TAXI AND PHV: BEST PRACTICE
At 8.23 under Vehicle Testing on page 37 of the draft guidance it is stated:
More frequent tests may be appropriate for older vehicles which may be more prone to mechanical defects.
This effectively acknowledges that older vehicles may be less reliable, more costly to run in terms of maintenance and repairs and potentially less safe. It also contradicts the following statement in the consultation document:
Removing age limits should not undermine safety provided those vehicles are maintained appropriately and inspected rigorously.
At 8.28 it is stated:
The frequency of testing required (see ‘frequency of vehicle tests’ above) to ensure the ongoing safety of vehicles is a separate issue to the setting of maximum age limits at first licensing, or maximum age limits beyond which an authority will not licence a vehicle. The setting of an arbitrary age limit may be inappro- priate and counterproductive and result in higher costs to the trade and ultimately passengers.
For example, a maximum age for first licensing may have adverse unintended consequences; a five-year- old used electric vehicle will produce less emissions than a new Euro 6 diesel or petrol fuel car – enabling the trade to make use of previously owned vehicles will assist it to transition more rapidly to zero emission vehicles and improve air quality.
It is clear that this statement is disingenuous and driven by corporate interests when it is obviously entirely feasible for an age limit policy to differentiate between different vehicle types. For example, in Cannock Chase it is proposed, subject to consultation, that age limits for vehicles on being licensed for the first time are set at three and a half years for ICE-only vehicles until 2026 when they are to be phased out altogether, five years for HEVs, PHEVs and EVs and 10 years for wheelchair-accessible vehicles.
8.29 states:
Licensing authorities should not impose age limits for the licensing of vehicles but should consider more targeted requirements to meet its policy objectives on emissions, safety rating and increasing wheelchair accessible provision where this is low.
The proposal in Cannock Chase meets all these objectives above without removing age limits.
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The automotive industry constantly improves standards through research and development into emissions (not just from any tailpipe but also from braking systems and tyres), noise levels, active and passive safety including better braking systems, Autonomous Emergency Braking which can now act to prevent collisions with pedestrians as well as other vehicles, Active Lane Keep Assist and new manu- facturing process technology which both reduces vehicle weight and offers better protection for passengers in the event of collisions.
With appropriately-set age limits, all these benefits will feed automatically into the makeup of licensed vehicles without the need for any friction between the trade and licensing authorities or any ‘cliff edge’ associated with a more targeted approach. It is worth noting that all ICE vehicles produced after September 2015 comply with Euro 6 standard without the need for any ‘targeted approach.’
In an ideal world, all vehicles licensed for the first time would be brand-new giving both drivers and the travelling public access to the latest automotive technology, safety, comfort, and environmental benefits. At the opposite extreme we abolish age limits altogether in order to satisfy the corporate lobbyists.
Somewhere between these two extremes lies a happy medium which takes into account all the above men- tioned factors, ensuring that high standards are balanced against affordability, availability and sustainability for the trade.
Such a balance should be left to each licensing authority to determine, subject to consultation, with all interested parties.
In licensing areas where there are no age limits we have seen licensed vehicles which are over 20 years old. We need to ask ourselves the following questions:
• Are vehicle standards from 20 years ago likely to be appropriate today?
• Are today’s vehicle standards likely to be appropriate in 20 years’ time?
• If the only time a member of the traveling public ever sets foot in a vehicle so old is when it is a licensed vehi- cle for which they are paying a fare, what effect will this have on public perception of our trade?
• What impression will this give of our trade to foreign tourists in particular?
JULY 2022
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