Further written evidence submitted by Mr Miroslav Podlecki (TPV0198)

Further to my email of 5 December 2025 and my oral evidence to the Committee on 3 December, I wish to provide clarification on the operation of geofencing technology and its relevance to the issues I raised regarding cross‑border private hire vehicles (PHVs) at Weybridge train station and other transport hubs. 

How geofencing works

• Geofencing is an IT‑based control mechanism used by app platforms. It functions like a digital “umbrella” around a defined radius. 
• Within the geofence, app‑booked drivers are not offered new jobs while they remain inside the restricted zone. They may still enter the area to drop off or collect pre‑booked passengers, but they cannot loiter in car parks or adjacent to taxi ranks while being available for immediate bookings. 
• Once a driver leaves the geofence radius, the system resumes normal operation and jobs can be dispatched to them. 
• This mechanism prevents drivers from positioning themselves directly next to taxi ranks or station entrances to gain an unfair advantage over locally licensed Hackney carriage drivers. 

Current limitations at Weybridge station

• In October 2024 Uber introduced a geofence at Weybridge station, but it covers only approximately 50% of the taxi rank. 
• While this partial implementation has provided some relief, many PHVs now loiter in station car parks without purchasing tickets, making themselves visible on apps and returning repeatedly after drop‑offs. 
• Because current law does not prohibit this practice, PHVs continue to exploit the loophole, undermining the regulated rank system and worsening congestion. 

Legislative need

• Councils currently lack powers to compel app platforms to introduce geofencing. 
• As reported in PHTM Taxi Magazine, app companies are exploiting this regulatory gap nationwide, creating unfair competition for Hackney carriage drivers. 
• I therefore respectfully propose that legislation require app platforms to implement geofences around all major stations and ranks, with a minimum protective radius of 0.25 miles. This would be sufficient to prevent loitering in adjacent car parks and station approaches, while still allowing legitimate pre‑booked journeys. 

Request for Committee consideration

I ask the Committee to review the situation at Weybridge station in Elmbridge Borough and to consider recommending statutory change to:

1. Mandate effective geofencing around taxi ranks and stations (minimum 0.25 miles). 

2. Empower councils to require and enforce geofencing by app platforms. 

3. Close the loophole that currently allows PHVs to exploit station car parks and surrounding land without accountability. 

Closing

Geofencing is a practical, proven technology. When implemented fully, it protects the integrity of taxi ranks, reduces congestion, and ensures fair competition for local drivers. Without legislative intervention, app platforms will continue to exploit the current loopholes, to the detriment of Hackney carriage drivers and passengers nationwide. 

Summary of the problem

Cross‑border private hire vehicles (PHVs) licensed by Transport for London or other boroughs are operating in Elmbridge without local licensing or local accountability. This creates a persistent enforcement gap and a range of practical harms for locally licensed Hackney carriage drivers and for passengers.

Observed impacts in Elmbridge and at Weybridge station

• Loss of fair work: Out‑of‑area PHVs operate under lighter local standards, reducing work for drivers who have invested in Elmbridge licensing and compliance. 
• Accountability gap: Complaints are routinely passed between Elmbridge Borough Council, TfL and South Western Railway with no effective enforcement outcome. 
• Taxi rank misuse: Private hire vehicles are not permitted to stop on taxi ranks; taxi ranks are reserved for Hackney carriage vehicles only. Despite this, PHVs are stopping on ranks and picking up passengers from them across the country, including at Weybridge station, in breach of the regulated system. 
• Geofence limitations: Uber implemented a geofence at Weybridge station in October 2024; in practice this geofence covers only approximately 50% of the taxi rank, leaving the remainder unprotected and available to cross‑border PHVs. 
• Car park loitering and app visibility: Cross‑border app‑booked vehicles routinely use nearby car parks and loiter adjacent to ranks and station entrances while remaining visible on booking apps. Positioning themselves close to the station gives them a clear advantage over local drivers. Local taxi drivers cannot work for app‑based pre‑booking companies because the council does not permit dual vehicle registration or simultaneous licensing across multiple councils. This practice gives a distinct advantage to the app platforms, while local drivers are restricted to taking work only from taxi ranks or from the streets within their own borough. Cross‑border vehicles should not be permitted to remain in the immediate vicinity of Weybridge station, other railway stations, and key locations across the country and be available for bookings via apps. 
• Traffic and congestion: PHVs entering station areas and ranks contribute to congestion and operational disruption. 
• Financial imbalance and driver hardship: Local drivers pay licensing and rank fees and comply with stricter local standards, while out‑of‑area PHVs operate without local contributions. Many local drivers are suffering severe financial loss and some are being forced to leave the trade because it is increasingly difficult to earn a living when constantly surrounded by cross‑border vehicles.

In Elmbridge there are only two functional taxi ranks where drivers can realistically earn fares, intensifying the impact.

Wider pattern: Reports and local observations indicate these practices are occurring at stations and ranks across the country.

Private land and enforcement gap at stations

• Private land limitation: Many train stations and taxi ranks are located on private land. Where ranks sit on private land, local councils have limited or no enforcement powers over activity on that land. 
• Operator constraints: In our case the landowner, South Western Railway, has limited ability to control cross‑border PHVs that loiter on station land, use car parks to appear available on apps, or pick up passengers from ranks reserved for Hackney carriages. 
• Need for stronger private‑land powers: Private landowners (including rail operators) should be given clearer statutory powers and enforcement tools to prevent misuse of station land by cross‑border PHVs. Without such powers, local borough licensing teams remain unable to act effectively where ranks are on private land, leaving a significant enforcement gap at key transport hubs. 
• Local impact at Weybridge: At Weybridge train station this private‑land enforcement gap is a primary cause of the problems described above, because neither South Western Railway nor Elmbridge Borough Council currently have effective powers over cross‑border PHVs operating on station land.

Regulatory recommendation and proposed remedies

I respectfully request that the Committee consider recommending statutory changes to address both the operator licensing gap and the private‑land enforcement gap:

1. Local operator licences for app platforms 

• Require app‑based pre‑booked platforms (for example, Uber, Bolt and similar operators) to obtain a local operator licence from each council in which they accept or fulfil bookings. 
• Grant councils the authority to request trip data and operator records, inspect vehicles and drivers, and impose sanctions (including fines or suspension of local operating rights) for breaches of local licensing conditions.

2. Mandatory geofencing around ranks and stations 

• Require all app platforms to implement geofences that cover the full extent of taxi ranks and a surrounding protective radius at major stations and hubs. I propose a minimum geofence radius of 0.5 miles around Weybridge train station and comparable locations; vehicles within that radius should not be available for immediate app‑based bookings that would undermine the rank system.

3. Stronger powers for private landowners 

• Provide statutory powers or clear enforcement mechanisms for private landowners (including rail operators) to prevent unauthorised stopping, loitering and passenger collection by cross‑border PHVs on station land and in station car parks. 
• Ensure coordination mechanisms between councils, rail operators and platforms so enforcement is effective where ranks are on private land.

Closing and call to action

Without the introduction of robust local operator licensing, effective geofencing and strengthened private‑land enforcement powers, local taxi drivers will continue to suffer unfair competition and financial hardship. I respectfully ask the Committee to consider recommending legislative change to:

(1) require local operator licences for app platforms,

(2) mandate effective geofences around taxi ranks and key transport hubs (minimum 0.5 miles at Weybridge and comparable locations), and

(3) grant private landowners the powers needed to control misuse of station land.

December 2025