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Key issues with TFL Consultation and Impact assessment.

Key issues with TFL Consultation and Impact assessment.
Firstly we must state that scoping some answers out of an assessment in our view shows a lack of mandate to then follow through with a pick and choose method following such a consultation.
We will address the following points however our concern that the responses have been ignored in some cases or altered to satisfy operator’s needs over those of the public and drivers.
Nothing has really been done to improve driver safety per se and incomes will continue to be adversely affected by operators not being forced to hold high standards.
The need for a minimum living fare whilst not a point of consideration within this consultation’s scope is still a GMB goal.
In effect many thorny issues exist which have not been resolved by such an expensive consultation process.
3.1 Proposal 1

The costs of this proposal to small operators and owner driver operators will be difficult to administer and manage.

Little thought has been given to the cost and complexity of such technology.

Services still reliant on radio to dispatch will also be hard hit

Many of these companies work within elderly communities who do not have the need for modern smart phone.

Some operators have mainly walk in trade and fixed free phones in supermarkets, clubs and other venues.

If this is forced in operators who cannot manage this expense may close and this will leave many without a local service.

Many people use unlicensed vehicles as they perceive its cheaper and don’t think of the risk factor involved Continued education to the public of the dangers is a must.


The watered down proposal to not need a full time number with the option to book a car is not only unreasonable it is discriminatory to those without smartphones or who may have disabilities which prevent smartphone use.

A connection to an operator via an app is not only unacceptable but impractical.

Fixed lines must be UK based as we all know that if based overseas many of the operators on the phones use a script but don’t always actually understand Local English, dialects or slang.

Operators need to be locally based and rather than not support UK preferably London based operators both the Mayor and TFL are ignoring not only safety but the reason the question was first asked.

TfL should not allow operators to use foreign call centers as this puts customers at risk of becoming victims of identity theft. There have been several well documented cases over the years where foreign call center personnel have sold customers personal data which then put the customers at risk of becoming victims of identity theft and being defrauded. Call staff should require a DBS to allow overseas individual’s access to such data invalidates data protection so in reality these operators can only be based in the UK.

Drivers also need protection or to seal with issues for TFL and the mayor to ignore this shows a distain for drivers and their needs.
In short TFL and the mayor don’t care about a driver and their needs where office contact is concerned.
Specifying the fixed fare will not be accurate now operators are allowed use miles and time taken per journey.
Time will always be a estimate and in todays congested roads will never be accurate.

Overall a fixed price is the way forward most ops already do this.

Estimated fares will cause friction between driver and customer especially if the estimate is incorrect due to journey changes.

The risk to drivers from a violence and income standpoint is not only unbalanced but unacceptable.

Waiting time and extra pickups and drop offs must be quoted at time of booking in case or a caveat must be handed or SMS texts / Email or via an electronic means to the passengers in clear text warning them of extra cost this must be advised verbally by any controller.

We suggest that either operators or TFL become liable should the driver be subject to loss on journeys or attack due to disagreements over fares as this is an unsafe rule.

English standards must be higher than what tfl suggesting as this level does not ensure driver can read or speak fluently this will create a barrier of missed communication.
Other trades require training before you earn so why is this a problem?

We would recommend that ALL drivers are tested for linguistic skills perhaps when renewing their license and when bringing their cars to be tested for licensing those who are not part of this process can perhaps present at tfl.

This will ensure standards are correct.

There is already a larger pool of drivers so
Operators will not lose out from a so called reduced pool.

Increasing numbers reduces income for drivers as supply outstrips demand.

This rule with TFL acting as Judge, Jury and Executioner will increase hardship if driver has only temp loss through illness as they could rent vehicle out as a form of income

Where serious offences take we agree on this but a totting up of points will increase hardship through cost when driver is able to reapply.

It is also easy to obfuscate the rule by another family member ‘buying’ the car.

ride sharing is dangerous and because its new and there is a lack of data does not mean it will have a harmful effect on driver incomes and the dangers are clear and obvious.
It will be difficult to stop ride share once the proverbial horse has bolted.

Full guidelines should have been in place before allowing ride share.

We also feel that public rideshares for non licensed vehicles is a safety risk on multiple levels.

In essence ride sharing poses a risk to passengers and drivers, TfL should not support such concept and should work to ensure such business model is not allowed to operate in a PHV. There have been several complaints by passengers on Twitter where they have been sexually harassed by the passenger they shared the PHV with, most notably a Times journalist. Such models also creates a higher risk to the driver and passengers should an intoxicated or violent customer become uncontrollable, so the Driver will be at risk whilst trying to ‘keep the peace’
We have seen over the years the various types of violent crimes committed on public transport therefore TfL must reconsider its position on “Ride-Share”. Also note there have been crimes committed by individual or groups of passengers on PHV drivers with severe consequences to the driver therefore this model puts the driver and other passengers at greater risk of violence & abuse. Transport for London needs to do more research on such operation prior to backing such model due pressures from their corporate partner. It is unacceptable that when TfL or the politicians want implement restriction on PHV drivers they spit the magic word “safety” however intentionally ignore genuine safety issues when it doesn’t suite their corporate partner’s business interest.

3.63 This removal of such a licensing option will increase, rather than deter, illegal touting and sex pests. It should be obvious why the proposal is dangerous to the travelling public.
The document explaining the proposals interestingly omits any mention of how customers and the private-hire trade reacted to Proposal 6, whereas consultation responses are summarised for other proposals in the document.
A facility to provide a safe option is better than no option at all.
TFL believe that this criminality is exhibited at most venues and the travelling public can use an app or book.
Not only is this narrow minded it opposes all that a licensing authority should stand for.
To help endorse lawlessness is questionable beyond the realms of understanding.
It also if enacted would put legitimate prebooked drivers at risk to illegal drivers who often offer violence when trying to purloin legitimately booked work.
TFL and the mayor should be ashamed of themselves for affirming such a change.
Fare estimation
To consider the ramifications of this proposal minor adverse either speaks to a lack of understanding by respondents or a lack of understanding of the effects on drivers where quotes are given for journeys.
It is not uncommon for individuals travelling to give a different destination to save money additionally journeys frequently change and the only individuals then dealing with the customer in relation to additional cost is the driver.
Often drivers are short paid or in some cases not paid at all as an altercation develops and the threat of violence to the driver means they withdraw.
Where quotes are given a verbal and written (Be this electronic or in person.) advice that the cost may be higher if the proposed journey is deviated from.
If TFL wish to enforce this rule then we recommend they and the operators who fail to allow drivers to be compensated pay the shortfall, resultant losses and damages in the event of drivers being assaulted.

DBS checks must and should be carried out on ALL operator staff who have face to face contact or have access to passenger data.
There is no way to prove that in some instances some individuals without DBS will be not asked to mind the office or that just because an individual has no direct customer contact that they may not use information about and individual or journeys for nefarious purposes.
A have an have not rule is not only impractical it is dangerous.
Insurance this rule has now been watered down to allow drivers not to have cover when not with an operator.
On this basis they should be removing Private hire discs and not able to use the congestion zone.
The benefits for all drivers with annualised policies would have been to see a reduction in overall monthly costs to drivers as the pot for insurers would have grown.
The reality is a driver can now obtain a vehicle licence and in some cases avoid the correct insurance as the public will see the disc in the window and presume the vehicle and driver is compliant.
The reality is that individuals who act in this fashion cost legitimate drivers work, create higher premiums and put the public at risk.
The issue of congestion charge avoidance is also a major point as TFL does not have the recourses to track which vehicles are with operators and those that are not thus allowing obfuscation of congestion charge fees.
It is with this point in mind that we question an app demanding drivers break the law to come in to the congestion charge zone with no prebooking in place

Posted: 23rd February 2016

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