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TRADE RESPONSES


SHPHA RESPONSE TO COMPANY CONDUCTING UNMET DEMAND SURVEY FOR SOUTHAMPTON CC


l Uber’s pricing strategy further compounds these issues. The company reduces fares during the day, which destabilises the market, and imposes significantly higher charges at night through surge pricing. These inconsistent fare structures affect both driver earnings and public trust.


l One of the core problems lies in the outdated legal framework,


namely the Local Government


Southampton City Council limits the number of hackney carriage licences to 283.


To maintain this number, the council employs LVSA to carry out an unmet demand survey on its behalf.


Here is Ian Hall, chairman of Southampton Hackney and PH Association’s, response:


“Good evening Mr MacDonald, LVSA


Thank you for your correspondence, which I have read carefully, along with the responses provided by Perry McMillan and Mark Paget.


In response to your question regarding how the trade has changed in recent years and the challenges we now face, I would like to share the following observations.


l The taxi and private hire trade has undergone significant transformation, primarily driven by the emergence of digital ride-hailing platforms such as Uber. While these platforms have undoubtedly introduced convenience for the public, they have also presented numerous challenges for local operators and regulators.


l In Southampton, we are currently experiencing serious difficulties due to an increase in Uber- licensed private hire vehicles operating within the city. A particularly troubling issue is **cross-border hiring (CBH)** - where vehicles licensed by other authorities work almost exclusively in Southampton. This undermines local regulation and creates an uneven playing field for Southampton-based drivers and operators.


32


(Miscellaneous Provisions) Act 1976, which was introduced well before the advent of mobile phones and internet-based platforms. This legislation is no longer fit for purpose in an era dominated by app- based booking systems, and urgent reform is needed.


l Moreover, enforcement capacity is lacking. Local councils are unable to dedicate sufficient resources to ensure compliance across such complex, digitally operated networks. Without robust enforcement, it becomes difficult to uphold standards and ensure public safety.


lWe also face a transparency issue: in Southampton, the names of private hire operators have been removed from vehicle door signage, meaning there is now no clear accountability as to which operator is responsible for a given vehicle. This undermines both public confidence and regulatory oversight.


All of these factors must be taken into account when conducting unmet demand surveys and similar consultations.


It is imperative that the Department for Transport’s Transport Committee consider whether new legislation is required to regulate apps and digital platforms more


effectively, ensuring fairness,


accountability, and safety in the evolving landscape of our trade.


Thank you for the opportunity to contribute to this discussion.


Regards Ian Hall Chairman Southampton Hackney and PH Association (SHPHA)”


SEPTEMBER 2025 PHTM


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