Skippy asked TDO to put this PCO response up for discussion. It relates to an official enquiry he made regarding the COF.
http://www.geocities.com/taxistats/pcoconditions.pdf
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Thank you for your email dated 22 October 2008, with regards to the turning circle, the Conditions of Fitness, emissions and wheelchair accessibility of the licensed London taxis.
If I may begin with your first concern regarding emissions:
The Mayor’s Air Quality Strategy (September 2002) identified taxi emissions as having a significant impact on air quality, particularly in parts of central London. Following this, the Public Carriage Office (PCO) consulted the taxi trade on options for reducing adverse air quality impacts from taxis and subsequently facilitated the development of various taxi emissions abatement technologies.
A taxi emissions strategy was introduced and implementation of this strategy started in July 2006. All of London’s taxis were required to meet Euro 3 emissions standards, as a minimum, in respect of PM10 and NOx by July 2008.
In addition, every new type of taxi offered for approval, since January 2007, must meet the current and relevant EC Directive for exhaust emissions, i.e. the respective Euro standard, currently Euro 4.
Transport for London (TfL) / The Public Carriage Office (PCO), are confident that with future technological and strategic developments London’s licensed Taxi fleet will meet the future challenges of vehicle emissions and climate change.
The PCO also continues to work with vehicle manufacturers to promote the development of technology that would reduce emissions contributory to health and environmental issues. The PCO is also developing its own ‘Carbon Strategies’ that are likely to include measures to address the CO2 output of both Taxi and Private Hire vehicles in the short, medium and long term.
With regards to your second concern and subsequent suggestion of removing the turning circle to allow vehicle owners to purchase alternative vehicle types:
The PCO imposes no restrictions on the type of vehicle licensed for use as a taxi in London, insofar as current legislation allows.
The PCO has previously and, continues to welcome applications for approval from car manufacturers, developers and designers with both traditional and innovative ideas for new types of taxi designs and any associated equipment that meets the full technical specifications/requirements set out in the current PCO Conditions of Fitness (CoF) 2007 document.
The CoF for London taxis came into force on the 1st January 2007, following extensive reviews. It specifies certain ergonomic and accessibility criteria and defines legislative requirements, including standards regarding safety, dimensions and manoeuvrability.
With reference to your third concern regarding the wheelchair accessibility of licensed London taxis:
Since 1995 the DfT have been developing specific taxi accessibility design features for wheelchair users and people with mobility difficulties using taxis. This has led to further enhancements and from the 1st January 2000 all licensed London taxis must be equipped to carry wheelchair passengers in a safe and secure position in a Department of Transport (DfT) reference wheelchair.
During the design stage of the TX taxi range and the recently introduced Mercedes Vito taxi, the manufacturers worked in consultation with the DfT to modify and develop improved accessibility features beyond those which first existed for the earlier generation of taxis. These included improved wheelchair ramps, improved headroom and an improved wheelchair restraint system.
However, the above DfT requirements are only general guidelines and not taxi specific, please see below for PCO requirements:-
The wheelchair must be: -
· Positioned in the approved location and positioned to be rearward facing with the wheelchair brakes applied.
· Secured by the approved wheelchair anchorages, using the approved wheelchair tie downs and the approved passenger restraint. The restraints for the wheelchair and its occupant must be independent of each other.
The PCO await the publication of a proposed DfT accessibility consultation document aimed at introducing specific, mandatory, accessibility design specifications for taxis.
The specification, dimensions and wheelchair space configuration used by the Public Carriage Office (PCO) which is based on the above guidelines are defined within the PCO Condition of Fitness 2007 document.
The PCO takes public safety very seriously and it is essential that all passengers are positioned or secured in the appropriate position and manner in licensed London taxis. The PCO will investigate any substantive complaint regarding the improper carriage of a wheelchair user.
For your further information I would refer you to the PCO web site for the current Taxi inspection manual and the current Conditions of Fitness 2007 document as regards London Taxis, (copy attached), and also various PCO Notices.
If I can be of any further assistance please do not hesitate to contact me.
Yours sincerely
Colin Wren
Vehicle Standards and Policy Manager
Public Carriage Office
020 7126 1406
Colin.wren@tfl.gov.uk