The LCDC Presented this to Val Shawcross City Hall

Which way now, Ma’am?






Does the London Taxi Trade have a future?

The question that is on every Cabbie’s lips! What sort of Taxi service does the Mayor want for London?

Taxis in London have found themselves at a fork in the road and someone needs to make a choice as to which way we should go.

The PH Act, which was introduced to London in 1998, wasn’t particularly well written or clear on how certain issues would actually be carried out, or the impact they would have on the London Cab & Hackney Carriage Acts.

London is unique and until the new legislation was brought in, it wasn’t really necessary to define ‘plying for hire’ because it was what Taxis in London did and the rules about who could drive a Taxi or what a Taxi looked like were stringently enforced.

To be a London Cab Driver one needed to drive a vehicle built for the purpose and to pass several tests. A ‘fit and proper’ person background check; a driving test on the the purpose-built vehicle and show that one had a pretty good knowledge of London, so that he/she knew where they were going. That seemed pretty sensible for a Taxi Driver.

That test became known as “The Knowledge” and is considered on par with studying for a degree, taking several years to pass.

But now we have new technology in the shape of Satellite Navigation systems via GPS (or Sat-Nav’s as they’re known for short), so do we really need ‘The Knowledge’?

2Well, the previous Mayor, Boris Johnson concluded on the 16th of December, 2015, that: “The Knowledge is vital.  It has proved itself over many years to be a unique feature of the London taxi trade and something that passengers certainly value.  It would be a great shame to lose that.  Many experiments have shown that the Knowledge is vastly superior to Sat-Nav, TomTom or whatever.”

Now we know you don’t really need former Mayor Johnson’s help, because as Chair of the Transport Scrutiny Committee, you thoroughly investigated Taxis and Private Hire with Caroline Pidgeon in one of the London Assembly’s longest running inquiries. Your ‘Future Proof’ Report set out 19 recommendations which you published in December 2014.





Future Proof Recommendations

Appendix 1 – Recommendations

Recommendation 1
By May 2015, the Mayor should publish a long term strategy for the development of both taxi and private hire industries. The strategy should clearly set out the Mayor’s position on the continued role of taxi and private hire services in London, and actions that will improve passenger and driver safety, guarantee a sufficient number of high quality drivers and vehicles across the city, and ensure that all services meet the highest possible standards for accessibility. The strategy should also set out how TfL will strengthen its enforcement and clamp down on illegal activity, within a clear and transparent governance and decision-making framework.

Recommendation 2
By May 2015, the Mayor and TfL should develop specific public awareness campaigns which show how to correctly identify whether a driver/vehicle is licensed.

TfL should also work with the tourism industry to ensure that visitors arriving in London have access to this information.

Recommendation 3
By May 2015, TfL should further develop the database that links drivers to vehicle and operator information. TfL should work with app developers to produce a tool that will enable passengers to check the status of their driver, vehicle or operator.

Recommendation 4
By May 2015, TfL should produce a signage strategy for the licensed taxi and private hire industries, including plans to pilot number plate-based fixed signage.

Recommendation 5
By March 2015, The Mayor and TfL should report back to the Assembly on options to incentivise the uptake of cashless payment options, for both the taxi and private hire industries.

Recommendation 6
By May 2015, the Mayor and TfL should set out how they intend to monitor and improve supply and demand, for both taxi and private hire industries, across London. This should include a specific study into potential demand for taxi services in outer London town centre locations.

Recommendation 7
By May 2015, the Mayor and TfL should set out plans to ensure that all Underground stations located on the 24-hour Tube network have a taxi rank in place by the launch of the programme in September 2015, and suburban Underground and National Rail stations have a rank by May 2016. TfL should also prioritise rank provision in outer London town centre locations with unmet demand.

Rank locations should be included on TfL journey planning tools and TfL should explore options for increasing the visibility of ranks through distinctive signage.

The Mayor and TfL should also set out clear guidance for event planners to ensure that taxi and private hire provision is explicitly contained in transport planning for major events and attractions.

Recommendation 8
By May 2015, the Mayor and TfL should satisfy this Committee that the entry requirements into each market are fit for purpose. This should include providing evidence that there are no artificial barriers to entry, that the requirements are relevant to the specific demands of each industry and that they ensure protection for passengers, drivers, and other road users.

Recommendation 9
The Mayor and TfL should ensure that disabled taxi and private hire passengers’ needs are met by taking steps to incentivise the provision of wheelchair accessible private hire vehicles (for example, through reduced vehicle licensing fees) with a view to reaching 25 per cent wheelchair accessibility across the private hire fleet by 2018.

By May 2015, TfL should also introduce requirements for all taxi and private hire drivers and operators to undertake mandatory disability awareness training as part of the licensing process.

TfL should also enforce a zero-tolerance approach to drivers and operators across both industries who illegally refuse to carry disabled passengers, and increase the visibility of its complaints process so that disabled passengers can name and shame providers who break the law.

Drivers and operators who are found to not comply with these regulations should face suspension of their licences.

Recommendation 10
By March 2015, the Metropolitan Police should improve the information it collects on cab-related crime, to ensure greater understanding of whether offences are committed by licensed taxis, private hire vehicles and Pedicabs, and by licensed or unlicensed drivers/vehicles.

Recommendation 11
By May 2015, The Mayor and TfL should provide the Committee with a definitive assessment of the resources currently devoted to enforcement, setting out costed plans to increase these where necessary and address funding gaps. This should include options to increase licence fees to ensure adequate enforcement resources are available.

Recommendation 12
By March 2015, The Mayor and TfL and the Metropolitan Police should set out specific steps that will be taken to improve the efficiency and visibility of non-covert night-time operations.

Recommendation 13
The Mayor and TfL should immediately clarify the policy on destination bookings and reinstate the requirement for private hire drivers and operators to record a destination at time of booking.

Recommendation 14
By March 2015, The Mayor and TfL should conduct a full review of the policy on ‘satellite offices’, identifying and securing the enforcement resources required to regulate these effectively, including plans to clamp down on unlicensed ‘marshals’. Any further satellite office applications should be suspended until this has been achieved.

Recommendation 15
By May 2015, the Mayor and TfL should enable greater joined-up working on enforcement, including working with the private hire trade and boroughs to develop a cohesive, pan-London policy on picking up/setting down arrangements.

Recommendation 16
The Government should act upon the findings of the Law Commission Review and propose legislation that introduces stiffer penalties for touting, and greater enforcement powers for borough and police officers, including higher fines and vehicle seizure powers.

Recommendation 17
By May 2015, The Mayor’s office, TfL and the trades should develop and publish a Memorandum of Understanding which clearly sets out terms of reference and defines the respective roles, responsibilities and expectations of each party. This should include specific service level agreements.

Recommendation 18
By March 2015, TfL should revise its driver engagement activity to ensure that it is as widely representative as possible, and improve the transparency of taxi and private hire policy and decision making processes by routinely publishing the minutes of meetings with the trades. TfL should also provide and publish a detailed breakdown of annual licence fee spending.

Recommendation 19
By March 2015, the Mayor and TfL should set out how it will increase the visibility and accessibility of its complaints process, and improve systems for passengers to give feedback and make complaints about both taxi and private hire services. Complaints data should be reported to the TfL Board on a quarterly basis.

From these recommendations TfL sought to introduce new regulations and rules for the Private Hire industry and you responded on behalf of the GLA to Leon Daniels, Managing Director, Surface Transport Transport for London.

Valerie Shawcross CBE AM, Chair of the Transport Committee.

Dear Leon,

Private Hire Regulations Review consultation

The Transport Committee welcomes Transport for London’s commitment to review private hire regulations and hopes that this will bring some much needed clarity in areas that are vital to the physical and financial protection of the travelling public.

This response builds upon our investigation into taxi and private hire services in London and the recommendations set out in our report, Future Proof, published in December 2014.

Our responses to the specific proposals are set out below and, unless otherwise indicated, represent the consensus position of the Committee. The Conservative group has expressed a minority opinion on a small number of the proposals; these are set out alongside the majority response from the Labour, Liberal Democrat and Green groups.

Proposal 1: Operators must provide a booking confirmation to passengers containing the driver photo ID and details of the vehicle being used to discharge the booking.

The Committee supports this proposal. We believe that providing details of both the driver and the vehicle to be used to discharge the booking is an important step in ensuring greater passenger safety. A survey of passengers for our Future Proof report found that only half of private hire passengers always felt safe when using private hire services. We therefore support action that will increase passenger security. In considering the exact parameters of this proposal, TfL should ensure that due provision is made to enable passengers who do not have access to smartphone technology to receive similar levels of assurance when making a booking.

Proposal 2: Operators must provide booking confirmation details to the passenger at least five minutes prior to the journey.

The Committee recognises the importance of creating a clear distinction between immediate hire and pre-booking. However, we do not support the proposal as set out in the consultation. We are concerned that the proposal as it stands would be largely unenforceable in practice, and could potentially give rise to situations which puts vulnerable passengers in danger. We do not believe that a strong public interest argument has been developed by TfL in support of this proposal. The Committee would like to see TfL examine alternative measures that would allow for a clear distinction between immediate hire and pre-booking. This may include seeking a formal statutory definition.

Proposal 3: Operators will be required to seek TfL approval before changing their operating model.

The majority of the Committee supports this proposal in principle, to ensure that all licensees remain compliant with the regulatory framework. However, in developing the proposal, TfL should ensure that it has the necessary resources in place to allow for any such approval process to be carried out within a reasonable timeframe. TfL should also clearly set out the criteria by which changes to an operating (as opposed to a business) model are defined.

Proposal 4: Security for app based booking platforms [e.g. facial or fingerprint login]

As set out in the response to proposal 1, we support measures that ensure that passengers have greater assurance around who is driving them. We therefore support the principle behind this proposal. However, TfL has not provided sufficient information on the technological or financial viability of this proposal for all operators. We therefore seek assurance from TfL that this proposal would not significantly penalise smaller firms.

Proposal 5: Operator must offer a facility to pre-book up to seven days in advance.

The majority of the Committee recognises the importance of a diverse range of services available across the private hire market. This should allow for the travelling public to access options that guarantee them certainty in terms of an available service. This is of particular importance for people who rely on private hire for specific services such as hospital transport. It is also of benefit to disabled passengers who may otherwise be unable to access a suitable vehicle when required.

Our understanding is that most traditional private hire operators already provide the ability to book services up to seven days in advance and in many cases, significantly further in advance. The regulatory framework should support the continuation of these services to ensure passenger choice. The majority of the Committee agree that it is reasonable to expect a private hire operator to provide a pre-booking service.

Proposal 6: To no longer issue licences for in-venue operators or temporary events.

The Committee examined the issue of in-venue licences as part of its investigation. In the Future Proof report, we suggested that no further licences of this type should be granted until TfL could demonstrate that effective enforcement was taking place at existing venues.

We remain concerned that TfL and the police do not have sufficient resources to carry out effective enforcement against touts at a large number of late-night venues.

We note the concerns of the private hire trade that legitimate operations which are convenient for some passengers may be adversely affected by this proposal. However, on balance we remain of the opinion that no further licences of this type should be issued at this time.

TfL should keep this policy under review.

Proposal 7: Operator must have a fixed landline telephone which must be available for passenger use at all times.

The Committee’s view is that passengers should be able to contact an operator directly and in real time to discuss matters relating to a past, current or future booking.

We do not believe it should be within the scope of the regulatory framework to mandate what specific technologies are used to facilitate this contact. Regulation in this area should focus on the required outcome – accessible communication – rather than the specific communication method, although we think it reasonable to incorporate some capacity for telephone communication.

TfL should satisfy itself through compliance checks that operators are maintaining systems that enable passengers to resolve any issues in real time.

Proposal 8: Operators must not show vehicles being available for immediate hire, either visibly or virtually through an app.

The Committee is concerned that allowing private hire vehicles to be visually represented in an app as available for immediate hire may encourage drivers to cluster at popular locations. The Committee has seen evidence of congestion and anti-social behaviour associated with such clustering at Heathrow airport.

The Committee is also concerned that this activity may amount to unlawful plying for hire and encourage touting. The Committee believes that further discussion is needed to establish the legality of this activity and consequently does not draw a firm conclusion at this time.

Proposal 9: Operators will be required to provide specified information including details of all drivers and vehicles to TfL on a regular basis.

The Committee welcomes this proposal, which builds on our recommendation in Future Proof that more should be done to increase the visible link between driver, vehicle and operator. We would like to see TfL use this information to improve enforcement and compliance operations.

Proposal 10: Operators must specify the fare prior to the booking being accepted.

The Transport Committee’s investigation found that passengers would welcome greater certainty over fares and we note that this proposal has been popular with TfL focus groups. This proposed amendment would provide certainty to customers and minimise the risk of customers being overcharged and/or additional charges being applied after the journey has commenced or due to waiting times. The majority of the Committee supports greater fare certainty, although some Members believe that this particular requirement would constitute over-regulation by TfL.

Proposal 11: Operators must record the main destination for each journey, which must be specified at the time the booking is made.

This was one of the recommendations in our Future Proof report. We heard that the recording of a destination was a crucial factor in allowing a journey to be planned in advance, which is one of the key features of pre-booking. We also heard that the absence of this requirement had made enforcement more difficult, as previously enforcement officers would have used the presence or absence of a recorded destination as evidence of a legitimate pre-booking or touting. Safety campaigners also expressed concern that changes to this policy- or ‘interpretations’ of the regulations, are potentially dangerous and confusing for the public:

“We have always operated on the basis that a pre-booked journey always includes a destination…it is just really important that our advice around safety is consistent with the regulator’s, as [the regulations] are being applied.” – Suzy Lamplugh Trust

The requirement for a main destination to be given at the time of booking was an established principle before the advent of app-based services, and considered best practice by TfL in its compliance checks.

It is also included in the Department for Transport Best Practice Guidance (Department for Transport Taxi and Private Hire Vehicle Licensing: Best Practice Guidance March 2010, para 32.) A majority of Committee Members therefore support the proposal. However, some Members are concerned that this requirement would add unnecessary complication to established booking practices.

Proposal 12: Harmonisation of record retention periods.

The Committee accepts this proposal, which will assist in the efficiency and accuracy of compliance checks.

Proposal 13: Limit on the number of business names attached to each Operator’s licence.

The Committee accepts this proposal, which should help to reduce passenger confusion over the services available to them.

Proposal 14: Specific requirement for an English language test for drivers.

The Committee supports this proposal, on the grounds that it will ensure that passengers can communicate with the driver effectively in the event of an emergency or a dispute. TfL should work with training providers to establish the most appropriate method of testing English standards, which should focus primarily on spoken English.

Proposal 15: Drivers to only work for one operator at a time.

This proposal requires further discussion, as it is not clear whether the requirement would prevent drivers from working for more than one operator simultaneously or sequentially.

In the case of the former, we think it is reasonable to expect that a private hire driver should only be working for one operator per shift, to ensure that drivers do not cancel accepted bookings if a more lucrative one becomes available.

However, in the case of sequential shifts, we have not been convinced that this proposal is in the interests of drivers, who are entitled to work for more than one company. We acknowledge that one possible benefit of this proposal may be to try and limit cases of drivers working extremely long hours. However, we also note that there is no comparable restriction for licensed taxi drivers who are currently exempt from working time directives.

TfL should therefore clarify the intent of this proposal.

Proposal 16: Driver and operator licences applicants should provide national insurance numbers and share with the Department for Work and Pensions.

The Committee supports this proposal as a means of ensuring that drivers and operators are fully compliant with tax and benefits requirements.

Proposal 17: Vehicle licence to be revoked if driver licence revoked.

The Committee supports this proposal. As set out elsewhere in our response, we welcome a strengthening of licensing which establishes clear links between driver, vehicle and operator. This proposal should reduce the possibility of an unlicensed driver using a licensed vehicle for touting and other illegal activity.

Proposal 18: Checks on convictions of operator staff.

The Committee supports this proposal. Operator staff should undergo checks to confirm they are suitable to work in roles that involve day to day contact with passengers and knowledge of passengers’ personal and financial details.

Proposal 19: TfL to stop accepting payment by cheque and postal order

The Committee accepts this proposal, which is consistent with changes to payment methods across other TfL modes.

Proposal 20: Hire and reward insurance to be checked at the point of licensing and must be in place for the duration of the vehicle licence.

The Committee supports this proposal, and calls for TfL to ensure that stringent checks of insurance are made at time of licensing and through regular compliance inspections. Operators who have been found to employ drivers without the correct insurance in place should be subject to penalties including revocation of the operator licence.

Proposal 21: Drivers to carry or display a copy of insurance details at all times

The Committee supports this proposal. We note that a similar requirement already exists for licensed taxi drivers and believe that this will assist in compliance checks.

Proposal 22: Hire and reward fleet insurance in place by operators (as an alternative to proposals 20 and 21).

The Committee suggests that this should be an optional requirement for larger fleets, to provide an additional assurance of cover. TfL should encourage larger fleet operators to adopt this proposal; however, we do not believe that this should absolve individual drivers of the responsibility to ensure that they have adequate personal cover in place.

Proposal 23: Introduce additional categories of licence type.

The Committee supports this proposal, which will allow for greater flexibility within the licensing process. In particular, the Committee is in favour of flexible licensing options that will incentivise the uptake of wheelchair accessible vehicles.

Proposal 24: Controls on ride-sharing in licensed vehicles.

The Committee remains strongly opposed to any services which seek to match passengers and unlicensed drivers and will continue to press TfL to take full enforcement action against firms or operators which do so. But the Committee is in favour of appropriate ride-sharing services as long as there are clear regulations to protect passenger and driver safety.

This is a comparatively new area of regulation for TfL. As set out in our response to proposal 3, TfL should ensure that market innovation is not unduly stifled, while passenger and driver safety must remain the absolute regulatory priority.

Proposal 25: Amendment of advertising regulation to include ‘in’ vehicle

The Committee accepts this proposal, to ensure advertising materials are of a consistent quality.

Additional measures.

Topographical skills: The Committee supports plans to enhance the content, management and delivery of topographical testing, to drive up standards and ensure adequate driving capability, with particular regard for the safety of pedestrians, cyclists, motorcyclists and other road users.

Complaints: The Committee welcomes TfL’s commitment to greater oversight and management of private hire complaints. This was a recommendation in the Future Proof report and we are pleased that TfL has already taken positive action in this area.

Disability awareness training: This was a recommendation in the Future Proof report and we fully support TfL’s plans to introduce mandatory disability awareness training. We would also like to see this developed for the licensed taxi trade. We repeat our calls for a zero tolerance policy for all drivers and operators who discriminate against disabled passengers.

The Committee is encouraged that TfL has adopted the recommendations in our report and that action is being taken to ensure that London’s private hire trade is sensibly and appropriately regulated. We hope that the views set out in this consultation will prove of use in this regard.

Yours sincerely,

Valerie Shawcross CBE AM

Chair of the Transport Committee.

So, what are we going to tell you that you do not already know?


Not a lot to be honest.

We agree with you that ‘Plying for hire’ could be defined, as could pre-booked.

There’s also issues that we both share about the distinction between the two services.

A two-tier strategy was always meant to be about Taxis providing an all-inclusive, all-encompassing service that was regulated to protect both the public and the driver without any compromise on safety or service at a fair fare, regardless of weather, time or date, within reason.

Private Hire was always about providing a pre-booked service that offered more choice of vehicles whilst allowing the customer time to shop around on price. It was never about one tier being able to grow at the expense of the other, undermining safety in the process or both competing in the same market. There are two distinct markets.

However, in the past few years that distinction and strategy has come under severe stress from the Private Hire industry who have pushed every conceivable boundary, blurring the distinction between the two services.

Ideally, the two tiers were supposed to exist in harmony, but in reality that has never happened and is unlikely to do so.

In the ‘Where to, Guv?’ investigation of 2005, the Public Carriage Office (PCO) were asked:

Is there a direct relationship between the demand for taxis and the demand for private hire?


“The PCO is unaware of any direct relationship or evidence to show that either trade is especially sensitive to changes or fluctuations in each other’s supply and demand. It appears that there is not much of a market overlap. In the broadest of terms, historically, most taxi hirings are in central London and spread out over the day with suburban work concentrated at station ranks. In contrast, private hire operates mainly in the suburbs with the majority of its work in the evenings and at weekends. Competition, however, is probably at its sharpest between large private hire companies and the taxi radio circuits for pre-booked corporate business.”

That cannot be said today. PHV’s are operating on-demand, virtually plying for hire.

The Report concluded: “The Committee feels that now the PCO has taken on responsibility for enforcing policy, a strategic, facilitating role would be more effective than the largely operational function it has had in the past. The PCO has undergone a lot of changes in its responsibilities since 2000, many of them particularly difficult undertakings. This investigation has found that the PCO is not providing as competent a service as it could in some areas, particularly in communications, and needs to restructure itself to reflect better the work it does. Now private hire licensing is business as usual, these changes need to be implemented as soon as possible. Then the PCO can ensure London’s world-renowned taxi service has a secure long-term future.”

A decade later, we are being asked to discussing saving taxis in London after TfL have mis-managed the industry to within an inch of its life.

The Taxi and PH Industry has become a political football, with big business in the PH Trade seeking to carve up the industry to make profit at the expense of Drivers and customers alike.

The playing field is not level. The Cab Trade has been blindfolded and handcuffed with our legs bound whilst PH have been allowed to have a free run at our customer base.

We are asked to compete without any assistance or the freedom that PH industry currently enjoys. We cannot negotiate our fares or choose the vehicles that we are told to use. Having been told we will have a choice of different vehicles to drive, we are still stuck with one manufacturer who is under no pressure to compete in the market place.

The only model we can buy at this present moment is £43,000 and with the ‘on-demand’ market being opened up to PHV’s that cost half the price, we are unable to compete. We are told that Mercedes may re-enter the Taxi market but prices are believed to be an eye-watering £47,000!

PH use the same model Vito as the Taxi trade but it is a third cheaper without having to meet the 25′ turning circle or mandated to be wheelchair accessible.

So, how can you help us?

Are we asking you to water-down our standards?

I don’t think any Taxi Driver wants that. We’ve sat in the Chamber at City Hall and heard you tell the previous administration that they were creating a ‘race to the bottom’!

The public deserve better! We deserve better! London deserves better.

But we are at that fork in the road and someone has to decide what the best route is.

We can sit and wait for Government to respond to the Law Commission and then wait for them to introduce new legislation that may take years. Meanwhile, the Taxi trade diminishes, withers and dies.


New Cab registrations are down to about 500/year from a high of 2,500-3,000 when the Taxi trade was thriving and drivers felt confident about their future.

Alternatively, the Mayor can revert back to the tried and tested legislation that is in place and rely on the long-standing interpretation and the spirit in which it was intended.

To offer two distinct services: one that is all-inclusive and encompassing-designed to be available instantly and on-demand, the other pre-booked and offering more choice of vehicles and with an opportunity to shop around for price.


TfL should be a flagship for everything that is good about Transport in London. It should not be scared of its own shadow. If anyone disagrees then let them take TfL to Court and prove their case rather than allow one of London’s icons to be destroyed in the pursuit of profit at the expense of its citizens.

London’s streets have become a war zone as casualties mount up at the expense of a PH trade intent in racing to the bottom. Sexual assaults increase as standards drop.

The words of an experienced Compliance Officer at Heathrow still haunt me, when he pointed out the dangers of a PHV with central locking and child locks engaged: “A Taxi has motion sensitive locks and a partition, but in a PHV with a flick of a switch, a vulnerable passenger is locked in a cage with someone who may not be the driver on the licence!”

We have a duty of care to Londoners and so does TfL!

London is governed by different legislation in respect of Taxis and PH. The two services are not the same as they are in other parts of the U.K. and London should be proud of its special status and uniqueness. It should be proud to lead on public safety, not be a beacon for low and lax standards as it currently is now.

If one reads the TFL response to the Law Commission, believed to be written around 2011, you could be forgiven for thinking you had lost your mind, given the number of contradictions with today’s stance since Über started to dictate policy:

Response by TfL to the Law Commission Consultation

on reforming the Law of Taxi and PH services.

By Thomas Moody


Annex A – TfL‟s view of national mandatory private hire standards.

TfL disagrees with any proposal which takes the power away from TfL to mandate private hire standards and which restricts TfL from setting operator, driver and vehicle standards that are appropriate for the size, scale and importance of London’s taxi and private hire industries.

TfL has a number of concerns including:

The mandatory standards set would not be stringent enough.

London as an area has specific local needs which should be determined locally by the licensing authority and not by central Government

  1. The mandatory standards set would not be stringent enough.

The Law Commission‟s proposal to limit existing powers by licensing authorities in favour of standards to be set nationally, does not give any indication of what standards would be in scope, or any indication of the levels of these standards, other than they must be safety related.

Within London the private hire industry was first licensed in 2001 following extensive public consultation, including input from the private hire industry and other key stakeholders. At that time standards were set that would allow as many reputable operators, vehicles and drivers to be brought under the new licensing regime as possible, with the view that these standards would be raised over time. As a consequence TfL has, and will continue to introduce additional policies and standards to the private hire industry to help ensure the public remains safe, and the distinction between taxis and PHVs is clear.

TfL recognises that because licensing authorities throughout England and Wales have had full autonomy over what standards are applied to private hire services, over time some have introduced requirements which may be considered over-regulatory and burdensome on the local trade.

London as a city is unique in England and Wales, by its size and importance for the UK economy as a whole. Public transport is a crucial element of this, ensuring Londoners and commuters can travel to and from work as well as serving tourists and the business community.

The reputation of this and the levels of service provided constitute part of London’s high reputation as can be demonstrated in the provision of transport and its services during the London 2012 Olympic and Paralympic Games. Therefore, we believe that the travelling public should expect the same standards of service and quality regardless of the mode of public transport used.

The general view from the Law Commission is that private hire services, because they are privately booked, and they operate in a competitive market, provides the travelling public with freedom of choice over which operator to book with – therefore operators which provide the better quality service will be chosen. In real terms the majority of the travelling public, be they Londoners or visitors, have an expectation that not only will they travel to their destination in safety, but also have assurance that the service meets other, less safety-related criteria.

Despite the fact that TfL is not responsible for much of the non safety related areas, TfL is the first point of contact when something goes wrong, and is seen as responsible by the public at large. TfL therefore needs to retain the power to appoint standards that are appropriate for a world class city.

These expectations include but are not exclusive to:

Courteous drivers with good levels of customer service

In most cases drivers who have a good command of verbal and written English

Vehicles which are clean and tidy

Drivers that have a good level of knowledge of the local area Drivers that have a high standard of driving ability

TfL recognises that many private hire operators adhere and exceed many of the standards that we set, and as a whole there are very few compliance issues with these larger, high end operators.

However 30 per cent of the London market is made up of smaller, medium size private hire operators, such as local minicab type firms. The nature and make up of these businesses can be very different to the larger operators, and to ensure the service provided meets what is expected of London, standards need to be mandated.

If national mandatory standards are set that only include safety related issues, it is anticipated that the quality and standard of customer service and condition of vehicles would go down in some of the less reputable businesses.

TfL understands the Law Commission’s rationale that as the private hire market is competitive the travelling public will vote with their feet and therefore choose the quality of service they require.

However, the means of booking a PHV does not allow for the person who is booking the vehicle to understand the quality of service they will receive and as we highlight above, TfL is often held accountable when inadequate service is provided.

The rationale given which alludes to choice and a competitive market in many other business markets is correct. A good example is that of the regulation of restaurants. A restaurant will have a number of regulatory responsibilities such as food safety, health and safety at work and employment responsibilities.

However, Government does not set standards as to the levels of service quality as there is freedom of choice by the consumer whether or not to dine at such an establishment. There is merit to relating this example to the private hire industry, however there are fundamental differences with the private hire market which are outlined as follows:

Competitiveness in the private hire market: Not all areas have more than one private hire operator/private hire vehicles operating in the area. Many areas in England and Wales have differing levels of public transport provision. In some rural areas there may be limited or no other competition for private hire services. In these instances if basic national safety standards were mandated, some less reputable operators which operate in areas where there is no competition may operate at a very low standard of service.

This may also be relevant where there is a large operator in an area which dominates the market. In addition, many areas where the public are less well served by public transport, private hire services are an essential means of getting about for vulnerable persons such as the elderly and disabled users.

Consumer choice: The nature of booking a PHV in real terms does not give the customer a quality choice. Booking with an operator over the phone or via the internet gives the customer minimal choice: The vehicle cannot be seen; there is no information of what driver training has been undertaken; and there is no evidence that the driver has good levels of customer service.

This is even more relevant with the proliferation of bookings via the internet/phone apps etc.

Reputational damage to both TfL and the wider private hire industry:

As we have highlighted above, the majority of the public have the expectation that the licensing authority has responsibility for private hire standards. Although generally this is the responsibility of the private hire operator, if there were a number of complaints concerning a private hire operator to the licensing authority this could be considered alongside other complaints and any other information held on the operator‟s record.

Impact on tourism: Of particular importance to London is that visitors would be particularly disadvantaged with the proposed system. A two tier taxi/private hire market is, on the whole, unique to England and Wales and therefore foreign tourists that pre-book PHVs will expect vehicles and drivers to have good quality standards and customer service. It would be unreasonable to expect a tourist to understand that they should undertake a considerable amount of research to be assured that these non safety critical standards are met.

In addition poor standards of service may also be an indication that the operator is not carrying out his or her duties to the required standard which may indicate inadequacies in other more safety related areas such as record keeping.

2. London as an area has specific local needs which should be determined locally by the licensing authority and not by central Government.

TfL disagrees with the principal of nationalising private hire standards if TfL can not add additional standards where it deems necessary.

The Mayor of London, through TfL, is best placed to determine the needs of London‟s citizens, and there are examples where a standard/policy set in London may not be relevant for the rest of England and Wales.

Mayor‟s Air Quality Strategy

To protect Londoners’ health and increase their quality of life by cleaning up the capital’s air the Mayor of London developed the Mayor’s Air Quality Strategy (MAQS) which was published in December 2010.

The strategy sets out a framework for improving London’s air quality and measures aimed at reducing emissions from transport, homes, offices and new developments, as well as raising awareness of air quality issues. PHVs are a fundamental part of public transport provision, alongside taxis, buses, trains etc and they contribute significantly to London‟s air quality.

The MAQS includes measures that TfL will take to achieve the relevant legal limits. A public and stakeholder consultation on the draft air quality strategy took place between 28 March and 13 August 2010 and involved organisations representing the taxi and PHV trades. This is particularly significant as the levels of PM10 and NOx in Greater London have historically been in breach of UK and EU legal limits.

Two of the pollutants that cause most concern within London are particulate matter (PM10) and oxides of nitrogen (NOx). Fine particulate matter (PM2.5) is widely acknowledged as being the pollutant that has the greatest effect on human health. A study22 commissioned by the Mayor estimated that long-term exposure to PM2.5 has an impact on mortality equivalent to around 4,300 deaths in London per year.

Research has also shown that people living in deprived areas are disproportionately affected by poor air quality, in part because these areas are near busy roads, which tend to have higher levels of pollution caused by road traffic. Taxi and PHVs contribute a significant proportion of both PM10 and NOx.

Impact nationalising the private hire industry may have on London.

Notwithstanding the theoretical arguments for or against mandating a national standard for private hire services, TfL has many serious concerns as to the impact this will have practically within London. Although the full impact is not clear the following issues are expected negative consequences:

  1. Flooding the market with out of town PHVs.

Allowing private hire operators and drivers to be licensed anywhere in England and Wales will give licensees a choice around which authority to be licensed. Invariably this decision will be affected by the licence fees charged by each individual authority and by the very nature of a cost recoverable service the fee will differ throughout the country based on a range of factors including staff costs (influenced by the cost of living) and enforcement costs and amount of enforcement undertaken (urban areas are likely to require greater enforcement due to the higher usage of taxi and private hire and specific problems such as illegal touting).

It is therefore anticipated that operators that are currently required to be based in London will choose to be licensed in authorities that have cheaper fees, yet still operate within London but TfL will be responsible for the enforcement of these vehicles operating in London and the associated costs.

2. Operator inspections

In London private hire operator inspections are carried out to check a range of records including booking and vehicle records. These inspections are essential to ensure compliance, but are also welcomed by the majority of the trade who see them as an opportunity to check they are correctly adhering to their regulatory responsibilities.

Operator inspections within London have also been highly valuable when operator licensing was first mandated in 2001. This view is consistent in other small businesses, as reflected in various Government research23. If private hire operators are based outside of the areas where they are licensed, the home authority would not be able the undertake operator inspections. Any removal of this existing requirement would severely lower the quality of private hire operations, which would lead to less desirable individuals entering the market and potentially compromising public safety.

3. Increased illegal plying for hire, touting, and ‘ranking’.

An increase of PHVs, licensed in other areas flooding to London hotspots will increase the amount of illegal activity on London streets.

As the driver, vehicle or operator may not be licensed to TfL, enforcement action will be extremely difficult as each licensing authority must retain decision making over licences granted, suspended or revoked. Introducing mandatory standards will create a similar ‘cross border hiring’ scenario which is common in other areas in England and Wales. It would be highly ineffective to introduce regulations to stop the problem in parts of the country, which would then create a similar scenario on a much larger scale within London.

If implemented, potentially tens of thousands of vehicles will flood into the London market which will operate under very little enforcement. This will undoubtedly lead to a significant increase in illegal activity which may compromise public safety.

4. Burdensome requirements on TfL in terms of notifying other licensing authorities of illegal activity/recommended sanctions or penalties.

A potential reshaping of the link between local services which may be licensed in any area of England and Wales will place an unnecessary burden on licensing authorities that may not be resourced to cope with an influx of applications, and conversely a significant reduction in budget from licensing authorities with higher fees.

TfL also does not believe that the Law Commission have come up with an efficient solution in terms of cross border enforcement.

The Law Commission’s preferred solution of providing formal procedures whereby the licensing authority where the problem occurred would give the licensee’s home authority a notice would create a huge administrative burden on TfL.

The counties of Berkshire, Buckinghamshire, Hertfordshire, Essex, Kent and Surrey are all within a short distance from London and within these areas there are over 50 district and unitary licensing authorities.

If the proposal went ahead TfL would be required to write recommendations to the licensing authorities from where these vehicles were licensed, and also be required to consider and carryout appropriate sanctions where TfL received recommendations from other licensing authorities. TfL considers this a highly ineffective and bureaucratic form of regulation.

Annex B – Mayor’s Transport Strategy objectives for taxi and private hire.


The Mayor, through TfL, and working with the London boroughs and other stakeholders will support improvements to the taxi service through a number of measures, including:

  1. Continued highway priority for taxi services, for example, access to bus lanes

(b) Reduced taxi vehicle emissions and development of low emission taxis

(c) Provisionofparkingandwaitingfacilities,including rest facilities

(d) Provision of ranks and facilities at interchanges

(e) Taxi marshalling

(f) Action against touting and illegal cabs

(g) Improved driving behaviour, to be encouraged through the licensing procedure of taxi drivers

(h) Ensuring regulated taxi fares changes allow drivers and owners to continue to recover the costs of providing the taxi service and provide a sufficient incentive for taxi provision to meet demand, in particular at night

  1. Continuous process improvements to provide a modern and cost effective licensing service.

Private Hire

The Mayor, through TfL, and working with the London boroughs and other stakeholders, will support improvements to private hire services (especially minicabs) through the following:

  1. Initiatives that deliver further the success of the Safer Travel at Night scheme

(b) Provision of facilities to pick up as well as drop off passengers where appropriate

(c) Action against plying for hire, touting, un-roadworthy vehicles and illegal cabs

(d) Continuous process improvements to provide a modern and cost effective licensing service

(e) Lower emissions from PHVs

That strategy the GLA Transport Scrutiny tried so hard to extract from the previous Deputy Mayor is (excuse the pun) virtually here. That is until a ‘virtual’ on-demand service started to dictate to others about how TfL should regulate the industry. Why did no at TfL speak up or point it out?

The DfT’s Best Practice Guidance gives some help on regulating the industry:


The aim of local authority licensing of the taxi and PHV trades is to protect the public. Local licensing authorities will also be aware that the public should have reasonable access to taxi and PHV services, because of the part they play in local transport provision. Licensing requirements which are unduly stringent will tend unreasonably to restrict the supply of taxi and PHV services, by putting up the cost of operation or otherwise restricting entry to the trade. Local licensing authorities should recognise that too restrictive an approach can work against the public interest – and can, indeed, have safety implications.


For example, it is clearly important that somebody using a taxi or PHV to go home alone late at night should be confident that the driver does not have a criminal record for assault and that the vehicle is safe. But on the other hand, if the supply of taxis or PHVs has been unduly constrained by onerous licensing conditions, then that person’s safety might be put at risk by having to wait on late-night streets for a taxi or PHV to arrive; he or she might even be tempted to enter an unlicensed vehicle with an unlicensed driver illegally plying for hire.


Local licensing authorities will, therefore, want to be sure that each of their various licensing requirements is in proportion to the risk it aims to address; or, to put it another way, whether the cost of a requirement in terms of its effect on the availability of transport to the public is at least matched by the benefit to the public, for example through increased safety. This is not to propose that a detailed, quantitative, cost-benefit assessment should be made in each case; but it is to urge local licensing authorities to look carefully at the costs – financial or otherwise – imposed by each of their licensing policies. It is suggested they should ask themselves whether those costs are really commensurate with the benefits a policy is meant to achieve.

We are not in the position of starting with a blank piece of paper, but London’s Taxis are as safe as any Taxi service can be! Yes, we’ve had the odd Cabbie slip through the net, but that’s all the more reason for raising standards not compromising them!

The PH trade cannot say the same.

Yet PH’s Representative on the TFL Board seemed to be able to use his position far more effectively than the Taxi Trade’s. Whilst Bob Oddy sat in silence when TFL discussed Taxi business, whilst Steve Wright appeared extremely vocal. Was it another case of Taxis playing by the rules, whilst PH did as they pleased?

Getting updates on strategies or policies let alone the 19 recommendations and the resulting new PH Rules and regulations, is almost impossible, yet these are the Terms & Conditions that our industry works under. No one tells us unless we force them to via Freedom of Information requests.

How can TFL be allowed to operate like that? Both yourself and Caroline Pidgeon called for openness and transparency at TfL but we still cannot get meetings minuted or reports sent in advance.

The Taxi Representation over the past decade has been absolutely woeful.

Two investigations at City Hall were ignored and it was only when the LCDC finally decided to engage with the London Assembly that we had our voice listened to.

The LCDC fully supported the GLA in its 19 recommendations and we were extremely disappointed that a year on from the date of intended implementation, many are nowhere near having been done.

Those frustrations are often carried into meetings with TfL, where we find ourselves repeating the same things, again and again. Enforcement! Enforcement! Enforcement!

Top of the agenda is the failure to enforce the rules and regulations relating to plying for hire. There is a great deal of case law that could be used and even regulations appertaining to just simple issues such as parking on Taxi Ranks that are not carried out because local authorities and their staff do not understand the distinction between Taxis and PHV’s. To many we are all the same.

We are not. We are two distinct services and although Taxis operate under the banner of Transport for London, we need our own distinct identity.

We also need a voice.

A Non-Executive Chair who can represent our view to outside bodies, advised by a Taxi Board made up of constituent parts of the Trade. A previous attempt at a Taxi Board was unbalanced and dominated by business rather than the labour force who buy the services of the businesses.

However, without a proper focal point for the trade we have become rudderless and mute.

It’s not going to be an easy task giving a voice to 25,000 self-employed sole-traders and the ancillary businesses, but where there’s a will, there’s a way!

However, if the Mayor were to hear our voice now, all he would hear are our screams as our trade is being murdered. We need someone to listen to our calls for help and protect us.


It wasn’t the Taxi trade who described Cab Enforcement as ‘woefully inadequate’ it was the Transport Scrutiny Committee. Enforcement On-Street has taken over the role of making sure that both Taxis and PH are complying with regulations and rules. However, it’s been virtually non-existent and the best example of that is at Heathrow Airport, where after almost eighteen months of badgering TPH we had our first ever Heathrow Compliance meeting last month, whilst at the same time we have been told that Über are going to be rewarded for their Drivers vile and disgusting behaviour locally.

There is no need for further deliberation of the subject as you are well aware of the issues having joined Taxi trade Reps to see the situation first-hand. What we cannot understand is how Heathrow Airport Limited intend to reward Über with a facility to operate from instead of making sure they use the 42,000 Car Park spaces already available.

London Assembly Transport Committee

Note of Site Visit: Taxi and Private Hire Issues at Heathrow Airport

Date: 25 June 2015


Figure 1- Valerie Shawcross CBE AM with taxi drivers

Valerie Shawcross CBE AM, Chair of the London Assembly Transport Committee, visited Heathrow Airport on the morning of 25 June 2015 to investigate taxi and private hire issues at Heathrow Airport. She was accompanied by two officers from Secretariat: Alison Bell, External Relations Manager and Reece Harris, Project Officer.

We met with Mark White and other taxi drivers at Terminal 2, before being taken to Terminals 3, 4 and 5 and Bolton’s Lane/Mondial Way, a mixed commercial and residential street. The main issues that we noted were: illegal parking and use of drop-off points, a lack of effective signage, uninsured/improperly insured vehicles, an uneven distribution of enforcement officers and passenger safety.

Illegal parking and use of drop-off points

We were able to see many examples of private hire vehicles plying and touting for trade, or waiting for extended periods of time in drop-off areas. This is illegal as private hire vehicles are not allowed to ply for trade and Heathrow does not allow passengers to be picked up from drop-off areas; passengers must be picked up from the car park. For example, at Terminal 2, we witnessed one silver car that remained parked for almost the full forty-five minutes that we were there, while an Addison Lee car and a member of the public were also there for a significant amount of time. We saw one vehicle illegally pick up passengers. We also saw similar scenes at Terminal 4, where one of the drivers actually offered a trip to us. Despite this, it was clear that many drivers were using the drop off point perfectly legally, dropping off passengers before departing. The taxi drivers with us believed that the lack of cameras and enforcement officers was responsible for infringements of the law. This situation has meant that taxi drivers can end up waiting for five to six hours in the airport’s holding area for trade.


Figure 2- Private Hire Vehicles waiting at drop-off point at Terminal 2.

We were also shown a nearby residential/commercial street called Bolton’s Lane/Mondial Way, where large numbers of exclusively private hire vehicles were parked, some on double yellow lines. We spoke to a local traffic warden for the London Borough of Hillingdon, who confirmed that the problem is prevalent across a number of local streets. The local McDonald’s fast food restaurant car park was also full of vehicles that appeared to be private hire vehicles.


Figure 3- Private Hire Vehicles in McDonald’s car park


Lack of clear signage.

At Terminal 2 there was a sign which appeared to direct people up an escalator towards the drop-off point rather than to the taxi rank. We saw a taxi driver volunteer ferry lost people to the correct location three times. The taxi rank itself was also nearly invisible when leaving the lift down to it and was obstructed by pillars and barriers. The taxi drivers present were concerned that Heathrow refused to allow the taxi drivers to provide their own marshal, and had to use a car parking marshal as provided by Heathrow, who was not able to provide effective advice for customers. This meant long queues (especially at night) which we witnessed while we were there, despite the fact that the airport was not particularly busy. They were also concerned about disabled access to the rank, due to the barriers.

Uninsured drivers

The taxi drivers we were with reported that there were some minicab and Uber drivers who did not have private hire insurance. The taxi drivers suggested that the Automatic Number Plate Recognition System (ANPR), which is designed to detect whether a car is insured or not, did not determine between personal insurance and private hire insurance. They proposed that private hire vehicles should be made to display their insurance prominently in the same way that taxis must by law. They also claimed that the ANPR system was not actually present as claimed in some places and that an inadequate number of cameras overall were leading to misuse of the drop off points.

Enforcement Officers and Passenger Safety.


We saw around 17 TfL enforcement and police officers on the day, with ten located at Terminal 3, and around five at Terminal 5. However, the officers were unevenly distributed, as there were no officers at Terminal 2, and only two police officers at Terminal 4, who claimed that they were unable to issue tickets as they had not been given the correct ones.


Figure 5- Valerie Shawcross CBE AM speaks to TfL enforcement officers

The officers were mostly focused on ensuring that the vehicles at the drop-off points had the appropriate insurance.

The officers noted concerns about foreign touts speaking the language of some new arrivals, drawing people away from the safer alternative of taxis or registered private hire vehicles. They were worried about passengers becoming locked into some vehicles, unable to escape, unlike in purpose-built taxis/private hire vehicles, where the doors unlock when the vehicle is stopped. They believed that the number of vehicles illegally picking up trade or without the correct insurance had risen by at least fifty per cent over the past few years. Both the taxi drivers and the enforcement officers agreed that their priority was passenger safety.

All of the Authorities at Heathrow, from TPH to the Met.Police through to Hillingdon Council have all been caught with their trousers down. Hollow boasts about increases in ticketing have been shown to be worthless as the 5-600% increases are only moving the goalposts from non-existent to negligible. The fact that Heathrow Airport and TFL are now having to apply for extra powers to enforce the roads and highways locally plus their own forecourts show how inept they have all been. If the Taxi trade had not screamed loudly for a long time to the London Assembly for help then they would not have bothered. What makes this all the more galling is the fact that Heathrow would rather talk about expansion plans with us and ask the Taxi trade to support its business despite the obvious problems with Air Quality that an 800 space Über Car Park can only exacerbate.


Proposed new waiting area for Private Hire Vehicles at Heathrow airport

Meeting: Mayor’s Question Time

Date: Wednesday, 25 May 2016

Reference:Question 2016/1353

Main question: Caroline Pidgeon

Has Transport for London undertaken any analysis of the impact on congestion and pollution that would be created by the proposal of Heathrow airport to create an 800-car waiting area for Private Hire Vehicles?

Officers are drafting a response which will be sent shortly.

Heathrow Air Quality (1)

Meeting: Mayor’s Question Time

Date: Wednesday, 20 January 2016

Reference:Question 2016/0302

Main question

Onkar Sahota

What measures has the Mayor put in place to improve the dangerous levels of Air Quality around Heathrow Airport?


The Mayor

Air quality monitoring data across a number of sites in the Heathrow area show concentrations are routinely above or very close to exceeding air quality limit values. My position is very clear.  This is just one of the reasons why I and others have consistently opposed expansion at Heathrow. Concerns around air quality has meant that the Government has rightly reopened the recommendations of the Airports Commission final report.

I have introduced several measures to improve air quality across the whole of London, including introducing tighter standards for the Low Emission Zone, ensuring all buses meet Euro IV emissions standards and retiring over 6000 of the oldest most polluting taxis. The introduction of the Ultra Low Emission Zone will bring significant benefits to the area around Heathrow, due to the reduction in emissions from bus and taxi fleets throughout London, as they and other vehicles are upgraded to comply with the standards. We estimate that ULEZ will halve the number of people living in areas exceeding legal limits in Hillingdon and Hounslow. TfL is working with boroughs to look at the feasibility of expanding the ULEZ and/or tightening the standards for the London-wide Low Emission Zone beyond 2020.

TfLis leading on the production of a West London Air Quality Action Plan, together with the relevant boroughs, key representatives and Heathrow Airport Ltd. The intention is for this plan to address air pollution levels around the airport but also in the wider vicinity, recognising there is a wider issue of air quality exceedances in the west London area. This work will look at a number of options, building on ideas in the Transport Emissions Roadmap (TERM) produced by TfL in Sept 2014, and the unique circumstances within the area.

Heathrow Air Quality (2)

Meeting: Mayor’s Question Time

Date: Wednesday, 20 January 2016

Reference:Question 2016/0303

Main question

Onkar Sahota

How many premature deaths are caused by poor air quality around Heathrow?



The Mayor

There are a number of different and complex sources that contribute to the overall pollution levels to which people are exposed. Therefore, the specific contribution of Heathrow Airport to the health impacts of air pollution has not been quantified.

That said, the Government must continue to scrutinise the existing operation of Heathrow Airport to mitigate its impact on poor air quality in the capital. A clear commitment is needed at a national level to ensure this area meets compliance as soon as possible to ensure health impacts are minimised.

If the poor air quality doesn’t kill us, allowing Über to virtually rank up on-demand in a facility nearer to the Central Terminals than Taxis is a decision that will lead to the demise of the London Taxi trade at Britain’s busiest Airport-a business that happily uses our iconic image to sell London to tourists, but undermines our business at every opportunity!

Are we only to become an attraction where tourists come to be photographed with a traditional Taxi only to use a Toyota Prius to get to their destination because no one will stand up to a Company who eventually will fleece them in the future when they have a monopoly over the market?

London and the Mayor needs to decide what sort of Taxi service it wants and if it will be one where passengers are sold off to the highest bidder whilst the driver works longer hours to try and make a living, reliant on in-work benefits or one that sustains itself at no cost to the people of London unless you actually get in a cab and pay a fare.

The London Taxi trade has been self sustainable for as long as we can remember. Other than a bit of road space, we cost TfL nothing! There has been hardly any investment in our trade for decades. There are no toilet facilities, canteens or depots yet we provide a valuable service, one that often keeps London moving when no one else does. When did the Taxi trade ever go on strike?

The value of a Taxi licence is fast becoming worthless and drivers are now having homes and Taxis repossessed as they leave the trade faster than new Drivers can replace them. Supply and Demand surveys have only just started being considered after TfL admitted that the market is now well beyond the saturation point. Yet more PH licences are being issued despite the fact Darren Johnson sought a moratorium a year ago:

Private Hire Vehicles – license moratorium

Meeting: Mayor’s Question Time

Date: Wednesday, 17 June 2015

Reference:Question 2015/1705

Main question

Darren Johnson

Why has TfL not put a moratorium on all new Private Hire (PH) licences until after TfL has finished its review of PH rules and regulation and the Mayor’s recent comments about there being too many?


The Mayor

“TfL is not able to put such a moratorium in place. Primary Legislation requires TfL to issue a private hire driver’s licence to any applicant if it is satisfied the applicant has met the relevant licensing requirements. However, I believe TfL should have the power to restrict private hire licence numbers, which are rising by more than 1,000 a month and causing increased congestion, as well as more pollution and problems with illegal parking.”

It’s now over 2,000/month!

But TFL and Boris Johnson got it wrong in the first place when they issued a licence to Über to ‘ply for hire’. PHV’s do not ‘ply for hire:

2015/1257 – Taxi and Private Hire Services in London
Valerie Shawcross AM:

Did TfL seek legal advice before deciding to license Uber in 2012? The information supplied to the Transport Committee following up the Future Proof report suggests that TfL did not seek legal advice until 2014. Is this correct?

Boris Johnson MP (Mayor of London):

“Thank you. This is Uber and whether it is allowed to operate legally. TfL decided that, in common with everybody else who applies for a licence to ply for hire in London, there was nothing it could see initially that was wrong with the Uber application. It then sought legal advice at the beginning of last year, which confirmed what they had thought, vis that the taximeter was not a taximeter or that the mobile phone device was not a taximeter. As you know, I do not agree with that. We need to test this in the courts, and it is being tested, and I hope very much it will get an adjudication as soon as possible within the next couple of months.”

Allowing PH to use a meter is not in the Public interest. It’s why PH Operate using fixed fares as their drivers have little knowledge if any at all.

A topographical knowledge test is needed as a safety requirement so that drivers keep their eyes on the road.

Wish list:

A Voice. Effective Representation.

Separation from SIP’s.

Proper Enforcement and Protection.

Increased PH Licence fees to pay for Compliance.

Plying for hire/Pre-booked defined.

Investment in the Taxi Trade. Infrastructure, the Knowledge.


Value in a licence.

Air Quality Strategy.

Strategies and Policies made with the taxi trade, not in spite of the trade.

Affordable vehicles or a scheme to make them more affordable, such as TFL purchasing and leasing to drivers. Use of sponsorship and advertising.

Credit card review. The recommendation was to incentivise the uptake not create greater cost via a badly handled mandate.

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