Suburban Taxi Licensing Consultation February 2014 · taxi service in London’s suburbs, this...

Suburban Taxi Licensing Consultation

February 2014

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Contents

1. Introduction .............................................................................................. 4

2. Background .............................................................................................. 5

3. Legislative background ............................................................................ 6

4. Proposals for consultation ........................................................................ 6

5. Licence areas .......................................................................................... 7

5.1 Background ..................................................................................... 7

5.2 Issues .............................................................................................. 8

5.3 Proposals for change raised by the trade ...................................... 10

6. Learning the Knowledge of London ....................................................... 11

6.1 Background ................................................................................... 11

6.2 Issues ............................................................................................ 11


7. Driver numbers ...................................................................................... 12

7.1 Background ................................................................................... 12

7.2 Issues ............................................................................................ 14


8. Taxi Ranks ............................................................................................. 15

8.1 Background ................................................................................... 15

8.2 Issues ............................................................................................ 16

8.3 Current activity and the way forward ............................................. 17

9. Helping to improve the supply of taxis in inner and central London ....... 18

9.1 Background ................................................................................... 18

9.2 ‘Going Home’ ranks ....................................................................... 18

9.3 Night time working ......................................................................... 19


10. Island ranks and licence area extensions .............................................. 20

10.1 Background ................................................................................... 20

10.2 Issues ............................................................................................ 21

10.3 Proposals for change .................................................................... 23

11. Radio and app bookings ........................................................................ 23

11.1 Background – taxi radio bookings ................................................. 23

11.2 Background – private hire vehicle bookings .................................. 24

11.3 Issues ............................................................................................ 24

11.4 Opportunities for change ............................................................... 26

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12. Other suggestions .................................................................................. 26

12.1 Background ................................................................................... 26

12.2 Compellable distance .................................................................... 26

12.3 Vehicle types ................................................................................. 27

12.4 Heathrow Airport ........................................................................... 27

13. Taxi trade initiatives to generate business in suburban areas ............... 28

13.1 Clapham case study ...................................................................... 28

13.2 Southfields rank case study........................................................... 28

13.3 Heathrow hotels ............................................................................ 28

14. Summary of consultation questions ....................................................... 29

15. How to respond to this consultation ....................................................... 30

Annex A – Knowledge of London Examination System ................................ 32

Annex B – Extension areas........................................................................... 33

Annex C - Initial Consultation List ................................................................. 34

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1. Introduction

Transport for London (TfL) is a statutory body established by the Greater London Authority Act 1999 and is the licensing authority for London’s taxi and private hire industries. It is the largest licensing authority in the country, being responsible for licensing approximately one third of all taxis and private hire vehicles (PHVs) in England. TfL is responsible for licensing and regulating taxi and private hire services; reviewing and setting taxi fares; appointing taxi ranks; improving travel information; and making services safer and more accessible. The Taxi and Private Hire directorate within TfL has day to day responsibility for the delivery of taxi and private hire licensing services. As a result of issues raised by taxi trade representatives and individual drivers on the disproportionate number of suburban taxis compared to the level of work available, the Mayor, in his 2012 election manifesto, made a commitment to review this issue. This document addresses issues that affect suburban taxi drivers and sets out options for potential reforms to the licensing arrangements designed to create a sustainable licensing system that benefits the taxi trade, the travelling public and London’s businesses. We commenced this review in the autumn of 2012 with two initial workshops with the taxi trade which identified their concerns and allowed participants to make proposals for reform. We also received many more ideas and suggestions from the wider community of drivers following the workshops. We have collated all these concerns, ideas and suggestions and have included as many as possible in this document. All the ideas and suggestions contained within this consultation document have been generated directly by the taxi trade and collated by TfL for the purposes of consulting to gain the views of the wider taxi trade and other stakeholders. Through our engagement process we received many ideas and suggestions for ranks and other improvements relating to specific locations. In order to create a strategic framework for providing a licensed taxi service in London’s suburbs, this document addresses the wider issues rather than those relating to specific locations. Once this framework has been established consideration can be given to ideas for individual locations on an area by area basis. Finally, the majority of ideas and suggestions submitted during the review relate to limiting the number of taxis in suburban areas, the structure of the licensing system or issues relating to the provision of additional infrastructure to support drivers. However, we have also been advised of initiatives that the trade itself has taken to encourage and increase demand for its services. While delivering such initiatives is outside the

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remit of the licensing authority, we support businesses and initiatives that seek to increase trade for licensees. In section 13 below we highlight some examples where the trade has taken steps to generate business and others may wish to use them as best practice models.

2. Background

London taxis (‘black cabs’ or ‘hackney carriages’) have been licensed since the seventeenth century, and the basis of the existing licensing regime was introduced in the mid nineteenth century. Taxi drivers could ply for hire anywhere within the Metropolitan Police District but in those days of horse drawn taxis and a much smaller city, taxi services were concentrated in what is now central London. The expansion of London through the growth of the suburbs created a need for taxi services in a much wider area. This was addressed in 1937 through the introduction of suburban licensing, where drivers would be licensed for a specific but smaller area and limited to work in that area only thus improving the availability of taxi services across the whole of London. There are now 25,597 licensed taxi drivers in London. Of these, 21,914 are licensed to ply for hire anywhere in the Greater London area (‘All London’ drivers). The remaining 3,683 are licensed to ply for hire in discrete areas of suburban London. All licensed taxi drivers are subject to the same compliance and regulatory obligations and licensed to the same standard except for the requirements of the Knowledge. Drivers who have completed the All London Knowledge can ply for hire anywhere in the Greater London area, but other drivers, who have completed the Knowledge only for specific suburban areas, will be issued with a limited licence. The type and vehicle specification for the taxis that they drive and the fares that they charge are the same for all categories of drivers in London. Taxis play a key role in delivering a door to door transport service throughout London and provide vital services to disabled Londoners and visitors. London taxis are all wheelchair-accessible and have grab rails, steps and other aids to help disabled people. Alongside the London boroughs TfL jointly fund the Taxicard scheme, providing subsidised door-to-door trips for disabled Londoners. Although the prime Taxicard contractor is one of the taxi radio circuits and most Taxicard work is carried out by taxis, trips are subcontracted to private hire vehicles if the passenger’s needs allow this and taxi availability is poor. Taxicard work is a significant part of a suburban drivers’ activity. Taxis form part of the capital’s integrated transport network. This network is an important enabler of economic growth and TfL recognises the need to provide a network that supports population and employment growth. Over the next 20 years the city’s population is expected to increase by almost one million people and employment by more than 600,000 jobs;

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London’s economic heartland is likely to extend further, integrating new clusters of activity and growth; and suburban centres will become busier. However, although growth is expected in the future, in recent years the rising number of suburban taxi drivers has outstripped any increase in demand, particularly with the general fall in economic activity. This has resulted in the current situation where there is an over supply of taxi services in many areas and at many times.

3. Legislative background

Legislation to license taxi drivers derives from Victorian times and allows TfL to grant a taxi driver’s licence to anyone who can satisfy TfL of ‘his good behaviour and fitness for such situation’1. TfL does have the discretion to refuse to grant a licence if ‘the applicant is not of good character and fit to act as a taxi driver’2 TfL has no direct statutory power to control taxi or driver numbers. Paragraph 27 of the London Cab Order 1934 allows TfL to limit a taxi driver’s licence to the area that he has demonstrated an adequate topographical knowledge for. Under this provision TfL licenses drivers either for the whole of the Greater London area or for one or more of nine suburban sectors. This provision creates an underlying principle that a driver is only licensed to ply for hire and therefore offer a taxi service in those areas for which that driver has demonstrated an adequate Knowledge.

4. Proposals for consultation

The following sections address all the proposals that have been received from the trade. The proposals are categorised by subject and preceded by background information and a discussion of the issues. The purpose of the consultation is to obtain feedback from both the taxi trade and those who use taxi services in London and particularly in suburban areas to enable us to make informed decisions on future policy. As such, comments are invited from all who may be affected by the proposals and issues discussed. Respondents are invited to comment on any aspect of the proposals or make other suggestions and in so doing provide any evidence relevant to issues or proposals. In making comments, respondents are asked to consider the impact on the taxi market as a whole; both suburban and All London drivers; and the travelling public.

1 London Hackney Carriage Act 1843 section 8 2 London Cab Order 1934 paragraph 25(a)

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Details of how to respond can be found in section 14.

5. Licence areas

5.1 Background The areas that suburban licences have been issued for have changed over time in reaction to the needs of the market and political boundary changes. It is a matter for TfL to determine the structure of suburban licence areas as appropriate. A summary of the different structures is set out below:

1937 – 1983 Within 2.5 mile radii of specified railway stations 1983 – 1989 Six sectors extending from the six mile radius from

Charing Cross to the boundary of the Metropolitan Police District.

1989 – 2000 16 smaller sectors extending from the six mile radius

from Charing Cross to the boundary of the Metropolitan Police District.

2000 onwards Nine sectors defined by borough boundaries within the

Greater London area.

The nine suburban sectors are: Barking & Dagenham, Havering, Newham and Redbridge Barnet, Brent and Harrow Bexley, Greenwich and Lewisham Bromley Croydon Ealing and Hillingdon Enfield, Haringey and Waltham Forest Hounslow, Kingston upon Thames and Richmond upon Thames Merton and Sutton

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Figure 1 - Suburban sectors and six mile radius from Charing Cross

One factor in the change in 2000 was the realignment of the Metropolitan Police District to that of the Greater London area. The boundaries of the new sectors were aligned as closely as possible with combinations of the existing sectors. Although some parts of the old sectors were lost to non-London local authorities, the new suburban licence areas now extend further into central London than before.

Drivers licensed under the previous structure had their existing licence areas converted into combinations of boroughs. Where these conversions resulted in some drivers only being licensed for parts of one or more of the new nine sectors, they could (and still can) apply to be assessed on their topographical knowledge of the other boroughs in the sector to enable them to be licensed for the complete sector. Nevertheless, as a legacy of the previous sector structure and conversion process, many drivers are still licensed for combinations of boroughs that do not match the new sectors.

5.2 Issues

Some drivers have argued that several of the current sectors are too small, restricting their ability to ply for hire. Drivers can apply to be licensed for additional sectors or for the All London licence but in order to do so they have to undergo the full Knowledge of London testing procedure, thereby meeting the regulatory requirement referred to at 3 above. Studying for the Knowledge of London for each sector takes on

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average, two years to complete (see 6.1 below) with the All London area taking an average of over four years.

Through the workshops held in 2012 an alternative licensing strategy has been suggested by some parts of the trade to the effect that consideration could be given to enlarging the existing sectors which would allow drivers to ply for hire in a wider area as opposed to the current sector by sector licensing. Three specific suggestions for alternative licence areas have been made:

a) Four sectors – north west, north east, south east and south west

b) Two sectors – north and south

c) One sector – a ring of all 22 suburban boroughs Larger licence areas would give drivers more work opportunities, offer increased flexibility of movement and reduce the number of disengaged miles they have to drive. However, the larger the area to be learnt, the longer the Knowledge of London would take. This would create a significant barrier to entering the industry. For example, if it takes two years to learn just one of the existing sectors, learning all or even just half of the entire suburban area of London is likely to take a prohibitively long time. Many drivers see much larger licence areas and associated longer periods of learning the Knowledge as a form of entry control measure which could, over time, reduce the perceived excess numbers of drivers. In the long term this might starve the industry of new drivers, and could also have the effect of encouraging the growth of private hire activity as it would be significantly easier to qualify as a private hire driver than a suburban taxi driver. Another effect could be that suburban drivers would concentrate on lucrative areas within the enlarged sectors, reducing the availability of taxis in some parts of London. If any of the above options were adopted, consideration would have to be given as to what steps existing drivers would have to take to increase their licence areas to match the new structure. A number of contributors to the review identified what they believed to be an anomaly in the current stipulation that drivers can only ply for hire in areas for which they have demonstrated an adequate Knowledge. The Knowledge testing system ensures that suburban drivers have a detailed Knowledge of their sector and an awareness of central London and neighbouring sectors, yet are restricted to only working within their

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sector. In contrast, All London drivers have a detailed Knowledge of central London and a general awareness of the suburbs but are allowed to work anywhere in the Greater London area. As a result, All London drivers can compete for trade with suburban drivers in outer London areas, for which they only have demonstrated a limited Knowledge but suburban drivers cannot do likewise in central London. Some contributors have suggested that a more equitable approach would be to replace the All London licence with an Inner London one, allowing drivers to ply for hire only within the six mile radius of Charing Cross. We do not consider replacing the All London licence with an Inner London licence a viable option however respondents are welcome to provide their comments on this. Another radical proposal that has been received from the trade is to discontinue the concept of the suburban licence and only issue All London licences. Over time the existing population of suburban drivers will diminish leaving All London drivers to meet the demand for taxi services in outer London. However, without restricting drivers to suburban areas there is a risk that All London drivers show preference for central London work only, which will in turn impact adversely on the availability of taxis in suburban areas. To ensure public safety other measures may be needed to encourage drivers to work in suburban areas.

5.3 Proposals for change raised by the trade Through the workshops and ongoing review, the taxi trade has made a number of suggestions for restructuring licence areas which are outlined below. Respondents are asked to consider whether these are desirable or practical.

Q1 Do you think that changes to the suburban licence areas are desirable and

practical? Q2 If changes are to be made, would you propose creating a new suburban

licence area structure of:

a) four sectors – north west, north east, south east and south west

b) two sectors – north and south

c) one sector – a ring of all 22 suburban boroughs or

d) some other arrangement? Please describe your proposal.

Please explain the reasons for your preference.

Q3 Would you support discontinuing the concept of the suburban licence? Please explain your reasons.

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6. Learning the Knowledge of London

6.1 Background

The Knowledge of London is designed to ensure that taxi drivers have an adequate knowledge of their licence area to allow them to deliver a good service to the travelling public. Suburban drivers are required to have an in-depth knowledge of their sector, knowledge of major locations in adjoining suburban sectors (e.g. transport hubs, 5 star hotels, sports venues, hospitals, shopping centres, etc.) and a general knowledge of central London. The latter includes knowing the locations of major points of interest in central London and how to reach them from the driver’s sector. They are also required to know how to reach Heathrow and London City airports from their sector. Of all those suburban drivers first licensed in 2013/14 to date, the average time to complete the Knowledge of London is 29 months. Drivers are required to have an in-depth knowledge of central London within the six mile radius of Charing Cross to qualify as All London drivers; it is estimated that these students learn in the region of 25,000 street names and 20,000 points of interest within this area. These drivers are also required to have a general knowledge of routes to suburban areas from both central London and Heathrow Airport. The average time to complete the All London Knowledge of London is currently 51 months. The Knowledge examination process is summarised in the diagram at Annex A.

6.2 Issues

The Knowledge examination system should ensure that licensed taxi drivers have a level of topographical knowledge of their licence area that allows them to provide a good service to the public. The current system tests students’ Knowledge to a high standard and there is no intention to lower that standard. However, changes could be made to the testing process. Through the Knowledge examination process and subsequent experience of working, existing suburban drivers will have and develop an awareness of their neighbouring sectors. However, to enlarge their licence area by adding a full sector to their licence involves a driver undertaking the full Knowledge of London examination process. It has been proposed that drivers who have been licensed for a specified period of time should be able to add neighbouring sectors without going through this lengthy process. This could be particularly pertinent if one of the options at 5.3 (Q2) was adopted.

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Some suburban drivers aspire to becoming All London drivers but struggle to combine the demands of earning a living as a suburban taxi driver and the time it takes to learn the All London Knowledge. Given that suburban drivers already have a general Knowledge of central London, it has been suggested that suburban drivers could enter the examination system for the All London Knowledge at a later stage (e.g. Stage 3 or 4). This could significantly reduce the time it takes a suburban driver to complete the All London Knowledge. However, any such driver would have to accept the risk that if their Knowledge was not of an acceptable standard, the current system would require them to repeat stages or revert to previous stages.

The grading system used in the Knowledge examination process allows those who demonstrate a higher standard to take fewer examinations and progress through the system at a faster rate. This should already benefit suburban drivers who have a good working knowledge of central London and reduce the time it takes them to become an All London driver. We have also received suggestions that any suburban driver who has been licensed for a specified period of time should automatically be ‘promoted’ to an All London driver. To do this without assessing a driver’s Knowledge would not only conflict with the requirements of the London Cab Order 1934 outlined at paragraph 3 above, but also undermine the investment that All London drivers have made to become licensed. In the circumstances we do not believe that this is a realistic proposal and it will not be pursued further.

6.3 Proposals for change raised by the trade The taxi trade has made a number of suggestions in regard to the Knowledge of London which are outlined below. Respondents are asked to consider whether these are desirable or practical.

Q4 Should suburban drivers be able to add adjoining sectors to their licence without undertaking the full Knowledge examination process?

Q5 Should suburban drivers who wish to become All London drivers be allowed to enter the examination system at an advanced stage?

7. Driver numbers

7.1 Background Unlike in some other parts of England and Wales, TfL has no express statutory powers to limit the number of taxi drivers in London. In accordance with Section 8 of the London Hackney Carriage Act 1843 all applicants who meet the required standards are licensed within the meaning of the 1843 Act.

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This key difference was recognised by the Law Commission in its 2012 consultation document on reforming the law of taxi and private hire services in England and Wales3. However, the Law Commission noted that “the stringent knowledge tests required of drivers in London and the costly vehicles required to meet the conditions of fitness constitute a significant barrier to entry and are widely regarded as achieving an equivalent result to quantity regulation”4. There are currently 3,683 licensed suburban taxi drivers. In the past 10 years the number of suburban drivers has increased by 18 per cent. During the same period the number of All London drivers has remained static and the number of private hire drivers has approximately doubled.

Figure 2 - Suburban taxi drivers5

Following a report commissioned by the Office of Fair Trading in 20036, the Department for Transport (DfT) issued guidance to the effect that existing taxi quantity control measures in place outside London should be removed wherever possible. This is similar to the view previously expressed by the Law Commission7 thereby indicating a clear desire from government to move away from restricting taxi numbers where they exist. However, in its interim report the Law Commission has stated that it no longer recommends abolishing quantity controls citing “the weight of

3 Law Commission, Reforming the law of taxi and private hire services (May 2012) 4 Ditto, para 9.1 5 As at 31 March apart from 13/14 where figure is for the date of this document. 6 Office of Fair Trading, The regulation of licensed taxi and private hire vehicle services in the UK (November 2003) 7 Law Commission, Reforming the law of taxi and private hire services (May 2012) para 17.14

3114

3147

3127

3225

3331

3580

3571

3582

3737

3683

2000

2250

2500

2750

3000

3250

3500

3750

4000

04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14

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evidence received during consultation and further comparative research have led us to change this key recommendation in order to allow licensing authorities to limit taxi numbers should they wish to do so”8. The Law Commission proposes to publish a draft Bill by the end of April 2014 but as the final decision rests with the government, it remains unclear as to whether or not licensing authorities will be able to control taxi numbers in the future.

7.2 Issues One of the main concerns the taxi trade has expressed during the review is that there are too many drivers competing for a share of the taxi market in outer London. To reduce problems such as over-ranking and to give existing drivers a better chance of earning a living many drivers have called for the number of drivers to either be capped or for a suspension in accepting applications. Advantages of quantity restrictions include congestion and environmental considerations; removing over-ranking and maintaining drivers’ earnings. However, there is evidence to suggest that where taxi numbers are restricted, any shortfall is likely to lead to a rise in private hire numbers. The Office of Fair Trading found that quantity restrictions can have a number of other adverse impacts including: • fewer taxis per head of population

• longer waits for taxis

• increased use of less suitable alternative modes of transport

• creation of a premium on licences and

• long waiting lists for licences. In guidance issued by the DfT9 it states that quantity controls should be approached in terms of the service to the travelling public and that licensing authorities should assess the benefits and disadvantages to them when considering controlling numbers. The DfT adds that numbers should only be restricted if there can be demonstrated to be no significant unmet demand for taxi services. However measuring unmet demand is a complex and expensive task that needs to be undertaken on a regular basis.

8 Law Commission, Taxi and Private Hire Interim Statement (9 April 2013) 9 DfT, Taxi and Private Hire Licensing: Best Practice Guidance (March 2010)

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The issues surrounding quantity restrictions were discussed in greater detail in chapters 9 and 17 of the Law Commission’s consultation document. As an alternative to prescribing a limit to taxi numbers, suspending new entrants to the industry would impact on the number of licensed drivers: The 20 per cent growth seen in the last 10 years would certainly be slowed and eventually there would be fewer drivers as older licensees retire. In February 2012, pending the outcome of the review and this consultation, we suspended accepting new applications for the three sectors with the highest number of licensed drivers and existing Knowledge students. This has resulted in a significant reduction in the overall number of applications for suburban licences, with little increase in application for the other six sectors. Many drivers have proposed that this suspension is extended to all nine sectors for a defined or indefinite period. The immediate advantage of not accepting new applications and licensing any more drivers is that the ever increasing competition for business will diminish. However, in the longer term, a restricted supply may not be able to respond to increased demand, especially taking into consideration that it takes on average two years to become a licensed suburban taxi driver. This may have the undesired effect of passengers turning to alternative means of transport.

7.3 Proposals for change raised by the trade The taxi trade has made the following suggestions in regard to the number of licensed drivers. Respondents are asked to consider whether any are desirable or practical.

Q6 Should the number of suburban taxi drivers be capped?

Q6a If numbers were capped, what criteria should be used to determine the limit?

Q7 Should applications for all suburban licences be suspended for either a specified or indefinite period?

Q7a If applications were suspended, what criteria should be used to determine a resumption of licensing, either in individual sectors or on a London-wide basis?

8. Taxi Ranks 8.1 Background

Taxi ranks are a vital part of the transport network and help ensure that taxi services can meet passenger demands. Work from ranks, often at rail

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or tube stations, is more significant for suburban taxi drivers than in central London where on-street hailing is more common. TfL can appoint taxi ranks on the public highway in all Greater London boroughs, with the exception of the City of London. However, although we have the power to appoint taxi ranks, the vast majority of taxi ranks are located on roads that are the responsibility of local authorities (London boroughs) and these authorities are responsible for maintenance of the rank and enforcement of parking restrictions. The final decision to appoint a rank depends on a partnership between those authorities and TfL. We also work closely with boroughs, taxi trade associations and other relevant stakeholders (e.g. Network Rail, hotels, airports, police, etc.) to try and ensure that sufficient taxi rank facilities are provided on both public and private land not under TfL control. Ranks at stations are particularly important in suburban London, but these and other ranks on private land are at the discretion of the landowner. In some cases a rank on station land will be fed from a related rank on the public highway. For a taxi rank to be effective and provide a viable location for taxi drivers to work and for the public to get a taxi, the rank must be well located, have space for a sufficient number of taxis and have good access for passengers. Every potential taxi rank location is assessed on an individual basis but finding suitable locations can be difficult, as there are often competing interests and requirements for road space. Roadside space is often wanted for loading bays, parking bays and other uses or it may need to be kept clear to maintain traffic flows. Even when a suitable location is identified there may be objections from some stakeholders (e.g. local residents, businesses, buses, etc.).

8.2 Issues

Suburban taxi drivers are concerned that there has not been an increase in rank spaces to accommodate the rising number of drivers. There is strong support from the trade to appoint more ranks at stations, supermarkets, hospitals and other locations where there may be high demand for taxis and appointing more ranks or enhancing existing ones may seem to be a simple solution to address this problem. However, the challenges listed above plus issues regarding timescales, budget, and resources can mean that it is not always easy or possible for a rank proposal to be realised and successfully completed. Despite a taxi rank appearing to be no more than just markings on the road and a couple of signs, the process for actually appointing a new taxi rank can be complicated, involve a number of different groups and take many months to complete. When a potential location for a new taxi rank is identified we will assess this to initially determine whether it is feasible. If a proposal is considered

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feasible then it will need to be submitted to the relevant highway authority, which in most cases will be the borough. The combination of budget and resource cuts means that a borough may not be able to consider a request immediately. Once a borough does consider a request they may have objections or have other stakeholders who object. For example residents may see additional parking spaces or businesses may see more loading bays as more important priorities. With the vast majority of taxi rank proposals it will also be necessary for the highway authority to conduct a consultation notifying the public of the proposal. Once the consultation period has finished responses and objections to the proposal will need to be considered. Finally, if there is agreement to appoint a new taxi rank, the highway authority will need to prepare a Traffic Management Order and TfL will need to publish the details in the London Gazette. Once all of this has been completed then the road can be marked and the signs put up. By way of example, appointing the new taxi rank at Richmond Station took many months to complete partly due to the need for discussions between many organisations including TfL, Network Rail, the London Borough of Richmond upon Thames and local taxi drivers plus the MP also had some involvement. The complexity of this process is not unique and normally has to be repeated for every rank that we seek to appoint. Although taxi ranks are an essential part of a successful and effective transport network they are just one of a large number of competing priorities for boroughs, particularly in the current economic climate. Similarly, landowners may have other demands on the space for vehicles. In some cases we provide funds to establish a rank in partnership with the local borough. However, we cannot use taxi licence fees for this purpose and we have limited other funds. Where TfL is unable to assist with funding new ranks or make changes to existing ranks then it may not be feasible to proceed with a new rank initiative. Finally, we can also face reluctance from stakeholders to assist in appointing new ranks when some existing ranks are under-used and regenerating such ranks is just as equally important as appointing new ones. A case study of how one particular rank was regenerated can be found at paragraph 13.2.

8.3 Current activity and the way forward In his 2012 election manifesto, the Mayor committed to asking TfL “to produce a ‘ranks plan’ that will protect existing ranks as far as possible and identify new ones”. In implementing this plan, we are engaging with each London borough through meetings, highlighting the benefits of having taxi ranks and

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encouraging them to support the appointment of new taxi ranks. We will also continue to engage with drivers on a sector basis to gain their views and opinions on ranks. Although the taxi trade has expressed a strong preference for an increased number of ranks, and has identified potential rank locations, creation of new ranks is not entirely within our control, as explained above. We already do everything in our power to achieve more rank spaces for drivers but if there are any suggestions for alternative strategies that we can deliver, please make them in your response to this consultation. We will then assess the feasibility of the suggested strategies.

9. Helping to improve the supply of taxis in inner and central London

9.1 Background The supply of taxis in central London is generally good and there is evidence of over supply in some contexts, particularly with over-ranking around main stations. However, late at night there are many issues with illegal cab activity and touting, and improving the availability of taxis could help to reduce the risks to vulnerable late night travellers.

9.2 ‘Going Home’ ranks In order to increase the supply of taxis in central London at night, in particular for passengers wanting to go home to the suburbs, it has been proposed that some ranks at key central London locations are designated as ‘Going Home’ ranks and that suburban drivers would be able to service these between certain hours. The concept is that suburban drivers should be permitted to ply for hire at specified ranks at certain times but only allowed to accept fares where the destination is within their licence area. Provision of this facility would clearly benefit suburban drivers but it is not clear that it could make a significant difference to the availability of taxis. It is also based on the assumption that demand for taxis in central London that cannot be met by All London drivers. A similar approach was tested with All London drivers at Cranbourn Street in Westminster between October 2004 and March 2010. Although there was some initial success, problems emerged with mismatches between the journeys passengers wanted to take and the directions that taxi drivers were ready to travel in, and there was often a shortage of taxis going south and west while several taxis were waiting for fares to east London. This undermined the accepted taxi rank principle of the first taxi taking the first fare (unless a passenger wants to choose a different one on the rank) and caused conflict at the rank. As a result, the directional element of the scheme was dropped.

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Passengers tend to rate their personal safety while at a rank along with the helpfulness of drivers and marshals as most important when using taxi services, suggesting that the ‘normal’ marshalled taxi ranks that currently operate meet passengers’ needs. To ensure that ‘Going Home’ ranks operate effectively and meet passengers’ needs, marshalling and enforcement would therefore be necessary which would incur significant associated costs. In summary, potential issues arising from ‘Going Home’ ranks include: • a lack of demand for taxis to particular areas;

• dealing with multiple drop offs that are in different sectors;

• costs of marshalling; and

• an increase in reports of suburban drivers in central London perceived to be plying for hire, the associated enforcement of which could overwhelm TfL’s compliance resources.

9.3 Night time working

An alternative proposal from some members of the trade to increase the supply of taxis at night in central London is to allow suburban drivers to ply for hire anywhere in central London at night. Again this assumes that there is a demand for taxis in central London that cannot be met by All London drivers. Significantly, suburban drivers have not demonstrated a Knowledge of central London in any detail which provides a real risk that the standard of service to passengers will go down and complaints about drivers will go up, damaging the reputation of London’s taxi trade. Moreover, without additional Knowledge testing, this proposal goes against the principle that a driver can only ply for hire in areas for which he has demonstrated a satisfactory Knowledge. Both this legal requirement and the risk to the service provided to the public could be mitigated by requiring drivers to undergo a form of Knowledge testing bespoke to London’s night-time economy although this will be perceived by All London drivers as a short-cut to working in central London, undermining the time and effort they have invested in learning the All London Knowledge. Enforcement of any form of restricted licence in central London would be highly onerous and virtually impossible and such an overly complex system could be confusing for the travelling public.

9.4 Proposals for change raised by the trade

The taxi trade has proposed ‘Going Home’ ranks and allowing suburban taxi drivers to work in central London at night as solutions to improving the

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supply of taxis in central London. However, for the reasons discussed above we do not believe that they are practical or realistic proposals and they will not be pursued further.

10. Island ranks and licence area extensions

10.1 Background It is often claimed that there are areas between four and six miles from the centre of London which are not well served by All London drivers but are not available to suburban drivers. Methods to resolve this have included designating island ranks and creating extensions to suburban sectors. Where a taxi rank close to the border with a suburban sector has been identified as not providing a sufficient supply of taxis, we have designated it as an island rank and allowed drivers licensed for the adjacent sector to ply for hire on the rank. At present there are six such ranks: • Finsbury Park Bus Station – Haringey drivers

• Garratt Lane (Arndale), Wandsworth – Merton and Sutton drivers

• Garrett Lane (Sainsbury’s), Wandsworth – Merton and Sutton drivers

• Mitcham Road (Tooting Broadway Station) – Merton and Sutton drivers without the Clapham extension

• Wimbledon Park Road (Southfields Station) – Merton and Sutton drivers

• High Street, Putney - Richmond upon Thames drivers In addition to these ranks, we have also designated temporary island ranks to facilitate transport provision at one-off events. For example, at last year’s Kenwood House summer concerts, the rank on Hampstead Lane in Haringey was made available to drivers licensed for the London Borough of Barnet. Similarly, to support the Radio 1 Hackney Weekend in June 2012, drivers licensed for Haringey, Waltham Forest or Newham were allowed to use the taxi rank in the Northern Spectator Transport Mall which is in Hackney. Island ranks only address demand at those specific locations rather than in a wider area. In 2003 an alternative scheme was launched in south London to provide a better taxi service in the Clapham, Balham and Tooting areas. The scheme consisted of allowing drivers licensed for the Merton and Sutton sector to apply for an extension to their licence that would permit them to ply for hire at the underused ranks at The Pavement (Clapham Common), Balham Station Road and Mitcham Road (Tooting Broadway Station) as well as within a prescribed area around those ranks.

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In order to meet the principle of drivers only plying for hire in areas for which they have an adequate knowledge, drivers who wished to add the extension to their licence were required to pass a single Knowledge of London assessment for the area concerned. The scheme was initially trialled with 100 drivers and following its success was later opened up to all drivers licensed for Merton and Sutton. Of the 620 drivers licensed for Merton and Sutton, 318 are now also licensed for the Clapham extension. At the time the Clapham extension was launched, we took the view that if the scheme was successful the principle could be extended to other areas and in 2006 a similar scheme was launched in Hackney. Drivers licensed for Haringey and/or Waltham Forest can apply to be licensed for the extension and 130 of the 196 eligible drivers have done so. Maps of the two extension areas can be found at Annex B.

10.2 Issues Although the primary reason for creating islands ranks and extensions is to meet un-met demand for taxis rather than to relieve over supply in suburban areas, there is no doubt that the existing island ranks and extensions have provided increased work opportunities for all taxi drivers eligible to work at these locations. Furthermore, the experience from Clapham is that once a regular taxi supply is created this in itself generates greater demand. Although only six island ranks and two extensions currently exist there may be potential to increase this number. While this may be a piecemeal approach to changing licence areas and be a departure from the simplicity of borough based sectors it would be focussed on the needs of the travelling public. During the review we received many suggestions that we should adopt an approach of designating additional island ranks and sector extensions, including proposals for specific locations. If an outcome of this consultation is to designate more island ranks and extensions, we would introduce a formal assessment framework to ensure that all suggestions are considered and assessed in a fair and consistent manner We propose that this framework would take into consideration: • the proximity of a proposed island rank to the nearest suburban sector

boundary

• the proximity of a proposed extension area to busy central London areas

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• what market the rank or extension serves (the likelihood that trips would take suburban drivers into their licensed area, or further way from it)

• what existing taxi ranks are in a proposed extension area

• the supply of passing available taxis

• roads or features which can be used to define an extension area and make it clear to the drivers where this ends

• the views of the Cab Ranks Committee

• the views of the local drivers

• feedback from the borough, local businesses, the public or other relevant parties

A taxi rank located in an area that is already well served by All London drivers or is too far away from any suburban sector boundary will not normally be considered as an island rank. In some locations it may be suggested that a new taxi rank is needed and that this should be immediately designated as an island rank. However, where a new taxi rank is appointed in a non-suburban borough this will normally operate as a rank for All London drivers. Use of the rank will be monitored and if it is not served, consideration will then be given to designating it as an island rank in order to increase the supply of available taxis. Where an existing taxi rank is not being used by All London drivers but, following a review, is not going to be designated as an island rank then the rank may be revoked. As with any other measures that allow drivers to ply for hire outside the boundaries of the suburban boroughs, drivers licensed for the extension areas may be perceived to be plying for hire outside their area which can result in increased reports of non-compliance or conflict within the taxi trade. Any measures that allow suburban drivers to work in areas that have to date been only available to All London drivers are likely to be unpopular with All London drivers. However, in the interests of providing an adequate taxi service we will consider the needs of the public in the first instance. Finally, licensing for the two existing extensions remains optional and does not form part of the standard Knowledge testing process for the either the Merton and Sutton or Enfield, Haringey and Waltham Forest sectors. It could be desirable to extend these two sectors on a permanent basis and remove the need for new licensees to undergo an additional Knowledge

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examination. If additional extensions were designated, these could also be fully incorporated into the respective sectors.

10.3 Proposals for change

Respondents are asked to comment on the following proposals and questions:

Q8 Should TfL pursue a strategy of designating further island ranks and extensions to suburban sectors?

Q9 If yes to Q8, what factors should be taken into consideration within a formal framework for considering and assessing further island ranks and extensions to suburban sectors?

Q10 If un-met demand for taxis is the principal criteria for designating extensions, how should it be measured?

Q11 For new applicants, should the Merton and Sutton and Enfield, Haringey and Waltham Forest sectors be extended on a permanent basis to include the extension areas?

11. Radio and app bookings

11.1 Background – taxi radio bookings

The legislation outlined in section 3 embodies the underlying principle that a taxi driver is only licensed to ply for hire and therefore offer a taxi service in those areas for which he has demonstrated an adequate Knowledge. When plying for hire, a taxi driver can accept fares through street hails, from ranks or via radio bookings. A driver can accept radio bookings that start outside his licensed area but it has been determined that the driver must be in his or her licence area when accepting the booking. The case of DPP v Computer Cab and John Baughan and others in November 1994 confirmed this position: The High Court determined that as the driver agreed all aspects of the hiring at the time of accepting the radio booking (in his licensed area), he was neither ‘plying for hire’ nor ‘permitting his cab to be hired’, as specified in paragraph 31(1) of the 1934 Cab Order, while outside of his licence area. This tends to undermine the principle of ensuring that the driver has an adequate Knowledge of the area in which he is providing a taxi service. Furthermore, it creates the irrationality that it is not where the taxi journey starts and finishes that matters but the location of the driver when he accepts the booking. It must be noted that the regulations governing the current situation were introduced long before the concept of telephone bookings or the internet existed.

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11.2 Background – private hire vehicle bookings As long as the booking is accepted by a licensed London PHV operator and discharged using a licensed PHV driver in a licensed PHV, there are no limitations on where the driver must be when allocated the booking or where the journey starts and finishes. From a passenger’s point of view there is little difference in the way they book a taxi through a radio circuit and a private hire vehicle with a private hire operator. From a regulatory perspective, the fundamental difference is that the private hire operator is licensed and has regulatory responsibilities. In addition to using licensed PHVs driven by licensed PHV drivers, section 4(2)(b) of the Private Hire Vehicles (London) Act 1998 allows licensed PHV operators to allocate private hire bookings to “a London cab driven by a person holding a London cab driver’s licence”. However, even when a licensed taxi undertakes a PHV booking, taxi legislation and regulations still apply. This includes the driver only permitting his cab to be hired when he is in his licensed area.

11.3 Issues As outlined above, taxis radio bookings and PHV bookings are in essence very similar yet the rules regarding drivers’ licensed areas have created an anomaly that disadvantages licensed taxi drivers, particularly suburban ones. A number of drivers we have engaged with have asked for a change in the rules to remove this anomaly. Smartphone applications (‘apps’) are now providing another fast and easy way of obtaining the services of a taxi. This is a significant area of development in the taxi industry and an increasing number of drivers have realised the increased business that such facilities can generate. The advent of apps that allow a passenger to ‘hail’ a taxi via their phone has exacerbated the anomaly affecting radio bookings as the app providers frequently rely on suburban drivers to fulfil bookings that start in the periphery of the central area, meaning that these drivers repeatedly have to return to their sector before they can accept a further hiring. Elsewhere in England and Wales a taxi can legitimately be hired if the driver accepts a pre-booking outside of his or her licence area. In its provisional proposals, the Law Commission not only recommends retaining this ability but also proposes including London in any revised legislation. If it was desirable to allow suburban drivers to effectively act as PHVs by accepting pre-booked fares when outside their area, regulations could be amended accordingly. For example, if taxi drivers were allowed to accept private hire bookings when outside their licence area, radio circuits could become licensed PHV

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operators and then discharge all their bookings to licensed taxis and not have to worry where the taxi was at the time. For radio bookings to be treated as PHV bookings would necessitate the radio circuits being licensed as PHV operators and meeting all the associated record keeping and other regulatory requirements. These operators could only continue to use the terms ‘taxi’, ‘taxis’, ‘cab’ or ‘cabs’ in their names or in any advertisements if they exclusively provided service with taxis. Alternatively regulations could be changed to allow radio circuits and app providers to give bookings to taxis regardless of the taxi’s location (although this could be constrained to the Greater London area) without becoming PHV operators. Adopting this position would make radio circuits quasi PHV operators that would sit outside the PHV licensing system and not be subject to the associated compliance regime. Allowing suburban drivers to accept pre-booked fares when outside of their licensed area could effectively allow suburban drivers to work anywhere in London, including the central area. While radio circuits and app providers may see this as an opportunity to ensure demand is always met and suburban drivers will see it as the removal of the disparity with private hire, All London drivers would perceive this as a threat to their business. Furthermore, this would to a degree create the ‘cross border hiring’ issue of taxis acting as PHVs outside of their licence area – a problem that affects other cities in England and Wales but not currently a significant one in London. The main difference is that suburban taxis in central London would still be operating within the jurisdiction of TfL which would allow us to undertake compliance and enforcement activity. Suburban drivers consistently working outside their licence area, albeit only undertaking radio or app bookings, could result in a reduction in the provision of taxis in suburban areas. However, this could also be seen as an opportunity to alleviate the apparent over-supply in outer London. Any measures that legitimised suburban drivers working outside their licensed area presents the risk that they may ply for hire when they are not allowed to do so. Although the introduction of taxi driver licence area identifiers makes the identity of drivers more visible, such a move would result in more suburban drivers being present in central London and a perception that they were plying for hire even when they were not. From the travelling public’s perspective there is an expectation that London taxi drivers will have a high level of knowledge of the area they are working in. The instant nature of some radio and app bookings means that there is not always the opportunity for the driver to pre-plan the route which could result in a gap between the passenger’s expectation and the service the driver is able to deliver.

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11.4 Opportunities for change Respondents are asked to consider whether any of the following opportunities for change are desirable or practical.

Q12 Should TfL introduce or amend regulations to allow taxi drivers to accept private hire, radio circuit or app bookings when outside their licence area?

Q13 Should TfL introduce or amend regulations to allow radio circuits and app providers to give bookings to taxis regardless of the taxi’s location (potentially constrained to the Greater London area) without becoming private hire operators?

12. Other suggestions

12.1 Background The preceding paragraphs have addressed many of the issues raised by taxi drivers and trade representatives during the review of suburban licensing. However, there were some other subjects that were raised that we do not intend to consider any further. These issues are outlined below. As mentioned in the introduction, the service provided by suburban drivers is exactly the same as that provided by their All London colleagues. This includes driving the same vehicles, charging the same fares and abiding by the same rules. As a result, no matter where in London they are, a member of the public can expect the same standards from any taxi they hire. Although some drivers have questioned whether this position remains appropriate and have proposed that different standards should be applied to suburban taxi services, we do not propose to move away from the universal standard of service that is provided by London’s taxis and taxi drivers.

12.2 Compellable distance London taxi drivers are compelled to accept any hiring of up to a distance of 12 miles (or 20 miles if the journey starts at Heathrow Airport) as long as the destination is within Greater London. For All London drivers this means that they will always be in their licensed area whenever the journey ends, however this requirement can easily cause a suburban driver to take a passenger to a destination outside of their licence area where they cannot ply for hire. The driver is then faced with ‘dead mileage’ as he returns to his sector before being able to accept a further hiring. Some drivers believe that this places suburban drivers in an unfair position. The compellable distance provides the public with the assurance that any taxi they hire in London will take them to their chosen destination (within common limits) regardless of who is driving it. There is no discernible

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benefit to the travelling public in allowing taxi drivers to provide different levels of service based on the area they are licensed for and we do not propose to change the compellability requirement.

12.3 Vehicle types All 22,700 taxis in London are licensed to the same standard10 which provides a fully accessible taxi fleet and modern vehicles that meet the Mayor’s Air Quality Strategy. This provides the public with the assurance that any taxi they hire in London will have the same features and provide the same quality of service. Some drivers have proposed that taxis that operate in the suburbs should meet different standards, in particular not having to meet the turning circle requirement or relaxing the 15 year taxi age limit. Drivers have argued that removing such restrictions could allow a wider range of vehicles to be licensed and the increased competition could result in reduced costs for drivers. We do not see any discernible benefit to the travelling public by allowing vehicles of different standards to ply for hire in different parts of the capital and do not propose to change the universal standard. Nevertheless, we will continue to work with vehicle manufactures to encourage greater choice and competition in the London taxi market.

12.4 Heathrow Airport Heathrow Airport is an important source of business for London’s taxi trade, but as the airport is on private property, the decision as to who can ply for hire at the airport rests with the airport operator, Heathrow Airport Limited (HAL). In managing the provision of onward travel from the airport and in order to meet their customers’ needs, HAL has determined that the taxi service at Heathrow should be provided by All London drivers only. Therefore, even though Heathrow Airport is situated wholly in the London Borough of Hillingdon, suburban taxi drivers licensed for Hillingdon are not permitted to ply for hire at the airport. Following representations from suburban taxi trade representatives, HAL revisited its position in 2011 and decided to retain the status quo. During our review a number of drivers proposed that suburban drivers be allowed to work at the airport. However, as the power to authorise taxi drivers to ply for hire at Heathrow rests with the airport operator, this is a matter entirely for HAL to determine and is not addressed any further as part of this consultation.

10 Metropolitan Conditions of Fitness

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13. Taxi trade initiatives to generate business in suburban areas

13.1 Clapham case study A scheme established and run by working suburban drivers in Clapham has been successful in generating increased work for drivers in that area. A 0800 telephone number, forwarded to pay as you go mobile phones provided to the 20 participating drivers, is being used as a taxi booking service. When members of the public want to obtain a taxi they call the 0800 number, free of charge, and the first participating driver on the Clapham Common rank accepts the booking. There is no ‘operator’ involved, no extra charges and the driver does not start the meter until he or she is at the caller’s address. In a similar way to that used by local private hire operators, the telephone number has been widely advertised via the distribution of business cards and leaflets. The organisers have now set up a website that advertises their services (www.sw4blacktaxis.com). The Clapham scheme was set up in October 2011 and is now receiving over 600 requests a month for taxis. With six 0800 numbers, the scheme has now been extended to ranks in Balham, Morden, Sutton, Wimbledon and Croydon. Advertising, providing and servicing the phones, the 0800 number and forwarding service does involve some costs but these are offset by the revenue that is being generated. The success of this scheme is due in no small part to the dedication, commitment and effort of a few individual drivers, but this example does demonstrate how taxi drivers can increase their business in a fairly simple, low tech, low cost way.

13.2 Southfields rank case study The taxi rank at Southfields Station was underused and risked being lost. To avoid this happening a small group of suburban drivers organised themselves to ensure that a regular taxi service was provided which would in turn generate repeat business for local drivers. Led by a local trade organisation representative, drivers took turns to ply for hire on the rank and even though they may not have been hired, their constant presence raised the public’s awareness of the availability of a taxi service.

13.3 Heathrow hotels The large number of hotels near Heathrow Airport provide plenty of business opportunities for the suburban taxi trade even though suburban drivers cannot ply for hire at the airport itself.

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To provide a passenger transport service to the airport terminals, many hotels have arrangements with local private hire operators. Members of the taxi trade believe that these journeys frequently cost significantly more than the journey in the opposite direction would in a taxi hired from a rank at the terminal and see an opportunity to compete for this business. Suburban drivers licensed for Hillingdon and Hounslow (the two boroughs immediately adjacent to the airport) have identified that ranks on the hotel forecourts would allow suburban drivers to meet this demand. As the hotel forecourts are private property we cannot appoint ranks at these locations but trade representatives are actively lobbying hotels to provide rank facilities and we will support their proposals where appropriate. Furthermore, while plying for hire on such ranks, suburban drivers are in an ideal position to accept radio or app bookings for journeys that start at the airport terminals.

14. Summary of consultation questions

Licence areas

Q1 Do you think that changes to the suburban licence areas are desirable and practical?

Q2 If changes are to be made, would you propose creating a new suburban

licence area structure of:

a) four sectors – north west, north east, south east and south west

b) two sectors – north and south

c) one sector – a ring of all 22 suburban boroughs

d) some other arrangement? Please describe your proposal.

Please explain the reasons for your preference.

Q3 Would you support discontinuing the concept of the suburban licence? Please explain your reasons.

Learning the Knowledge of London

Q4 Should suburban drivers be able to add adjoining sectors to their licence without undertaking the full Knowledge examination process?

Q5 Should suburban drivers who wish to become All London drivers be allowed to enter the examination system at an advanced stage?

Driver Numbers

Q6 Should the number of suburban taxi drivers be capped?

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Q6a If numbers were capped, what criteria should be used to determine the limit?

Q7 Should applications for all suburban licences be suspended for either a specified or indefinite period?

Q7a If applications were suspended, what criteria should be used to determine a resumption of licensing, either in individual sectors or on a London-wide basis?

Island ranks and area extensions

Q8 Should TfL pursue a strategy of designating further island ranks and extensions to suburban sectors?

Q9 If yes to Q8, what factors should be taken into consideration within a formal framework for considering and assessing further island ranks and extensions to suburban sectors?

Q10 If un-met demand for taxis is the principal criteria for designating extensions, how should it be measured?

Q11 For new applicants, should the Merton and Sutton and Enfield, Haringey and Waltham Forest sectors be extended on a permanent basis to include the extension areas?

Radio and app bookings

Q12 Should TfL introduce or amend regulations to allow taxi drivers to accept private hire, radio circuit or app bookings when outside their licence area?

Q13 Should TfL introduce or amend regulations to allow radio circuits and app providers to give bookings to taxis regardless of the taxi’s location (potentially constrained to the Greater London area) without becoming private hire operators?

15. How to respond to this consultation

This consultation document seeks views on issues relating to suburban taxi services in London. Respondents are invited to comment on the proposals and are also invited to provide relevant information to support our decisions on this issue.

The document is being sent initially to the organisations and individuals listed at Annex C. Comments from other interested organisations or individuals are also welcome. You are invited to pass this document on to anybody else that you think should see it. We welcome suggestions as to other organisations that should see this document.

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Please let us know your views on these proposals by visiting our consultation website at consultations.tfl.gov.uk/tph/suburbantaxis. Responses must be received by 11 April 2014.

You can also contact us by emailing [email protected], stating ‘Suburban Taxis’ in the subject line. Please state your views on the questions set out above, as well as any other comments you wish to make. It will also be helpful if you can give your name and postcode, and information about any involvement you have with the taxi or private hire trades.

Alternatively, you can contact us by post at the address below. If you are responding by post, please give us your views on the questions and any additional comments, as well as your name, postcode and involvement (if any) with the taxi or private hire trades. Please submit two copies of your response.

If you are responding as a representative organisation, please provide background information about your organisation and the people that you represent.

The Freedom of Information Act 2000 requires public authorities to disclose information they hold if it is requested. This includes information contained in responses to public consultations. If you ask for your response to be kept confidential this will only be possible if it is consistent with TfL’s obligations under the Freedom of Information Act and if certain grounds for confidentiality under the Act apply.

Enquiries about the contents of this consultation document may be made by email to [email protected].

Further copies of the consultation document can be obtained via the TfL consultation website shown above.

Suburban Taxi Consultation London Taxi and Private Hire Transport for London 4th Floor, Zone Y6 Palestra, 197 Blackfriars Road London SE1 8NJ

https://consultations.tfl.gov.uk/tph/suburbantaxis

mailto:[email protected]

mailto:[email protected]

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Annex A – Knowledge of London Examination System

Stage 3 One-to-one examinations (56 day intervals)

Basic points and runs

Stage 1 Introduction

Application accepted and Blue Book issued

Stage 1a Voluntary Self Assessment (All London applicants only)

Stage 2 Written Examination

(All London applicants only)


Intermediate points and runs

4 x D

First Time


Advanced points and runs

Second Time

4 x D

First Time

Second Time

Licensed

Pass

Stage 6 One-to-one examination

Suburban London (All London applicants) Central London (suburban applicants)

Pass

Total of 12 points

Total of 12 points

Total of 12 points

Fail

Second Time

Fail

First Time

4 x D

Appearance Grades (Stages 3-5)

AA Exceptional 12 points

A Very good 6 points

B Good 4 points

C Satisfactory 3 points

D Unsatisfactory 0 points

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Annex B – Extension areas

Extension to Merton and Sutton sector

Extension to Enfield, Haringey & Waltham Forest sector

(Dashed lines indicate boundaries of extension areas)

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Annex C - Initial Consultation List

Consultees are welcome to forward the consultation document to other interested parties and responses from these parties are also invited.

• All licensed London taxi drivers Taxi driver associations

• Heathrow Airport Taxi Drivers United • Licensed Taxi Drivers Association • London Cab Drivers Club • London Suburban Taxi Drivers

Coalition • RMT Cab Trade Section • Unite the Union Cab Trade Section • United Cabbies Group

Other taxi trade bodies

• Computer Cab Plc • Dial-a-Cab • Get Taxi • Hailo • Heathrow Taxis • London Motor Cabs Proprietors

Association • Radio Taxis Group Ltd

Knowledge schools

• Computer Cab Knowledge School • Double K Knowledge School • Knowledge for U • Knowledge Point • 5 Star Knowledge School • The London Knowledge School • West London Knowledge School • Yellow Badge Knowledge Club • WizAnn

Private hire trade associations

• Chauffeur and Executive Association • GMB (Greater London Private Hire

Drivers Branch) • Institute of Professional Drivers and

Chauffeurs • Licensed Private Hire Car

Association • Private Hire Board

Other licensing authorities

• Neighbouring taxi & private hire licensing authorities

• National Association of Licensing and Enforcement Officers

• Senior Traffic Commissioner User groups and other stakeholders

• Action on Hearing Loss • Age UK • City of London Police • Department for Transport • Disabled Persons Transport Advisory

Committee • Equality and Human Rights

Commission • Guide Dogs • Heart of London • Heathrow Airport Ltd • Inclusion London • Joint Committee on Mobility for

Disabled People • Living Streets • London Accessible Transport

Alliance • London Assembly Members • London Chamber of Commerce and

Industry • London City Airport Ltd • London Councils • London Cycling Campaign • London First • London local authorities • London MPs • London NHS bodies • London TravelWatch • Metropolitan Police Service • Network Rail • New West End Company • Passenger Focus • People 1st • RNIB • Roads Task Force members • Society of West End Theatres • Suzy Lamplugh Trust

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• Train Operating Companies serving London

• Transport for All

• TfL Youth Panel • Visit London (London & Partners)

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