...CAPITAL NEWS Recommendation 4


TfL should work with stakeholders to determine whether there is unmet need for wheelchair accessible vehicles. If this is found, TfL should explore whether requir- ing larger operators to provide a minimum proportion of accessible vehicles within their fleets would resolve this issue.


The setting of percentages of WAVs within a private hire fleet has proven over the years to be entirely too subjective; as dis- cussed widely amongst the Task and Finish group, the parameters of setting such per- centages are difficult to set down. The Government agrees, as demonstrated by its response to the TFG recommendation 30 concerning percentages of WAVs espe- cially on private hire fleets:


“We will


continue to monitor the proportion of WAVs within overall taxi and PHV fleets… and seek clarification from authorities as to the steps they are taking to assess and respond to the local need for such vehi- cles.” It really is a matter of assessing unmet demand locally, both in London and all other licensing authorities with low numbers of WAVs.


Recommendation 5


TfL should consider how an accreditation scheme can contribute to raising stan- dards and come forward with specific proposals for a Charter Mark scheme. TfL should also review the criteria for ‘fit and proper tests’ for private hire operators, in line with Government findings.


It is submitted that an accreditation scheme, with specific proposals for a Char- ter Mark scheme, would be the most positive move TfL could take for the private hire industry in the capital at this time – apart from removing the congestion charge exemption and reducing their horrendous fee structure, neither of which looks like happening. However, it should come with the caveat: Who would determine the Charter Mark levels of achievement/accred- itation for operators? They must be fully experienced and qualified to pass judgment on the calibre of operators, and to rate them according to a set of criteria put down by ?whom? – as this type of judgment is always subjective in nature. Of course the ‘fit and proper’ criteria for PH operators is being reviewed outside London as well, and the two sets of criteria should rightly be in line with each other.


Recommendation 6


TfL should consider whether elements of the New York model could be applied in


MAY 2019


Right: we’re talking about a third tier of licensing here, which you may or may not agree with in principle. However it is easy to see why New York has gone down that road, and they have fewer hailed taxis than London. The concept is sound; it remains to be seen as to whether this third-tier idea would work in practical terms. What is rev- olutionary is the basing of operator fees, issuing the operator licence etc., on vol- ume of bookings rather than fleet size. Certainly there should be an obligation for the larger fleet management to submit congestion statistics – not only for the administration of any third tier, but also to get more accurate figures on the impact of the combination of the congestion charge and the Clean Air charge.


Recommendation 7


We urge TfL to work with stakeholders to develop proposals for a framework for regulation of on-demand bus services that addresses the convergence of private hire and bus services.


We’ve said it many times before: the abil- ity to run on-demand bus services has been in existence both inside and outside London since the passing of the Transport Act 1985. However, there has been very lit- tle take-up of these services around the country. Is this because of lack of demand? Lack of funding for the vehicles? Lack of


direction on the part of the licensing authority(ies)? Surely the survival of such services in London would depend upon the availability (or lack) of current bus ser- vices.


Recommendation 8


We urge the Mayor to bring forward a more comprehensive analysis of the potential benefits and risks of ride sharing for drivers and passengers, with a view to developing appropriate regulation, backed by calls for new legislation as necessary.


London, with a new type of high-volume operator licence based on the number of journeys an operator carries out, rather than simply the size of its fleet. In particu- lar, TfL should consider how to review the current tiered licence fee structure to reflect proportional impact of the opera- tor on enforcement and administration, rather than size of fleet. TfL should also consider whether introducing require- ments on high volume operators to submit an analysis of their impact on congestion, and anonymised trip data, should be repli- cated in London.


The feedback we have received from licence holders from all over the country pretty much runs along similar lines: that whilst the concept of ride sharing might sound like a sensible, economical way of conveying more passengers and gaining more/better fares, the risk factor(s) may well outweigh the benefits in these circum- stances. The most glaring example would be the outcome of putting strangers in a vehicle with either children or vulnerable adults, who may well feel threatened or unsafe in some way. Those feelings are often shared by able-bodied and ‘ordinary’ (non-vulnerable) passengers as well. Add drink and/or drugs to the formula and you’re really asking for trouble. With respect, one cannot


legislate for


behavioural changes or abnormalities on the part of any passenger. It is submitted that ride sharing should not even be con- sidered without the presence of solid-state CCTV inside the vehicle.


Recommendation 9


We reiterate our calls for TfL to improve its engagement with drivers, operators and passengers for both the taxi and pri- vate hire trades, recognising that each group has distinct concerns and needs that must be effectively addressed through regulation.


Hallelujah! We cannot shout it loudly enough:


improved engagement with


every segment of the industry as listed above is the responsibility not only of Transport for London, but of each and every licensing authority in the country. Improved engagement should start with more communication: education of the travelling public via press and broadcast media; direct communication with all licence holders in the district by way of letter or email, rather than just saying “look it up on the council’s website”; and overall, not just talking but listening - to gain more detailed insight into the indi- vidual issues and difficulties faced by every group.


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