NAL THE END OF THE INDEPENDENT CABBIE?
dealing with Covid-19 related matters. It is understandably tempting to let matters run their course with licensed vehicles and react to changes in the future. However, this course of action may limit the scope of future action. Alternatively, collecting information about current and evolving conditions enables licensing authorities to plan and act for the public benefit.
Lack of action at this time, where licensing authorities maintain a hack- ney carriage limit, can lead to bids for additional hackney carriage licences, accompanied by the threat of legal action if refused, on the basis that the limit is not based on current information regarding the adequacy of provision. If anecdotal evidence suggests that the num- ber of available hackney carriage drivers and/or vehicles is reduced, then any challenge to a limitation policy could be difficult to defend.
CONCLUSIONS
Some factors may be considered to benefit the public. Others cer- tainly do not.
WHAT DOES LVSA CONTRIBUTE TO THE DEBATE?
A large proportion of our business is conducting hackney carriage unmet demand surveys. These surveys are conducted in licensing areas which limit the number of hackney carriages which may be licensed. In order to justify a limit, it should provide a benefit to the public. If a licensing authority wishes to retain an existing limitation policy or implement a new limitation policy, then they must be satis- fied that the level of provision of hackney carriages is sufficient to meet demand and that there is no significant level of unmet demand from passengers (Section 16 of the 1985 Transport Act).
Surveys are undertaken periodically to gather information on which to base the judgement regarding hackney carriage limits. DfT guid- ance recommends a survey is undertaken at least every three years.
Some may consider that the changed circumstances at present, with reduced levels of demand and fewer drivers operating the licensed vehicles in most areas, means that undertaking a HC unmet demand survey would be inappropriate. However, in order to protect the pub- lic and ensure that licensed vehicle services are providing a beneficial service to the public, it is essential to know what is happening cur- rently. Used wisely, the information collected can also enable authorities and councillors to see how they can help the trade move forward and continue to contribute to economic survival and recovery.
UNINTENDED CONSEQUENCES TO MITIGATE AGAINST?
For example, if hackney carriages are currently off road with Statuto- ry Off Road Notices (SORN), these clearly cannot be used to carry passengers. Do such vehicles continue to comply with licensing reg- ulations? Vehicle licences run normally for a year, and in some cases are renewed at the same time each year. Few authorities offer any recompense for early surrender of a licence. Even if a licence is held, the vehicle still needs a driver, with some proprietors seeking to rent, and often now not being able to do so.
HC and PHV drivers are often licensed for three years before licences need to be renewed. Therefore, it can be up to three years before licensing authorities know that drivers have left the industry.
Where a small number of players dominate the local licensed vehicle market, it is only these players who know the level of demand and the level of availability of vehicles and drivers to service demand. This effectively places control of supply and pricing in the hands of these individuals.
Licensing officers are placed under a great deal of pressure currently, OCTOBER 2020
So, do the changes that have occurred mean the end of the indepen- dent cabbie? Probably not the end, but certainly increasing the challenges faced.
Should licensing authorities act? It is difficult to say with certainty. Generally speaking, it is better to plan and act on knowledge of the public requirements and licensed vehicle provision. However, there are limits to what action can be taken.
On the other hand, just waiting to see what happens takes more con- trol of action away from the licensing authorities. The issue is that Spring 2021 will be nearly a year after the pandemic began, and very few individuals can continue for such long periods without having to change to adapt to the revised situation – which may lead to loss of significant experience to the trade unless authorities show support and encouragement.
The consideration of whether one should wait until the situation becomes ‘more normal’ is also influenced by factors which are not readily apparent. What is the new normal that we are waiting for? Is it for the level of passenger demand to return to 2019 levels? How will we know? How long should we ‘wait and see’? Does the public deserve the same level of protection and service benefit now as they did before Covid-19? Should we enable more control of the market and supply of licensed vehicles, to pass into the hands of large cor- porate entities?
This article was written from the viewpoint of what best benefits the public. It doesn’t advocate any form of protectionism for existing businesses or to promote or object to the growth of major corporate entities. Both provide benefits in different ways. We recommend that the industry is mindful of what balance will best serve the public and in turn, best preserve the market for the licensed vehicle trade to ser- vice.
But more than anything, we encourage you to gather information, draw it together and work together for the future. We have a good number of clients whom we have provided information for over the years and who can demonstrate policies based on the reviews we have done for them have benefited the public, the trade and the economy. If you are not already one of them, join in!
You can contact us by first emailing:
ian.millership@
lvsa.co.uk or
iain.macdonald@
lvsa.co.uk.
LVSA (Licensed Vehicle Surveys and Assessment) is a joint trading name of CTS Traffic and Transportation and Vector Transport Consultancy
www.lvsa.co.uk 45
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