Transport for London’s proposal to impose the Congestion Charge on Private Hire Vehicles is based on flawed analysis, works against the policy’s stated objectives of reducing congestion and pollution and will hold back the industry’s investment in cleaner, more environmentally sustainable vehicles, according to research commissioned by Addison Lee Group.
Oxera Consulting’s research shows that far from reducing congestion, the removal of PHVs exemption would have no impact on traffic within the charging zone – the impact described as ‘indistinguishable from zero’ – and could unintentionally increase traffic as drivers congregate on the zone’s boundary, only entering the centre when a fare becomes available.
The study describes TfL’s idea of “specialisation” to reduce traffic – whereby PHV operators separate their fleets into vehicles operating inside and outside the zone – as ‘implausible’, given the high proportion of journeys that start or end outside the zone and its’ impact on vehicle optimisation. This theory is at the heart of TfL’s projection of a 6% reduction in PHV traffic, the evidence for which is described in the research as ‘not credible’.
Costs will have unintended consequences
Oxera’s research shows that the costs of the proposal will have to be borne by one or a combination of the following, all with unintended consequences:
Passengers, faced with higher PHV fares, would be likely to switch to older, more polluting black taxis, which remain exempt from the charge under TfL’s plans despite, on average, emitting twice as much nitrogen oxide and three times as much particulate pollution as PHVs. The retention of the exemption for black taxis may also fall foul of State Aid and Competition Law concerns.
If the cost was borne by drivers, Oxera estimate that it would cost them up to £250 a month, and that this would fall disproportionately on the BAME and mixed driver community, which make up 92% of PHV drivers, compared to just 12% of black cab drivers.
By taking money out of the private hire industry – the charge is likely to cost Addison Lee £4 million a year – the cost would disincentivise moves by the entire industry to shift towards electric.
ALG are proposing an alternative policy designed to deal with pollution and congestion:
Raise the Charge overall by £1 to £12.50, which would be raise a similar amount to TfL’s proposals to remove the exemption, reduce traffic by 1% and protect PHV investment.
Install a network of rapid electric chargers in London to help the PHV industry meet the current ULEZ requirements for low-emission vehicles by 2020. In earlier independent research funded by ALG into London’s charging network, it showed that to support just 25% of the capital’s PHVs, a network of over 2500 rapid chargers would be needed. There are currently 100.
Limit black taxi licences to 10 years rather than the current 15.
This would be alongside ALG’s ongoing investment of £60m to the end of 2019 in cleaner vehicles to comply with TfL’s Ultra Low Emission Zone (ULEZ), which Addison Lee fully supports.
Andy Boland, Chief Executive, Addison Lee Group, said: “Addison Lee is fully on board with TfL’s objectives of tackling congestion and improving air quality in London, and is investing £60m to meet the existing ultra-low emission zone policy. However, independent analysis suggests that far from helping to meet these objectives, imposing the congestion charge on private hire vehicles would make matters worse. We believe our proposed policy of focusing on ULEZ and closing its loopholes, a small increase in the overall charge and a proper rapid charging network would be fairer, simpler and more effective.”
He added: “It’s an exciting time for our industry as we invest in new forms of transport – including electric power, autonomous vehicles and ride-sharing – all of which will contribute to a cleaner, more accessible city. Imposing this charge would hold back that progress and would create an unjust imbalance between private hire drivers and taxi drivers.”