Response 117979285

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The taking of bookings– review of regulations

1. Should the current booking office licensing regime be updated and the definition of the licensed activity amended?

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Radio button: Ticked Yes
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Comments:
Any individual or business should be registered and it made compulsory for all data to be kept for an appropriate period in order for any relevant checks to be made if required.

2. In what ways should the booking office licensing regime be amended?

In what ways should the booking office licensing regime be amended?
This should include any means with which any bookings are made now and in the future using any means of communication.

3. What would be the impact for local Licensing Authorities, the trade and the public?

What would be the impact for local Licensing Authorities, the trade and the public?
The Local Authority should already have a record of all drivers, vehicles and companies. Any individual completing a booking, placed by any means, must accept the responsibility for ensuring that the booking has been made through a duly registered individual or company. Any individual or company accepting a booking must be fully licensed and ensure that the vehicle is properly licensed, insured and the driver completing the booking is a licensed fit and proper person.
With modern technology it is imperative that the public be fully protected and anyone making a booking through any means must be given the protection of the law.

4. Should the current exemption to the licensing regime for booking offices with three or less relevant vehicles be amended?

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Radio button: Ticked Yes
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Comments:
Booking technology has moved on a great deal since the legislation was introduced and should be amended.

5. What should the limit be amended to?

What should the limit be amended to?
one or more vehicles.

6. What would be the impact for local Licensing Authorities, the trade and the public?

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Radio button: Ticked Yes
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What would be the impact for local Licensing Authorities, the trade and the public?
see 3 above. The main criteria must be the protection of the public.

Local presence

8. If a business is taking bookings where should it be registered? For example should it be registered in every local authority where it takes bookings?

If a business is taking bookings where should it be registered? For example should it be registered in every local authority where it takes bookings?
Taxis are not allowed to ply for hire in any other Local Authority area other than the one in which the vehicle or driver is registered. However both Taxis and PHC can accept bookings made in advance from areas outwith their Local Authority. I do not think it necessary for there to be a requirement to be registered in any other Local Authority where bookings are generated but I do think a record of all bookings should be retained and all individuals or companies accepting any bookings should be properly licenced and they must ensure that the vehicles and drivers are properly licenced and insured.
Any vehicles transporting passengers should be properly licenced and insured and this should include wedding, funeral, limousines and executive hire. All drivers of these vehicles should also be properly licenced and all individual or companies must be licenced and appropriate records kept.

9. What sort of information or assistance should a business taking bookings be required to provide and to whom?

What sort of information or assistance should a business taking bookings be required to provide and to whom?
The name of the individual being picked up, the date, time, place of pick up, the drop off point and the vehicle and driver picking up the passenger. The data protection act might come into force therefore it may be the Police that can access any information required.

10. Do you have other concerns about where the taking of bookings should be licensed?

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Comments:
The same procedure should be applied to all Local Authorities.

11. Should the current position and status quo be maintained?

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Comments:
As previously stated I believe that amendments are required.

Taxi and private hire car maximum fares

12. Would it be appropriate for taxis and private hire cars to be required to have a taximeter?

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Radio button: Ticked Yes
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Comments:
I believe the public should be protected from surge pricing therefore it is appropriate to have meters fitted.

13. Should the Scottish Government impose the requirement of a taximeter on all taxis and private hire cars ?

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Radio button: Ticked Yes
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Comments:
as above

15. What would be the impact, for example additional costs, of requiring all taxis and private hire car vehicles to install and operate a taximeter. In particular could this jeopardise provision in rural areas?

What would be the impact, for example additional costs, of requiring all taxis and private hire car vehicles to install and operate a taximeter. In particular could this jeopardise provision in rural areas?
Meters are relatively inexpensive and in larger towns and cities this should not pose any problems. In rural areas a judgement would have to be made by the Local Authority but all vehicles and drivers should be properly licenced and insured. Any individual or company taking bookings should also be licenced and insured.

16. Are you aware of particular problems with the charging of fares in your local area?

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Radio button: Ticked Yes
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Comments:
It has been reported in the press of the excessive charging made by some internet based companies.

17. Can you suggest, or have you experienced licensing authority good practice in relation to fares?

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Radio button: Ticked Yes
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Comments:
Edinburgh has a system in place which has worked relatively well in the past. The problem arises when individuals making the decisions on fare increases do not apply common sense.

Other Concerns

18. Do you have any additional concerns regarding the issues raised in this consultation?

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Comments:
Larger cities and towns impose the types of vehicles that can be used both as Taxis and PHC vehicles. The purpose built taxi is now so expensive that taxi drivers are finding it harder to compete. The purpose built vehicle is not only more expensive to purchase but is also more expensive to maintain. There is a move to introduce these taxis as electric or hybrid with the future models currently under development. It may be reasonable to suggest that this new purpose built taxi will be even more expensive. My existing taxi is an LTI TX4 purchased in March 2015 at a cost of £37395 this was £5400 more than the purchase price of the TX4 it replaced which was 18 months old. Today I understand a new TX4 is circa £43500 which is an increase of £6k in a year. The taxi fares in Edinburgh have not increased during this period partly due to an appeal to the Traffic Commissioner. I would suggest that some sort of subsidy and also zero VAT for wheelchair purpose built vehicles be considered. Failure to do so will ensure that the fleets using purpose built vehicles will get older and older. The majority of taxis worldwide are private cars which off course are substantially cheaper to buy and are readily available in nearly new low mileage examples which are substantially cheaper to buy than brand new models.

19. Do you have any suggestions or are you aware of existing good practice, for addressing the issues raised in this consultation?

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Radio button: Ticked Yes
Radio button: Unticked No
Comments:
Taxis by the existing conditions are licenced to ply for public hire and Local Authorities must be compulsory made to ensure that taxi ranks are supplied in the areas required by public demand. The existing ranks at the Transport hubs in Edinburgh are so say the least dire. The Taxi rank in Market Street Edinburgh supplying the Waverly station exit is for 7 taxis and the "For Hire" lights cannot be seen by the passengers exiting from the Market Street exit. This has been a temporary Taxi Rank for quite some time and is completely inadequate for the public demand. It replaced the rank which was situated inside the Waverly Station. Another rank which is situated on the Waverly Bridge holds 4 taxis. This has not increased in size in the 35 years I have been driving taxis. The Council had ample opportunity to expand this rank when the Waverly bridge was redesigned and is another example of the public being let down. Another exit from the Waverly Station is via Princes Street and no rank was introduced for public use. Haymarket Station Taxi Rank is now in it's third location since the major revamp of the station and there is discussion to change this yet again! This should have been sorted when the plans were drawn up for the station revamp. Edinburgh airport in another example where the Airport Management do not allow all licenced taxis to ply for hire, it should be made mandatory that all licenced Edinburgh Taxis be given the right to ply for hire to ensure the public gets the best service. The Airport Management also charge one of the largest fees in the UK for taxis to pick up this should be investigated. Over the years I have been told many times of the importance of Taxi Drivers to the City and the impact that we have on both business people and tourists, my long experience in the Trade has me in full agreement with this line of thought. If this is still the line of thought with the Decision Makers then surely we must work together and ensure that all passengers are given the consideration and respect that they deserve. This would have benefits to all.