P-05-775 Allow Free Movement of Taxi Drivers to Carry Out Private Hire Work Anywhere in Wales – Correspondence from the Petitioner to the Committee, 27.09.18

Thank you for giving TDC the opportunity to respond to 'Taxis Without Borders' petition. Obviously we disagree strongly with their assertion that licensed drivers should be able to work anywhere in Wales regardless of what Local Authority they are actually licensed by.

If taxis are allowed to work without borders they will obviously gravitate to the busiest and most populous areas. Consequently many areas would be left with a shortage of vehicles to provide a vital transport service for the elderly and disabled members of the community. If taxis are to be considered part of the transport infrastructure a situation that sees the risk of the most vulnerable members of society marginalised and disadvantaged cannot be allowed.

We strongly believe that you should only work where you are licensed. In our briefing paper, which we sent to every AM (attached) we state:

Changes we believe that are required

1. Every journey for both Hackney and Private Hire needs to start or end in the area the driver and vehicle is licensed OR operators must not dispatch a booking to a vehicle when the vehicle is outside the authorities border, unless the booking ends within the authorities border. This will not stop customers from requesting a fare to any destination, and from any company but it will prevent areas becoming saturated with ‘out of town’ vehicles working predominantly in areas they are not licensed. This will

simplify legislation and make it easier to enforce.

This week we also saw the publication of the Department for Transport Task and Finish Group report into Taxi and Private Hire licensing (attached)

Among the reccomendations they make in Westminster are:

Recommendation 11

Government should legislate that all taxi and PHV journeys should start and/or end

within the area for which the driver, vehicle and operator (PHV and taxi – see

recommendation 6) are licensed. Appropriate measures should be in place to allow

specialist services such as chauffeur and disability transport services to continue to

operate cross border.

Operators should not be restricted from applying for and holding licences with multiple authorities, subject to them meeting both national standards and any additional requirements imposed by the relevant licensing authority.

Also included in the DfT report is the setting of national standards and the ability for local authorities to cap the amount of Private Hire licenses issued, both of which we strongly agree with.

Whilst it is encouraging that Mr Ken Skates proposals will "include new measures to limit out of area working" we feel measures to just limit out of area working will not go far enough, and will leave the door open for loopholes in legislation to appear and be exploited. The whole licensing framework needs to be simplified and we feel if cross border hiring is not stopped in its entirety then it will only confuse matters further.

As far as the need to increase capacity during major events, perhaps more pressure needs to be placed on local authorities when it comes to transportation in the way of more frequent "night buses" and on the train companies in the way of more frequent and reliable trains laid on through the night.

Kind Regards