent order being issued by the High Court, agreeable by both parties, in this case Rossendale Borough Council and the Rossendale Taxi Association, which read: “the restrictions on tinted windows would be removed from policy.”


Another approach, at the request of a car dealership, was to launch a nationwide campaign on this subject, since they could only sell cars to drivers from a reduced number of local authorities due to such restriction being in place for some, but not for others; the result of this was the publication of two articles in the national trade publication, Private Hire and Taxi Monthly (PHTM) in July and August 2021.


In these articles, and in the judicial review, NPHTA relied heavily on the reasons why manufacturers were moving, and indeed had move towards rear tinted glass as standard, which were actually quite widespread, including public safety, passenger comfort, and emissions reductions.


With this in mind, NPHTA, as the largest specialist nation- wide trade representative body, welcomes and appreciates the comparison shown within this consultation, which quite simply put, compares a private hire vehicle and driver, (standard private hire) to a private hire vehicle and driver (executive and chauffeur work) asking the very clear question, why is one private hire vehicle allowed tinted windows, when the other private hire vehicle is not?


47


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