TfL branded “woefully inadequate” at regulating Taxis and mini cabs
After reading the London Assembly Transport Committee report, “Future Proof: Taxi and Private Hire Services in London", Taxi Leaks feels the report, while extremely welcome, doesn't go far enough with regard to e-hailings, instant hirings and pre-bookings.
Change is needed and long overdue.
It would appear that if a PH company is big enough and wealthy enough, TfL will facilitate by changing/bending the rules rather than enforcing.
We've seen this in the past with major PH players such as RD2, Addison Lee and Uber
More money is required desperately, to employ a substantial "Cab Enforcement" force to deal with touting.
Needed most of all, is the political appetite to deal efficiently with the matter, presently sadly lacking.
The implementation of temporary taxi ranks should be common practise outside major venues when large events take place. We saw only too well, the chaos that ensued when the regular Taxi rank went missing at this years Winter Wonderland.
Although the need for more Taxi ranks was discussed, sufficient and effective ranking seem to have been overlooked by the report. Its pointless having a rank 250 meters from an exit, as licensed and fake minicab drivers will park up in front the Taxis at venues and tout.
A survey, carried out by Westminster Council nearly a decade ago, pointed out that the public will get into the first mode of transport they come across, when leaving a venue. The recent BBC documentary "Inside Out London" also showed most night revellers don't know the difference between a minicab and a licensed Taxi.
This report is proof that our crys of bias and incompetence at TfL's running of LTPH, haven't been unjustified. Both sides of the trade have suffered substantial damage under this administration.
The report is substantial at 67 pages so we have posted an overview covering the most important issues, plus the19 recommendations, made at the end of the report.
One thing that has come out of this report, is that the whole trade, a united trade took part.
We can only sit and wonder what type of position our trade would be in today, if only the LTDA, LCDC and Unite had said no to Masons trade splitting engagement policy back in 2010.
Report summary
Over 300,000 journeys are made by taxi or private hire vehicle in the capital every day. Black taxis are one of the oldest and most instantly recognisable icons of London transport and, together with private hire vehicles, form a vital part of the public transport network for both visitors to, and residents of, the city. Taxis and private hire services fill a gap in public transport provision, providing services in places and at times when other forms of public transport are unavailable, and for those who are unable to access buses, the Tube, or trains due to disability or mobility impairment. Taxis and private hire are used by both the highest earning in our society and those on lower incomes, for business and leisure purposes, at every hour of the day and night.
Efforts to modernise taxi and private hire services and meet passenger expectations are being hindered by the lack of a Mayoral strategy for the future of these trades. This makes it difficult for Transport for London (TfL) to regulate the industries efficiently and effectively. Taxi and private hire services form a crucial element of London’s public transport offer, including for some of the most vulnerable passengers, but competition from new technology, and changing passenger demands, are challenging the traditional ways in which these services are delivered. London’s taxi and private hire services will need to evolve to meet these challenges. Failure to address fundamental issues affecting the trades threatens to spark a race to the bottom in terms of standards, putting the travelling public at risk, and threatening London’s reputation as a world leader for these services.
Strategy
The inherent role of the regulator, TfL, is to protect the interests of the travelling public. We call on the Mayor and TfL to preserve the distinction between the licensed taxi and private hire industries, recognising that diversity of choice is critical to meeting passengers’ differing requirements. We need a clear strategy to ensure the survival and prosperity of both of these services, which covers three critical, inter-related areas of public interest: safety, availability and accessibility.
Safety
The Committee heard that more passengers say they always feel safe and secure when travelling by licensed taxi, than private hire vehicle. A lack of supply of licensed taxi and private hire services in some locations may lead people to make unsafe transport choices; this is a particular concern in the context of cab-related sexual assaults and robberies. We call on the Mayor and TfL to develop specific public awareness campaigns on what to look out for when determining if a driver or vehicle is licensed. We also call for a comprehensive signage strategy for both taxi and private hire vehicles, and for open access to data so that tools that use technology to link drivers to vehicle and operator information can be developed. We believe that cashless payment options would benefit both the industries and their passengers, reducing the risk of crime and removing a barrier to making safer transport choices. TfL, as a regulator, can greatly advance this cause by working constructively with the trades to iron out potential difficulties, explain the wider benefits, and explore options to incentivise a transition towards cashless payment options.
Availability
People often choose to use a licensed taxi or private hire vehicle at times when other public transport is closed, or in locations where other public transport modes are not available, particularly in parts of outer London. Passenger views on availability differ from those of licensed taxi drivers. The Committee heard that there are a number of ways in which TfL could regulate the market more effectively to ensure a better match between supply and demand across the city. In particular, there is a need for better data to inform policy decisions on issues such as sector boundaries, licensing numbers, and rank space provision.
Providing taxi ranks has a number of benefits relating to safety and availability, as well as potentially reducing congestion and vehicle emissions as drivers are not forced to continually drive around to look for work. However, rank provision is chronically underfunded and under prioritised, the process of appointing ranks is too lengthy, and the needs of passengers and drivers are not prioritised when allocating kerb space. We call on the Mayor and TfL to work with the boroughs to improve and increase rank provision, especially in outer London, and to ensure that existing facilities are better publicised.
Taxi driver numbers have remained static for the last decade, while the number of licensed private hire drivers has more than tripled. Some industry experts have questioned whether administration of the Knowledge creates an artificially high barrier to entry for taxi drivers, and, conversely, whether the explosion in private hire driver numbers in the last decade is because the entry requirements to this market are artificially low. We urge the Mayor and TfL to assess entry requirements into both markets to ensure that they are fit for purpose, that the requirements are relevant to the specific demands of each industry, and to ensure protection for passengers, drivers, and other road users.
Accessibility
Large parts of the public transport network are still unusable for many older and disabled Londoners, and taxis and accessible private hire vehicles are a vitally important part of ensuring good quality of life for disabled and older Londoners. Disabled people told us about a range of problems in accessing these services, including taxis not stopping when hailed in the street by disabled people, broken equipment, refusal to carry assistance dogs and insufficient numbers of wheelchair accessible private hire vehicles. Alongside efforts to increase the supply of accessible vehicles, TfL should work with disability campaigners and the trades to improve disability awareness amongst both drivers and booking staff, and adopt a zero tolerance policy towards drivers and operators who discriminate against disabled passengers.
New technology
The rise of new technologies has immense potential to change the way in which transport services are used. There is significant appetite for new technology among both passengers and drivers, especially when it comes to booking and paying. TfL must ensure that it has the regulatory muscle, and the political will, to hold the line against developments which threaten the interests of passengers. An unbalanced market may ultimately lead to a reduction, rather than an expansion, of passenger choice. The Mayor and TfL need to be prepared for the inevitable consequences of a transport environment in which technology is evolving faster than the legislation that is needed to govern its use.
Enforcement
Touting is viewed by both industries as the single biggest enforcement and passenger safety issue affecting the trades. Enforcement numbers are ‘outstandingly low’, compared with other world cities. Trade representatives have raised the possibility of the trades paying higher licence fees if this would guarantee better enforcement, and there are opportunities to improve enforcement through better use of technology. The Committee is deeply concerned that specific TfL policies, such as those around satellite offices and booking destinations, could be creating more problems than they solve. We urge the Mayor and TfL to re-evaluate their enforcement strategy and to explore ways in which enforcement resources could be increased and better deployed. Current enforcement activity is disjointed due to the different enforcement powers available to police and borough enforcement officers. The strategy should contain specific actions that the Mayor and TfL, along with partner organisations and the trades, will take to ensure that the laws and regulations governing these industries are properly enforced. This should include closer working with the criminal justice system, and lobbying Government for the use of stiffer penalties for touting and greater enforcement powers including vehicle seizure powers.
Governance and Communication
Mass demonstrations on the street and votes of no confidence from trade organisations are not generally indicators of a healthy relationship between industries and their regulators. Effective communication between TfL and the trades is vital to implementing changes to the industry that will benefit passengers, but communication appears to have hit rock bottom in the last year. Many within the industries feel that, at a senior level, TfL is simply not listening to their concerns. The Mayor and TfL urgently need to address the widespread view that they are out of touch with the needs of the industries. TfL’s Taxi and Private Hire Unit’s current structure lays itself open to accusations of an inherent conflict of interests. 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.
Passenger engagement
Failure to address passenger concerns damages the long term interests of the trades, and TfL’s reputation as their regulator. The ultimate survival of both taxi and private hire industries will depend on them providing the standard of service that passengers want. The public can provide crucial feedback on drivers, operators and organisations that can help detect illegal activity, identify poor behaviours, and provide suggestions for how to improve services. We call for improved systems for passengers to make complaints and give feedback on both taxi and private hire services.
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 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 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.
