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The Private Hire consultation ends tomorrow, makes sure you fill it in and submit your response.

Below are the questions you will encounter in the consultation and suggested responses…
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Click on This LINK

You will be taken to the online consultation
Below Question by Question is the Consultation document…. Copy the suggested response (or add your own) and paste it into the consultation document…

I have also included screenshots below in case you are having difficulties.

1.Operators must provide a booking confirmation to passengers containing the driver photo ID and details of the vehicle being used to discharge the booking

I agree with this proposal. It will improve passenger safety by ensuring that passengers do not get into the wrong vehicle.

2.Operators must provide booking confirmation details to the passenger at least five minutes prior to the journey commencing

I agree with this proposal. PHV drivers must not accept immediate hirings as it will invalidate their insurance and make it impossible for enforcement agencies to protect the public from touts. There is a belief that passengers will be caused an unnesesary 5 minute wait. This is a misleading idea. Passengers realising that they will need to book 5 minutes in advance need only “push the button” 5 minutes earlier.

3.Operators will be required to seek TfL approval before changing their operating model

I agree with this proposal. Operators moving to an app or new technology method will be required to approval and ensure their app will comply with TfL guidlines.

  4.Security for app based booking platforms

I agree with this proposal. It will help ensure the safety of passengers, preventing an unlicensed and uninsured driver from taking their fare.
There is definitely sufficient technology available for this, it should be left to the operator to decide upon which technology to use but scrutinised by TFL as to its efficiency and effectiveness.

5.Operator must offer a facility to pre-book up to seven days in advance

I agree with this proposal. All PH Operators are required to be prebooked, this is a long held criticism of passengers who need certainty in their travel arrangements.
Yes, passengers should be able to book as long in advance as they so wish.

6.TfL proposes to no longer issue licenses for in-venue operators or temporary events

I agree with this proposal. With the advent of smartphones to book Taxi or private hire services passengers are able to easily and quickly book their journeys home and be sure they are using a licensed vehicle.
Taxi ranks should be appointed outside each venue and should the customer require a private hire vehicles then they can either phone for one or use an app.

7.Operator must have a fixed landline telephone which must be available for passenger use at all times

I agree with this proposal. The principle of the telephone is that passengers can speak to the operator in realtime and address any issues that may arise regarding their booking.

8.Operators must not show vehicles being available for immediate hire, either visibly or virtually via an app

I agree with this proposal. Displaying  a vehicle on the screen of a smartphone is “plying for hire” – PHV may not ply for hire. This is a real threat to public safety. Without an approval process for ehailing apps there is no known record of any ehailed ride as it may be hosted outside the UK.

9.Operators will be required to provide specified information including details of all drivers and vehicles to TfL on a regular basis

I agree with this proposal. TfL must have an up-to-date database of drivers, allowing them to respond quickly to infringements of the law and act accordingly. It will also help improve passenger safety, with emergency services and enforcement officers being able to correctly identify the driver quickly. This will improve passenger safety.

10.Operators must specify the fare prior to the booking being accepted

I agree with this proposal. PH Operators only take advanced pre bookings and have the advantage of being able to plan a route, taking into account the time of day, roadwork’s and other traffic problems and can accurately calculate in advance, distance and likely journey times. With this information they can quote an exact fare and advise the customer at the time of booking-again this is custom and practice for the majority of PH Operators.

11.Operators must record the main destination for each journey which must be specified at the time the booking is made

I agree with this proposal. In the interest of public safety, a precise account of where each journey is essential. It would ensure that should something go wrong, a detailed log can be consulted to better assist TfL and/or emergency services. Until recently TfL required all PH Operators to record both the pick up and the destination addresses. The details recorded should be a full postal address not just a postcode or GPS coordinates.

12.Harmonise retention periods for records

I agree with this proposal. This will make it easier for PHV operators to comply with regulations, ensuring more effective compliance. A copy of these records should be filed with TfL.

13.Limit on the number of business names attached to each Operator’s licence

I agree with this proposal. This will help TfL keep better track of each operators’ activities.

14.Specific requirement for an English Language test

I agree with this proposal. It is imperative that drivers understand everyday English, so they are able to communicate with passengers and other road users and ensure the safety and experience of passengers and others on the road.
Drivers should be able to speak and understand English to a standard that they are able to communicate with customers.

15.Drivers to only work for one operator at a time

I agree with this proposal. It is common sense to support anything that helps TfL effectively enforce PHV regulations and ensure that drivers are not tired when on the road. There have been numerous reports of PH drivers being involved in accidents after falling asleep; being able to work for multiple operators makes it impossible for operators to monitor the hours worked by their drivers.

16.Driver and Operator licence applicants to provide National Insurance numbers and share with Department for Work and Pensions (DWP)

I agree with this proposal.

17.Vehicle licence to be revoked if driver licence revoked

I agree with this proposal. This will help ensure the safety of the public, by preventing unlicensed drivers from picking up fares illegally.

18.Checks on convictions of operator staff

I agree with this proposal. It is crucial for the safety of passengers that employees who deal with passengers directly and handle their details have undergone sufficient background checks. In an era where cyber-attacks/hacking is becoming more commonplace, this will be especially vital for web-based employees.

19.TfL stop accepting payment by PO and cheque

I agree with this proposal.

20.Hire and Reward insurance to be checked at point of licensing and must be in place for duration of vehicle licence

I agree with this proposal. Any licensed PH vehicle should be insured for Hire and Reward purposes at all times in parity with the taxi trade.

21.Drivers to carry or display a copy of insurance details at all times

I agree with this proposal. Licensed taxis must have Hire and Reward insurance in place at all times and have a copy of that insurance displayed in their taxi. PHV drivers should also display a certificate of the correct insurance type we suggest in place of the now defunct road fund license.

22.Hire and Reward fleet insurance in place by operators

I agree with this proposal. One of the biggest areas of concern over the safety of minicabs in London is uninsured vehicles. Currently there is no fail safe method of ensuring that a PH vehicle is insured to carry passengers for Hire and Reward. ANPR and roadside checks will only reveal if the vehicle has normal Social Domestic and Pleasure cover. Even insisting a PH vehicle is insured at the point of licensing will not resolve the current problem of drivers insuring a vehicle for H&R and then cancelling the policy after a short period in favour of a cheaper non H&R policy. If the responsibility for insurance is transferred to the Operator the potential for uninsured PH vehicles would be almost totally eliminated and the process of checking a few thousand Operators policies would be much easier than checking tens of thousands of individual policies. Addison Lee (one of London’s best operators) do exactly this, further it will tie drivers into one operator, and fleet discounts will be available rather than individual driver policies.

23.Operator licence type

I agree with this proposal. There current system is outdated. Given there are 93,000 PHVs in London, more categories need to be introduced.

24.Controls on ridesharing in licensed vehicles

I agree with this proposal. The safety of passengers and drivers is paramount. PH drivers do not possess the Knowledge of London and planning multiple pick ups and drop offs using map books or Satellite Navigation would necessitate frequent stops to input changed data, with drivers possibly being pressurised to do it whilst driving.

25.Amendment of advertising regulation to include “in” vehicle

I agree with this proposal.
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