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PHC highlights the key points and recommendations of TfL’s official response to the London Assembly Transport Committee’s private hire and taxi survey

 

Kingston tout imageRECOMMENDATION 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 RESPONSE
TfL already has a well established Safer Travel at Night (STaN) campaign which started in 2002/3, in collaboration with the Met Police and City of London Police, and focuses on how to book a legal licensed private hire vehicle (PHV), rather than how to identify a licensed driver/vehicle.

The award winning STaN campaign, which last year won the Safety Campaign award at the Suzy Lamplugh Trust National Personal Safety Awards, has been extremely successful in raising public awareness of the dangers of using unbooked minicabs, and improving understanding that any minicab picked up off the street without a booking is dangerous.

In light of the Committee’s recommendation we will investigate further potential tie-ins with colleagues at London & Partners, Heathrow and London City Airport. By May 2015 TfL would be happy to consider any further proposals the Committee has for joint working in this area.

 

RECOMMENDATION 3
By May 2015, TfL should further develop the database that links PHV 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.

TFL RESPONSE
We understand and support the principles behind the recommendation to allow private hire operators to link drivers and vehicles through our database. However we are constrained by a series of practicalities, including;

  • PHV drivers have the flexibility to work for multiple operators and freely move between them at any time
  • As with taxis, licensed PHVs can be driven for private purposes by unlicensed drivers or can be driven by multiple private hire drivers through sharing arrangements
  • Strict limitations in the legislation that require PHVs drivers, operators and vehicles to be licensed separately
  • Any changes would need to be considered within the legal boundaries of data protection of driver details

There is currently no requirement for operators to upload details of the drivers and vehicles registered with them to Transport for London’s licensing database. We are planning to amend our online functionality to include a bulk upload facility for operators to upload details of the drivers and vehicles they are using and expect to introduce this by late 2016.

 

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.

TFL RESPONSE
TfL intends to pilot the idea with a separate number plate surround, with a view to eventually securing statutory approval from the DVLA to incorporate the signage into the manufacture of the number plate itself.

In addition to the proposed number plate identifiers, the signage strategy will include clearer driver photo ID to be displayed on the vehicle and a requirement for all private hire operators to provide a passenger with details of the VRM and driver ID of their booked vehicle ahead of the passenger entering the vehicle, as already provided by many operators including Addison Lee and Uber.
TfL action date: Trial to commence Autumn 2015

 

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.

TFL RESPONSE
TfL’s role is to regulate and licence the taxi and private hire trades, not to manage supply and demand. However, a detailed study of driver working patterns via a driver diary survey will be undertaken this autumn. We will explore with the two trades the potential to use technology to undertake this survey.
TfL action date: Autumn 2015

 

Wheelchair symbol imageRECOMMENDATION  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 PHVs (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 and enforce a zero-tolerance approach to drivers and operators across both industries who illegally refuse to carry disabled passengers.
TFL RESPONSE
We take accessibility seriously. This is why the London Taxi Conditions of Fitness require 100 per cent of the taxi fleet to be wheelchair accessible. There are also some 2,500 – 3,000 (around five per cent of the overall private hire fleet) specialist wheelchair accessible PHVs.
We will consider what incentives can be put in place to encourage the take up of more wheelchair accessible PHVs but the trade does not support the imposition of quotas for the provision of accessible vehicles.
TfL supports the proposal to take a zero tolerance approach to driver and operators across both industries who illegally refuse to carry disabled passengers. Any licensed driver or operator who is successfully prosecuted, or where there is clear evidence of poor conduct from our investigation, will in future have their licence automatically suspended.
TfL is also working closely with the Guide Dogs charity to develop a campaign aimed at PHV drivers reminding them of their legal obligations to transport assistance dogs with their owners unless they have a valid exemption document.
TfL action date: May 2015
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, PHVs and Pedicabs or by licensed or unlicensed drivers/vehicles.                                                                                                                                                   

TFL RESPONSE
TfL and the Met Police have put together a bespoke process to collect and extract information on cab-related crime which we use as intelligence and analysis to improve the effectiveness of TfL and police response and crime reduction activities. We will continue to work together to improve this area.

However, in many cases of cab related crime, especially in cab-related sex offences, a suspect is never identified and it can often be unclear whether the driver was licensed or the private hire vehicle was booked.

TfL has established systems, such as our online reporting tool for touting and other cab-related offences. Further improvements are currently being made to intelligence systems and processes to target resources more effectively.

 

Police and PHV imageRECOMMENDATION 11
By May 2015, The Mayor and TfL should provide the Committee with an 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.

TFL RESPONSE
TfL and the Metropolitan Police Service have over 400 officers available for taxi and private hire compliance and enforcement operations. We directly fund 68 dedicated police cab enforcement officers, and now have 41 TfL compliance officers (rising to 48 by March this year) and a further 32 vehicle inspection staff.

Major operations also use Safer Transport Team officers and a group of 290 female police officers are called upon as part of covert anti-touting operations. When this is taken into account, we believe these stand us in good stead against any comparable world city, including New York, which according to the Committee transcript is reported to have a total of 189 enforcement officers available for similar work. TfL will discuss options with the trade for increasing enforcement and compliance officers and the impact this will have on licence fees.

 

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.

TFL RESPONSE
We, alongside the Met Police Roads and Transport Policing Command (RTPC) and City of London Police use a broad range of tactics including high visibility roadside driver and vehicle licence checks, Automatic Number Plate Recognition operations, and uniformed and covert patrols in hotspot locations to deter, disrupt and detect illegal cab activity.

Furthermore, we are working with the Met Police to ensure there is greater flexibility for the Command’s 2,300 Police and Police Community Support officers to boost cab enforcement numbers for specific 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.

TFL RESPONSE
Before the commencement of each journey booked at an operating centre specified in his licence an operator shall enter the following particulars of the booking in the records:
  • The date on which the booking is made and, if different, the date of the proposed journey
  • The name of the person for whom the booking is made or other identification of him, or, if more than one person, the name or other identification of one of them
  • The agreed time and POB, or, if more than one, the agreed time and place of the first pick up
  • The main destination specified at the time of the booking
  • Any fare or estimated fare quoted
  • Name of the driver carrying out the booking or other identification of him
  • The booking has been sub-contracted and the registered number of the vehicle to be used or such other means of identifying it as may be adopted.
The regulations only require an operator to record “the main destination specified at the time of the booking”, and even then, only at the commencement of the journey, not at the time of the booking itself. If no destination is specified by the customer (as there is no legal requirement for a customer to specify one) then the operator is under no legal obligation to record one.
TfL action date: Spring / Summer 2015 (consultation)
Fabric nightclub imageRECOMMENDATION 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.
TFL RESPONSE
We have committed to reviewing the policy on ‘satellite offices’ as part of the Regulations Review. We welcome the suggestion to suspend applications for ‘in-venue’ operators pending the outcome of this. We will issue a trade notice advising that all applications for ‘in-venue’ operators received after 25 February 2015 will be placed on hold pending the outcome of the Regulations Review.
TfL action date: February 2015 (TPH notice suspending applications) / Spring / Summer 2015 (consultation)
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.
TFL RESPONSE
We warmly welcome evidence from the private hire trade of locations where borough parking enforcement is causing problems. We can then work with the borough and trade representative to address the issue.
Tout arrested sticker imageRECOMMENDATION 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.
TFL RESPONSE
This is a matter for Government. Nevertheless, we welcome the Committee’s support on the Law Commission Review and will use this as part of our continued lobbying on the matter.
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.
TFL RESPONSE
We agree in principle but would propose incorporating the development of this into the Mayor’s and TfL’s plans to develop a new approach to engagement with the taxi and private hire trades, as outlined in our response to other Recommendations.
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.
TFL RESPONSE
We believe our current engagement activity matches the requirements of passengers and the trade. Our Engagement Policy was shared with the Committee and explains the rationale for which trade associations we meet. Since autumn 2014 we have implemented a new action tracker for all formal engagement meetings with trade representatives and will publish these regularly.
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.
TFL RESPONSE
As part of the Regulations Review we will consider:
  • Private hire operators being required to provide TfL with general information regarding driver related complaints
  • Private hire vehicle owners being required to display the TfL contact details for complaints on public facing material, such as web sites to encourage reporting direct to TfL
  • TfL Taxi and Private Hire public facing literature being reviewed to make clear customers can contact TfL directly to complain about a private hire journey.
We are also considering the merits of introducing a Code of Conduct for all taxi and private hire driver and operator licensees which would be accompanied by a Passenger Leaflet. To further improve the service provided to passengers, we are also considering the introduction of a tailored training course for taxi and PHV drivers
TfL action date: Summer 2015 (complaints) Summer 2016 (training)

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