Who'd have guessed the Institute of Licensing would oppose responsibility for licensing and enforcement being shifted and consolidated away from local licensing fiefdoms
To be fair, some decent enough points here.
On the other hand, a bit too much self-congratulation. Even after a couple of weeks in the trade 30 years ago now, I developed a deep mistrust of councils and licensing, and absolutely nothing to change my mind since

Of course, they're right insofar as any shortcomings at the local level might just reappear on a bigger scale at the LTA level. And could actually make things worse. But, for example, when I look at stuff like the vehicle inspection and spotcheck regimes in both areas I know well (Dundee and Fife) I fail to see that a more uniform Scotland-wide system with more consistent procedures and protocols could fail to be an improvement (while, for example, that tier of inspection and compliance doesn't exist at all in Wolverhampton

).
(Of course, I'm not sure if the IoL includes Scottish members, and in any case there's no change in the offing as regards any of the separate legislative framework up here.)
Anyway, link to the document near the top of the article here - it's only half-a-dozen or so pages...
IoL warns government’s taxi licensing overhaul is “unworkable”https://instituteoflicensing.org/networ ... nworkable/The Institute of Licensing (IoL) has sharply criticised government plans to shift taxi and private hire vehicle (PHV) licensing from local councils to Local Transport Authorities (LTAs), warning that the proposals are unsupported by evidence, risk destabilising local services, and could undermine public safety.The Department for Transport’s consultation, part of the wider English devolution agenda, argues that consolidating licensing within LTAs could reduce cross‑border working, improve consistency and strengthen enforcement. But the IoL’s response paints a very different picture, describing the reforms as disruptive, impractical and unlikely to achieve the outcomes ministers expect.
In its submission, the IoL argues that LTAs are not regulatory bodies and lack the systems, expertise and enforcement capability required to run a complex public protection regime. It warns that LTAs would need to build entire licensing structures from scratch, including specialist teams and committee systems, at significant cost and with no clear benefit.
The organisation also rejects the government’s claim that larger licensing areas would reduce out‑of‑area working, stating that cross‑bordering already occurs at a scale far beyond any proposed LTA boundaries. Instead, the IoL says national standards and national enforcement powers—already being developed separately—are the real solution.
The response highlights wider risks too. Most councils operate multi‑skilled licensing teams, and the IoL warns that removing taxi licensing staff to LTAs would “decimate” remaining teams, reducing capacity across alcohol, entertainment, gambling and animal welfare licensing. The timing is also a concern, with England already undergoing major local government reorganisation. Layering LTA reform on top of this, the IoL argues, would create confusion, duplication and governance gaps.
The IoL stresses that taxis play a vital role in local communities, particularly in rural areas and the night‑time economy, and that councils are better placed to understand local risks and work with police and community partners. It points to the Welsh Government’s 2019 exploration of a similar model, which was ultimately rejected due to concerns about public safety and loss of local control.
While opposing the LTA proposal, the IoL emphasises that reform is needed. It calls for national suitability standards, national vehicle and operator standards, mandatory in‑vehicle CCTV, improved police‑licensing information sharing and a national licensing register—measures it says would deliver consistency without dismantling local structures.