Following today’s announcement that the private hire (PHV) regulations review has been published and its recommendations watered down significantly, myself and the United Cabbies Group are disappointed that TfL never stood by their recommendations.
It was TfL who wrote this document yet allowed lobbyists to derail some important and significant steps to ensuring both public safety and ensuring a level playing field for all players in the private hire and taxi trades.
The most notable omission is the requirement for any "app" based private hire operator to offer pre-booking facilities. In our reading of it, the law requires that any private hire operator can offer this.
The recommendation was that any operator offer a minimum delay between booking and availability be five minutes and up to seven days for customers who may have need of this.
The story the lobbyists have been leading ministers to believe is that people will be standing around in the rain waiting five minutes for a car to arrive.
This argument is futile: who doesn't know five minutes in advance they are about to travel? Why wait until you are standing in the rain before pushing the button on the app? Why not push the button on the app while you are putting your coat on inside out of the rain five minutes earlier?
This begs the question, if the law requires that all private hire vehicles be pre-booked, what is pre-booking? In a 4G world, is it one second between pressing the button and availability?
If you see a PHV exhibiting itself at the kerbside and you click the button, is that really a pre-booked journey?
In 2012 the law commission undertook a yearlong review in a two tier system (pre-booked private hire versus taxis) and concluded it was in the public interest to retain the two tier system. But if pre-booking is not defined for these apps what is the definition of pre-booking?
Where does that leave the taxi trade with 93,000 private hire vehicles acting as taxis without the regulation that the taxi trade is forced to obey?
We will be asking the markets and monopolies commission to look into this as it is clearly unfair competition. All we have ever asked for is a level playing field.
We contest that a pre-booking is one that Lord Denning's "common man on the upper deck of a London Clapham Omnibus" would conclude.