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Unite the union Response to TfL’s Suburban Taxi Licensing Consultation

Introduction

Unite welcomes the Suburban Taxi Licensing Consultation as it presents a massive opportunity to grow the taxi trade in all of the suburban taxi sectors. Unite believes that the suburban consultation can bring all sections of the London taxi trade and London Taxi & Private Hire together to put in place a strategy to regain and create new taxi work in the suburban sectors. The focus of this response will be on bringing the suburban sectors into the twenty-first century. For too long this attitude has been inward looking with no drive to move out into the sectors to look at how the customer base can be expanded. Unite feels that building an increasing customer base is the solution to the problems that suburban drivers are currently experiencing. A well thought out strategy which brings together suburban drivers, drivers organisations, radio circuits, app providers, the London cab ranks committee and LTPH, can revolutionise the current approach to the suburban sectors and bring about an exciting future for suburban drivers.

It is this strategy of linking drivers and customers to build the taxi market in the suburban sectors that is at the heart of this response.

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.

Unite believes that the current nine sectors give the best opportunity to expand the taxi customer base in the suburban sectors. There is logic to the current sectors and we believe that leaving the sectors as they are is the best way of expanding the taxi trade in these sectors. At the moment it takes an average of 29 months to complete the knowledge in one of the sectors. Increasing the size of the sectors by merging together existing sectors in any of the ways proposed, will lead to the knowledge for these new sectors taking an unacceptable length of time. Merging sectors will also mean drivers will be pulled to the lucrative ‘honeypot’ areas, at the expense of customers not in those ‘honeypot’ areas. This has been seen consistently outside of London when authorities have ‘de-zoned’, drivers head to the lucrative areas and ignore those areas they previously worked in, forcing customers in those areas to find alternative forms of transport. A suburban strategy of increasing the taxi customer base in the suburban sectors cannot work if the sectors are expanded as suggested in question two and three.

Instead, our view is that all stakeholders in the taxi trade and LTPH should work together within the existing sector structure to build the taxi customer base with a strategy based on reaching out to customers, rather than passively waiting at main ranks. There are many tube stations and mainline stations throughout the suburban area that do not currently have taxi ranks but have a thriving private hire trade operating at them. There is no reason why taxis cannot capture some of that market. This applies to shopping centres, retail outlets, supermarkets, hotels, clubs and sporting events. The taxi driver’s organisations and LTPH working with the radio circuits and the app providers can quickly identify areas which need ranks to enable the taxi market to expand. Many customers in the suburbs would never see a taxi in their street but can book a taxi very easily through a variety of smartphone/internet devices. The taxi can come to the customer, rather than the customer having to find a taxi. But in order to do this the sectors need a better coverage of taxis throughout the sector not just at the lucrative locations. That is the reason why a holistic strategy for the whole suburban licensing area is required.

For all of these reasons we believe that the sectors should remain as they are and no changes should be made.

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

For the reasons above Unite does not believe that the current nine sectors should be changed. Unite would not support suburban drivers being able to add adjoining sectors without undertaking the full Knowledge examination process. This would encourage drivers to get addition sectors in order to ‘cherry pick’ the work in these areas without any commitment to build the taxi customer base in their own sector. The Knowledge process is one of the most fundamental reasons for the excellent reputation of London’s taxi drivers. This applies to every driver regardless of the type of licence the driver has got. Every customer that gets into a London taxi has the confidence that the driver has the Knowledge and has been thoroughly tested. As the consultation says ‘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.’ If changes are made to the Knowledge process then this undermines the knowledge process. Learning a whole sector currently takes on average 29 months. Just allowing a driver to be licensed for an adjoining sector will completely undermine the Knowledge in the suburban sectors. Why would a driver of an adjoining sector have a better knowledge of the sector that a private hire driver, a courier or a person living in the sector?

This is completely the wrong approach. It will do nothing to build the customer base in the sectors or to improve the amount of work available for drivers. Drivers will have less reason to look to build work as they will feel that they can just go into an adjoining area and ply for hire there. Each sector has two adjoining areas so drivers are likely to want to be licensed in both adjoining areas, and then if this is inadequate then get licensed for areas even further away. Once the full Knowledge examination process has been compromised then what will be the arguments to stop this? The Knowledge system that has built the customer confidence in the London taxi trade will be undermined.

For all of the above reasons we completely reject any attempts to undermine the full Knowledge process in London.

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

Unite believes that every driver should undertake the full Knowledge examination for whichever area they wish to be licensed for. Currently it takes 51 months to undertake the All London Knowledge of London. But that is an average. If a suburban driver has a good knowledge of London then the Knowledge process allows drivers to become an All London licensed driver in a much shorter time. There is no reason why a suburban driver should start the Knowledge process at an advanced stage when a private hire driver, a courier, bus driver or any other professional driver, in the same area has to start at the beginning. Why would a suburban driver have a better knowledge of London than any of these other categories? It completely undermines the knowledge process for every other driver in London that has undergone the full examination process. Customers need to have the confidence that every driver has been tested to the same degree and there is no ‘quickee’ knowledge.

It is suggested that ‘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.’ Well, most of our members struggled to combine the demands of earning a living whilst learning the knowledge. Very few people have the luxury of being able to do the knowledge full time. The demands on suburban drivers are no greater than on a person in full time work in another trade. This has always been the case and Unite sees no reason to make exceptions for anyone. Once exceptions are made then where will the cut-off be? It begins to undermine the whole knowledge process.

In Unite’s opinion, questions four and five are a complete distraction from the main issue of trying to build the customer base in the suburban sectors. They are inward looking and not addressing the real issues facing the suburban trade, namely, looking to increase the work in the suburban sectors through a strategy of engagement with the public.

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?

Unite is against capping the number of suburban taxi drivers in any of the suburban sectors. Due to the length of time of the knowledge process once numbers are capped there is a long lag in the system if it is decided to remove the cap. Outside of London there are a number of licensing authorities that have a cap on the number of taxi plates that it issues. They are compelled to have a supply and demand survey at least every three years and if there is found to be unmet demand then the council can immediately issue the required number of new plates. The demand is met immediately. In London it is not possible to operate in the same way. If a cap is put on the number of drivers in suburban sectors, (remember there is no cap on driver numbers anywhere in the country only on the number of taxi plates), then it would not be possible to increase the number of drivers immediately in the way that it is possible to issue extra plates for vehicles outside of London. If a cap on numbers were put on tomorrow then drivers would continue to be licensed in that sector for the foreseeable future. The cap would not take effect for years. There would then be a lack of drivers licensed in that sector and if it was decided to remove the cap then drivers would not be licensed for that sector for a considerable time. There will be a lag in the system due to the time it takes to complete the Knowledge in the relevant sector. The reasons for the cap at the time may not apply when the cap actually starts to take effect. A cap does not inspire confidence in an outward looking trade, one that is looking to expand and look for a new customer base. In fact, it sends a signal that if a sector just stagnates then everything may eventually work out with no intervention. It absolves responsibility from actually trying to engage with customers and the rest of the trade to increase the volume of work in the sectors.

Many years ago Unite, along with other driver organisations, met with TfL to try to find a supply and demand process which would meet the needs of drivers and customers. The main problem was that there was no way of being able to immediately respond to market demands. When the economy is flat, cutting driver numbers may make sense, but by the time the driver numbers are cut the economy may have picked up, and there would be no immediate response. London cannot operate like the rest of the country due to the Knowledge process and its size. The only way to change this would be to speed up the Knowledge, which Unite is opposed to.

A far better approach is to increase the amount of work available through a positive strategy of engagement rather than being inward looking and disengaging from building the customer base. The strategy outlined above of the whole trade, drivers organisation, radio circuits, app providers and LTPH, working together to build the taxi trade in the suburban sectors offers a better way forward than capping driver numbers.

For these reasons, Unite totally rejects capping driver numbers or suspending applications as outlined in questions six and seven.

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?

Currently LTPH meets with the taxi driver’s organisations to discuss ranks through the London cab ranks committee. This is a long established organisation that ensures through constant monitoring, that rank locations keep up with London’s ever changing landscape. This a challenging remit but we believe that it has served this purpose very successfully. As acknowledged in the consultation it is often a very difficult process to successfully appoint taxi ranks but it is essential that the partnership between LTPH and the taxi trade continues and strengthens if there is to be a successful strategy to reclaim and expand taxi work in the suburban sectors.

The designation of island ranks has been successful to date as outlined in the consultation document and if new island ranks are identified then these should be considered by the cab ranks committee. The overarching reason for island ranks must be convenience for the travelling passenger with an overlying strategic reason for the placement of the rank. But island ranks are not the only answer to increasing taxi availability to customers. There are vast areas within the suburban sectors that are inadequately supplied with taxis. It would be better to identify these areas and to locate ranks in these areas where possible, to increase the work in these sectors, through a joined up approach of intelligence and responsive action. Just focusing on island ranks is a diversion from the real issue of increasing the customer base in the suburbs.

Ranks are one of the most important ways that drivers working with the radio circuits, app providers, London cab ranks committee and LTPH can increase the coverage of the suburban sectors. Ranks give everyone a base from which to build work and drivers an opportunity to increase their customer base. We see ranks as an essential tool to build the taxi market throughout the suburban sectors, not just at the periphery.

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?

We believe that TfL should not introduce or amend regulations to allow taxi drivers to accept private hire, radio circuit or app bookings when outside their licence area. The reasons listed in the consultation show that this would be the wrong option. The introduction of the taxi driver licence identifiers has made drivers more visible allowing other drivers and passengers to know the type of licence that a taxi driver holds. Any relaxation of the 1934 Cab Order allowing a driver to accept a booking outside of their licencing area would be detrimental to the whole of the taxi trade not just for suburban taxi drivers. As outlined in the consultation customers expect drivers to have a high degree of the knowledge of London. Given the instant booking nature of many of the radio circuits and app providers, drivers would not be able to identify a route before the booking and customers could receive an inferior service. Not only would the customer receive an unprofessional service but that customer could then decide to stop using taxis and find alternative forms of travel. This would be a disaster for the taxi trade and the companies providing the service and is likely to lead to a loss in work, rather than any gains being made.

There will be an exodus of drivers from the suburbs into Central London. The reverse was seen when the identifiers were introduced but if suburban drivers can legally accept hiring’s outside of their licensing then many suburban drivers are likely to be attracted to Central London, especially at the busiest times. Not only will this be detrimental to growing the taxi market in the suburbs but it will lead to enforcement issues and to suburban drivers plying for hire outside of their licensing area. It is also likely to inflame conflict between drivers as All-London drivers will see suburban drivers picking up outside of their licensing area and assume they are doing so illegally. There will be no way of immediately checking as often radio and app bookings are immediate and can appear that the driver was plying for hire.

All of these reasons are highlighted in the consultation and we agree that allowing drivers to accept a hiring outside of their licensing area would be wrong. It is far better for the travelling public, taxi drivers and LTPH if the focus is on building the customer base in the suburban sectors rather than being distracted by changing the 1934 Cab Order.

For these reasons we also do not see the need to 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. There would be no need to consider this if there are no changes to the 1934 Cab Order.

We hope this is useful and we have shown our massive desire to make the Suburban review work for taxi drivers and customers in the suburban sectors. We are keen to work with LTPH to ensure that the review delivers real change in the suburban sectors leading to more work for drivers through an increased customer base and a more responsive service for customers. This will present real challenges for LTPH and the taxi trade in London, but Unite is convinced that with the correct strategy and desire these challenges can be overcome.

Jim Kelly

Chair, Cab Trade Advisory Committee

Jim.Kelly@unitetheunion.org

31 March 2014

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