Written evidence submitted by LEVC (TPV0077)

LEVC is the Coventry-based manufacturer of the iconic London ‘black-cab’ - the traditional Hackney carriage TX taxi. Our heritage stretches back to 1908 when we began making purpose-built vehicles for the professional taxi trade. Backing from the Geely Group in 2016 enabled us to bring the taxi to the forefront of green urban mobility, and in 2018 we launched the TX, the world’s first zero-emissions capable electric taxi. Today, the TX model remains the only taxi that meets London’s exacting conditions of fitness, making it the world’s most advanced, accessible, zero-emission capable taxi, making up more than half of London’s taxi fleet and saving to date more than 300 million kilograms of carbon worldwide.

Taxis and Private Hire vehicles (PHVs) each fulfil distinct and important roles in supporting local transport needs. Local authorities should ensure they use the frameworks available to them coupled with the enforcement of local policies to enable taxis to fulfil their role in supporting that authority’s transport needs. In areas where the taxi trade can rely on clear and enforced licensing regulations, and ambitious plans to improve air quality and reduce emissions from road transport, LEVC sees a growing opportunity for the taxi trade to contribute to greener, accessible transport in that area.

Changes to taxi and PH licensing in the Deregulation Act 2015 aimed at increasing flexibility and simplifying subcontracting across licensing boundaries have however made it more challenging for local authorities to effectively regulate PHV drivers, leading to market saturation and damaging the traditional taxi trade - resulting in drivers leaving the trade, fewer drivers becoming licensed, and ultimately poorer availability of accessible taxis for the local population, many of whom rely on wheelchair accessible transport for critical journeys every day. As there is no barrier to PH drivers avoiding stricter licensing checks by simply obtaining their license in a more lenient area, we see an oversupply of PH drivers with lower earnings, and damage to the long term sustainability of the traditional taxi trade who are at a competitive disadvantage with stringent local knowledge testing, fixed fare structures and restrictions on where they can operate. In Coventry for example - where licensing conditions are similar to those in London - taxi driver earnings have fallen to such a level that drivers tell us they cannot afford newer, cleaner vehicles as they struggle to compete for work against PH drivers licensed in Wolverhampton, whose outgoings are less. This has resulted in new emissions rules being delayed and a decline in the standard of service offered to passengers through aging vehicles. Low numbers of Hackney carriages has reduced the provision of wheelchair accessible taxis, resulting in disabled passengers in Coventry being underserved.

a. Do current licensing arrangements and tools enable local authorities to effectively regulate and oversee the taxi and private hire vehicle (PHV) sector across England, in terms of safety, accessibility and quality of service? If not, what improvements could be made?

The legal and administrative framework for regulating licensed taxis in England is based on a combination of national legislation, government guidance and local authority policy. Local licensing powers enable local authorities to develop policies based on their population’s transport needs and individual features of local infrastructure. It is our experience that there is insufficient weight given to the role of taxis in supporting last mile transportation and meeting critical accessibility needs for school transport, including for children with special educational needs, and hospital transport in local policy development. As a result, many areas still lack sufficient numbers of wheelchair accessible vehicles to support the wider transport needs of the population. With rising demand for SEND student transport and a shrinking pool of licensed taxi drivers, some councils are already raising concerns about how to meet transport needs for a growing number of students and whether the existing system can cope with future demand.[1] In addition, local authorities underestimate or fail to account for the very significant contribution zero emission capable taxis can make to achieving local clean air ambitions.

There is currently no minimum licensing standard for taxis across England, so the overall picture of licensing arrangements, particularly governing emissions standards, vehicle age and accessibility requirements in local authorities is a patchwork picture. Local authorities are responsible for enforcing taxi licensing in their areas, but in practice local conditions and policies mean the level and effectiveness of enforcement varies council by council. Where local policies and conditions are not enforced, or licensing bodies have limited enforcement powers, taxi driver earnings are undercut by PHVs effectively plying for hire illegally, and staying in or entering the traditional taxi trade is a less economically viable prospect. 

The issues surrounding cross-border hiring have been well publicised this year. As drivers licensed in one authority may legally operate in another despite differences in standards between the two, means local authorities lose control over standards of service, vehicle condition and driver safety for taxis and PHVs operating within their own area. The difference in cost and ease of applying for a license between one authority and another has effectively created a ‘race to the bottom’ effect, where some drivers are shopping around for the cheapest and least demanding licensing regime, safeguarding and safety standards to minimise their personal regulatory burden and the cost of obtaining a license.

b. What is the impact on the travelling public and drivers of variation between licensing authorities? Is reform needed to bring greater standardisation?

Variation in licensing standards ultimately creates both a perception of, and actual unevenness and unreliability in the travelling public’s ability to access accessible, green and safe door to door transport. Huge variation in safeguarding training, CCTV requirements and accessibility requirements means members of the public are not informed about what they are accessing at the point of need. That licensing officers cannot inspect or take enforcement action against vehicles licensed by another licensing authority even when they are operating in their area also creates a real safety concern for passengers, as this acts as a barrier to effective compliance and safety checks.

For drivers, variation in regulatory and licensing standards between local authorities also creates an uneven playing field. It is a concern to see Wolverhampton Council report a sharp growth in private hire licensing figures for the year 2024-25 amounting to an increase of 7,508 new licenses granted in the previous year. Some reports have suggested Wolverhampton now issues more than 10% of all licenses across England. As drivers can bypass stricter regimes in favour of minimal vetting and cheaper licensing fees yet work in any local authority, an excess of drivers are competing for a finite number of jobs, forcing driver earnings down. Saturation of the market impacts all drivers, with reports of PHV drivers taking on excessively long hours to earn enough across a shift, with safety and safeguarding implications for themselves and their passengers.

Comparatively, and unsurprisingly given that Hackney drivers are required to take stricter knowledge tests, the Hackney carriage trade in Wolverhampton itself is virtually non-existent, with only two new licenses issued in the past twelve-month period. Out of area licensing and specifically the overwhelming level of PHV licensing in Wolverhampton has wider implications across England including London, as average earnings within the traditional taxi trade are undercut. Many drivers report significant decline in their earnings, with some choosing to leave the trade altogether as a result of being unable to make the career work economically. For new potential applicants, we are concerned that the taxi trade is not viewed as an attractive prospect when considering the investment required in the vehicle and the Knowledge test.

The ongoing surge in licensed drivers from one area without legal restriction on drivers requiring them to work in the area in which they are licensed effectively causes a ‘race to the bottom’, is damaging to all drivers, and requires urgent regulatory reform.

c. What would be the practical implications for licensing authorities and operators of more stringent or standardised licensing conditions in respect of safety, accessibility, vehicles and driver conduct?

Reform to local licensing of taxi and PHVs will likely initially increase the administrative and legal burden on local authorities, some of which are already ill-resourced to manage taxi and PHV licensing where they have very small fleets of vehicles due to the local transport environment. These measures could lead to additional enforcement action which would require additional resources with the need to train and equip additional licensing enforcement officers. Conversely the enforcement burden should eventually reduce if officers are not having to investigate licensing breaches from out of area drivers. The government should make dedicated funding and support available to enable local authorities to manage these new and increased pressures.

d. What steps should the Government take to address the challenges posed by cross-border licensing in the taxi and PHV sector?

‘Out-of-area’ operations should be restricted by a requirement for drivers to begin or end a job in the area in which they hold their license. In addition, reform of cross-border hiring rules with national licensing enforcement powers allowing local officers to check and penalise any non-compliant taxi operating in their area would safeguard local licensing rules designed to protect passengers and drivers.

These reforms should be supported by a national licensing database accessible by licensing officers at the point of use to access or record vital information such as driver licensing, enforcement actions and vehicle records.

LEVC would be in favour of a national minimum licensing standard that includes standardised rules for vehicle safety, environmental standards and accessibility, requiring all authorities to mandate a minimum proportion of accessible vehicles and to enforce penalties for drivers who do not comply with accessibility obligations (e.g. refusing wheelchair users).

e. What would effective reform look like in terms of enforcement, passenger safety and safeguarding, and regulatory consistency? Is there a role for regional transport authorities?

Effective reform must balance passenger safety, fairness for drivers and the need to minimise regional inconsistencies. Key actions would include unified enforcement powers for local authorities as described above, and real time data sharing between authorities to access vehicle and driver data on the spot regardless of where the vehicle is licensed. Whether stricter penalties for non-compliance with licensing breaches is necessary or if enforcement simply needs to be more consistent is an important question that local authorities themselves would be better positioned to answer. Passenger safety and safeguarding would also be better ensured with mandatory driver DBS checks and safeguarding training at a minimum, although this is not in our sphere of expertise.

Regional transport authorities have an important role to play in setting, managing, coordinating and enforcing reform through regulatory and policy development. Transport for London, Transport for Greater Manchester and others already perform this role and should be empowered to manage a more integrated approach to licensing and enforcement across councils, as well as ensuring the role of taxis is properly considered in policy development and integrated into the wider public transport ecosystem.

The government should consider its role in setting national minimum licensing requirements for all local authorities in key areas such as vehicle safety, and safeguarding. These unilateral standards could be complimented by additional local licensing requirements, coordinated by regional bodies.

i. What are the implications for taxi and PHV licensing of the future rollout of autonomous vehicles?

The prospect of autonomous vehicles in the future will have major implications for both taxi and PHV licensing, with the redefinition of ‘driver’ alone having huge practical, legal and societal impact on accident accountability, system fitness, operator liability, safeguarding and data responsibilities, and we note that Government is currently consulting in this area. Whilst AV technology is still maturing it is unclear how it will be integrated into existing transport systems, how it will co-exist alongside driver-operated vehicles and whether it would work for all passengers. We see a potential concern for disabled passengers who rely on the driver to support them with entering/exiting the vehicle.

Undoubtedly, when we reach this stage there will be significant disruption for licensing frameworks, drivers, and safety with the need for significantly increased regulatory oversight and legislation. It is our view that whilst AV technology has an important role to play today in easing the driver task by relieving tiredness and boredom and therefore improving safety, the reality of integrating fully autonomous taxis into local transport networks will require a major regulatory shift to ensure safe deployment and is still some way off fulfilment. 

We have not answered the following questions as we believe others will be better placed to provide evidence on these topics.

f. How are digital ride-hailing platforms impacting standards in the sector, and is further regulation in this area required?

g. How effective, accessible, and trusted are complaints and incident reporting systems in the taxi and private hire vehicle (PHV) sector, for both passengers and drivers?

h. How effective is the National Register for Revocations, Refusals and Suspensions (NR3S). in supporting consistent licensing decisions across local authorities? What barriers, if any, are limiting its use or impact?

August 2025

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