stumbled across this whilst surfing,have searched the site for maqs no results,so i thought to post,report states consultation to finish 18/07/11 which would tie in with rainycityripoff claim of an announcement on the 19/07/11,yes i know its TFL but..........
Transport for London
London Taxi and Private Hire
Exemptions to age-based limits - Consultation
23 May – 18 July 2011
SUPPLEMENTARY INFORMATION
Contents
1. Introduction and purpose of this document .......................................................... 2
2. The Mayor’s Air Quality Strategy and age-based limits for taxis and PHVs......... 2
3. The licensing and inspection regime for taxis and private hire vehicles, and the introduction of age-based limits and emissions standards ......................................... 3
4. The proposed exemptions ................................................................................... 5
5. Rationale for and application of proposed exemptions ........................................ 7
6. Operational issues ............................................................................................. 12
7. Euro standards .................................................................................................. 13
8. Impacts of the proposals .................................................................................... 15
9. Review and monitoring of the policy .................................................................. 16
10. Decision-making and implementation timetable ............................................. 16
11. Responding to the consultation ...................................................................... 16
12. Appendix 1: Table of age-based limits, emissions standards and proposed exemptions ............................................................................................................... 17
1.
Introduction and purpose of this document
This document sets out proposed exemptions to the age-based limits for taxis and PHVs, which will come into operation on 1 January 2012. These were put in place by the Mayor’s Air Quality Strategy (MAQS) in December 2010 following public and stakeholder consultation.
The MAQS sets out age-based limits and emissions standards, and states that there may be special exemptions to them for particular vehicle groups (para 3.10.4), which would be implemented via the taxi and Private Hire Vehicle (PHV) licensing regimes, and would be consulted on with the trade. This consultation document sets out the proposed exemptions (including time extensions and “grandfather rights” where vehicles have had approved conversions) and describes how they have been developed. The age-based limits and related emissions standards introduced by the MAQS are not themselves subject to further consultation but some information has been provided on them here in order to give context to the proposed exemptions.
Since the publication of the MAQS, there have been a number of enquiries and suggestions made to TfL and the Mayor regarding the nature of these exemptions. These have been considered in developing the proposals set out here.
To avoid undermining the purpose of the limits and standards set out in the MAQS, and to make them workable, it is envisaged that any approved exemptions would need to be tightly-defined and apply to a relatively small number of vehicles. They would also need to be capable of being integrated within the current vehicle licensing regime.
2.
The Mayor’s Air Quality Strategy and age-based limits for taxis and PHVs
The Mayors Air Quality Strategy (MAQS) for London was published on 14 December 2010. It was preceded by an extensive period of public consultation, during which comments were invited from stakeholders, including the taxi and PHV trade. The strategy sets out a wide range of measures for improving air quality by reducing air pollution emissions, including emissions from transport. The principal air pollutants considered are particulate matter (PM) and oxides of nitrogen (NOx)1. The strategy includes actions that need to be taken by other organisations such as the Government and the EU as well as by the Mayor and TfL.
Policy 4 of the MAQS, ‘Reducing emissions from public transport’ sets out proposals for buses, taxis, PHVs, rail and river transport, and for GLA, borough and public sector fleets. One of these is the introduction of age limits and emissions standards for taxis and PHVs. The relevant standards for this consultation are summarised below:
1 NOx is made up of nitric oxide (NO) and nitrogen dioxide (NO2). NO easily converts to NO2 in the air so to reduce concentrations of NO2 it is important to control emissions of NOx. The EU limit value applies to NO2.
2
•
From 1st January 2012, no licence will be issued for a taxi over 15 years old.
•
From April 2012, all taxis new or new to licensing are to meet a minimum Euro 5 emissions standard.
•
From 1st January 2012, no licence will be issued to a PHV over 10 years old.
•
From April 2012, all PHV’s new or new to licensing are to meet a minimum Euro 4 emissions standard and to be 5 years old or newer.
The aims of this approach are to promote the use of newer, cleaner vehicles in both vehicle sectors; improving London’s air quality and environment and providing improved safety and passenger amenity benefits derived from the use of more modern vehicles. The MAQs sets out that these limits will be implemented via the taxi and PHV licensing regimes.
There are a number of other initiatives set out in the MAQS to improve the environmental performance of taxis and PHVs such as the age-based and emissions limits connected to this consultation, eco-driving and supporting the development of new technologies. The Mayor is collaborating with the taxi manufacturing industry to develop an affordable taxi capable of zero-emission operation by 2020 and to ensure that all new taxis available by 2015 have 60 per cent improved fuel economy compared to current vehicles. The Mayor has also announced the establishment of a financial incentive scheme that will offer a reduction on the purchase price of qualifying low emission vehicles to London’s taxi drivers.
A full copy of the MAQS, an Executive Summary and other related documents, including the GLA’s response to comments received during the consultation, are available online:
http://www.london.gov.uk/air-quality/links
3.
The licensing and inspection regime for taxis and private hire vehicles, and the introduction of age-based limits and emissions standards
The age-based limits and emissions standards put in place by the MAQS will be implemented via the existing regimes for taxi and PHV inspection and re-licensing (licence renewals). Any exemptions would also be implemented in this way. London Taxi and Private Hire (TPH) is the directorate within TfL that manages the licensing regime for both taxis and PHVs.
In this context, it may be useful to reiterate the legal and operational context for taxi and PHV licensing in London, and how changes to the current regime are put in place.
The legislation with regard to TfL’s ability to license vehicles as taxis in London is set out in the Metropolitan Public Carriage Act 1869 (MCA). Under the Cab Order 1934,
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TfL can specify Conditions of Fitness for taxis. These, and the relevant Inspection Manual, are used in the inspection and (re) licensing of taxis.
Private Hire Vehicles (PHVs) in London are licensed under the Private Hire Vehicles (London) Act 1998. This legislation enables TfL to prescribe regulations with regard to the vehicles licensed. The PHV regulations, and the relevant Inspection Manual, are used in the inspection and (re) licensing of PHVs.
Owners of both taxis and PHVs are required to apply for a licence from TfL before the vehicle can be used for taxi or private hire work in London. They must fulfil the criteria set out in the Conditions of Fitness (CoF) for taxis, and the vehicle regulations (for PHVs). Subsequent to this, an annual re-licensing process applies. For taxis this is a combined mechanical and licensing inspection, reflected in the taxi inspection manual2. For PHVs this is two MOTs per annum plus a PHV licensing inspection, as described in the PHV inspection manual.
The Conditions of Fitness, the relevant Inspection Manuals and the PHV regulations will be issued in an updated form later in 2011. (These documents are not part of this consultation.) The updates will reflect both the age-based limits and emissions standards brought in by the MAQS. These will be available on the TPH section of TfL’s website.
The exemptions from those age limits, which this consultation is about, will be confirmed by the Director of TPH by means of publication of a TPH notice, once he has considered all the responses received, and all other relevant matters.
TPH keeps taxi and PHV stakeholders informed of changes to regulations, as well as other relevant news and information, via TPH notices, which are posted on its section of the TfL website and sent to vehicle operators. At the start of this consultation, a TPH notice was sent out. A further TPH notice will be sent out when the decision on the exemptions has been taken.
Prior to this, at the start of May 2011, TPH Notice 05/11 announced the introduction of age-based limits and emissions standards and provided an email address for queries. Attached to the Notice was a poster setting out the changes, which PHV operators were asked to display in places where their drivers would see them. This notice was also put on the website for download.
TPH has also identified from its records those PHV drivers whose vehicles may not comply with the new age-based limits and will write to them to alert them to the forthcoming changes.
2 It is planned to replace this with two MOTs per annum plus a basic annual taxi-related inspection, by April 2013
4
4.
The proposed exemptions
It is proposed that a limited number of exemptions are applied in respect of the age-based and emissions limits subject to stated conditions and requirements. Some of these are pure exemptions (where the vehicle is not subject to the age-based limit) and others take the form of ‘grandfather rights’ (for certain older vehicles) or time extensions – the age-based limit will still apply, but it is extended for an additional period of time (for example, a 5 year extension to the 15 year age limit). These are maximum, one-off time extensions to the normal age limit and any extension granted is always subject to normal annual taxi and PHV licensing and enforcement requirements. The proposed time extensions would mean that the age-based limits would need to be met by 2017.
This section sets out the proposed exemptions for taxis, followed by those proposed for PHVs. For reference, the age-based limits and emissions standards and the proposed exemptions are set out together in Appendix 1.
Taxis
It is proposed to extend the normal 15 year age limit by up to 5 years for taxis which have been converted to use approved alternative fuels – LPG, CNG and biomethane – or (looking to the future) which are electric vehicles or plug-in series or parallel electric vehicles.
For taxis with approved conversions to alternative fuels, the proposed extensions are linked to the date of first licensing with TPH and the date of conversion:
Date of first licensing with TPH
Criteria for proposed exemption
Licensed before implementation date of 1 Jan 2012
If approved & converted before 1/1/12, additional 5 years on 15-year rolling age limit
If approved & converted on or after 1/1/12 and meets full emissions standards for Euro 5, additional 5 years on 15-year rolling age limit
Licensed on or after 1/1/2012 and before 1/4/2012
If approved & converted on or after 1/1/12 and meets full emissions standards for Euro 5, additional 5 years on 15-year rolling age limit
Licensed on or after 1/4/2012.
If approved & converted on or after 1/1/12 and meets full emissions standards for Euro 5, additional 5 years on 15-year rolling age limit
5
PHVs
For PHVS, it is also proposed to offer time extensions for certain conversions to alternative fuels. In addition it is proposed to give exemptions for historic and classic/niche vehicles; time extensions for Wheelchair Accessible Vehicles (WAVs) and for Specialist Needs Transport (SNT). Finally, it is proposed to offer a time extension to any PHV in scope for the London Low Emission Zone (LEZ).
Alternative fuels
It is proposed to offer additional time for compliance for PHVs which have been converted to use approved alternative fuels – LPG, CNG and biomethane. Looking to future developments, electric and plug-in or parallel series hybrid electric vehicles will also come within this category of exemption.
For PHVs with approved conversions to alternative fuels, the proposed extension is as follows:
•
For PHVs first licensed before 1 January 2012, an additional 5 years on the 10-year rolling age limit will be permitted if they meet Euro 3
Historic and classic/niche vehicles
It is proposed to exempt all normally qualifying historic and classic/niche PHVs.
Wheelchair Accessible Vehicles (WAVs) and Specialist Needs Transport (SNT)
The proposed time extensions are linked to date of first licensing with TPH:
•
For WAVs and SNTs licensed before 1 January 2012, it is proposed to allow an additional 5 years on the 10-year rolling age limit
•
For WAVs and SNTs licensed on or after 1 January 2012 but before 1 April 2012, it is proposed to allow an additional 5 years on the 5-year age limit at first licensing; subsequently an additional 5 years on the 10-year rolling age limit
•
For WAVs and SNTs licensed on or after 1 April 2012, it is proposed to allow an additional 5 years on the 5-year age limit at first licensing; subsequently an additional 5 years on the 10-year rolling age limit provided (in both cases) vehicles meet Euro 4.
London Low Emission Zone (LEZ)
It is proposed that PHVs which are in scope for the London Low Emission Zone (LEZ) be given a time extension from the age-based limits and emissions standards
6
put in place by the MAQS. They will, however, remain subject to the emissions standards put in place by LEZ.
It should be noted that from 3 January 2012 more vehicles are brought into scope for LEZ: including larger vans, minibuses and specialist diesel vehicles. The PHVs most likely to be affected from 2012 here are larger vehicles, some of which may be adapted for specialist uses. Taxis are not affected by LEZ.
Please refer to the dedicated section of the TfL website for more information on LEZ
www.tfl.gov.uk/lezlondon
5.
Rationale for and application of proposed exemptions
The proposed exemptions set out in Section 4 are intended to take into account the concerns of taxi and private hire trade associations and individual drivers as expressed in the MAQS consultation and in subsequent contact with TPH. They are also designed to reflect the fact that some operators will have already made an investment in their vehicle to either reduce its air pollution emissions, or to enable that vehicle to be wheelchair-accessible or be available to the Specialist Needs market. It is recognised that these operators need some opportunity to recoup their investment, and so an extension to the normal time limit is proposed. In addition, a small number of operators use classic or niche vehicles as part of their trade and without an exemption to the age-based limits this type of business would not be viable.
However, it is also important that all taxis and PHVs make a contribution to improving air quality in London, and the age-based limits and emissions standards remain an important way to achieve this. For this reason, the proposed exemptions usually take the form of a time extension rather than an indefinite exemption. The approach of implementing both the new standards, and any exemptions which are confirmed, via the existing TPH licensing regime will help to minimise any additional bureaucracy and compliance cost to operators.
In this way it is intended to achieve a balance between the need for taxis and PHVs to play their part in reducing air pollution emissions and the need for requirements to be cost-effective and workable. It is also important that the quality of the fleet overall is maintained and putting in place a requirement to replace older vehicles – albeit more gradually – will help to maintain the safety and amenity provided to drivers and passengers.
The number and type of exemptions proposed here is in part determined by the nature of the taxi and PHV markets. Since taxis are purpose-built, there is no need to propose an exemption for historic or classic/niche vehicles, or for Specialist Needs Transport. Nor is it appropriate to offer exemptions for wheelchair-accessible taxis, given that this is already one of the conditions of licensing. In contrast, vehicles used
7
in the PHV trade are diverse, and the exemptions proposed take account of the range of vehicles in operation.
The remainder of this section describes the rationale for the proposed exemptions, considering each in turn.
Alternative fuels
The use of alternative fuels can have benefits in terms of reduced air pollution emissions, compared to conventional fuels. The proposed time extensions set out in Section 4 above are made in recognition of the financial investment made by vehicle owners using alternative fuels, and the associated reductions in PM and NOx emissions from these vehicles. At present, the number of these vehicles licensed in London is small, around 23 taxis and 83 PHVs.
Time extensions are proposed for both taxis and PHVs, although the exemption criteria differ, due to the different vehicle types used in the two fleets. The exemptions have been developed with regard to the wider range of alternative fuel options available for PHVs, the relative costs of replacement for PHVs and taxis, and the feasibility of implementing the proposed exemptions within the existing licensing regime. The rationale for the proposed alternative fuel time extension is set out for taxis and PHVs separately below.
Taxis using an alternative fuel must have had a conversion post-manufacture. This conversion usually involves a significant cost. There are currently no manufactured alternative-fuel taxis, although the MAQS sets out the Mayor’s ambition to encourage the development of these in future.
The PHV fleet is comprises a much wider range of vehicle types than that for taxis. As such, PHVs using an alternative fuel may be manufactured as such, or a conventional engine may be converted after manufacture. PHV operators have a much wider range of vehicles to choose from and have a greater opportunity to choose an alternative fuelled vehicle, rather than have to pay for a conversion (although this is still an option). Nevertheless, there is still a cost incurred in either choosing or converting to an alternatively-fuelled PHV, and this is recognised in the proposals. It is also important not to penalise taxi and PHV operators who have taken the initiative to improve the air pollution emissions of their vehicles in advance of the introduction of the MAQS standards.
For both taxis and PHVs there would be a requirement to demonstrate reduced emissions from the conversion.
In most cases alternative fuel taxis and PHVs use Liquid Petroleum Gas (LPG), although a few Compressed Natural Gas (CNG) vehicles are registered. TPH already notes these alternative fuel types at annual inspection. It is proposed that the time extensions would be available to LPG, CNG and biomethane vehicles, provided that the relevant European emissions standards (Euro standards) are met.
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Anticipating future technological advances the additional time would also, in principle, be available to taxis and PHVs that were electric vehicles and plug-in hybrid electric vehicles, although in practice this would only apply to PHVs, and none are licensed or available at present. In principle, this would also apply to taxis, should taxis of this type become available and licensed in future.
A vehicle conversion to the above alternative fuel types can be verified at the annual inspection, and there is assurance that this alternative fuel continues to be used throughout the year. In contrast, other alternative fuels such as bioethanol and biodiesel can be alternated with conventional fuels, and their continued use cannot be assured beyond point of inspection. In addition, it is considered that there is insufficient evidence on their benefits to air quality. For this reason, no exemption is proposed for other types of alternative fuel and the proposed time extension is limited to LPG, CNG and biomethane.
No time extension or exemption is proposed for hybrid vehicles (in practice, only relevant for PHVs) which are not plug-in hybrid electric vehicles. Although these vehicles will often have reduced air pollution emissions compared to conventional engines/fuel types, there are a wide range of vehicles and modifications/conversion that could potentially be described as hybrid, and it is not feasible to assess and be assured of all these types using the existing PHV inspection regime. Non plug-in hybrid electric PHVs first licensed before 1 January 2012 will be subject to the 10-year rolling age limit (unless other exemptions apply). Operators who plan to apply to license vehicles on or after this date will be subject to the 5 year age limit at first licensing and then 10 years subsequently. By the time the standards come into effect in January 2012, operators will have had sufficient notice of the introduction of the age-based limits.
Alternative fuel taxis: Euro standards requirements
Taxis first licensed before 1 January 2012 and approved and converted before this date, will still be required to meet Euro 3 for PM and NOx, regardless of the new standards introduced by MAQS.
Alternative fuel taxis licensed before 1 January 2012 but approved or converted on or after that date will need to demonstrate compliance with Euro 5 in order to qualify for the 5 year extension to the rolling 15-year age limit. The meaning of compliance with Euro 5 here means meeting the limits for all the air pollutant emissions in the standard. This is considered reasonable given that an operator would have had sufficient notice of the decision to implement standards announced in the MAQS in December 2010. The operator would need to provide evidence of compliance with Euro 5 to TPH in order to be eligible for this additional 5 years. Alternative fuel taxis which do not demonstrate full compliance with Euro 5 will not qualify for an extension and will be subject to the normal 15-year age limit. Please see the tables in Section 7 below which set out the emissions standards for relevant Euro standards.
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Taxis licensed on or after 1 January 2012, and approved and converted on or after this date, must be fitted with an engine certified as, and fully compliant with the Euro 5 emissions standard which becomes mandatory for this class of vehicle on 1 January 2012, as per EU regulation 715/2007. Alternative fuel taxis which are not certified and compliant with all the requirements of Euro 5 will not qualify for an extension and will be subject to the normal 15-year rolling age limit.
Alternative fuel PHVs: Euro standards requirements
It is proposed that alternative fuel PHVs licensed before 1 January 2012 and approved and converted before this date should have a 5 year extension to the normal 10-year rolling age limit. This is in recognition of the costs incurred in either converting the vehicle or choosing an alternatively-fuelled vehicle.
No extension to the normal rolling 10 year age limit is proposed for alternative fuel PHVs licensed after 1 January 2012 and/or approved and converted on or after this date.
In the same way as for taxis, the proposed exemption is in recognition of the costs incurred, and the fact that some operators have chosen to improve the air pollution emissions of their vehicle in advance of the MAQS standards. However, there is a wider range of vehicles which can be used as PHVs compared to taxis, and therefore the costs of either choosing an alternative fuel vehicle or converting a conventional engine, are relatively lower. Regardless of fuel type, PHVs may be replaced at a lower cost than taxis, and in general the PHV fleet is younger and more often replaced than that for taxis. For these reasons, and because operators will have had sufficient notice of the introduction of age-based limits, it is not proposed to offer additional compliance time to PHVs licensed on or after January 2012 and/or approved and converted on or after this date.
Abatement equipment to meet Euro standards (both taxis and PHVs)
Fitting abatement equipment to a vehicle can reduce its emissions and may ensure compliance with the relevant Euro standard.
At present there is no evidence that any effective abatement system is available to enable otherwise non-compliant vehicles to be converted to meet relevant Euro 4 or Euro 5 emissions standards for both NOx and PM. Notwithstanding the current position, TPH will consider any abatement equipment system presented for inspection and testing with a view to establishing to TPH’s satisfaction whether it would permit a vehicle to be converted and credibly maintained to the relevant Euro emissions standard. In the event that this can be established consideration will be given, on case by case individual vehicle basis, as to whether it would be appropriate to grant that vehicle an extension to the normally applicable age limit and what the period of any extension would be. The granting of any such extension will be subject to other normal licensing considerations and requirements.
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The classification of historic, classic and niche vehicles already exists and is assessed annually by TPH as part of re-licensing, as well as at first licensing. A historic vehicle is one manufactured before 1 January 1973 (as per DVLA definition). TPH has criteria to determine classic and niche vehicles which are applied at licensing. Vehicles recognised as being in one or more of these categories will be exempted from the age-based limits and emissions standards applied by the MAQS.
Historic vehicles (and some classic/niche vehicles) were manufactured prior to the introduction of Euro standards. While in some cases it may be possible to fit equipment which may ensure compliance, this is thought to be generally unlikely, and an undue burden. For some classic and niche vehicles, their age and character is the main selling point of their business. Without the proposed exemption, these vehicles would not be able to operate as PHVs. In all cases – historic, classic and niche, a relatively small number of vehicles would be affected by the proposed exemption. TfL reserves the right to review this category of exemption if the numbers of vehicles affected increase significantly.
Wheelchair Accessible Vehicles (WAVs)
WAVs are identified as such at licensing / re-licensing. It is considered appropriate to provide a time extension for these vehicles because they fulfil an important social role and will have been specially-constructed or converted in order to carry wheelchairs, which incurs a significant cost. In addition, the numbers of vehicles affected are relatively small. That said, it is considered important that these vehicles are encouraged to improve their level of emissions, and for this reason it is proposed that these vehicles are given additional time to comply with the age-based limits, rather than a complete exemption. In addition, WAVs licensed on or after 1 April 2012 must meet Euro 4 standard. It is considered reasonable that vehicles new to the fleet meet the emissions standard, which was confirmed in December 2010, giving operators sufficient notice of this requirement.
Specialist Needs Transport (SNT)
This classification will be determined at licensing/ relicensing. Operators with these vehicles generally work under contract from local authorities, health care trusts and educational authorities. These vehicles are adapted to carry passengers with particular needs and are typically larger type vehicles.
If the vehicle has been adapted to perform work of a specialised purpose, TfL may have to assess exemption on a case-by-case basis. Evidence confirming a contract with an appropriate authority or other agency to provide this service may be required at point of licensing. The proposal to allow additional compliance time for SNTs follows the same principal as for WAVs. This includes the requirement for vehicles licensed after 1 April 2012 to be Euro 4 at point of licensing.
It should be noted that certain SNT PHVs will fall under the requirements of the Low Emission Zone, however it is proposed that these are eligible for an additional 5 years on the age-based limit (see below).
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The London Low Emission Zone (LEZ)
It is proposed to offer a further 5 years’ compliance time for PHVs licensed before 1 April 2012 which are within scope of the LEZ. Vehicles which are likely to be in scope for LEZ from January 2012 are heavier vehicles – larger vans, minibuses and some specialist diesel vehicles. For PHVs, this may include certain vehicles which have been specially converted to carry wheelchairs or as Specialist Needs transport. These conversions can incur significant cost. The proposed time extension is in order to avoid these operators having to comply with two sets of standards, which would be excessively onerous. In practice a very small number of vehicles would be affected.
The London Low Emission Zone (LEZ) contributes to improved air quality and associated health benefits by discouraging the most individually polluting heavy diesel vehicles from operating in Greater London. It operates 24 hours a day, 365 days a year and sets minimum emissions standards that vehicles are required to meet in order to drive within the zone without paying a substantial daily charge. The first phases were introduced in 2008 and require lorries, buses and coaches to meet a Euro 3 standard for PM emissions. From 3 January 2012, larger vans, minibuses and other specialist diesel vehicles will be required to meet the Euro 3 standard for PM emissions and the standard for lorries, buses and coaches will be tightened to Euro 4 for PM emissions. Cars and taxis are not included in the LEZ.
Some PHVs fall into the vehicle classes to be covered by the LEZ from January 2012. These are typically conversions of vans or minibuses, sometimes to produce WAVs or vehicles for providing Special Needs Transport but in some cases to serve a specialised market that would not fall under one of the other definitions. To allow the owners and operators of these vehicles to recover the costs associated with conversion and LEZ compliance, it is proposed that there should be additional compliance time to meet the age limits and emissions standards. This additional time would be the same as that proposed for SNT vehicles. PHVs which come in scope for LEZ and which are licensed on or after 1 April 2012 will be required to meet Euro 4 standard at point of licensing.
Vans and minibuses under 10 years old (at 1 Jan 2012) will, as a matter of course, meet the requirements put in place by LEZ in January 2012: Euro 3 for particulate matter, and so no particular exemption to the age-based limits is required.
6.
Operational issues
The implementation of both the age-based limits and emissions standards put in place by the MAQS, and any of the proposed exemptions which are confirmed following this consultation, will be via the existing TPH mechanisms for annual inspection and re-licensing of taxis and PHVs. It may be useful to set out here some additional definitions, to aid understanding of how these will work in practice.
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TPH will inform the taxi and PHV trade of any changes to licensing via TPH notices and other communications, as is usual practice.
Date from which age of vehicle is calculated
Both the age-based limits and emissions standards put in place by the MAQS, and the proposed exemptions (exemptions, time extensions and grandfather rights) refer to the date of licensing and/or the age of vehicle. For these purposes a vehicle’s age will normally be based on the date at which the vehicle was first registered with the DVLA. In exceptional circumstances, TPH may allow this to be determined by the date of manufacture, subject to a case for doing so and the presentation of acceptable documentation.
Date of first licensing (newly-licensed)
In this document the date of licensing means the date of first licensing with TPH. Vehicles may have been licensed outside London prior to this.
Annual re-licensing and the rolling age-limits
The rolling age limits – and additional years for which the vehicle is eligible – will be applied at the point of vehicle licensing and re-licensing or licence renewal (the vehicle’s ‘birthday’).
Lapses in licensing
Occasionally, an operator may choose not to apply for re-licensing (licence renewal) at every licensing birthday. In order to still remain eligible for the proposed exemptions, re-licensing or renewal would need to take place within 3 months of the date the license lapsed.
Further information
Please refer to the relevant documents for further information regarding licensing. For taxis this will include the Conditions of Fitness, the Inspection Manual. For PHVs this will be the vehicle regulations and Inspection Manual. As described in Section 3 above, updated versions of these will be issued later in 2011.
7.
Euro standards
As set out in the Conditions of Fitness, new taxi models, or currently approved taxi models which are new to licensing in London, must meet the current and relevant EC Directive for exhaust emissions ( i.e. the current respective Euro standard) as notified by TPH from time to time by means of a TPH notice. Taxi models approved and licensed in London prior to October 2006 must meet prescribed Euro 3 emissions standards for NOx and PM.
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The new standards put in place by the MAQS include a Euro 3 and Euro 5 standard for taxis and a Euro 4 standard for PHVs licensed on or after 1 Jan 2012.
The proposed exemptions also, in some cases, require the vehicle to comply with specified Euro standards. These are set out in full in Appendix 1. In summary, Euro 5 for taxis, and Euro 3 and Euro 4 for PHVs are relevant here.
The European emissions standards (‘Euro standards’) define the acceptable limits for exhaust emissions of a range of pollutants from new vehicles sold in the EU. There are different requirements for different vehicle categories and each standard is progressively more stringent than the previous standard. As soon as each standard comes into force, EU Member States must refuse the approval, registration, sale and introduction of vehicles that do not comply with the emissions limits. An additional specified period of time is allowed for the registration and sale of new vehicles.
The legislation for Euro 3 and Euro 4 is EU directive 70/220 EC amended with 98/69/EC and further amended by 2002/80/EC. The most recent standards, Euro 5 and 6 are now enacted through European Council Regulation 715 / 2007. Although the name of the Euro standard is the same, the actual emissions limits vary by class of vehicle.
With regard to Euro standards, taxis are usually treated as N1 vehicles. Most PHVs will be classified and treated as M1 vehicles, on the basis that they are passenger cars, although some larger PHVs may be in other vehicle classes. The tables below set out the emissions limits (grammes/km as measured on NEDC3 test cycle) for the Euro standards that are relevant to the proposed exemptions.
Note that newly-manufactured taxis from 1 January 2012 will meet Euro 5, ahead of the introduction of the emissions standard introduced by the MAQS.
Taxis (Euro 5)
N1 class 3 limits
CO
HC
HC+NOx
NOx
PM
Diesel engine
0.74
-
0.350
0.280
0.005
LPG
2.27
0.16
0.082
0.005
PHV Euro 4 (assuming based upon passenger cars)
M1 car limits
CO
HC
HC+NOx
NOx
PM
Diesel engine
0.5
-
0.30
0.25
0.025
3 New European Driving Cycle 14
Petrol Engine
1.0
0.1
-
0.08
-
LPG
1.0
0.1
-
0.08
-
PHV Euro 3 (assuming based upon passenger cars)
M1 car limits
CO
HC
HC+NOx
NOx
PM
Diesel engine
0.64
-
0.56
0.50
0.05
Petrol Engine
2.30
0.20
-
0.15
-
LPG
2.30
0.20
-
0.15
-
8.
Impacts of the proposals
It is expected that, in the fleet projected for 2012, around 1,200 taxis and around 4,000 PHVs would be affected by the age-based limits and emissions standards introduced by the MAQS. The projected fleet in total at that time would comprise 22,000 taxis and 49,000 PHVs (all figures are rounded). The exemptions proposed within this document would apply to a relatively small number of vehicles which would be affected by the MAQS standards. These figures, and the assessment set out below, formed part of the MAQS consultation and are not part of the present consultation on exemptions.
Assessment of impacts
An Integrated Impact Assessment4 (IIA) of the proposals contained in the draft MAQS was published for the public consultation on the draft strategy in summer 2010. Following the confirmation of the MAQS in December 2010, a Post-Adoption Statement (PAS) to the IIA was also published.
The IIA included an assessment of Policy 4, noting that the proposals would “encourage and accelerate the introduction and use of cleaner vehicles. These will generally reduce emissions of CO2 and reduce noise pollution, as well as creating business opportunities.” It also noted that the vehicles covered by the proposals “do large mileages in busy areas, so reducing emissions from a small number of vehicles can have disproportionate benefits.” The IIA assessed proposals against 15 objectives, and for the Air Quality objective assessed Policy 4 as ‘++ policy very good for this objective.’
4 Integrated Impact Assessment of Clearing the Air: The Mayor of London’s draft
air quality strategy. Levett-Therivel Sustainability Consultants with Ben Cave Associates,
Zahno Rao Associates, University of Huddersfield
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The IIA and the PAS are available online:
http://www.london.gov.uk/air-quality/links
9.
Review and monitoring of the policy
The MAQS states that the impact of the age limits and approved exemptions to them, will be monitored and may be subject to review in the future (see Policy 4). It is envisaged that TPH would undertake this monitoring as part of its ongoing appraisal of the fleet. If a review were to result in a proposal to change the age-based limits, the emissions standards or such exemptions to these as may be approved following this consultation, there would be discussion with the taxi and PHV trades. It is envisaged that any further changes would be reflected in the Conditions of Fitness and the PHV licensing regulations, and be announced via a TPH notice.
10.
Decision-making and implementation timetable
Responses to this consultation will be considered by the Director of TPH. His decision on the approved exemptions from the age-based limits will be announced later in 2011 following consideration of the responses to this consultation and any other relevant considerations. That decision will be disseminated via a TPH notice which will set out the exceptions to the normal age-based limits for taxis and PHVs that will then apply, together with any related conditions or other requirements.
11.
Responding to the consultation
The proposals for exemptions set out in Section 4 of this document are subject to consultation from 23 May to 18 July 2011. Responses should be addressed to the Director of Taxis and Private Hire, and may be made by email or post as follows:
By email:
tph.consultation@tfl.gov.uk
By post:
John Mason
Taxi and Private Hire
Transport for London
4th Floor Yellow
Palestra
197 Blackfriars Road
London, SE1 8NJ
The consultation questions:
•
Are the proposed exemptions the correct ones?
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•
Do you feel any additional exemptions are required?
•
If so, what are these and why?
•
Do you agree with the proposed definition of vehicle age for the purposes of the age-based limits (normally calculated from date of first registration with the DVLA)?
•
Do you agree with the proposed date of 1 January 2012 as the cut-off point for ‘grandfather rights’ where vehicles have had approved conversions?
You may suggest other categories of exemption or comment on the material contained in this document.
12.
Appendix 1: Table of age-based limits, emissions standards and proposed exemptions
Please see next page
Taxi & PHV Exemptions - ConsultationAge-based limitEmissions StandardProposed exemptions Implementation dateMaximum rolling age-based limit (2)Minimum Emissions Standard (Euro Standard)Alternative fuel Historic vehicle (6) and classic/niche (7)Wheelchair-accessible vehicles (8)Specialist needs transport (9)Vehicle covered by LEZ requirementsIf approved & converted before 1/1/12, additional 5 years on 15-year rolling age limit (4)Not applicableIf approved & converted on or after 1/1/12 and meets full requirements for Euro V, additional 5 years on 15-year rolling age limit (5)Not applicableLicensed (1) on or after 1/1/2012 and before 1/4/201201-Jan-1215 yearsEuro III (under current CoF)If approved & converted on or after 1/1/12 and meets full requirements for Euro V, additional 5 years on 15-year rolling age limit (5)Not applicableNot applicable - all taxis are wheelchair-accessible as part of CoFNot applicableNot applicableLicensed (1) on or after 1/4/2012.01-Apr-1215 years (3)Euro V/5 Not applicableNot applicableNot applicable - all taxis are wheelchair-accessible as part of CoFNot applicableNot applicableLicensed (1) before implementation date of 1 Jan 201201-Jan-1210 years N/AAdditional 5 years on 10-year rolling age limit if conversion meets Euro 3 Exempted (7)Additional 5 years on 10-year rolling age limit (10)Additional 5 years on 10-year rolling age limit (10)Additional 5 years on 10-year rolling age limit (10)Licensed (1) on or after 1 January 2012 and before 1 April 201201-Jan-1210 years N/ANo exemptionExempted (7)Additional 5 years at first licensing on the 10-year age limit (10)Additional 5 years at first licensing on the 10-year age limit (10)Additional 5 years at first licensing on the 10-year age limit (10)Licensed (1) on or after 1 April 2012.01-Apr-125 years at first licensing, then 10 years subsequentlyEuro 4 No exemptionExempted (7)Additional 5 years on 5-year age limit at first licensing; subsequently additional 5 years on the 10-year age limit; must be Euro 4 standard (10)Additional 5 years on 5-year age limit at first licensing; subsequently an additional 5 years on the 10-year age limit; must be Euro 4 at point of licensing (10)Additional 5 years on 5-year age limit at first licensing; subsequently an additional 5 years on the 10-year age limit; must be Euro 4 at point of licensing1Licensed here means first date of licence with TPH 2Age is from date of registration with DVLA. The age for the taxi or PHV will be as at date of annual re-licensing3Note that all newly-manufactured taxis will be Euro V/5 from January 20124Approved as per Conditions of Fitness - would need to meet Euro 3, TPH will assess conversions5To meet emissions standards of the EC directive on Euro V/56As per DVLA definition: manufactured before 1 Jan 19737Classic/niche vehicles will be determined on application to TPH using existing criteria. If they meet these criteria, they will be exempted from the age-based limits. 8Wheelchair Accessible Vehicles (WAVs) are already identified as such at licensing9Operators will need to apply to TPH to be registered as Specialist Needs Transport (SNT)10Certain classes of diesel vehicles will still need to meet LEZ emissions requirements - Euro 3 for PM This section is not for consultation (is set out in MAQS)Proposals below are for consultationEuro III (under current CoF)Exemption criteria not relevant for taxisTaxisPHVsLicensed (1) before implementation date of 1 Jan 201201-Jan-1215 yearsExemption criteria not relevant for taxis - all taxis are wheelchair-accessible as part of CoFExemption criteria not relevant for taxis
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