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Dear Mr xxxx,
Thank you for your letter of 1 October 2004 seeking clarification on the right of
access to the Royal Parks by licensed private hire vehicles. Please accept my
apologies for the delay in affording you this response.
Insofar as private hire vehicles are concerned they are defined as vehicles used
for ‘trade or business’ under The Royal Parks and Other Open Spaces
Regulations 1997. Only three (3) exemptions are detailed in the Regulations
namely
‘Taxis’ (licensed by Transport for London)
‘Vehicles transacting business with any person either
residing in a Palace or Park or using land therein under
licence from the Secretary of State.’
‘A vehicle used for the purpose of repair or removal of any
other vehicle, which is broken down in a park’
Whilst use of the Royal Parks for the purpose of taking passengers from pick ups
to destinations outside of the Parks is not allowed you can legitimately pick up or
deliver customers within the Parks under the second exemption quoted above.
From correspondence and other communications being received from the
industry it appeared that the Royal Parks Constabulary had adopted a policy of
issuing FPNs to licensed private hire vehicles seen in the Parks only recently. As
soon as this was brought to my attention, I contacted the police commander for
the Parks and the Park Authorities immediately in an effort to resolve the matter
quickly, for the benefit of London’s private hire industry. (I recognised however
that a permanent solution could only be achieved by a change to the 1997
Regulations.)
The information I subsequently received was that in the preceding weeks only
one (1) fixed penalty notice (FPN) had been issued by officers of the Royal
Park’s Constabulary and that whilst police would continue to enforce park
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regulations in no way was the penalising of licensed private hire vehicles seen as
a policing priority.
To a degree this gave some reassurance that London’s private hire industry was
not being targeted but fell short of the commitment we were seeking.
Consequently we are pursuing, at both a political and official level, a permanent
solution through an amendment to the 1997 Regulations and I am hopeful of a
positive outcome.
In the interim should you or any of your colleagues receive an FPN whilst passing
through a Royal Park can I suggest that this is challenged through the appeals
process. It would also be invaluable if I could be advised of specific cases where
FPNs have been issued to licensed private hire vehicles in order to assist our
case to get the change in regulations.
I enclose schedule 1 from the 1997 Regulations which lists the areas to which the
Regulations apply.
Yours sincerely,
Alexander Kennedy
Head of Service Delivery and Standards
Direct line: 020 7941 7837