IoL - ALL THINGS LICENSING
cern due to deviation of standards between authorities, and unfortunately the attempt by the guidance to bal- ance safety against a too restrictive approach is highlighted by the contradictions between paragraphs 8.3 and 8.9.
Paragraph 8.3 indicates that it may be too restrictive to licence vehicles for less than their seating capacity, whereas 8.9 states that seating capacity can be restricted for reasons of comfort and safety. A clear position for all authorities is needed to prevent inconsistency.
Tinted windows
Where the guidance does provide some clarity is around the question of tinted windows which is a ‘hot topic’ for many due to the increased use of factory fitted privacy glass. The guidance suggests that factory fitted glazing should not be removed due to the costs unless there is evidence to justify such a position.
There is a useful guidance on imported vehicles. Frequency of vehicle tests
Chapter 8 also discusses the frequency of vehicle tests, indicating that vehicles should be tested once a year. The legislation sets out that vehicles can be tested up to three times during the course of a licence. Considering that ‘normal’ motor cars are subject to an annual MoT, only testing a licensed vehicle which will be subject to consid- erable use at the same frequency is perhaps surprising, particularly given that failure rates for MoT inspections run between 20-25%.
There is an argument for testing older vehicles at a higher frequency, with a view to dropping ‘arbitrary’ age limits.
Vehicle signage
The other inconsistent issue surrounds vehicle signage. The guidance appears to favour minimal or negligible sig- nage on PHVs, with only a licence plate and ‘pre booked’ door sticker. This element could benefit from clarification to ensure a consistent approach.
CHAPTER 10 - TAXI FARE RATES
Moving to another subject close to my own interests, Chapter 10 discusses taxi fare rates recognising the Com- petition and Market Authority guidance of using fares to alleviate mismatches between supply and demand.
JUNE 2022
Chapter 10 also recommends the use of a ‘simple formu- la’ for setting fares, and again it would be beneficial for this to be identified to ensure a consistent approach.
CHAPTER 11 - RANKS AND INFRASTRUCTURE
Chapter 11 contains new guidance on taxi ranks and other infrastructure which should help ensure that authorities regularly review this important provision, although in practice this is often difficult in already busy town centres where space is at a premium.
CHAPTER 15 - TAX CHECKING REQUIREMENTS
The final chapter (15) highlights the recent tax checking requirements and there are a number of appendices, repeating the current PHV licensing guidance and model Byelaws, although changing hackney carriage byelaws is notoriously difficult.
The most useful appendices are the driver ‘daily check sheet’ which should be completed prior to using the vehi- cle each day and a number of sample notices and safety guidance.
CONSULTATION DETAILS:
No doubt the PHTM EXPO provided an excellent forum to discuss these changes. At last year’s event the Depart- ment for Transport was clear that it wanted as much feedback as possible on the consultation.
The consultation period began on 28 March 2022 and will run until 23:45 on 20 June 2022. More information is available at:
https://www.gov.uk/government/consultations/taxi- and-private-hire-vehicle-best-practice-guidance.
However this guidance alters from the consultation draft, there will be significant changes for both local authorities and the licensed trade and I would encourage members of the trade to consider its contents and feed views back to the DfT.
Yet again, there is no more important time to be ‘in the know’ about licensing issues affecting the trade and I would again encourage members of the trade to join the Institute of Licensing where the guidance is likely to be subject of many events and publications this year and after its final release after consultation.
Full details are available at:
www.instituteoflicensing.org. 9
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