Written evidence submitted by Southampton Hackney Private Hire Association (TPV0042)

May I begin by respectfully introducing ourselves as the Southampton Hackney Private Hire Association (SHPHA) a local taxi and private hire association proudly affiliated with the National Private Hire Taxi Association (NPHTA).

We are happy to participate in this inquiry, though we must raise an initial concern: inquiries such as this are only worthwhile if their findings are acted upon. To illustrate, the extensive and costly 2011 Law Commission review into taxi and private hire services concluded in 2014 with a published report and draft bill—yet no legislative action has followed. Similarly, the 2018 Task and Finish Group made several relevant recommendations addressing industry challenges, some of which remain unimplemented due to the lack of enabling legislation.

1. Effectiveness of Current Licensing Arrangements

In response to the question of whether current arrangements enable local authorities to regulate the industry effectively: we suggest that answers already exist in the Law Commission report and the 2018 Task and Finish Group review. The government should revisit these findings and identify which elements are still relevant to today’s landscape. Additionally, bodies such as the *Institute of Licensing (IOL)* host regular meetings that involve expert stakeholders from our sector. The government should draw more practical insight from these meetings and adopt some of the proposals discussed there.

2. Cross-Border Hiring (CBH)

The most pressing issue in our view is *Cross-Border Hiring*, primarily involving private hire vehicles (PHVs) and operators. Currently, the system permits PHV drivers and operators licensed in one area to work predominantly in another—undermining the authority and standards of the licensing council.

Some areas apply an *Intended Use Policy* (IUP) for hackney carriages, which we strongly believe should also be introduced for PHVs. The “Triple Lock” system—licensing the operator, vehicle, and driver in the same authority—should be enforced more strictly. A PHV should only operate bookings that begin and end in their licensed area or return to it. The abuse of this loophole by platforms such as *Uber* has significantly undermined local regulation and industry integrity.

3. Standardised Licensing and Driver Identification

More stringent and standardised licensing was recommended by the 2018 Task and Finish Group. All drivers—whether hackney or private hire—should be required to wear visible ID badges at all times. We recommend MPs engage more directly with this issue to push for updated, standardised licensing policies.

4. Concerns Around Devolution

There is ongoing discussion about merging licensing areas, such as Southampton and the New Forest. We believe this form of *devolution*—or the potential introduction of a *Regional Transport Authority*—would severely damage local trade. Each local authority understands the needs of its area and should retain full control over its taxi and private hire policy. Centralising or regionalising control would reduce accountability and harm local operators.

5. Impact of Digital Ride-Hailing Platforms

Digital platforms have unquestionably transformed the industry. While they offer increased convenience for the public, they have raised serious regulatory challenges. These platforms operate under outdated legislation not designed for modern digital business models. We recommend that app-based ride-hailing services be brought under new legislation and subject to platform-level licensing and financial contributions, including a regulatory charge for each booking.

(Please see attached email to Iain MacDonald for further commentary.)

6. Effectiveness of Complaint Systems

In Southampton, private hire vehicles once displayed operator names on both front doors. Due to pressure from *Uber* and the *GMB Union*, these identifiers were removed. This change eliminated clear accountability and made it harder for passengers to know who is responsible for a vehicle. We believe this should be reversed immediately to improve trust and enforcement.

7. National Register of Refusals, Revocations, and Suspensions (NR3S)

The NR3S system has the potential to be an effective tool if used consistently and accurately. However, there are still questions about its implementation, particularly concerning safeguarding and road safety implications.

8. Autonomous Vehicles

We are firmly opposed to the introduction of autonomous vehicles. The UK lacks the infrastructure for a wide EV rollout, let alone driverless cars. Autonomous vehicles raise serious safety concerns, increase the risk of uncontrolled incidents, and eliminate the role of the driver—placing public safety and job security at risk. Furthermore, enforcement and police intervention would be hindered in the absence of a driver.

Thank you for the opportunity to submit these views on behalf of our association. We hope they will help shape a more robust and fair regulatory framework for the taxi and private hire industry.

August 2025