Supplementary written evidence submitted by the National Private Hire and Taxi Association (TPV0193)

 

 

  1. Allegation that drivers are sleeping in cars and drug users:

When Paul James from UNITE made this statement during the oral evidence committee meeting, both I and everyone present in the public gallery were shocked by such an unexpected and serious allegation. The remark was so concerning that Andy Mahoney immediately intervened, clearly stating that he had never encountered any such issues.

Since then, we have received numerous messages both from our members and from those who viewed the proceedings, expressing outrage at such a defamatory and unfounded statement directed against an entire industry.

While we acknowledge that, as in any profession, there may be a small minority of individuals who engage in inappropriate or illegal  behaviour, it is wholly inaccurate and unfair to suggest that our industry as a whole is associated with habitual drug use or that drivers routinely sleep in their vehicles. There is absolutely no evidence to support such damaging and irresponsible allegations.

Suggestion / summary:

 

Remove these allegations from the record as being false, misleading, and dangerous.

 

  1. Repetitive training courses for drivers:

We do not believe that there is any meaningful benefit or advantage to drivers—or to the travelling public—from requiring drivers to repeatedly undertake the same training courses. Where such repetitive testing is in place, it serves only as a waste of time, effort, and money for drivers, while providing nothing more than a revenue stream for the course providers.

Furthermore, we see no justification for requiring private hire drivers to complete wheelchair accessibility training unless they specifically intend to drive fully wheelchair-accessible vehicles. For those applicants, the training should focus on how to assist passengers with limited mobility — for example, helping them safely transfer from a wheelchair to a vehicle seat, and folding and securing the wheelchair appropriately in the luggage area, This approach aligns with the Taxis and Private Hire Vehicles (Disabled Persons) Bill introduced by Peter Gibson MP

https://bills.parliament.uk/bills/2912

 

We fully support the requirement for first-time applicants to complete such courses, as they provide valuable foundational knowledge and promote high standards among new entrants to the industry. However, once a driver has successfully completed and passed a course, repeating the exact same material every three years — with little or no change to course content — is counterproductive and unnecessary.

We would instead support refresher training only where there is clear evidence of a lack of understanding or competence. For example:

Finally, we believe that the same training courses should also be mandatory for all licensing officers, committee members, and police officers involved in licensing enforcement. This would allow them to gain the same practical insights and understanding as drivers, rather than receiving training limited solely to the legislative aspects of the role.

Suggestion / summary:

 

When considering national standards, entry level courses should be entry level only. Reassessment should only be required when supported by evidence.

 

  1. Full Wheelchair accessible vehicle policies. (WAV)

Having not only owned and driven a wheelchair accessible vehicle (WAV), but also enjoyed many years working within the nursing home sector, I have a deep personal and professional understanding of the needs of both disabled and elderly communities, as well as practical experience in the safe transportation of wheelchair users.

While there is a clear and justified need for a higher proportion of WAVs in areas with elevated levels of tourism—such as London and Blackpool—the same level of supply is not necessary or viable in other regions.

To illustrate this point, consider nursing homes and hospitals: although these facilities may accommodate over a hundred residents, many of whom are wheelchair users, they typically maintain only a limited number of wheelchairs on-site. The same principle should apply to the taxi sector—a required percentage of WAVs is entirely reasonable, but a 100% WAV policy is not a sustainable business model. This is primarily due to the high purchase cost of these vehicles compared with the low frequency of their use for their specific purpose.

It is also important to distinguish between wheelchair users and those who are wheelchair-bound, as the two categories represent different levels of mobility and need. This distinction has been discussed in detail in articles published in the national trade publication Private Hire and Taxi Monthly (PHTM).

Suggestion / Summary

 

Rural and low-demand areas should not be required to operate a 100% WAV fleet. Instead, a mixed fleet model should be adopted, provided that a minimum number or percentage of WAVs is maintained to ensure accessibility needs are met.

 

  1. “No excuse for abuse campaign”

 

A sign with a hand and text AI-generated content may be incorrect.

I was visibly shocked when Paul claimed that UNITE the UNION had recently launched the No Excuse for Abuse campaign. In fact, the campaign was launched by PHTM Newspaper back in 2018, in response to the increasing number of attacks on our drivers. Evidence of this can be found here: PHTM January 2019 Issue, page 64.

https://content.yudu.com/web/43sy4/0A43sy5/PHTMJanuary2019/html/index.html?page=64&origin=reader

 

Local authorities from across the country, who have to approve the distinctive double sided window stickers before they can be displayed, have been fully supportive of this campaign and regularly purchase the stickers which are now produced both in English and English/Welsh to distribute to their licensed vehicle owners.

 

A sticker on a window AI-generated content may be incorrect.

 

  1. Reflection on the Casey Report and the Role of Taxi/Private Hire Services:

During our recent session, reference was made to the Casey Report, though time did not allow for a full discussion. Having reviewed the report in detail, I noted that of the twelve recommendations made, only one related specifically to the taxi and private hire sector, focusing primarily on cross-border working and its perceived link to child exploitation activity.

It is important to recognise that this is not a new issue. The original Casey Report of 2012, which focussed on the Rotherham area, identified that taxi and private hire vehicles had been used by perpetrators to transport victims. This finding led Rotherham Council to introduce mandatory in-vehicle CCTV in 2014 to enhance safeguarding and evidential integrity. However, this measure was not replicated in other areas such as Newcastle, Telford, or Rochdale, despite similar cases emerging in those areas.

It should also be emphasised that of those drivers accused of direct involvement in grooming activity, very few were ever convicted, but they were had all locally licensed. The evidence therefore does not support the view that cross-border licensing was a contributing factor. Rather, the issue has consistently been one of systemic safeguarding failures, intelligence sharing, and multi-agency communication.

The taxi and private hire trade has, unfortunately, been used as a means of transport by offenders — no differently to buses, trains, or other public transport. The vehicles themselves were not the cause; the lack of early identification and safeguarding coordination was.

I have been actively involved in safeguarding initiatives through LANPAC (Lancashire Partnership Against Crime), where child exploitation awareness has been a consistent focus. The taxi and private hire sector play a critical role in these efforts, working closely with the police and local authorities to identify risks, report concerns, and protect vulnerable passengers.

Having personally experienced the care system, passing through multiple children’s homes and foster care placements from an incredibly early age, this issue is one I hold close to me heart. I therefore remain committed to ensuring that our sector continues to be part of the safeguarding solution, not mischaracterised as part of the problem.

Suggestion / summary:

  1. Capping of private hire vehicle (PHVs) numbers:

We do not believe that introducing a cap on the number of private hire vehicles (PHVs) would be beneficial to the travelling public. On the contrary, evidence suggests that such restrictions would have a detrimental effect not only on passengers but also on the private hire industry as a whole.

In practice, a cap on PHV numbers would primarily benefit large hire companies, which would acquire available vehicle licences (“plates”) and then rent them to drivers. This would create capitalisation and monopoly, forcing independent drivers to rent rather than own their vehicles. Such concentration of ownership reduces competition, raises costs, and limits flexibility within the industry.

As David Pattison of Wolverhampton Council has rightly observed, there is a real risk that a company based in another area—for example, Manchester—could acquire the majority of a local authority’s available plates. This could leave residents within that authority, such as those in Wolverhampton, without sufficient local service provision, simply due to an imposed cap on vehicle numbers.

Current Legal Position:

Under existing legislation in England and Wales, local authorities do not have the power to cap the number of private hire vehicles.

Accordingly, any attempt to introduce such a cap would require primary legislative change.

Comparative Example: Glasgow:

In Glasgow, a cap on PHV numbers exists under Scottish legislation, the impact of this measure has been mixed and remains controversial. Independent drivers in Glasgow are unable to license a new vehicle or replace one that has been damaged or written off because no new vehicle licences are available. This forces drivers to rent vehicles from plate holders, artificially inflating vehicle rental values and restricting independent enterprise.

It is also important to note that under the Scottish licensing framework, a private hire driver may accept their own bookings until operating three or more vehicles. At that point, they are required to obtain a Booking Office Licence—the Scottish equivalent of a private hire operator licence under the system in England and Wales. The Scottish experience illustrates the economic and operational drawbacks of capping PHV numbers.

Suggestion / summary:

Introducing a numerical cap on private hire vehicles would be harmful to both the industry and the travelling public. It would:

Current law does not permit such restrictions, and where caps do exist—such as in Glasgow—they have led to negative consequences. For these reasons, we strongly oppose any proposal to cap private hire vehicle numbers and urge policymakers to maintain an open, competitive, and fair licensing environment that prioritises public benefit.

Introduction of residential address being considered as part of “fit and proper” test.

An interesting question, we believe there is clear scope to establish a defined boundary beyond which licence applications could reasonably be rejected. While there are legitimate cases where drivers may reside outside the licensing authority area, many continue to live near their licensed district and genuinely work within it.

For example, in Rossendale, many licensed drivers reside in nearby areas such as Nelson or Keighley, yet their work and licensing activities are fully centred within Rossendale itself. Likewise, some applicants may live just beyond an authority’s boundary, where their local environment — in terms of nighttime economy or access to schools — differs significantly from the licensed area, but where their proximity and intended work justify inclusion within that authority’s remit.

If residency were to form part of the “fit and proper” test, such a requirement could be structured to allow for a reasonable radius or to permit applicants to demonstrate a genuine intention to work within the licensed district. Examples exist of drivers living at greater distances — for instance, on the Isle of Wight — who nevertheless travel to and work consistently within the Transport for London (TfL) licensing area. This illustrates the importance of aligning policy with intended use, as outlined in our written and oral submissions.

We believe that a combined approach incorporating:

would collectively bring an end to the widespread issue of out-of-area operation within twelve months.

A practical example of such an intended use policy can be seen in Rossendale Borough Council’s policy:

https://www.rossendale.gov.uk/downloads/file/13839/intended-use-policy,

While several local authorities have adopted similar approaches, these currently apply only to hackney carriage licences.

Finally on cross border, it is important to clarify a point I made within my verbal evidence, where I suggested that cross border hiring started in Berwick, this comment was not 100% accurate, the issue started long before 2007 and was only brought to light as a result of the Berwick case which can be found here:

 

https://www.casemine.com/judgement/uk/5a8ff7c760d03e7f57eb201e

 

Suggestion / summary:

 

We support the establishment of a residential boundary as part of the “fit and proper” licensing criteria, provided there is flexibility to account for drivers who genuinely live outside the area but primarily work within it.

Mechanisms such as intended use policies, geo-fencing, and verifiable commuting intentions can ensure compliance while addressing the issue of out-of-area licensing effectively. Historical and practical examples demonstrate that a balanced approach can reduce cross-border hiring abuses without penalizing legitimate drivers.

 

  1. Single national licence

We do not consider this a sensible or logical proposal, as it would entirely remove local authority involvement in licensing. Implementing it would require a complete repeal of the LGMPA 1976, which is explicitly designed for “Local Government” activities.

If such an approach were adopted, licensing would need to be centralized under a body such as the DVSA, with enforcement conducted by police forces using their powers. This would place a significantly greater burden on an already stretched police service.

The only apparent benefit of this model would be to simplify operations for large operators, allowing them to hold a single operator license and use any driver or vehicle anywhere in the country. We believe this poses serious risks and should be avoided.

Given the current discussions around devolution, the number of licensing authorities is likely to be reduced anyway. We consider this a suitable compromise, particularly when combined with a national standard, the confusion and complexities of licensing variations will be reduced.

 

  1. National standards:

We fully support the principle of introducing national standards, as expressed in both our written and oral submissions. However, there are significant complications within that notion which must be carefully considered when seeking the right balance between differing regulatory models.

For example, in London, Transport for London (TfL) operates under the 1998 Act, where private hire vehicles (PHVs) are only considered licensed while on duty. This allows such vehicles to be driven by anyone for personal use when not operating. In this system, there are no visible licence plates attached to PHVs, which may work effectively in the capital given the much higher levels of enforcement activity.

In contrast, under the 1976 Act, which governs the rest of the UK, a PHV is always considered a licensed vehicle, regardless of its use. The visible licence plates therefore form a vital part of the public safety and enforcement regime.

Adopting the TfL approach nationally could undermine public safety expectations and enforcement mechanisms outside London, while adopting the wider UK model would likely meet resistance from those licensed by TfL.

Additionally, inconsistency between local authorities could lead to further complications, as illustrated by Milton Keynes’ recent decision that all new hackney carriages must be fully wheelchair-accessible and must be fully electric or hydrogen — going further to stipulate “must have no exhaust.” Such a rule, while environmentally motivated, has the unintended consequence of rendering the current fleet non-compliant, and removing the ability to license any new vehicles, since no such vehicle presently exists.

This formed the basis of my suggestion that, while the new national standard should be absolute, provision must be made for regional variations. However, any such variations should only be introduced following substantial input and active engagement with the industry, in accordance with the Regulators’ Code (2014), they must also be fully detailed and justified, without such safeguards, we risk repeating the same issues already identified in many of the other written submissions.

  1. DBS standards:

There are two longstanding issues within the Disclosure and Barring Service (DBS) system that continue to disadvantage licensed taxi and private hire drivers, and which have been the subject of ongoing campaigning across the industry. Despite widespread support — including from many local authorities and the Institute of Licensing — progress has been minimal.

We call for:

  1. A single, unified DBS check covering both taxi/private hire and regulated school transport work.
  2. Modernisation of the DBS Update Service to allow Direct Debit renewals, preventing unnecessary lapses and reapplications.

Issue 1: Duplication of DBS Certificates

Current DBS rules require drivers who undertake school transport contracts (more than three times per month) to hold a separate enhanced DBS certificate for “regulated activity,” even if they already hold an enhanced DBS for their taxi or private hire licence.

This results in:

Practical Example

A driver may transport the same child, from the same address, to the same school, in the same licensed vehicle — but the DBS requirements differ solely based on whether the booking was made by the school (regulated) or by the parent (non-regulated). This is an artificial distinction with no safeguarding benefit.

Proposed Solution

Amend DBS guidance to allow one enhanced certificate to cover both:

This would maintain safeguarding integrity while removing unnecessary duplication.

Issue 2: DBS Update Service Renewal Mechanism

The DBS Update Service is fundamentally flawed in its renewal process. Currently, renewal is only possible via debit card payment, not direct debit.

Problems

Proposed Solution

These simple administrative reforms would preserve continuity, reduce bureaucracy, and support workforce stability.

Summary /suggestion

The industry is not calling for reduced safeguarding — only for a fair, consistent, and efficient system.
We urge the Home Office, the Disclosure and Barring Service, and the Department for Transport to:

  1. Implement a single DBS framework for all licensed taxi/private hire work.
  2. Enable Direct Debit renewals for the DBS Update Service.

Both actions would significantly reduce administrative burden, improve safeguarding continuity, and better support the drivers who provide essential transport services to schools, vulnerable people, and the wider public.

  1. Devolution:

We believe that the spirit of devolution is sound. The principle of reducing variations in licensing conditions, creating larger and more consistent working areas, and implementing clearer and more practical licensing policies is a promising and necessary step forward.

For example, we have observed significant inconsistencies in how window tint restrictions are applied across different licensing areas. In one area, tint is regulated by a specific percentage of light transmission, while neighbouring authorities allow vehicles with “manufacturer’s standard glass.”

Where such percentage-based restrictions exist, they often rely on the use of light transmission meters to measure compliance. However, these devices have repeatedly been found to be inaccurate, uncalibrated, or incorrectly operated. This has resulted in unreliable readings that are frequently challenged. In some cases, the same person using the same device on the same vehicle has produced different results — highlighting the futility of applying such precise percentage conditions in practice.

We have even seen cases where vehicles failed compliance tests for being just 1.5% below the allowed tolerance — a difference imperceptible to the human eye and with no measurable impact on safety or visibility. In such instances, vehicle owners were forced to replace all windows at a cost of approximately £1,000, whilst undermining the vehicle’s original Type 1 approval status, despite reasonable alternative proposals being rejected.

The only suggested justification for such restrictive conditions is that enforcement officers should be able to see into vehicles as they pass. However, given that most enforcement takes place during daylight hours, and that vehicles typically pass at speeds of around 30 mph, this argument lacks logical or practical merit.

This issue has already been the subject of several judicial reviews involving local authorities, many of which subsequently removed such conditions without any impact on public safety. The matter has also been discussed in detail in the Private Hire and Taxi Monthly (PHTM), notably in the July 2021 (Issue 346, p.6) and August 2021 (Issue 347, p.6) editions, where we fully explain the reasoning behind vehicle manufacturers’ adoption of tinted glass as standard.

Reduced Services for the Travelling Public

However, we do have significant concerns regarding the broader proposals for devolution and the full amalgamation of existing local authorities. Experience from areas such as Bournemouth, Christchurch and Poole (BCP) and the new North Yorkshire Council has shown that such large-scale mergers can lead to inconsistent service provision and a lack of meaningful engagement with local stakeholders. Issues such as fare structures, fee setting, and local service conditions have too often been “stitched together” without adequate consideration of the real-world impact on drivers or the travelling public.

When large, combined authorities are created, the “controlled districts” in which hackney carriages may operate can expand dramatically. This creates a serious risk that high-demand urban areas become saturated with drivers seeking higher fares, while rural or low-demand areas are left with minimal service provision.

To illustrate: under current arrangements, Greater Manchester comprises ten separate local authorities, each with its own controlled district. If these were merged into a single entity, the area of operation would expand from around fifty square miles to more than five hundred square miles. This would encompass major transport hubs (airports, train stations), the nighttime economy, and high-demand shopping districts—all drawing drivers away from less profitable, but socially essential, local services.

The likely consequence would be reduced access to transport for elderly or infirm residents, patients attending medical appointments, and even families relying on school run services. Naturally, drivers will gravitate toward areas offering the greatest earning potential, leaving smaller communities underserved.

Suggestion / summary:

 

While devolution and local authority amalgamation may deliver administrative efficiencies in theory, we strongly recommend that existing licensing zones remain in place. Each zone should continue to manage its own fare structures and service conditions to ensure fair access and sustainable service levels across both urban and rural areas.

 

October 2025