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simple through an app on their smart phone. These services are, for the most part, on-demand services only with no real facility to book journeys in advance. A ‘sched- uled trip request’ is just that, a request made for a given time set by the user. It is little more than an organiser and does not form the basis of any purported contract between the licensed operator (the app platform) and the passenger.


As a result, these platforms manage fluctuations in supply and demand through dynamic pricing or ‘surging.’


Where it is a mandatory requirement (this is NOT a driver choice, nor is it to enhance his or her desires), it is in fact a requirement imposed upon them by the local authority on the basis of public protection. So when we hear and see: “Why should we pay for CCTV in vehicles?” from local authorities, this is the wrong question to be asking.


The truth is that local authorities are demanding or mandating, forcing, or insisting on such installations on the pretext of public safety, so the question should be: “Why would the local authority NOT be supporting and subsidis- ing public safety initiatives?”


These devices are not spare wheels. They are not first-aid kits. They are not replacement windows. They are public safety evidence gathering devices, protecting both the travelling public and the licensed member of the public driving the vehicle.


A LEVEL PLAYING FIELD


When passengers wish to book a licensed vehicle, they have a number of options. They can use one of the app platforms such as Uber, Bolt, Ola, Hailo, Gett, Free Now, etc. or large regional and local companies that may also accept bookings via an app as well as by telephone.


The public interest is served by ensuring that such freedom of choice for the consumer is maintained. For this, the regulatory playing field should not be tilted in favour of the international app platforms over more localised services (or vice versa).


The international app platforms have the advantage, from the consumer’s perspective, of being widely known and available across much of the UK, certainly in urban areas. The process of making a request for a journey is quick and


JULY 2022


In order for on-demand services to function 24/7 without wild fluctuations in fares they need more vehicles and drivers than the more traditional telephone-based opera- tors who are able to flatten the curves of supply and demand by offering lead times when demand is high. The customer is essentially placed in a virtual queue with an estimated waiting time instead of paying a premium, but a purported contract is essentially in place between operator and passenger. This is important from a public safety perspective to ensure that passengers, especially vulnerable persons, are not left stranded.


The facility to book in advance, establishing a purported contract between the operator and passenger in so doing, is clearly in the public interest, particularly when passen- gers have scheduled appointments to keep or need to catch a bus, train or flight at a given time. This is the unique selling point of the more traditional regional or local oper- ator and it should not be undermined, potentially by corporate lobbying.


Operators, particularly those only offering on-demand services not only need as many drivers as possible to function as intended, the drivers also need to work long hours to ensure availability through peaks in demand. When drivers are working on a self-employed basis driving their own vehicles they have a number of thresholds to cross on their way to earning a living wage in the following order:


1) Cover fixed costs - vehicle purchase/finance, licensing, compliance testing and/or MoT, road tax, insurance and depreciation through age, operator rent or ‘settle.’


2) Running costs – fuel, servicing, repairs, mainten- ance and depreciation through use, operator commission fee.


3) Earning a living wage. 4) The tiredness threshold.


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