London Cab Drivers Club response to TfL Ultra Low Emission Zone Consultation

London Cab Drivers Club response to TfL Ultra Low Emission Zone consultation issued 27th October 2014

Introduction

1. The London Cab Drivers Club (LCDC) is one of the main taxi trade organisations in London, actively involved in committees and liaison meetings with TfL at all levels. We have participated in the recent GLA investigation into Taxi and Private Hire services in London and in the TfL consultation meetings on the Cycle Super Highway. We have also attended all the ULEZ consultation meetings organised by TfL, engaged with stakeholders including manufacturers, road users, influence groups and trade organisations. Our Chairman sits on the Mayor’s “Cabbie Cabinet” which meets quarterly to discuss strategic issues. The main strength of the LCDC is that all of its committee members are active and working London taxi drivers. This means our organisation is uniquely close to the key issues and attitudes of London taxi drivers.

2. The LCDC welcomes the opportunity to formally respond to the consultation and proposals for the introduction of the ULEZ in 2020 and the licensing of only zero emissions capable new taxis and private hire vehicles from January 2018. We also totally support the Mayor’s aims of reducing pollution and emissions in London, making our city a safer and more pleasant place to live and work in. In this response we will putting forward a number of positive recommendations to reduce taxi emissions in London.

3. This response concentrates on the effects of the TfL proposals on London’s taxi industry. The standard proposed by TfL for zero emissions capable taxis has been defined as: having an average CO2 emission of 50g/km; a capability of 30 miles continuous on battery power alone; and with a supporting internal combustion engine using petrol only; and the introduction of a 10-year age limit from September 2020. The 50g/km target compares with the EU agreed target of 95g/km by 2020.

4. We agree with Matthew Pencharz (Senior Policy Advisor to the Mayor) when he said that the proposed ULEZ scheme needs to be “fair, proportionate, reasonable andaffordable” (GLA Environment Committee 4th December 2014). Therefore any scheme to reduce emissions for London’s taxis should be: fair and reasonable because it should not disadvantage taxis compared to other businesses in London; it should be affordable for the taxi industry so that it does not put an unreasonable or intolerable economic burden on the taxi trade; and above all it should be proportionate and achievable because it adopts a technology standard that is capable of being supplied by manufacturers offering taxi drivers a choice of purpose built taxis.

5. Through the active involvement and discussions with all the stakeholders involved in the ULEZ meetings we have come to the conclusion that the outcome of the current proposals, if implemented, will be quite the opposite of the intention of the Mayor’s Senior Policy Advisor. The LCDC, along with the other taxi trade organisations as well as Private Hire bodies view the proposals as being: “unfair, unreasonable, disproportionate and certainly unaffordable.”

6. The LCDC makes a series of proposals to the Mayor to reduce emissions in London. These can be seen in our ‘Recommendations’ section. Instead of outlawing older cabs the Mayor should immediately incentivise the uptake of new Euro 6 standard taxis in London. These vehicles, with much lower polluting NOx emissions, promise to significantly reduce taxi pollution. Moreover, it is only sensible to introduce regulations which include hybrid or electric vehicles when those taxis are actually on the market. The Mayor’s policy should not be made on other people’s promises.

Unaffordable

7. London’s taxis already have to meet some of the strictest standards in the world: a combination of the 25-foot turning circle requirement and the need to meet defined accessibility standards result in only two vehicles meeting the criteria and at a high average price of circa £40,000. This is more than double the cost of a typical saloon vehicle which is used by private hire drivers in London. The way in which the purpose built taxi driver has been able to make his vehicle economically justifiable has been through the ability to depreciate his taxi over a longer period of time. As a result London taxis are well known for their durability and high quality standards. Historically vehicles have lasted for at least 15 years, although this was capped from 2012 when a 15-year age limit was introduced.

8. However, the proposal to introduce a 10-year age limit will have a significant impact on the viability of the London taxi. In the current market a typical 10-year old taxi can have a re-sale value of £10,000. If the owner/driver is required to scrap or dispose of his taxi after 10-years then the scrappage cost for the total London fleet of 22,500 taxis would be at least £200 million. This is considerably in excess of the £40 million support being considered. At the GLA Environment Committee meeting on 4th December 2014 it was stated by Elliot Treharne of the GLA that the £40 million would be made available to the 7,000 drivers whose cabs would have reached 10 years old in 2020. This works out at £5,700 per taxi, or half the actual depreciation cost to be borne by the taxi owner. Moreover, it is hardly fair or reasonable NOT to also support taxi owners whose taxis become 10-years old in 2021-2024, 10 years after the 10-year age limit was first announced. Surely it cannot be fair to exclude taxi owners who bought taxis in 2013 when they were not aware of the proposed 10-year limit. Furthermore the economic impact on the remaining drivers will be such that it will seriously undermine the ‘business case’ for becoming a taxi driver.

9. Savings of up to £3,000 per annum have been suggested by converting to electric hybrid vehicles (Matthew Pencharz at GLA Environment Committee on 4th December 2014). We are not aware of this calculation and would like to see these being real world savings and not just a forecast. The Osaka syndrome where taxi drivers of electric vehicles tried to conserve energy by switching off their heaters and lights demonstrates the risks of assuming savings on electric vehicles (see report in Japan Today 20/2/13). London’s taxis working in an inner city environment, using more air conditioning, heating and stop/start energy will quickly use up the battery power. Moreover plug-in charge points may well prove to be expensive due TfL’s decision to privatise London’s charging points.

10. Hybrid vehicles meeting the proposed criteria will not be widely available, if at all, by 2018 and therefore will be more expensive due to the high capital investment required by manufacturers aiming to enter the market in 2018.

11. It is estimated by TfL that approximately 30% of London’s taxis would be forced off the road in 2020 (Michelle Dix at Royal Mint Court on 25th November 2014). As the economics argument becomes more difficult to justify in the taxi driver’s own mind then there is a significant risk that there may be a substantial fall in the number of taxi drivers and taxis in London. This would jeopardise accessibility and safety on London’s streets by taking at least 7,000 taxis off the road before they could be replaced. The Mayor and TfL would do well to understand the reasons for the growing tide of protests against TfL by the taxi trade.

Disproportionate and unachievable

12. Vehicle manufacturers have been committed to support the drive towards lower emissions through investing billions in the Euro standards regime with lower emission engines, hybrid technology and light weighting of components. Both the London Taxi Company and Mercedes-Benz will be introducing Euro 6 compliant engine technology during 2015. The Euro 6 standard represents a major shift down in terms of NOx emissions, making diesel emissions equivalent to petrol engines.

13. By 2020 motor manufacturers are aiming that their new vehicles will achieve a European target of average CO2 emissions of 95g/km. Yet the TfL proposed standard of 50g/km, is nearly half that European target level and it is claimed that manufacturers will have this technology ready for January 2018.

14. Of the three manufacturers quoted by Matthew Pencharz on 4th December being capable of producing zero emission capable taxis by 2018 only one is a current manufacturer. The other two do not currently have approved production-intent taxis on the market. We understand and agree with the position that Steve McNamara of the LTDA took on this matter (see his submission to GLA Environment Committee on 4th December 2014): there is too much at risk, too much uncertainty to frame regulations based on what some vehicle designers and manufacturers may or may not be capable of achieving in 2018.

15. We also endorse the late Barry Hooper when he wrote in his last TAXI magazine article (TAXI magazine 9th December 2014. Page 10). Barry cast doubt on the effects of the zero emissions proposal for taxis and the likely outcome with the manufacturers…. “So, where are we now? Nissan is out. Mercedes long term future in the trade is uncertain, but is probably also out……….The new Metro as far as I know is not yet in production and even if it does go into production will not be available for a year or two and the price tag will be very high. That means only one thing, a return to the bad old days at M&O, or LTC as it is now known………This is all down to the Mayor. He is pinning his plan on vehicles that are simply NOT available.” The LCDC would go further: the Mayor will legislate at his peril, and ours, based on the promises made by any vehicle manufacturer. We encourage the Mayor to wait until we see the green vehicles in place before putting the taxi trade at such severe risk.

Unfair and unreasonable

16. It is unreasonable for taxi drivers that TfL has set the Euro 6 standard for coaches, vans and HGV’s, which together account for 34% of London’s emissions, but it has set the zero emissions capable standard for the taxi and private hire industry which account for a lower 22% of London emissions. The TfL reason for only applying the Euro 6 standard to coaches, vans and HGV’s is that zero emissions is not available on these forms of transport (Michelle Dix in answer to questions at ULEZ conference at Royal Mint on 25/11/14). In our view it is reasonable that the same rationale should be applied to taxis and private hire. Or, at the very least, the Mayor and TfL should not consider introducing the zero emission standard until there are vehicles in operation, meeting these standards.

17. The LCDC expects the sales of new Euro 6 taxis to fall because of the fear and uncertainty of the proposed introduction of the age limit tied to zero emission taxis. Where will this leave the manufacturers, like the London Taxi Company who claim to have invested over £10 million* in achieving the Euro 6 standard for their TX4 taxi? Without a return on the Euro 6 investment how can the main supplier hope to carry through its future investments? (* source: claim made by Dave Oriel of LTC at ULEZ meeting, TfL offices, 55 Broadway on 10th December 2014)

Euro 6 standard and the taxi duty cycle

18. The introduction of the Euro 6 standard is recognised by TfL and manufacturers as representing a major change in reducing emissions. Diesel vehicles, including taxis, which will be available from next year will considerably reduce NOx emissions to similar levels compared to petrol vehicles. Our view is that if TfL wish to have a major impact on quickly reducing emissions coming from taxis then there should be an accelerated programme of incentivising the uptake of Euro 6. The table below shows how the NOx levels of a Euro 6 diesel vehicle will be some 84% lower than the NOx levels of a Euro 3 vehicle.

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Source: SMMT see: http://www.smmt.co.uk/industry-topics/air-quality/#responsiveTabs3

19. Much has been made of the introduction of the NEDC (New European Driving Cycle) standard of testing which will be applied to new Euro 6 vehicles. This is aimed at overcoming some of the criticism of the previous testing regime because it did not reflect the real world driving. The new testing standard also includes some on road driving. However we believe that even this test is inappropriate and will not reflect the real world in London. TfL’s own road cycle for central London (ref. TfL Travel in London Report 3 fig 4.1) shows much lower speeds than the NEDC R101 test cycle, and even then a significant proportion of the area considered was outside the ULEZ. Moreover the duty cycle of London’s taxi fleet is quite different from a car or van working in London. Taxi work involves much more stopping with engine running or stop/starting (on ranks) and slow ‘trawling’ looking for work; along with acceleration and higher speeds for runs to Heathrow and Gatwick. The LCDC consulted several of its members and these drivers estimate that as much as 30% of their time is ‘dead’ mileage. Therefore it is strongly recommended that TfL understand the real taxi duty cycle and the emissions on any taxi model coming into London by developing a London taxi duty cycle. From this TfL would be able to gauge real world emissions of taxi and develop targeted standards accordingly.

Inappropriate standards

20. The distinction between petrol and diesel, where TfL intend to allow only petrol engines in new taxis from 2018, is inappropriate. Whilst we understand the arguments behind reducing the number of polluting diesels on the road, it is also recognised that the new Euro 6 diesels provide reduced NOx emissions very similar to equivalent to petrol vehicles. Also, diesel engines are inherently more efficient and produce better CO2 figures and economy per vehicle than petrol engines. See SMMT New Car CO2 Report 2014 at http://www.smmt.co.uk/wp-content/uploads/sites/2/SMMT-New-Car-CO2-Report- 2014-final1.pdf

21. 30 miles zero emission capability is specified but the type of hybrid vehicle also needs to be appropriate. Thus, parallel hybrids are more appropriate for inter-city or suburban work, with longer journeys: parallel hybrids are low range EV’s with small batteries. Whereas series hybrids can deliver longer continuous zero emissions but need larger batteries for inner city work. The disadvantage with series hybrids is that the larger batteries require more re-charging to deliver the performance target of 30 miles zero emissions, and may not be achievable when undergoing the normal taxi duty cycle.

22. The aim of achieving 50g/km CO2 emission is incompatible with the requirement to have 30 miles zero emission range. This will require vehicles to have to have substantial and heavy battery packs which will increase weight and therefore also increase the non- electric fuel consumption and CO2 emissions.

23. There is no certainty at all where geographically the 30 miles of battery powered zero emissions will take place. What if the zero emissions occur completely outside the ULEZ zone, when the taxi driver is travelling into or out of work? Unless a most technologically complicated system of geo-fencing is employed then there can be no certainty that any of the zero emissions will be in the ULEZ.

24. The NEDC is short, it allows high use of plug-in hybrid’s battery capacity. Under typical taxi mileage of 70-100 miles per day 50g/km will not be achieved. If battery use is exhausted in ULEZ then the remaining mileage will be significantly higher than 50g/km.

Summary and recommendations

25. The 10-year age limit and new more expensive taxis will be extremely damaging to the taxi trade. Even with the proposed TfL incentives many drivers may leave the trade and new drivers may opt to go to private hire. This will by definition reduce the provision of safe, accessible transport for London’s population.

26. Recommendation 1. We strongly recommend that the Mayor waits until the technology is in place and working before introducing the TfL proposals for zero emission taxis from 2018. There is a significant level of risk that no manufacturer will be able to meet the proposed zero emission requirements and at a true London taxi duty cycle. To frame policy before the technology is available and proven is not responsible. The Mayor should declare his intention to introduce the 50g/km target but only when a minimum of 2 vehicle manufacturers can demonstrate they can produce taxis to at least a volume of 1,000 each per annum. If a zero emission target is introduced then it also must be capable of being programmed so it works in the ULEZ zone.

27. Recommendation 2. TfL should encourage sales of Euro 6 diesel engine taxis as the fastest most practical way of reducing taxi emissions in London. This could be done by providing some level of purchase incentive on Euro 6 taxis.

28. Recommendation 3. The Mayor should require TfL to introduce a standard taxi duty cycle which sets the emissions testing measurement for any taxi vehicle which is introduced into London, to hit the 50g/km target or whatever target is agreed as achievable.

Taxi Licensing, Compliance and Enforcement Meeting Tracker

“The LCDC Chairman made a controversial decision last month to attend the Compliance meeting after the LTDA & Unite decided to boycott that part of the day. Someone had to explain to TfL ‘why?’ and challenge the current regime over their thinking. Here are the actions that LTPH compliance have said they will look into.

We will be following up with this and events including ‘Shine’, Old Billingsgate, RD2 and Battersea Park.

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Future proof,Taxi and Private Hire Services in London

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Click the link below to read the The London Assembly Transport Committee response and recommendations for the Taxi and Private Hire Trade.

Future Proof Taxi and Private Hire Services in London

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The LCDC welcomes the GLA report into TfL.

It raises many of the important issues that the LCDC have been raising with TfL over the past few years. If these GLA recommendations are implemented it could have a dramatic effect on ensuring the safety for the travelling public.

The Club has always believed that the Surface Implementation Programme would have disastrous consequences for our trade, the fact that only a couple of Saturdays ago there were only 4 compliance officers out for the whole of London justifies our concerns.

We believe that after many years of pressure our fears for the future are finally being recognised by others outside our industry

Grant Davis

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Transport for London Board Statement – Uber Wednesday 10 December 2014

Earlier today, Leon Daniels gave the following statement to the TfL Board with a summary of the position regarding Uber, especially following the numerous stories in the media about activities worldwide.

Uber remains a licensed PH operator in London, fulfilling the requirements as set out in private hire legislation.

There have been various stories in the media about their activities and the sanctions applied in other countries and other jurisdictions. We note all of these, but the laws in those jurisdictions are different.

In one case, it was reported that Uber had shown, at a public event, the location of a famous personality in an Uber vehicle. This we regarded very seriously as a potential breach of privacy.

We took steps to immediately look into this and Uber London Ltd gave us an absolute assurance that no data about individuals was ever released.

This week there is also a story about a case where an Uber driver in India has been arrested on a charge of rape involving a passenger in his vehicle. As far as we are aware no one has yet been convicted of any offence.

There has been a concern from the taxi trade that individuals could be licensed as drivers from countries where the current DBS checks cannot be obtained. The position regarding drivers who have recently arrived in the UK and apply for a private hire driver’s licence remains the same as before. To be licensed, and in the absence of a DBS check, a certificate of good conduct is required from the Embassy of the country of origin. This discloses any offences that have been recorded against the individual.

I should remind Board Members this is a long standing requirement which applies to all PH drivers and predates the arrival of Uber in this market. I would also repeat that all PH operators are subject to periodic compliance checks. The last check at Uber was found to be satisfactory but in common with all operators further checks will take place at a time of our choosing.

Lastly, Board Members will recall that there remains the issue of whether or not the smartphone provided by Uber to its drivers is a taximeter as defined in private hire legislation and if it is whether or not Uber private hire vehicles are unlawfully equipped with it. Whilst we have already stated that we do not think it is, we accept that the law is open to a different interpretation having been written well before the advent of such devices.

Because the law is unclear we have said that the appropriate way forward is to seek a declaration from the High Court – which of course we will enforce.

This might well have been concluded by now. However, the LTDA chose to bring a private prosecution in the Magistrates’ Court against a small number of Uber drivers on the taximeter issue. The High Court does not have jurisdiction to consider applications for a declaration whilst there are on-going prosecutions in the criminal courts in relation to the same legal issue. Recently the Magistrate dealing with the prosecutions concluded that the matter was rightly the province of the High Court.

However, the LTDA did not agree to withdraw the criminal summonses and the case was adjourned indefinitely to allow us to pursue our application to the High Court.

However, since the criminal case remains outstanding, we are of the view that the High Court will still not accept an application for a declaration as we would wish.

For this reason we have written to the LTDA asking them to withdraw their criminal summonses. Unless and until they do so, we will remain in a position where the very concerns of the taxi trade that we are trying to resolve cannot be progressed because of the actions of the LTDA..

Taxi Liaison Meeting 26/9/14 LCDC Report

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Transport for London (TfL) and Heathrow Ltd (HAL) confirmed that the Taxi Feeder Park charge was to remain in place and drivers could still apply the Extra after the TfL Surface Transport Panel meeting that took place on the day of the demo.

Next item on the Agenda was a FINANCIAL REVIEW from HAL regarding detailed figures for the Taxi Feeder Park and contributions to the various bodies that operate at Heathrow including the Police.

HAL informed the Trade that genuine cost savings had been made giving efficiency savings of about £250,000. Costs that are normally recovered from the Cab Trade amount to over £2 million; this has been reduced to £1.8m

Consequently the current £5.22 Entry charge will reduce to £3.54 or £3.18, but a deal has been offered to make that £3.38 for 24 months until a review in September 2016. The new charge will apply from January 1st 2015.

The Trade were told the Allocated Costs include Policing and Support Services and promised more information. Annual Total Policing Costs at Heathrow amount to £36.8 million.

Information on how much money Heathrow Police receive from the Taxi Trade is currently not available from either HAL or the Police. The facts of the matter are being investigated by the LCDC. According to HAL, policing costs are lumped together with costs relating to the provision and management of the Taxi Feeder Park.

Reps asked that a refund for ‘Blowing Out’ at night be looked at again after the projections for next year were made. Previously the Trade had been told an additional fee of 17p would be incurred for the software change necessary but this will now be looked at after it was revealed the fee to enter the Feeder Park will drop substantially.

There followed a brief report on TOUTING/ENFORCEMENT by the Police who were heavily criticised by Taxi reps for failing to use the bye-laws to stop minicabs from picking up from the Set Down points on the passenger terminals. The Police were unable to explain why they were failing to deal with this major problem. Cab Enforcement will be challenging PH/Taxi Drivers for Badges and Bills on Ranks and in Terminals.

The Trade were informed that there are only four officers in the Tout Squad. This is obviously under resourced even when backed up by TPCSO’s.

However, the Police were able to hold another successful operation involving local Council and Immigration Officers which they hope to repeat every 6 weeks. 485 Drivers were stopped and checked during the operation.

It was suggested by Reps that using Automatic Number Plate Recognition (ANPR) Cameras, be employed to monitor forecourts more effectively as the congestion is horrendous at times, particularly Terminal 4 at night on Weekends.

In their report, APCOA said they had now reached a full complement of staff: there are 37 Rank Agents of which 22 are Experienced Staff. However, there are still too many incidents like this one on Terminal 2 last weekend where customers queued to get into Taxis whilst Cabs queued to reach customers!

The Meeting overran its allocated slot but there were additional initial discussions on a BUSINESS PROPOSAL which included a DISCIPLINARY SCHEME or CODE OF CONDUCT with TERMS & CONDITIONS.

The LCDC emphasised the need for the trade to ensure that any plans to weed out the few bad drivers at Heathrow would not include putting them on trial at a kangeroo court.

This followed on from questions which were asked about the source of HAL’s authority to suspend a driver in order to produce a workable scheme.

Taxi Trade Reps would be interested to hear Drivers opinions which can be sent to:

feederparkinfo@gmail.com

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Mercedes Benz statement RE KPM-UK Taxis PLC

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KPM-UK Taxis PLC Statement

Mercedes-Benz Vans has removed the Taxi franchise from KPM-UK Taxis PLC, based in East London.

We are working hard to ensure our customers are supported during this time and all existing workshop bookings and customer vehicle deliveries are being distributed among local Mercedes-Benz Commercial Vehicle Dealerships.

We are contacting all customers affected by the removal of the franchise from KPM-UK Taxis PLC.

If customers are concerned, they can contact Mercedes-Benz customer service via cs.uk@cac.mercedes-benz.
com or call 00800 9777 7777 or 0207 660 9993.

Ends

The Mercedes-Benz Commercial Vehicle Dealers with a full knowledge and broad experience of the Vito Taxi are:

· Mercedes-Benz of Brentford LCV 0208 560 2151
· Mercedes-Benz of Croydon 0208 665 4540
· Mercedes-Benz of Park Royal 0208 896 1565
· Mercedes-Benz of Stratford 0208 221 4460
· Orwell Truck & Van Colchester 01206 751 550
· Rossetts Commercials Crawley 01293 652 560
· Rygor Commercials Heathrow 0208 890 8907
· S&B Commercials Stansted 01279 712 200
· S&B Commercials Welham Green 01707 261 111
· S&B Commercials West Thurrock 01708 892 500
· SG Smith Croydon 0208 665 7800
· SG Smith Sydenham 0208 659 3636
· Sparshatts of Kent Ltd (Ashford) 01233 610 400
· Sparshatts of Kent Ltd (Dartford) 01322 520 030
· Sparshatts of Kent Ltd (Sittingbourne) 01795 479 571
· Sparshatts of Kent Ltd (Tonbridge) 01732 370 920

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