The true criteria which entitles Tfl to grant a cab licence.

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Stephen Mulligan

Dear Transport for London,

It has come to my attention that 'All London' taxi drivers are licenced to ply for hire in the entire 606 sq miles that make up Greater London despite only have undertaken 'the knowledge' for 113.04 square miles (6 mile radius of charing x) or 20% of their entire licence area. This means that they are not trained to the rigorous standards we are led to believe they are compelled to achieve for 80% of their licence area.

Also as a legacy of various changes in the boundaries that comprise the suburban sectors over the last 31 years, some suburban drivers too have been licenced for, and despite further changes remain licenced for whole boroughs that they have completed no knowledge for.

Please can you disclose which laws or policies determine which areas a cab driver can be legally licensed for and what the criteria for this licensing must be.

It seems to me that Tfl are entitled to issue licences for drivers to work wherever Tfl choose to allow them to work, reguardless of whether any knowledge has been assessed. Is this the case or are there strict knowledge based criteria.

Can a driver work any area stated on his or her licence legally or would they be working illegally if they have not passed a knowledge test for areas Tfl have chosen to licence them for.

Please include any other laws or policies that may be relevant to these large numbers of drivers who are giving the fare paying public the impression of being trained to take the shortest possible route from A-B in an area they are licenced for without any training or knowledge assessment.

Yours faithfully,

Stephen Mulligan

FOI, Transport for London

Dear Mr Mulligan

 

Our Ref:         FOI-0327-1415

 

Thank you for your e-mail received on 3 June 2014 asking for information
about taxi licences.

 

Your request will be processed in accordance with the requirements of the
Freedom of Information Act and TfL’s information access policy. 

 

A response will be provided to you by 1 July 2014.

 

In the meantime, if you would like to discuss this matter further, please
feel free to contact me.

 

Yours sincerely

 

Gemma Jacob

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

 

[1][TfL request email]

 

 

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Buggey Simon (TPH), Transport for London

2 Attachments

Dear Mr Mulligan

 

Thank you for your email regarding the licence areas of London taxi
drivers.

 

Article 27 of the London Cab Order 1934 states that TfL may limit a
licence by attaching a condition prohibiting a driver from plying for hire
except in the area for which he or she has demonstrated an adequate
knowledge. Under this provision TfL licenses drivers either for the whole
of the Greater London area or for discrete areas in suburban London.

 

Since 2000 our policy has been to license new drivers for one or more of
nine specific suburban sectors and drivers licensed prior to the changes
in 2000 for sectors or combinations of boroughs that align to their
previous licence areas.

 

When the structure of suburban licence areas was realigned to  match
borough boundaries there was never going to be a complete match  between
the old and the new sectors. However in the event that a driver  lost a
part of their old sector they were compensated by gaining an area for
which they had not learnt the Knowledge. We consulted with the taxi  trade
who endorsed the changes and the current structure has worked well for the
past 14 years with all drivers now being licensed for one or more complete
borough.  

 

I have attached a copy of the Notice that announced the changes to the 
taxi trade in 1999 which stated that slight gains would be offset by 
reductions with the introduction of borough based licensing in April 2000.

 

The Notice also advised drivers that in the event that a driver’s new 
licence area resulted in him or her being licensed for just part of one
of  the new sectors, the driver can apply to be assessed on their 
topographical knowledge of the other boroughs in the sector to enable
them  to be licensed for the complete sector. A number of drivers took up
this opportunity which still remains available.   

 

Earlier this year we undertook a consultation exercise which addressed
issues affecting suburban taxi services, including the structure of the
suburban sectors. We are currently assessing and analysing the responses
to the consultation which will be used to inform decisions to create a
sustainable licensing  system that benefits both taxi drivers and the
travelling public.

 

I hope that this addresses your query but if you require any further
detail regarding Knowledge testing criteria, please let me know.

 

Regards

 

Simon Buggey

Driver and Operator Policy Manager

 

London Taxi and Private Hire

Transport for London

4^th Floor - Yellow Zone

Palestra

197 Blackfriars Road

London SE1 8NJ

 

020 3054 2927 (Auto 82927)

07590 600281

 

[1]http://source.tfl/images/YOTB_MASTER_LOG...
Visit [2]www.tfl.gov.uk/yearofthebus for information
about Year of the Bus.

 

 

 

 

 

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Stephen Mulligan

Dear Buggey Simon (TPH),

Thank you for taking the time to reply to my question.

Having read your reply I feel you have answered some of the questions I was asking but you have not addressed whether it is illegal for a taxi to ply for hire in an area that they have not completed the knowledge for.

As you say in your reply, legislation requires drivers to have an adequate knowledge of the area they are licenced for, but All London drivers are only tested on 20% of the area that they are licenced for, so how can this be deemed to fall into the definition of 'an adequate knowledge' when suburban drivers work for years to acquire the adequate Knowledge of only a small part of these same areas.

Also before 1983 suburban drivers were required to learn a 2.5 mile radius of a designated station. These drivers were then given without any further knowledge requirement vast sectors which when later broken down into smaller sectors were not withdrawn to the new sector their original knowledge covered, but they continue to be licenced for all of the area given to them. On the most recent borough changes these drivers have been given whole boroughs and in some cases whole sectors that they have not acquired any knowledge for.

My question is this; what criteria legally entitles a driver to ply for hire in a given area. Is it actually whether they have done the knowledge for this area, or Tfl have issued a licence stating that they are entitled to ply for hire there, regardless of whether they have undertaken any formal knowledge of the area is issued for?

Is there a law or policy which clarifies this point, or is it left to Tfl's discretion? And if this is the case what is the point of the knowledge if drivers can ply for hire in areas they are clueless about?

I do find these anomalies quite confusing considering london taxis trade on their ' encyclopedic' knowledge of their licence area!! If they haven't done the knowledge, what's the difference between them and a minicab?

Yours sincerely,

Stephen Mulligan

Buggey Simon (TPH), Transport for London

Dear Mr Mulligan

In answer to your outstanding question, it is only unlawful for a driver to ply for hire in an area for which he is not licensed. It is for the licensing authority, which since 2000 has been TfL, to decide what level of knowledge is adequate when determining what areas drivers are licensed for.

Regards

Simon Buggey

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Stephen Mulligan

Dear Buggey Simon (TPH),

Thank you for your reply.

I appreciate that it is for Tfl to decide the level of knowledge required for a driver to be licenced for an area, but my original question asked for the criteria by which this is established.

One is lead to believe it would be relevent, as the name suggests, to the drivers familiarity with the roads and buildings within the area the licence is issued for.

One is also lead to believe that by being licenced for an area, all drivers have the same high standard of knowledge to provide the world class service one expects when hailing the iconic London Taxi.

Please can you provide a pdf of the relevent policies and criteria which state the level of knowledge Tfl require of a student before licencing them to be fit and able to immediately and spontaniously take a fare paying passenger the shortest possible route to their required destination without hesitation or reference to any other information materials.

There must be some policy documentation that determines why a Suburban driver is required to learn every road, public space, comercial and residential building, place of worship, hospital and other point of interest in Bexley, whereas an All london driver only has to identify the main roads from Greenwich to Thamesmead and Erith, from Deptford Bridge to Barnehurst and Crayford and from Lewisham to Old Bexley.

It is clear that the first takes many months and the second a couple of days, so please state the guidelines that Tfl use to determine the level of knowledge required to provide an acceptable service in this area and how these two licences can vary so dramatically in their requirements.

I realise that Tfl inherited the system when they took over the licencing responsibility, but having changed other aspects of taxi licencing since they took over, it seems that they continue to endorse the current system and are happy with the guidelines which expose such woeful discrepencies in consistency and quality of service to the fare paying public.

Yours sincerely,

Stephen Mulligan

Buggey Simon (TPH), Transport for London

5 Attachments

Dear Mr Mulligan

Thanks for your latest email.

I have attached all relevant documents regarding Knowledge of London testing. The issues you are concerned about were also raised during the consultation on suburban licensing earlier this year and will properly be addressed through that process.

Thank you again for writing.

Regards

Simon Buggey

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Stephen Mulligan

Dear Buggey Simon (TPH),

Thank you again for your time to reply.

Please could you advise of any timescale to the publication of the results of the consultation you refer to.

Having googled this consultation to read the relevent passages, I note that it closed two months ago, but no mention has been made of a timescale to learn the results and implimentation of the conclusions drawn from this process.

Yours sincerely,

Stephen Mulligan

Buggey Simon (TPH), Transport for London

I am on annual leave until Friday 27 June 2014 and will deal with your
enquiry on my return. If the matter is urgent please contact Paul Reemer,
Policy Officer - [email address] or 020 3054 2928

 

Regards

 

Simon Buggey

Driver and Operator Policy Manager

Transport for London, Taxi and Private Hire