Agenda item

The Committee received a deputation from Chris Douglas in relation to item 4.1 (Taxi and Private Hire Policy). Article 9 of this minute refers.

Mr Douglas advised that it was his understanding that when a policy was reviewed, the local authority was required to clearly define the scope of the review and take a substantive review on the policy as a whole, and not only on those clauses that have not been reviewed for some time, as this could be seen as procedurally unfair.

He indicated that Appendix 1 stated, in the first paragraph, that the policy was approved by the Licensing Committee on 26 October 2022, with an implementation date of 1 April 2023, and amended on 4 December 2025, which suggested the policy was both relatively recent and already amended.

He sought to clarify when the individual clauses within this policy were last reviewed, and how long ago that review took place.

He made reference to the policy, noting that it contained 29 clauses, grouped into four clear categories, which were taxi vehicle conditions; private hire vehicle conditions; shared taxi and private hire vehicle conditions and driver conditions.

He explained that these covered matters such as, but not limited to zoning, vehicle age, wheelchair accessibility, advertising, CCTV, and of course the Street Knowledge Test.

He intimated that it was important for the trade/stakeholders to have clarity about exactly which clauses were now being reconsidered, and why, given that there had also been no stakeholder engagement.

He made reference to the report, which in the case of ‘Zoning’, suggested  that views were sought on combining the current city and airport taxi zones, so that all taxis were licensed for the whole council area. He indicated that it was his understanding that this related directly to clause 5.1.2 of the policy, which applied to taxis, noting that the clause referred to city taxis, identified by yellow plates, and airport taxis, identified by green plates. He advised that the wording referred to pre-booked work, but it did not explicitly include private hire vehicles, even though private hire vehicles could and do operate also at the airport through pre-booking. He suggested that it would be helpful that it clearly state which clause was being considered; what it currently said and which vehicle types it applied to.

In terms of ‘vehicle age limits’, Mr Douglas intimated that the report stated that wheelchair accessible vehicles must be no more than 10 years old at first licensing, and other vehicles, no more than 5 years old, and asked whether those limits remain appropriate. He explained that those requirements appeared across multiple clauses including clause 5.1.5 for taxis, clause 5.2.1 for private hire vehicles, and clause 5.1.3 for wheelchair accessible vehicles. He sought confirmation whether the recommendation was aimed at taxis, private hire vehicles, wheelchair accessible vehicles only, or all three, noting that without clarity, consultation risked becoming confused and misleading.

In relation to ‘advertising’, Mr Douglas indicated that the report noted that advertising was permitted on taxis, with some exceptions, but not on private hire vehicles, and suggested seeking the views on both the existing exceptions and on allowing advertising on private hire vehicles. He explained that this appeared to relate to clause 5.1.8 for taxis and clause 5.2.4 for private hire vehicles and therefore sought clarity given that these clauses served very different parts of the trade.

In terms of the ‘Street Knowledge Test’,  Mr Douglas revealed that clause 5.4.1 currently applied equally to taxi drivers and private hire drivers and the report suggested seeking views on whether the test should remain for both; be amended for private hire or removed entirely for private hire applicants. He explained that what was being discussed today was being framed as a taxi problem, yet many of the proposed changes focussed only on private hire, which was not the same thing, acknowledging that Public hire taxis served ranks and on-street demand and that Private hire vehicles were pre-booked.

He advised that if the issue being described was a lack of taxis available at ranks at peak times, then lowering standards for private hire drivers did not solve that problem and it addressed a different market entirely.

He intimated that what the Committee had done was working well to increase the amount of licenced drivers in the city.

He made reference to the Street Knowledge Test Review Working Group that was established some time ago, explaining that the ongoing standards that had been put in place were delivering great results. He advised that movement around the city had improved significantly post covid, demand had increased and the taxi trade had responded.

He estimated that in December 2025 alone, the industry serviced over 50,000 more bookings than in previous periods which did not suggest that the system was failing, therefore suggested that if the test was working, if standards were improving, and if availability had increased, then there was no need to weaken one of the core mechanisms (the Street Knowledge Test) which ensured competence.

Mr Douglas advised that operators needed confidence that when a driver joined their booking office (whether taxi or private hire), the driver met a clear, consistent standard, given that no operator wanted two different levels of competence and there were no passenger benefits from lower expectations.

He explained that the if the issues being raised related to service quality, high demand, or availability, then the answer was more training, better targeting of policy, and smarter regulation, not less or none.

Mr Douglas intimated that history showed that deregulation did not increase competition in the long term, noting that initially, it allowed more drivers and operators to enter or flood the market, but over time, large firms with deep pockets undercut smaller local operators, drove prices down to unsustainable levels, and ultimately aimed to dominate the market, which in itself, was the very definition of a monopoly.

He advised that what followed would not be a better service, but less investment, lower standards, and fewer local businesses, explaining that it would become a race to the bottom and lowering the barrier to entry for private hire drivers would not increase the number of yellow-plate taxis working ranks at peak times at all. He indicated that these were two separate functions, one was pre-booked and the other was immediate, on-demand public hire.

He suggested that if the Council and indeed the public wanted more taxis at the ranks, then the solution lay within taxi policy itself, therefore there was a need to look honestly at what constrained the growth of public hire taxi vehicles, including vehicle specifications, wheelchair accessibility requirements, inspection regimes and costs that disproportionately affected taxis compared to private hire drivers.

Mr Douglas intimated that at present, it was easier and cheaper to operate a private hire vehicle, given that non-Wheelchair Accessible Vehicles avoided certain aspects of inspections, such as ramp gradient requirements, which were essential for taxis but irrelevant for private hire saloons. He advised that the reality was that this pushed drivers toward private hire, not public hire, acknowledging that the amount of private hire cars was increasing.

He indicated that deregulating private hire further would not fix the perceived taxi rank shortages, it would erode the taxi sector entirely and once that sector was gone, the very problems regulation was meant to prevent, would return in a far worse form. He suggested that proper regulation was the answer and  always had been and which was currently in place.

Finally Mr Douglas revealed that the common-sense approach had already been achieved by the Council and the evidence suggested that the system was working. He advised that the focus now should be on refining the taxi and private hire policy where necessary, supporting investment and maintaining consistent standards, but not undoing progress that had already been made to erode the industry for one operator’s commercial gain.

The Committee resolved:-

to note the deputation.