Sussex wrote:
Also the consultants recommend quality controls instead of quantity controls.
What's wrong with that?
Subject to my first bullet point below, under equilibrium conditions (as consultancy companies like to write) this would be fine. But Birmingham Hackney & PH are a long, long way from equilibrium conditions.
Again I will bullet point the reasons why the consultancy’s recommendations for age (not quality) control are not sustainable under the current position that both the Birmingham Hackney & PH trade find themselves in.
• Firstly, although the Study Report mentions a quality policy, it actually recommends an age policy, which although linked IS NOT THE SAME THING.
• Quality of vehicle is about how the proprietor of the vehicle looks after his HC or PHV.
• There are 12 year old HCs in Birmingham that are so pristine that they would grace a bride on her way to marry her groom.
• Conversely, there are 3, 5 & 7 year old HCs that are a disgrace to the trade, with last weekend’s chip papers still in the passenger compartment & that have not had a whiff of an air freshener since the driver last had a haircut.
• The above two points are also relevant to PHVs.
• These points are again an enforcement issue; if the drivers cannot keep their vehicles up to standard, then enforcement should do spot checks.
• So a vehicle age policy is NOT the same thing as a quality of vehicle policy. It is quite conceivable to have Proprietor A not being able to maintain a 4 year old vehicle to the standards (that should be) required, whilst Proprietor B is quite capable of maintaining a 12 - 15 year old vehicle to the standards (that should be) required.
• De-restriction is so far advanced in Birmingham that if the council adopt the Study Report’s recommendations, over 1200 HC in the current fleet would need to be upgraded by 2012.
• This represents over 85% of the HC fleet.
• Upgrading WAVs to a maximum age of 7 year old vehicles by 2012 is excessive & incomprehensible.
• It is obvious that many in the HC fleet will not be in a financial position to manage this upgrade.
• The council introduced a policy of de-restriction in 1996, against the wishes of the taxi trade (although the trade did manage to convince the council to adopt a policy of free issue HC licence must have a brand new WAV, to try & maintain incoming quality), & 12 years on there is an age/quality policy proposal on the table, that if adopted will undoubtedly put proprietors out of work.
• Obviously, the HC trade had to work with the council's decision of 1996.
• UNDER EQUILIBRIUM CONDITIONS, the idea of upgrading your vehicle is accepted.
• However, the Birmingham taxi trade is a million miles from an equilibrium position & is massively oversupplied. To follow the recommendations of the report would be morally repugnant due to the losses of livelihood that would occur.
• If the report’s recommendations were to be adopted, the logical scenario that would follow would be for proprietors who could not upgrade (due to financial constraints) to transfer their plate to multi-owner, as they would probably be the only ones with enough financial muscle to both pay any premium value that the plate may still have & also to fund an upgrade of the vehicle. And the result would be that previous proprietors would be driving for multi-owners & could be using a HC with the plate number that they previously owned. (I just wonder if this was the scenario in decades gone by in New York???)
• There are no figures available yet for PHVs that would need to be upgraded if the proposed recommendations were adopted, but it is estimated that over 90% of the present PHV fleet would go by 2012.
• Again there would be loss of livelihood.
• None of these recommendations, even if adopted, would start to address the problems of enforcement (mentioned in my previous post), especially with 'out-of-towners' plying for hire in their older vehicles & both HC & PHV licensed in Birmingham having to compete with their newer, far more costly vehicles.
• Birmingham is surrounded by 7 other licensing authorities, with several others in close proximity. It is a stone blind certainty that if the Study Report’s recommendations for a maximum age policy were adopted on the PHV, many of those proprietors would get their older vehicles licensed in another neighbouring authority & continue their illegal plying for hire in Birmingham at weekends, because they already ‘know the ropes’ & are fully aware of the non-existent enforcement.
• When the above was achieved, there would be a shortfall of funds at Birmingham’s licensing department & this would place a financial burden on enforcement & in general & licesing fees would rocket.
• It is quite possible that councils up & down the country have adopted age policies as a disguise for a quality policy. IMO this is to make life much easier for themselves. If you have an age policy, then that is a hard & fast rule, NO VEHICLE OVER 12 YEARS OLD, full-stop. No work for the enforcement officers, the policy takes care of that.
• A quality policy though is subjective & would usually requires a written code of minimum quality of vehicle standard (which would obviously apply to newer & older vehicles) & would need ‘GETTING UP OFF BACKSIDE’ to draft the code & inspect & make a decision. Life would then be a lot harder for the poor enforcement officers.
• AN AGE OF VEHICLE POLICY IS NOT A QUALITY OF VEHICLE POLICY!!!
• And last but by no means least an extract from the DfT's Taxi and Private Hire Vehicle Licensing: Best Practice Guidance;
Section 22
Sub-section Age Limits.
It is perfectly possible for an older vehicle to be in good condition. So the setting of an age limit beyond which a local authority will not license vehicles may be arbitrary and inappropriate. But a greater frequency of testing may be appropriate for older vehicles – for example, twice-yearly tests for vehicles more than five years old. (Definition of Arbitrary = Above the Law, Authoritarian, Autocratic, Dictatorial, Tyrannical, etc, etc)
Etc, etc, etc.
Goodnight, going to bed!!
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