ALL THINGS LICENSING Reminding ourselves that Section 48 (6) (a) says:


“Subject to the provisions of this Part of this Act, no person shall use or permit to be used in a controlled district as a private hire vehicle in respect of which a licence has been granted under this section unless the plate or disc issued in accordance with subsection (5) of this section is exhibited on the vehicle in such manner as the district council shall prescribe by condition attached to the grant of the licence.”


So, section 75 allows the council to grant an exemption to the legal requirement to display a licence plate on the vehicle. This ‘plate exemption’ as it is commonly known is used up and down the county by authorities for vehicles undertaking a wide range of work, with ‘executive hire’ being a regular practice.


Unfortunately, like many other areas of licensing, there is considerable variation between local practice with councils adopting different standards on the type of vehicle and work where an exemption may be permitted. I have seen many examples of what could only be described as a ‘rather old family saloon’ being granted an exemption while other local authorities adopt a far stricter criteria.


Draft Best Practice Guidance


This variation is perhaps not helped by the current ‘Best Practice Guidance’ being silent on the issue of plate exemptions. The more recent draft Best Practice Guidance consulted upon last year offers a bit more on the practice and stated:


“Licensing authorities should only exempt the display of a licence plate by a private hire vehicle in exceptional circumstances. ‘Executive hire’ services are licensed as private hire vehicles and licensing authorities should assure themselves that, given the signage on private hire vehicles will be negligible, there is sufficient justification to exempt these vehicles from a requirement to display a small plate or disc in the absence of an effective means to prevent the vehicle being used for ‘normal’ private hire work.”


PHTM JULY 2023


Vehicle Signage - Need for Consistency


As I have written previously, the issue of vehicle signage is often an inconsistent one and one where there needs to be a more constant national picture. Clearly the above paragraph isn’t the uniform position we are looking for as it indicates signage on private hire vehicles will be negligible whereas elsewhere in the draft it advocates for PHV signage to be a licence plate and a ‘pre booked’ door sticker. This element could benefit from clarification to ensure a consistent approach.


Again, I am not going to get into the arguments for and against vehicle signage in this article, however the above does seem to suggest the approach of only granting an exemption in exceptional circumstances, which is one I agree with. Generally executive hire and airport transfers seem to be a common reason for exemptions to be requested and I struggle occasionally to understand how the dignity of the average business traveller could be affected by being seen in a taxi or PHV going to the airport.


However, being a fan of classic and high-performance cars I could understand the argument of not wishing to drill a rather expensive hole in your pride and joy if it were licensed!


I am not expecting the updated Best Practice Guidance to offer a comprehensive guide to plate exemptions and performance racing cars when it is published, however if it does, you can be confident that being a member of the Institute of Licensing you would be able to find out all about it.


Full details are available at: www.instituteoflicensing.org.


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