TRANSPORT COMMITTEE INQUIRY
7. Introduction of residential address being considered part of “fit and proper” test
An interesting question, we believe there is clear scope to establish a defined boundary beyond which licence applications could reasonably be rejected. While there are legitimate cases where drivers may reside outside the licensing authority area, many continue to live near their licensed district and genuinely work within it.
For example, in Rossendale, many licensed drivers reside in nearby areas such as Nelson or Keighley, yet their work and licensing activities are fully centred within Rossendale itself. Likewise, some applicants may live just beyond an authority’s boundary, where their local environment - in terms of nighttime economy or access to schools - differs significantly from the licensed area, but where their proximity and intended work justify inclusion within that authority’s remit.
If residency were to form part of the “fit and proper” test, such a requirement could be structured to allow for a reasonable radius or to permit applicants to demonstrate a genuine intention to work within the licensed district. Examples exist of drivers living at greater distances - for instance, on the Isle of Wight - who nevertheless travel to and work consistently within the Transport for London (TfL) licensing area. This illustrates the importance of aligning policy with intended use, as outlined in our written and oral submissions.
We believe that a combined approach incorporating:
l Intended use policies (which would effectively end out-of-area licensing within a year)
l Geo-fencing technology (to restrict booking ranges and reinforce Section 75(1)(a) enforcement), and
l Consideration of residential addresses within licensing criteria
would collectively bring an end to the widespread issue of out-of-area operation within twelve months.
A practical example of such an intended use policy can be seen in Rossendale Borough Council’s policy:
https://www.rossendale.gov.uk/downloads/file/13839/i ntended-use-policy
While several local authorities have adopted similar approaches, these currently apply only to hackney carriage licences.
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Finally on cross-border working, it is important to clarify a point I made within my verbal evidence, where I suggested that cross-border hiring started in Berwick, this comment was not 100% accurate, the issue started long before 2007 and was only brought to light as a result of the Berwick case which can be found here:
https://www.casemine.com/judgement/uk/5a8ff7c760 d03e7f57eb201e
Suggestion / summary:
We support the establishment of a residential boundary as part of the “fit and proper” licensing criteria, provided there is flexibility to account for drivers who genuinely live outside the area but primarily work within it.
Mechanisms such as intended use policies, geo- fencing, and verifiable commuting intentions can ensure compliance while addressing the issue of out- of-area licensing effectively. Historical and practical examples demonstrate that a balanced approach can reduce cross-border hiring abuses without penalising legitimate drivers.
8. Single national licence
We do not consider this a sensible or logical proposal, as it would entirely remove local authority involvement in licensing. Implementing it would require a complete repeal of the Local Government (Miscellaneous Provisions) Act 1976, which is explicitly designed for “Local Government” activities.
If such an approach were adopted, licensing would need to be centralised under a body such as the Driver and Vehicle Standards Agency, with enforcement conducted by police forces using their powers. This would place a significantly greater burden on an already stretched police service.
The only apparent benefit of this model would be to simplify operations for large operators, allowing them to hold a single operator licence and use any driver or vehicle anywhere in the country. We believe this poses serious risks and should be avoided.
Given the current discussions around devolution, the number of licensing authorities is likely to be reduced anyway. We consider this a suitable compromise, particularly when combined with a national standard, the confusion and complexities of licensing variations will be reduced.
NOVEMBER 2025 PHTM
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