vehicle registration mark of the vehicle. If more than one vehicle with the operator’s logo is in the area, the passenger would again need to check to see if the vehicle was for them or rely on a unique identifier.


WOLVERHAMPTON PHV SIGNAGE NPHTA COMMENT:


An operator’s details can help narrow down the vehicles a passenger would enquire with, but this assumes that the booking is not sub-contracted or that if it is, the passenger is advised of the details of the operator fulfilling the booking. In the interest of safety, passengers should always verify the vehicle they have been allocated.


On the issue of the carrying of children, I am aware that we have already corresponded on this issue back in July. As I set out then, the Best Practice Guidance says:


“The safest way for a child to travel by car is in an appropriate car seat. It is however unreasonable and impractical for a taxi or private hire vehicle to carry a range of seats to meet the possible needs of all passengers. If the correct child car seat has not been provided, the law allows children to travel in taxis and private hire vehicles, but only if they travel on a rear seat; children under three can travel in a rear seat without a seat belt, and children who are three or older must wear an adult seat belt.


Children aged 3 and over should always count towards the licensed capacity of the vehicle because if an appropriate car seat is not available, they must wear an adult seat belt. Children under the age of 3 do not need to wear an adult seatbelt when an appropriate car seat is not available, so they do not need to count towards the licensed capacity.


Licensing


authorities should provide advice to licensees on its policy on the carriage of children under three years to provide certainty in terms of overloading and refusal of carriage in such situations.”


As you have noted some licensing authorities do provide advice to licensees on their approach to provide certainty over ‘overloading’ of licensed vehicles.


I hope this explains the position taken in the Guidance, although I appreciate that you have different views on what should be best practice.


Yours sincerely Taxi and PHV Policy Team


PHTM OCTOBER 2024


Having read the report from iCars we have to say this is extremely detailed, very well written and accurate on all points. The NPHTA did raise the very same concerns within our response to the Department for Transport consultation.


We are also concerned that the DfT seems to think that a passenger should not be counted as a passenger for licensing purposes where it says: “Children under the age of three do not need to wear a seatbelt so they do not need to count towards licensing capacity.”


In our view this would be a direct breach of licensing conditions, the Road Traffic Act 1988 and insurance regulations. If there is a person in the vehicle regardless of age or seatbelt, they still have a head and a bottom and must therefore be counted as being a person. We have raised this concern directly with the DfT, both in writing and verbally, in Institute of Licensing meetings. There are other concerns within the guidance such as the way in which Group 2 medical records are written, but that is a whole separate matter.


Whilst we do understand the desire from some drivers to be less identifiable, we are of the opinion that the DfT has gone too far by stating that all such signage should be removed as opposed to leaving it optional. The reason for this is because many operators do own those vehicles; many elderly people are indeed vulnerable people and do not, as stated, receive electronic notifications; there are also people with disabilities, such as sight impediments and dyslexia, who do not have the ability to read such messages anyway.


We have also seen other examples of operators who have dispatched vehicles, and the passengers refuse to get into them since they have no visible markings to verify:


l they are licensed at all l they have been sent by the correct operator l they are easy to identify as being legitimate


We would agree with the concerns raised by iCars (Swale) Ltd in their entirety and suggest or recom- mend that the DfT changes its stance, and local authorities should be allowed to keep PHV signage optional since there may be those who wish to remove signage, and those who do not.


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