TAXI AND PHV: BEST PRACTICE
At this point a driver should be able to stop working in the interests of their own safety, that of their passengers and other road users. They also need to maintain an appropri- ate work/life balance for their physical and mental health and for the emotional wellbeing of themselves and their loved ones.
Operators often set fares low, not to be competitive because this industry is not particularly price-sensitive but to make drivers work more hours. For the most part, journeys in a licensed vehicle are usually in the context of much greater expenditure. Whether the journey home from a local supermarket with groceries costs £4 or £5 is relatively insignificant if the weekly shop is over £100. Equally, a group of four on a night out to a neighbouring town or the bright lights of the big city are not going to care very much whether the return fare is £40 or £50 as that is only an extra £2.50 per passenger compared with the overall expenditure on the night out. A ten-pound dif- ference for an airport transfer is insignificant in comparison with potentially thousands of pounds spent on a family holiday.
However, these differences will significantly affect the number of hours needed for a driver to reach their required earnings threshold. The longer it takes for a driver to work through the various thresholds the more hours they will need to work. Drivers have frequently been working through their tiredness threshold long before they reach that of their required earnings. For the operator, a driver working 80 hours is the equivalent of two drivers working 40 hours.
When Travis Kalanick was CEO of Uber he actively discour- aged passengers from tipping the drivers. This was clearly intended to make them work longer hours.
We know from the public reaction to P&O Ferries sacking 800 staff members and subsequently hiring new staff below the minimum wage that the general public tend to take a dim view of exploitation, at least when they are made aware of it.
Whilst it would be neither practical nor desirable to set mandatory limits to driver working hours or distort the market by fixing fares, we do need to establish an appro- priate regulatory framework to ensure that drivers are not exploited. If consumers have a wide choice of operators and business models, so do drivers. Competition for drivers on the part of operators is healthy in this regard. For this reason, a level regulatory playing field allowing a variety of operator models, large and small, app-based, telephone based or both, on-demand only or via advance bookings to participate is essential.
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However, drivers should be discouraged from switching between operators on an ad hoc or momentary basis, as explained below.
VEHICLE LICENSING – IDENTIFICATION AND SIGNAGE
If drivers are encouraged or permitted not to carry any signage advertising a given operator, they are free to switch from a local or regional operator to app-based platforms or even ‘multi-app’ from moment to moment. This completely undermines the facility for passengers to make advance bookings or be given reliable lead times when making ASAP bookings.
Whilst drivers are usually free to start and finish working when they choose, predictable working patterns tend to emerge which allow operators to assess driver availability at any given time before accepting a booking. When drivers are able to switch between operators without notice, in some cases after they have already accepted a journey from an operator, there is no such predictability. Moreover, it is at times of high demand that drivers are more likely to switch operators, suddenly and without warning.
By undermining the facility to pre-book, the proposal to allow the removal of all signage advertising a given operator tilts the playing field decidedly in favour of the on-demand-only platforms and against both traditional operators, especially smaller ones that do not use automated systems to inform the passenger of the vehicle description and registration number at the time of dispatch, and the wider public interest.
Another NPHTA board member, Des Broster, who repre- sents VEEZU, a company which operates in a number of areas with their own local or regional brands across the UK has expressed his concerns in this regard.
We propose that in this Best Practice Guidance, licensing authorities are actively encouraged to apply restrictions to drivers’ freedom to switch from one operator to another on a momentary basis.
This is not to say that we believe that drivers should be required to work exclusively for a single operator. A driver may, for example, wish to accept most of their journeys from one operator but have a school contract through another. They should also be free to choose which operator they work for over the longer term.
We agree that private hire and hackney carriage vehicles should be clearly distinguishable from each other in accordance with Sections 47 and 48 LGMPA 1976.
JULY 2022
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