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Cabbies Against Boris, Part 2 - Formal Complaint to the Competition andMarkets Authority

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The Mayor of London has imposed an unlawful and improper London Taxi Age limit which actually means that harmful pollution is INCREASED and is therefore not for proper purpose. He has now proposed to reduce the London Taxi Age Limit from 15 years to 10 years.


This is despite the Mayor's own statement in a written report to the Environmental Audit Committee in 2010 that a new Euro 5 vehicle would create 5 times as much NO2 as a 15 year old vehicle.


It also contradicts solid technical and scientific evidence published by Defra in May 2013, following the testing of 10,000 taxis in London by the Environmental Research Group at Kings College London and proved that the new taxis are creating MORE pollution than those that are being scrapped.

 

The Mayor has needlessly scrapped 6000 London Taxis at great expense to taxi drivers and operators which has now created a significantly increased cost of taxi rental and purchase as a direct result of a monopoly situation.

 

There is only one type of taxi that drivers are forced to buy at an extortionate price manufactured by the London Taxi Company.

 

There is no new taxi available to buy which is proven to be less polluting than existing taxis.

 

The London Taxi Age Limit is therefore not only improper in purpose, it clearly breaches competition laws and creates a monopoly market and raises serious questions about the impartiality of the Mayor of London, Transport for London (TfL) and the Licensed Taxi Drivers Association (LTDA) who have argued supporting the 15 year taxi age limit (against its own members interest) and have argued against the removal of the requirement of the turning circle (against its own members interest), which is a serious restriction on the type of vehicle which can be manufactured and approved as taxis.

 

We are calling for

1/ An immediate suspension of the London Taxi Age Limit as it breaches competition laws and creates a monopoly situation and because it is for improper purpose as there is no new taxi available which has improved emissions. It also does not comply with the requirements of Public Law as it is not evidence based , rational, reasonable, fair or for proper purpose.

 

2/ A full independent investigation of  London Taxi Age Limit which was initiated by Tory MP Tim Yeo who was Chair of the Environmental Audit Committee Air Quality Inquiry in 2010 which led to the London Taxi Age Limit, but was also Chair of Eco City Vehicles, the company selling a new Mercedes Vito taxi which drivers were forced to buy at a cost of £40k. 


This is a clear breach of Parliamentary Rules which state that if the Chair of a Committee has a vested interest he should step aside for that committee (so as not to improperly influence it)

 

3/ A full independent investigation into the Mayor of London and TFL who have implemented an improper and unlawful 15 year London Taxi Age Limit and who now propose to reduce this to 10 years even though there is only one manufacturer of taxis available which creates a monopoly. The Mayor of London and TFL also continue to impose  improper requirements for conditions of fitness of taxis  , which deliberately creates and perpetuates a monopoly situation.

 

4/ A full and Independent investigation into the LTDA who have supported an improper and unlawful  Licensed Taxi Age Limit and have argued against the removal of the turning circle requirement, in direct conflict with their own members interests. 


This raises concerns about the impartiality of the LTDA and what connections they have with taxi manufacturers.


There is also concerns about the impartiality and conflict of interest of its Chairman , Bob Oddy who is also paid by TfL as a board member for them. There are concerns that he cannot properly represent his members whilst being paid by the organisation that he is supposed to challenge on behalf of his members.

 

 

1.       The concept of a Taxi Age Limit to reduce pollution is improper.

 

2.       The Mayor himself said in a report in 2011 to the Environmental Audit Committee that ‘ a new Euro 5 vehicle creates 5 times as much pollution as a 15 year old vehicle’

 

3.       Camden Council among others commissioned emissions testing of vehicles in London, The result of that testing by the Environmental Research Group confirmed that the new taxis were creating MORE pollution than the 15 year old taxis. It seems that Camden Council are ignoring the evidence of the testing that they themselves commissioned.

 

4.       The London Taxi Age limit has therefore INCEASED pollution by scrapping older less polluting 15 year old vehicles.

 

5.       The London Taxi Age Limit should have been stopped as soon as the Defra report confirming that new Euro 5 vehicles were more polluting was published in May 2013. Instead it has been ignored

 

6.       It is therefore not reasonable, rational or evidence based to impose any taxi Age limit of any sort .

        The suggestion that a 10  year taxi age limit will somehow reduce pollution is clearly not based on evidence, as has been proven.

 

7.       It is also therefore not reasonable to suggest that it would be acceptable to do so if certain criteria are met i.e. electric charging points for taxis (because there are no electric taxis and even if there were they are not commercially or logistically viable)

 

8.       There are no new vehicles available as taxis as of today which would offer a commercially and technically viable solution to reduce pollution.

Until there is a reasonable solution actually in place then it is improper to scrap perfectly serviceable taxis on the false premise that it is reducing pollution

 

9.       The proposal for a 10 year London Taxi Age Limit is a distraction from the proper and effective emissions strategies in relation to taxis that should be implemented immediately.

 

10.   A regulation for Clean Diesel (as used in Sweden) could be implemented  overnight. It would reduce PM by 30% and NO2 by 10% and would do so in every diesel vehicle in London immediately. There would be no cost because the fuel economy would increase. The scale of emissions reduction would be massive because the emissions of every single vehicle would be reduced immediately, compared with changing of vehicles which cannot take place quickly and only has a small incremental affect.

 

   There is no reason why this should not be implemented.

 

11.   BioDiesel is another option which has been ignored

 

12.   Other measure could include a diesel engine clean up system (previously proposed to TFL and ignored) and improved traffic management.

 

13.   A ban on peak time deliveries would massively reduce overall pollution and has again been ignored.


 

    Regards Dave Davies



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