On Friday 27th March Transport for London launched its keenly awaited Private Hire Regulations Review Consultation. The consultation is open until 19th June 2015. Unite Cab Section will be engaging fully in this consultation but we urge every taxi driver to participate in this consultation. This consultation comes at a crucial time with many changes taking place very quickly in the private hire trade. The number of private hire drivers is currently increasing at a rate not seen before. We do not know where these drivers are working because there is no way of tracking them at the moment, but the consultation gives an opportunity to change this. Unite will be commenting on the consultation immediately we have had time to study the 25 questions posed within the consultation. These questions are summarised below.
Summary of consultation questions
Question 1: Do you consider it necessary to make any changes to this current regulation [regarding booking records]?
Question 2: In particular do you consider it necessary to make it mandatory for an operator to record the main destination for every booking made before the commencement of each journey? Please explain why and how this could be enforced effectively.
Question 3: What are your views on the use of business names and do you consider that current arrangements should be changed?
Question 4: Should operators continue to be allowed to specify an unlimited number of business names on their licence?
Question 5: What is your experience of making complaints about private hire services and have you any suggestions for how current arrangements could be improved?
Question 6: Should the retention period of booking, complaints, lost property and driver, and vehicle records be harmonised?
Question 7: If so, what should the retention period be?
Question 8: What are your views on current arrangements for regulation of invenue operators and how they may be improved?
Question 9: How are shared private hire services different to exclusive hires and how should this be reflected in the requirements that apply to them?
Question 10: What are your views on licensing of private hire services at temporary events?
Question 11: What changes to the current licensing requirements could be made for TfL to better serve members of the public who attend such events?
Question 12: What are your views on whether TfL should explore establishing controls in this area [Notification of convictions / cautions of individuals working for private hire operators]?
Question 13: Should TfL prescribe requirements relating to operating centres?
Question 14: If so, what requirements for operating centres should be prescribed in the regulations?
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Question 15: Do you agree that licensed private hire operators should provide passengers with details of the Vehicle Registration Mark and Driver photo ID and where contact details are provided by the customer (e.g. mobile phone number or email address) these details should be provided electronically (e.g. text message or email) before a booking is carried out?
Question 16: Should operators be required to engage with TfL before changing their operating model and, if so, what is the best way to achieve this?
Question 17: Do you consider that TfL should introduce a requirement for private hire driver applicants to be able to speak English to a certain standard? If so, what should this requirement be and what criteria should we set to determine how applicants meet this criteria?
Question 18: Do you consider it appropriate for TfL to introduce new training for private hire drivers and if so, what topics should be covered?
Question 19: Who should provide the training and have you any suggestions as to how it is delivered (e.g. face to face in a training centre, via an online training package etc.)?
Question 20: What are your views on [the proposal to check that hire and reward insurance is in place at vehicle licensing]?
Question 21: Should it be mandatory for operators to supply and electronically upload details of their drivers and vehicles to TfL and, if so, how frequently?
Question 22: Should we explore revoking vehicle licences in instances where the owner of a licensed vehicle is a licensed driver and we have had cause to revoke the driver’s licence? Reasons for this course of action could involve cases where the driver has been convicted of a touting offence, a sexual offence, or has been revoked on medical grounds
Question 23: Do you consider that requirements for private hire licences are “fit for purpose” and what are your views on them generally? Do you consider that TfL should prescribe further requirements in the private hire regulations and, if so, what should these be?
Question 24: Do you feel that TfL should stop accepting payment by postal order and cheque?
Question 25: Do you feel that there are any other regulations not covered in this paper that it would be appropriate to review?