Chamber and committees

Scottish Taxi Federation submission of 6 January 2022

PE1856/M - Support the taxi trade

Background - Scottish Taxi Federation

The Scottish Taxi Federation was founded in 1984 and is the only truly representative body of the taxi trade in Scotland, with our members collectively transporting an estimated 100 million passengers annually.

Our members pride themselves in offering the people of Scotland with the provision of a fast, safe, reliable, and economical service by our thousands of experienced professional licensed taxi operators and drivers. It should be acknowledged that across our cities and towns, our members are the only transport provider operating 24 hours per day, 365 days of the year.

Taxi trade in Scotland in serviced by circa. 8,000 taxi operators and supports around 30,000 jobs across manufacturing, repairs, management, administration, and drivers.

The Scottish Taxi Federation is in principle supportive of the above Petition and provides the following comments on specific issues impacting the future sustainability of the taxi trade in Scotland.

Financial Support

During the engagement on appropriate financial support in response to Covid, the Scottish Taxi Federation repeatedly emphasised the need for government at all levels to understand the distinction between taxi operators and drivers.

Consequently, despite support for drivers, there has been inadequate support for taxi operators against the full academic evaluation of costs, namely:

• Vehicle Purchase
• Vehicle Maintenance
• Fuel Costs
• Licensing Costs
• Insurance Costs
• Dispatch / Radio System (if applicable)

National Level Representation

The Scottish Taxi Federation recognises there are several significant issues that are best served at a national level but are currently being left failing to be addressed at a local level.

Legislation

Our assertion is Civic Government (Scotland) Act 1982 is outdated and requires a significant review to ensure it encapsulates the modern trading environment of taxis and private hire, especially in respect of digital booking channels and the regulation of the ‘Gig economy’.

Enforcement - Protection of Public Hire

Our members are increasingly despondent over the lack of enforcement of 1982 Act in particular private hire vehicles illegally picking up members of the public without prior bookings, which is now commonplace across Scotland’s town and city centres.

This practice, commonly known as ‘pirating’ or ‘seagulling’, has been acknowledged by both Police Scotland and local authorities as an increasing problem but not being addressed. The lack of enforcement has led to a growing misconception in the public’s perception and to serious concerns over the public safety.

Drivers

The average age of drivers is currently 57 years, and this is increasing year on year.

Active driver numbers have been devastated by Covid, with many licensed holders having decided not to return to the taxi trade in favour of other employment options. Despite the best efforts of our members, across multiple channels, have gathered limited interest.

Cited barriers to obtaining a driver’s licence include:

• Topographical Test (i.e., irrelevant, route learning)
• SVQ Professional Taxi Driver Qualification (i.e., Cost)
• Speed of Application Process (i.e., licensing sections)

Local Authority Process

Our members cite interactions with their local authorities as generally being onerous, bureaucratic, and time consuming, with consistent issues:

Disparate / Siloed Council Departments

The taxi trade is particularly disadvantaged due to the lack of cohesion amongst the council departments e.g., licensing, planning, procurement, roads, economic sections etc.

Taxi Ranks

Our members are increasingly having to commit a disproportionate amount of time and resources into lobbying local authorities to prevent the removal of vital taxi ranks from high visibility areas and/or confinement to hidden side streets. Ranks that are appointed lack enforcement with Police Scotland directing complainants to the Local Authority as they wrongly believe the matter is now a civil one. Section 21(7) of the 1982 Act is clear that the matter is a criminal offence and remains under their jurisdiction.

Procurement

Our members observe inconsistent application of procurement rules locally.

Low Emission Standards

The introduction of the Low Emission Zones (LEZ) and beyond presents what is potentially the most significant challenge to the taxi trade.

Cost of Vehicles

An entry level LEZ compatible hackney vehicle is around £40,000 rising to £60,000 for an electric range extending hybrid. It should be noted that there are currently no fully electric vehicle options in the market, but once launched these are anticipated to be circa £70,000.

Retrofit Options

A number of retrofit options for hackney taxis are under development to extend the life of vehicles by means of updating the exhaust systems, with financial support available.

It should be noted that such vehicles can be up to 14 years old at the point of conversion, having previous being utilised in the London or elsewhere, and we consider this as a short term and counterproductive solution.

In our opinion the financial support would have been better directed towards replacing ageing vehicles with new Euro VI compliant vehicles, as is being explored in Manchester.

Our Request

Our submission is we are now at a critical point where ageing licence holders, in an ageing taxi fleet, must consider whether to invest and continue in the trade. With consideration of these and many other factors, the continuation of the taxi trade in Scotland is under threat over the next decade i.e., death by a thousand cuts.

In support of the Petition, Scottish Taxi Federation calls upon the Scottish Parliament to:

• Commission a comprehensive review and holistic assessment of all the issues affecting its financial viability & sustainability of the taxi trade in Scotland.
• Initiate a review of the Civic Government (Scotland) Act 1982 to ensure its ongoing suitability in the provision of taxi and private hire services.
• Notwithstanding the necessary review of primary legislation, to:
• Ensure the maintenance & enforcement the legal distinction between Public Hire and Private Hire by local councils, Police Scotland, and other agencies.
• Issue guidance to local authorities and licensing sections across Scotland to encourage consistency and good practice in respect support for the taxi trade (e.g., ranks, topographical test etc.)
• Promote Taxis as viable solution to reducing private car usage in Scotland.
• Consider the wider implications for taxi trade in any future development & expansion of Low Emission Zone (e.g., towards zero emissions).