Driving Test for Private Hire Drivers
- Do you agree or disagree with the proposal to require all existing PHV drivers to take the advanced driving assessment on the next renewal of their licence? Strongly disagree
- Do you agree or disagree with the proposal to introduce an advanced driving assessment for all PHV drivers? Strongly disagree
- Please let us have any comments about the proposal to introduce an advanced driving assessment for all PHV drivers and for existing PHV drivers to take the assessment when they renew their licence.
- Comments
- We have surveyed our members and just 6% of responders agree with these proposals. The Private Hire Vehicles (London) Act 1998 requires PHV drivers to be 21 years of age and must have held a full licence for three years.
- To get insured for hire and reward insurance at all, and at a viable cost, you will need to have had a fairly exemplary driving record.
- Many London PHV drivers have driven for many years without fault accidents and or penalty points, so to retrospectively test such drivers would be unnecessary, expensive and foolish.
- Many drivers will also have undertaken specialist driving training, training would be far more appropriate than testing and the LPHCA would like to have considerable dialogue with TfL prior to anything in this area being introduced.
- Looking at lessons learned from the English Language requirements this needs comprehensive, open and frank discussions with trade representatives prior to any decisions being taken.
- Do you agree or disagree with the proposal to introduce an enhanced wheelchair assessment for the drivers of all wheelchair accessible PHVs? Strongly disagree
- Do you agree or disagree with the proposal that only PHV drivers who have completed the TfL wheelchair assessment should be allowed to drive wheelchair accessible PHVs? Strongly disagree
- If you do not agree, please explain why.
- Comments
- Nearly every London PHV carries elderly, disabled, special needs and vulnerable passengers and many PHVs are not specialist vehicles, but nevertheless they are the preferred mode of door-to-door transport for such passengers.
- We are very supportive of measures that improve disabled vehicle provision but around 90% of disabled passengers are not wheelchair bound and rely on normal PHVs for their transport, with many actually preferring non-wheelchair accessible vehicles.
- Most PHV drivers with wheelchair accessible PHVs will have undertaken training and or testing for such vehicles already, so the notion that TfL should do a separate wheelchair assessment is unnecessary.
- We would therefore believe further dialogue with the London PHV trade representatives, London's specialist PHV providers and disabled groups like the Disabled Persons Transport Advisory Committee (DPTAC) should be held to discuss how private hire can play a greater role in providing appropriate vehicles.
- There are considerable qualifications in place for Specialist Disabled Vehicles that are already widely used by London’s PHV drivers and operators who provide such services.
- Rather than TfL set up its own enhanced wheelchair assessment for the drivers of all wheelchair accessible PHVs, which in our view would be costly and unnecessary, TfL would be better placed to consider modular disability vehicle training, when applicable, rather than blanket testing to avoid the types of problems that have ensued with the English language tests of a ‘one size fits all’ approach.
- If TfL were to embark on its own enhanced wheelchair assessment for the drivers of all wheelchair accessible PHVs, it would need a comprehensive list of exemptions for those already well qualified to drive wheelchair accessible PHVs. We believe the great majority of drivers will already be qualified, so this would be costly and unnecessary.
Private Hire Vehicle Signage
- Do you agree or disagree with the proposal to introduce additional signage in PHVs that will display customer contact information? Strongly disagree
- Do you agree or disagree with the proposal to introduce additional signage in PHVs advising passengers to look out for cyclists when opening the vehicle doors and getting out? Strongly disagree
- Do you agree or disagree with the proposal to introduce additional signage in PHVs that will advise passengers to wear their seat belt? Strongly disagree
- Do you agree or disagree that these messages should be displayed in one combined sign? Strongly disagree
- Do you have any alternative suggestions to ensure that passengers are aware of the contact information or any comments on these PHV signage proposals?
- Comments
- No - private hire ttrade representatives and the wider London trade have consistently stated whenever asked that PHVs should have as little signage as possible displayed to both the Public Carriage Office and Transport for London for safety reasons.
- PHVs are privately booked and, for this reason alone, there is not the need to plaster them with signs and signage, which confuses the public and would vary with signage regimes across the country.
- Do you agree or disagree with the proposal to change the colour of the PHV licence disc on an annual basis? Strongly disagree
- Do you agree or disagree with the proposal that licensed PHVs should be more identifiable? Strongly disagree
- Please state either why you support the proposal that PHVs should be more identifiable, and what additional signage should be considered, or why you do not support this proposal. Please also include any other ideas for how expired PHV licences can be identified.
- Comments
- PHVs should not be more identifiable because they are privately booked and today there are far more appropriate and safer methods than signage to identify PHVs and drivers.
- Firstly, all vehicles have a number plate, which cannot be easily compromised, and TfL introduced a range of measures already like supplying this prior and other details prior to the passengers being picked up. With today’s technology being used by the majority of PHVs, the Police and Compliance officers, it would be a retrospective move to put more signage on PHVs.
- We also know that the more signage you put on a PHV, the more likely it will be confused as being a taxi. More signage will also confuse tourists and members of the travelling public regionally. We also know that false signage has been used to aid and abet some terrible sexual assaults.
- Where PHVs have a great deal of signage we know that drivers can be harassed to take people illegally, sometimes very aggressively, which compromises driver safety. PHVs must be pre-booked and unlike taxis that are hailed they must not be publicly hired, too much signage compromises that.
- TfL recent policy on signage should therefore not be changed and any front or side facing signage or branding should not be introduced.
Private Hire Driver Identification
- Do you agree or disagree with the proposal that exemptions from displaying signage should be considered by TfL on case by case basis? Strongly agree
- Do you agree or disagree that the information contained on the PHV driver ID card should be visible from outside of PHVs? Strongly disagree
- Do you agree or disagree with our proposal that a version of the PHV driver’s ID card should be displayed on the nearside of the PHV on the front windscreen in the top corner? Strongly disagree
- If you do not agree that the information contained on PHV driver ID cards should be more visible from outside of PHVs or agree with our proposal please specify why?
- Comments
- As well as attracting passengers towards potentially bogus PHVs these measures, if adopted, will compromise drivers safety and confuse the public, particularly foreign visitors and people from outside of London.
- Displaying a driver's personal details will compromise their safety and well-being, as they will be revealing personal information to total strangers, some of whom could be dangerous criminals.
- PHVs are booked and unlike ad-hoc hailed taxis, passengers are already given a great deal of information, electronically where possible, and they can call or contact the PHV operator for a great deal of detail.
- Drivers' photographs are now sent electronically where possible and drivers already have to wear a current TfL badge that gives all the details necessary to facilitate the drivers legitimacy.
- More requirements will only serve to confuse and compromise a system that is already working fine.
Insurance Requirements for PHVs
- Do you consider any changes are needed to the existing PHV hire or reward insurance requirements? No
- If you answered yes what changes do you think are needed? (tick all that apply)
- Hire or reward insurance should be in place at all times the vehicle is licensed as a PHV
- PHV operators should be required to have hire or reward insurance in place covering all of the private hire drivers and vehicles available to them
- Other (please specify)
- We selected 'Other', our comments follow: with respect, this question does not give those answering no the opportunity to say why, so we have put this under other!
- Hire or reward insurance should not be in place at all times the vehicle is licensed as a PHV because many drivers work seasonally or for periods such as term time and insure appropriately. Similarly when a driver is broken down or subject to an accident, which will often not be their fault, they would normally transfer their cover to the vehicle being used from the one being worked upon.
- For passenger well-being firstly for ensuring the vehicle is insured and secondly keeping their costs down. This measure is unnecessary, firstly as licensed operators must check their drivers insurance, secondly because they would be covered by the Motor Insurance Bureau indemnity scheme in the event of no insurance and thirdly because TfL’s own compliance figures, show that no insurance issues on PHVs in London are extremely rare as the operator, driver and vehicle licensing system provides multiple checking.
- When working should PHV drivers be required to produce evidence to confirm that the PHV they are using is covered by hire or reward insurance? Yes
- If you answered yes, what form should the evidence they produce take?
- Original certificate
- Photocopy of original certificate
- Letter from insurer or insured person
- Electronic copy of original certificate
- Other (please specify)
- We selected 'Other', our comments follow: the answers supplied in the survey for this question are inadequate because several of the answers could be applicable and other answers are not included as options.
- In our view all of the above are acceptable, in addition a copy of a fleet schedule (also know as a blanket policy) is also good. As previously stated the operator is required to check for insurance and keep this information as part of their licence.
- Enforcement Officers also have the ability to check against the Motor Insurance Bureau (MIB) database in real time. The police allow (so-called) producers seven days to produce such documentation and as previously stated the public are protected regardless.
- Please let us know of any evidence you have to support any proposed changes or why you feel this proposal will enhance public safety?
- Comments
- We know of no evidence to support any proposed changes to insurance requirements as none of the insurance proposals will enhance public safety, just increase costs, bureaucracy and waste a great deal of time. Since London Licensing began we have not learned of any problems with public safety being compromised by insurance matters. Our regular compliance meetings with TfL support that too.
Background Checks for PHV Drivers
- Please provide your views on how TfL can best establish background character information for persons who have lived for an extended period outside the UK or come to the UK from another country? Please provide any evidence to support your comments.
- Comments
- Industry representatives and the former regulator in London (The PCO) looked at the options for establishing background character information for persons who have lived for an extended period outside the UK or come to the UK from another country.
- The options for doing much more than is done already by TfL are limited because the UK Enhanced Checking system is just that a UK system. TfL should however follow up checks and references supplied robustly and deal with any flaws it has discovered in their systems.