Taxi Policy Changes

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We are seeking your views on changes to the Mid Devon District Council Hackney Carriage and Private Hire Policy (the Policy). The consultation will run from 15 January to 15 April 2024 and is open to all residents, the licenced Taxi and Private Hire trade, and any other interested parties. The key changes are summarised below, and the full draft policy can be accessed here.

Please complete the survey using the link below to give us your views.

During September 2023, an in-depth review of the existing policy was carried out. The review has identified a number of proposed changes. The aim of the updated policy is to ensure it remains fit for purpose and provides a workable, fair and compliant policy for the regulation of the taxi trade in Mid Devon. Furthermore, that the policy enables continued public confidence in the taxi licensing regime where drivers and vehicles are fit for purpose in order to protect public well-being and ensure the safety of users.

The survey asks some directed questions on the parts of the policy that are likely to have the greatest impact on the licenced trade. There is also an opportunity at the end of the survey to provide comments and feedback on any section not covered within the question section of the survey.

Your views are very important and will help shape the final policy.

The table below provides an overview of the limitations and proposed changes identified during the policy review:

Section 1

Safeguarding training

Main policy, page 26

Safeguarding is a key responsibility of a licenced driver. Where licences are held for many years, this understanding of safeguarding issues can be lost. Safeguarding training is currently required on new application, but not at renewal.

The draft policy requires 3 yearly update training for all licenced drivers.

Requirements for Private Hire Operators and proprietors to undertake safeguarding training at a lower frequency of every 5 years will also be introduced.

Section 2

Penalty Point Scheme

Appendix 1

A penalty point scheme will be introduced which allows minor breaches of the rules to be recorded and considered in context, while referring those with persistent or serious breaches to the licensing committee.

Such systems can provide greater consistency in enforcement and make better use of the licensing committee’s time.

Section 3

Increased driving course/assessment requirements

Appendix 3, page 55

“The Road Safety Statement published in 2019 stated that:

The need to improve road safety does not end with the driving test; nor does it exclude those who drive or ride professionally or as part of their job.

Licensing authorities should require taxi and private hire vehicle drivers, as professional drivers, to display a higher degree of driving aptitude and diligence than a private motorist. This is considered appropriate and proportionate and is consistent with other elements of taxi and private hire vehicle driver licensing, for example, medical and vision assessments.”1

The draft policy introduces a requirement for a driving course/assessment to be undertaken every 10 years.

Section 4

Requirements for medical assessment

Appendix 3, page 56

Medical certificates are required for licenced drivers at the initial application; and valid until the age of 45, thereafter every five years until the age of 65; and every year from the age of 65. The policy does not currently require vision tests.

The draft policy introduces the right for the Council to seek a second opinion (at the expense of the applicant) in any case where it has any concerns about the medical fitness of an applicant, both on application and at any time during the duration of the licence.

Section 5

Considering age of vehicle and exceptional condition criteria for vehicles over 5 years of age

Appendix 4, page 80

The Council has an aging fleet of licenced Hackney Carriage and Private Hire vehicles, with 20% of vehicles over 10 years of age.

The Low Carbon Vehicle Partnership (Zemo Partnership) and Energy Saving Trust (EST) note that “Currently there are more than 290,000 licenced taxi and private hire vehicles across England and Wales, and 23,000 in Scotland. The average traditional UK black taxi is 12 years old and so these older vehicles are experiencing ever-greater scrutiny by licensing bodies and authorities due to the high level of emissions they produce. Encouraging a transition to newer, low emission vehicle types within city centres is essential to improve urban air quality and reduce greenhouse gas emissions in line with national targets.”2

Guidance states that Licensing authorities should carefully and thoroughly assess the impact of vehicle emission requirements to enable the sector to plan for the future. The short-term objective should be to mitigate the harm from internal combustion engines through the setting of high EURO emission standards for example, EURO 6 but, in the long-term, the trade will need to be fully prepared for the end of the sale of new petrol and diesel cars and the need to transition to zero emission vehicles. Licensing authorities should set out their own long-term plan in good time.1

Age limits on vehicles reduce the flexibility to enable second hand electric vehicles to be used, which will slow down the transition to achieve longer term objectives. Our current policy sets an age limit on first application, but no limit on renewal.

Please give your views on the approach that you feel we should adopt to help prepare the Taxi and Private Hire trade for the commitment to a zero carbon future.

Section 6

Increased frequency of testing for vehicles over 5 years of age

Appendix 4, page 88

Typically a taxi will cover nearly 4 times the mileage that a domestic vehicle would travel (10,000 miles for a domestic vehicle against between 30,000 – 40,000 for a taxi). In addition to this, aging vehicles may be more prone to mechanical defects.

The draft policy requires an increase testing frequency for vehicles over 5 years of age, of every 4 months. One being the annual MOT and a further vehicle test every 4 months carried out by a Mid Devon District Council approved garage.

Section 7

Changes regarding the assessment of Private Hire Operator dispatch and booking staff

Appendix 5, page 104;107

Private hire operators and their dispatch and booking staff are privy to personal information about hirers and their specific circumstances that may leave them more vulnerable to crime. For this reason it is essential that only trustworthy individuals are put in this position of responsibility.

The draft policy introduces requirements for Operators to demonstrate that they are fit and proper, by the provision of a DBS and that they apply the same requirements and considerations of character to their own dispatch and booking staff.


References

  1. Department for Transport: 'Taxi and Private Hire Vehicle Licensing: Best Practice Guidance': https://www.gov.uk/government/publications/taxi-and-private-hire-vehicle-licensing-best-practice-guidance
  2. LowCVP_Low_Emission_Taxi_Guide-March_2019_Update.pdf (zemo.org.uk)

We are seeking your views on changes to the Mid Devon District Council Hackney Carriage and Private Hire Policy (the Policy). The consultation will run from 15 January to 15 April 2024 and is open to all residents, the licenced Taxi and Private Hire trade, and any other interested parties. The key changes are summarised below, and the full draft policy can be accessed here.

Please complete the survey using the link below to give us your views.

During September 2023, an in-depth review of the existing policy was carried out. The review has identified a number of proposed changes. The aim of the updated policy is to ensure it remains fit for purpose and provides a workable, fair and compliant policy for the regulation of the taxi trade in Mid Devon. Furthermore, that the policy enables continued public confidence in the taxi licensing regime where drivers and vehicles are fit for purpose in order to protect public well-being and ensure the safety of users.

The survey asks some directed questions on the parts of the policy that are likely to have the greatest impact on the licenced trade. There is also an opportunity at the end of the survey to provide comments and feedback on any section not covered within the question section of the survey.

Your views are very important and will help shape the final policy.

The table below provides an overview of the limitations and proposed changes identified during the policy review:

Section 1

Safeguarding training

Main policy, page 26

Safeguarding is a key responsibility of a licenced driver. Where licences are held for many years, this understanding of safeguarding issues can be lost. Safeguarding training is currently required on new application, but not at renewal.

The draft policy requires 3 yearly update training for all licenced drivers.

Requirements for Private Hire Operators and proprietors to undertake safeguarding training at a lower frequency of every 5 years will also be introduced.

Section 2

Penalty Point Scheme

Appendix 1

A penalty point scheme will be introduced which allows minor breaches of the rules to be recorded and considered in context, while referring those with persistent or serious breaches to the licensing committee.

Such systems can provide greater consistency in enforcement and make better use of the licensing committee’s time.

Section 3

Increased driving course/assessment requirements

Appendix 3, page 55

“The Road Safety Statement published in 2019 stated that:

The need to improve road safety does not end with the driving test; nor does it exclude those who drive or ride professionally or as part of their job.

Licensing authorities should require taxi and private hire vehicle drivers, as professional drivers, to display a higher degree of driving aptitude and diligence than a private motorist. This is considered appropriate and proportionate and is consistent with other elements of taxi and private hire vehicle driver licensing, for example, medical and vision assessments.”1

The draft policy introduces a requirement for a driving course/assessment to be undertaken every 10 years.

Section 4

Requirements for medical assessment

Appendix 3, page 56

Medical certificates are required for licenced drivers at the initial application; and valid until the age of 45, thereafter every five years until the age of 65; and every year from the age of 65. The policy does not currently require vision tests.

The draft policy introduces the right for the Council to seek a second opinion (at the expense of the applicant) in any case where it has any concerns about the medical fitness of an applicant, both on application and at any time during the duration of the licence.

Section 5

Considering age of vehicle and exceptional condition criteria for vehicles over 5 years of age

Appendix 4, page 80

The Council has an aging fleet of licenced Hackney Carriage and Private Hire vehicles, with 20% of vehicles over 10 years of age.

The Low Carbon Vehicle Partnership (Zemo Partnership) and Energy Saving Trust (EST) note that “Currently there are more than 290,000 licenced taxi and private hire vehicles across England and Wales, and 23,000 in Scotland. The average traditional UK black taxi is 12 years old and so these older vehicles are experiencing ever-greater scrutiny by licensing bodies and authorities due to the high level of emissions they produce. Encouraging a transition to newer, low emission vehicle types within city centres is essential to improve urban air quality and reduce greenhouse gas emissions in line with national targets.”2

Guidance states that Licensing authorities should carefully and thoroughly assess the impact of vehicle emission requirements to enable the sector to plan for the future. The short-term objective should be to mitigate the harm from internal combustion engines through the setting of high EURO emission standards for example, EURO 6 but, in the long-term, the trade will need to be fully prepared for the end of the sale of new petrol and diesel cars and the need to transition to zero emission vehicles. Licensing authorities should set out their own long-term plan in good time.1

Age limits on vehicles reduce the flexibility to enable second hand electric vehicles to be used, which will slow down the transition to achieve longer term objectives. Our current policy sets an age limit on first application, but no limit on renewal.

Please give your views on the approach that you feel we should adopt to help prepare the Taxi and Private Hire trade for the commitment to a zero carbon future.

Section 6

Increased frequency of testing for vehicles over 5 years of age

Appendix 4, page 88

Typically a taxi will cover nearly 4 times the mileage that a domestic vehicle would travel (10,000 miles for a domestic vehicle against between 30,000 – 40,000 for a taxi). In addition to this, aging vehicles may be more prone to mechanical defects.

The draft policy requires an increase testing frequency for vehicles over 5 years of age, of every 4 months. One being the annual MOT and a further vehicle test every 4 months carried out by a Mid Devon District Council approved garage.

Section 7

Changes regarding the assessment of Private Hire Operator dispatch and booking staff

Appendix 5, page 104;107

Private hire operators and their dispatch and booking staff are privy to personal information about hirers and their specific circumstances that may leave them more vulnerable to crime. For this reason it is essential that only trustworthy individuals are put in this position of responsibility.

The draft policy introduces requirements for Operators to demonstrate that they are fit and proper, by the provision of a DBS and that they apply the same requirements and considerations of character to their own dispatch and booking staff.


References

  1. Department for Transport: 'Taxi and Private Hire Vehicle Licensing: Best Practice Guidance': https://www.gov.uk/government/publications/taxi-and-private-hire-vehicle-licensing-best-practice-guidance
  2. LowCVP_Low_Emission_Taxi_Guide-March_2019_Update.pdf (zemo.org.uk)
Page last updated: 14 Feb 2024, 12:51 PM