“In its response to this consultation TfL needs to clarify the rationale to holding the private hire industry to what appears to be a lower environmental standard.”
With the deadline for Transport for London’s consultation on taxi age limits ending at midnight today, Assembly Member Caroline Pidgeon shared her submission with TaxiPoint.
In the submission which was sent directly to Gareth Powell, Managing Director of Surface Transport, Assemby Member Pidgeon wrote:
Maximum age limits for taxis
The issue of poor air quality remains one of the major challenges for London. Diesel, with its high levels of nitrogen oxide, is a significant part of the problem and taxis, despite improvements in recent years, are one of the main contributors. It is right that TfL should seek to speed up the process of removing the oldest, most polluting vehicles from our streets, so I welcome this consultation and broadly support its aims.
As taxis continue to play an important role in our transport infrastructure, it is of course very important to make these changes in a way that will succeed in its aim. This means creating the right incentives, supporting taxi drivers through the transition and providing the right levels of up-to-date infrastructure. The changes must be clear-cut so taxi drivers do not feel let down or misled by the process.
I welcome the recent policy U-turn from the Mayor to provide financial assistance for owners of Euro 5 taxis to convert their vehicles to Liquid Petroleum Gas (LPG). Allowing vehicles that are converted before the launch of the new, proposed changes to retain their 5-year extension is also welcome, as is the exemption of LPG taxis from the proposed lower age limits. LPG is not the long-term solution to cleaning up London’s taxi fleet, but it is significantly cleaner than diesel and does provide an important degree of flexibility as we make the transition to a zero emissions fleet.
The consultation document refers to there being 50 LPG fuelling stations in London. Whether this number is sufficient should be kept under close review alongside take-up of the conversion grants and the overall numbers of LPG taxis.
It is essential that the number of rapid charging points in London, particularly those dedicated for use by taxis, matches the demand. Otherwise efforts to move to a zero emissions fleet could be seriously undermined. I welcome the work of the Electric Vehicle Infrastructure Taskforce and look forward to the publication of the shared delivery plan in the near future.
The consultation document refers to a phased reduction of the age limit with it reducing by one year, each year from 2020 to 2022. I support the idea of a phased reduction but am concerned that the rate at which this affects taxi drivers could be faster than it seems to be. Each year two ‘classes’ or age groups of taxis will become un-licensable. This is because each year the age limit would reduce by one year AND all taxis get a year older. In response to an enquiry I made on this point, TfL provided the following table, which shows the rate at which taxis will become un-licensable. This information should have been included in the consultation document and I hope will be made widely available if the decision is made to go ahead with the proposals.
The recent revision to the taxi delicensing scheme is welcome. The increased funding should help more drivers to make the switch to ZEC models or other cleaner vehicles. Careful consideration needs to be made of whether the payments have been set at the right level. The impact of the revised scheme should be monitored closely along with the impact on taxi drivers.
Impact on switching rates
The London Taxi Drivers Association (LTDA) has claimed that the proposed changes could in fact reduce the rate at which older vehicles are removed from the road, as the proposals have apparently had a notably negative impact on the resale value of taxis. This then could make it harder for owners to ‘bridge the gap’ to affording a ZEC model. TfL’s response to an enquiry I made about this point rejects the concern, pointing to an acceleration in ZEC orders since the £10,000 payments were introduced and the possibility that newer non-ZEC taxis could see their resale value go up. That is all very well and good, but it does not mean the LTDA concerns are necessarily misplaced. If the proposed changes are to proceed it is important that they are effective not only at getting older vehicles off the road, but also at replacing them with ZEC models. TfL should look carefully at the LTDA concerns and review any plans accordingly.
Alternative ZEC models
Another aspect of encouraging a switch to ZEC models is the lack of options to taxi owners considering making the change. At one point it had been suggested that there might be five different models, but at present there is only the TXe. Possible alternatives such as Nissan’s Dynamo and a ZEC Vito taxi are apparently still in the pipeline, with the Dynamo said to be significantly cheaper than the TXe. While the development of alternative models is out of TfL’s hands, it is important that TfL does what it can to encourage the creation of a range of options.
Hardship exemption confusion
The consultation document states very clearly that the hardship exemption, introduced in 2012, will be removed. It states that the exemption was on a case by case basis and was for ‘cases of exceptional hardship’. However, the consultation’s accompanying ‘Information and Integrated Impact Assessment’ creates confusion by stating ‘exemptions and/or extensions to the current applicable age limit will only be granted in exceptional circumstances, where it is considered reasonable to do so’. This means the consultation is unclear how the proposed changes would be different to the current set up in this regard. If TfL goes ahead with removing this exemption, it must clarify this point, giving particular attention to what kinds of ‘exceptional circumstances’ might qualify.
Contrast with Private Hire
These proposed changes put additional pressure on the London taxi industry at a time when many of its members are already feeling the strain. While I support the aim to move the taxi fleet towards ZEC, in its response to this consultation TfL needs to clarify the rationale to holding the private hire industry to what appears to be a lower environmental standard.
Image Author: Keith Elkins