The guidance recommends that licensing authorities consider the safety benefits to passengers, drivers and pedestrians of vehicles which have received a higher NCAP rating, given the benefits this could have in reducing injuries and fatalities. It would be helpful if the DfT provided licensing authorities with additional information on the NCAP scheme. Additionally, further clarity would be helpful in this section to improve consistency, for example recommending that only 4 or 5 star rated vehicles are licensed.
The guidance suggests that, in general, tinted windows should be permitted in taxis/PHVs. The LGA has concerns about the possible public safety implications of tinted windows. We are aware of several councils who try to take a preventative approach in their local areas by restricting the use of vehicles with tinted windows. Their view is that a more widespread use of tinted windows could impact on the public’s confidence to use taxis/PHVs and increase safeguarding risks in an area. Other councils expressed views that if tinted windows are to be permitted, it is important to have other safety measures, such as CCTV, in place.
Several councils would agree with the DfT’s assessment that the installation of CCTV has merits. For example, one council in the West Midlands which has a mandatory condition on CCTV in all taxis/PHVs said that the reaction to this condition has been positive from customers and drivers who feel safer, with drivers reporting the additional benefit that the number of false allegations made against them has decreased. However, some councils who have consulted on the installation of CCTV in vehicles have received representations from the taxi/PHV trade around the expense and practicalities of installing CCTV. Additionally, some councils have expressed concern that if CCTV is mandated, someone within the council has to be appointed as the CCTV data controller which is a significant responsibility.
Vehicle identification and signage is a complex issue. We agree that removing the ability of PHVs to have roof signs is a sensible recommendation, and we also welcome the recommendation to display a ‘pre booked door sticker’ as this plays an important role in demonstrating that the vehicle cannot be hired immediately. Some councils believe that displaying the livery of the operator the driver is working for is a helpful safety measure as it assists passengers with identifying the car they have booked. However, councils also recognise that a driver could work for more than one operator and therefore displaying livery on a car could impose a financial and administrative burden on the driver. Additionally, the recommendation for councils to try and not licence a PHV that is the same colour as its taxis is undermined by out of area working.
Again, many councils identified out of area working as a challenge in taking an environmentally friendly approach to licensing, if vehicles that are licensed by licensing authorities with lower standards routinely enter their area. Whilst councils recognise the importance of this work, many will want to take an incremental approach to avoid placing an unfair burden on drivers who are still recovering from the effects of the COVID-19 pandemic.