Licensed Private Hire Car Association Inc London Private Hire Car Association56 Austins Mead, Bovingdon, Hemel Hempstead, Herts HP3 0LHTel: 01442 833483 Mob1: 07956 329288 Mob2: 07931 483345E-mail: LPHCA@btinternet.com Web: WWW.LPHCA.CO.UK

Licensed Private Hire Car Association (LPHCA)Response to TfL ULEZ Consultation 9th January 2015

Set out on the following pages is the considered response of the Licensed Private Hire Car Association (LPHCA) with relation to the Central London Ultra Low Emission Zone (ULEZ) proposals published in late October 2014, in particular with regard to the Private Hire Industry and the potential impact on it.

We start by saying that the LPHCA is absolutely committed to the aims and objectives of the ULEZ to improve air quality and reduce CO2 emissions but straightaway must point out that we feel that the proposals, as currently set out for our industry, are absolutely not anywhere near the best way to achieve the aims and objectives.

You will be aware that the LPHCA representatives have facilitated and attended ULEZ meetings and prior to that engaged with TfL, some of its Directors, Board Members and the Mayor with regard to Air Quality.

As Chairman I attended the launch of the Mayor’s Air Quality Strategy and the LPHCA responded to the subsequent consultation. The LPHCA also had dialogue with Deputy Mayor for Transport Isabel Dedring when she was the Mayor’s Air Quality Advisor, which culminated in a meeting we hosted with her, TfL Directors, Board Members and our own members to see what our industry could do to improve Air Quality in the capital.

I mention the above to demonstrate how committed the LPHCA and the PHV Industry in London is regarding London’s Air Quality.

CONSULTATION PERIOD AND ENGAGEMENT WITH THE INDUSTRY

The LPHCA has a membership of around 200 Private Hire Vehicle (PHV) Operators that interface to around 20,000 drivers.

During 2014 the ULEZ team has engaged with representatives from the LPHCA and the Industry at various meetings including our Road Show in late September (attended by nearly 500 delegates). We also met with the ULEZ team at general meetings and did in fact arrange for some of the primary Industry Vehicle suppliers to attend.

Whilst these meetings have been productive and the proposals have been slightly improved as a result, a big problem for us has been that the full proposals were not known until the publication of the consultation in October. So even at our Road Show we were talking about the ‘likely’ and not the ‘actual’ proposals.

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We pointed out at a very early stage that an October publication of these proposals would coincide with the three busiest months of the industry’s working year, which included the Christmas period. It is therefore no surprise that since the proposals were announced, as we predicted, it has been difficult to get the industry’s attention.

The problems of the short period of engagement (10 weeks with Christmas period in the middle) were compounded by the publication of the GLA inquiry into Taxi & Private Hire Vehicles and the passage through Parliament of major legislation during the consultation period (the De-regulation Bill that will considerably affect the Taxi and Private Hire Industry).

Whilst you offered us a few days extension to this consultation the first point we wish to make is that the consultation period does not meet with best practice guidance and has simply not been long enough for proper engagement with the trade. With the Christmas Period in its midst, the industry has not had enough time to consider everything fully, despite our very best efforts.

By not allowing an ‘appropriate consultation duration’ it has created the impression that these proposals are being rushed through, which is a view that has been constantly expressed by our members.

In spite of the very short duration and no allowances for the Christmas holiday and busiest / worst possible time of the year for the industry, we have endeavoured to engage with our Members and the wider PHV industry.

In this regard we have written to all our Members, E-alerted them and held an executive meeting of our Platinum Members just a few weeks before Christmas, which for obvious reasons was not as heavily attended as usual due to the reasons set out above. We have also published 10,000 printed copies of the consultation in our Trade Magazine as well as sending the magazine digitally to over 1,300 of our online subscribers.

The LPHCA also attended two meetings with the ULEZ team in December, one of which was attended by the Office for Low Emission Vehicles (OLEV). As LPHCA Chairman and as a person absolutely committed to both your team’s and the Mayor’s objectives, I have also given evidence to the GLA Environmental Committee regarding the proposals at City Hall in December.

An LPHCA delegation comprising of myself and representatives from Member companies (who run nearly 6,000 vehicles in total in major fleets) also met in mid-December with Mercedes-Benz at their UK headquarters in Milton Keynes to discuss the ULEZ proposals for Private Hire, this with a panel of experts that cover Mercedes-Benz vehicle development, fleet and environment issues, not only in the UK but in Europe and Worldwide.

This meeting was important as Mercedes-Benz is the biggest supplier of vehicles to the London PHV marketplace.

The final point we need to make on the consultation period and engagement with the industry, is that our research shows that at driver level, the 73,000+ Private Hire Vehicle Drivers in London have little or no real understanding of the impact of these proposals and the consequences for their futures. The first that many drivers knew about the proposals was when the consultation was published.

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PROPOSED CHANGES TO THE TAXI AND PRIVATE HIRE VEHICLE (PHV) LICENSING REQUIREMENTS

All new Taxis and PHVs must be zero emission capable from 2018

This proposal shows a grave lack of understanding of the PHV industry, the way drivers enter it, the vehicles already being used and the ways the bigger fleets are procured.

The first point to make is that the PHV Industry appears to be ‘lumped together’ with the Taxi Industry whilst London’s PHV Industry has environmental credentials that are light years away from London’s Taxis. PHVs in London have ‘year on year’ (since the licensing of vehicles commenced in 2004) become cleaner and greener.

In addition the PHV industry boasts one of the best profiles of the greenest vehicles of any large group in the public transport sector and the current proposals suggest unnecessary, unrealistic, unachievable and unhelpful requirements.

In the 10 years since the licensing of PHVs in London became law (following many years of campaigning by the LPHCA) the industry has spectacularly converted the profile of vehicles that on average were older than Licensed Taxis, to a current average age of 5 years, some 3 years below that of London’s Licensed Taxis, which are now on average 8 years old.

This has been achieved without the need for draconian regulatory requirements as a natural process, which will continue in the same way as more and more improvements are made to vehicles alongside the arrival of fit for purpose vehicles as they become available from the industry supplying motor manufacturers.

Zero Emission Capability

The Zero Emission Capability requirement is in our considered view ‘a complete folly’. The current ULEZ proposals are asking for the impossible – PHVs to be mandated with expensive requirements in law, without the physical infrastructure, road space and availability of suitable vehicles, this alongside prohibitive and unrealistic costs.

If a Zero Emission Capability requirement was implemented in 2018, vehicles would continue to run on petrol or other fuels as they would not be able to charge up and run on electricity for many reasons.

Asking for a very clean industry to spend multi-millions on unworkable, unaffordable and impractical solutions is in effect paying lip service to the real problems, which won’t be solved.

It was clear in our discussions that with respect, the ULEZ team had little understanding about how the Private Hire Vehicle Industry operates, believing that vehicles returned to their offices and would therefore have time to charge up with electricity between jobs.

There was talk of ‘Charging Points’ in every borough and at main line stations, etc., but the reality is there is already very little (if any) space allocated to London’s 70,000+ PHVs at main line stations to pick up and set down passengers, let alone park and charge up vehicles.

Nobody knows better than TfL that Road Space is already at a premium and there has already been great difficulties finding space for the Cycle Hire Bikes, let alone charging points for the many PHVs that service Central London.

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As well as infrastructure issues there are apparently many different types of charging connectors, clearly issues like this have to be resolved before embarking on any move towards electric options for Zero Emissions Capability.

The Zero Emission Capability idea is also flawed at the other end of the spectrum because at a minimum you need a private drive or garage with electricity infrastructure to charge vehicles. With the vast majority of PHV drivers not having these facilities at their homes, how on earth can they charge such vehicles? Whilst buses can return to a depot, PHVs don’t.

The whole idea that an electric or ‘part electric’ vehicle solution is a viable option from 2018 is flawed for infrastructure and many other reasons.

It would not be financially viable to expect drivers to invest in a vehicle type they could rarely use to reduce emissions, which would have to use normal fuels (petrol or diesel) to deliver its electric operational capability on most occasions.

Environmental Credentials of Going Electric

Before going onto other major constraints and critical factors, we would like to understand fully the ‘Environmental Credentials’ of going for an Electric Solution.

The ‘Environmental footprint’ of providing the infrastructure to go electric is massive, alongside the potential disruption. That is also before we consider the generation of the electricity, the logistics and environmental impact of bringing vehicles half way across the planet (where most are currently manufactured).

There is also the significant subject of disposal of batteries at the end of their life cycle and the environmental footprint needed to get the rare metals extracted that feature in today’s electric vehicle models.

Battery weight (which increases fuel consumption) and the space overhead in vehicles is also a major concern. Whilst what comes out of the exhausts of vehicles is extremely important, so is the overall ‘Environmental footprint’ of moving towards Electricity as the source of fuel for vehicles.

Poor Vehicle Availability

The Private Hire Industry in London provides the most flexible and versatile range of Licensed ‘Door to Door’ Vehicles with over fifty makes and hundreds of models. We cater for the blind, the physically disabled, wheelchair dependent, elderly, young and able-bodied passengers, many without their own vehicles.

The Licensed PHV Industry supplies many purpose built vehicles, as well as customised and converted models that have extremely expensive modifications, alongside expensive testing requirements and certification. These vehicles quietly go about their day to day work transporting the disabled, special needs, sick and elderly passengers. Many Licensed Operators will be unable to source such vehicles from those current availability.

Mercedes-Benz provides the most PHVs in London, many to the very important Chauffeur and Executive part of the Industry. Currently they do not have a vehicle in their portfolio that meets the ULEZ proposals and future plans indicate that their market for such vehicles will be for vehicles in the £100,000+ price bracket.

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The biggest fleet of PHVs in London belongs to one of our members - Addison Lee, who utilise a fleet of People Movers that are currently far more environmentally friendly than buses and taxis. These vehicles (over 4,000 in total) have the capacity to take 6 passengers and therefore are a far more Environmentally Friendly option than running a lot more vehicles to do the same amount of work.

The company have looked at the marketplace to see if there are currently any options for equivalent replacements that are ‘Zero Emissions Capable’ but there aren’t and any chance of future vehicles being of this type are remote.

VEHICLE AGE LIMITS

There is a paranoia expressed around ‘Regulation by Vehicle Age Limits’, which we have constantly rejected.

We have always maintained that it’s the condition of a vehicle, rather than the age, which is important. In the case of Emissions it’s what comes out of Exhaust Systems, not the age of a Vehicle that is paramount.

We were ignored when we put this forward and TfL ploughed ahead with the simplistic but absolutely flawed utilisation of Age Limits for Taxis and PHVs. Beyond belief was the fact that Licensed PHV requirements were set 5 years below those of Taxis (the known serious polluters).

This very poor decision meant that very clean Hybrid PHVs over 5 years old could not be licensed but far more polluting ‘younger’ vehicles could be licensed. We were astonished that nothing has been learned from this bad mistake.

The PHV Industry complained about this for over 2½ years and we’ve only just got this farcical situation addressed.

Mapping environmental considerations to Euro Standards and Emissions Output is the way forward, not arbitrary age limits.

Prohibitive Costs

Notwithstanding the unavailability of PHVs that are capable of complying being exceptionally limited, comes the next serious problem for the Industry, which is extremely high costs. A reasonable amount of Zero Emission Capable Vehicles have successfully entered the Industry marketplace like the Toyota Prius; however that particular vehicle suits a limited amount of PHV passenger’s needs and is fairly unique in its reasonable cost and availability (due to its mass production).

Our research shows that costs for many of the vehicles required to be Zero Emission Capable Vehicles could be up to 50% dearer because they cost a great deal to produce and have little competition to drive market forces favourably on price (the next Prius is set to be around 30% more expensive).

When specialist servicing costs and battery disposal are factored in there are even more concerns on costs. Our industry clearly can’t finance or meet these much higher costs.

Problems are exacerbated because of the limited amount of choice and it simply doesn’t work to say if ‘X’ manufacturer can’t supply vehicles then get ‘Y’ manufacturer’s vehicles. Corporate procurement often looks worldwide for its specifications of vehicles and if companies ask for ‘X’ they won’t want ‘Y’ in isolation in London.

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Some of our Platinum Members have kindly emailed us regarding the ULEZ proposals, following a meeting we hosted a few weeks ago. They indicate that if these proposals are implemented it would increase costs to an unrealistic level, they would lose drivers and it would prevent drivers coming into the industry, causing many problems.

Potential Funding

LPHCA Members and other PHV Trade Representatives met with the ULEZ Team late in December and a representative attended from The Office for Low Emission Vehicles (OLEV), which is part of Department for Transport, Department for Business, Innovation & Skills and Department of Energy & Climate Change.

LPHCA Members had asked for a representative of OLEV to meet PHV Trade Representatives to try to establish what assistance would be available from Government to support any transition towards electric.

Rather than outline what funding could be available the meeting was left absolutely confused because current funding is running out and any new rounds of funding would be subject to Government approval and political will. With a general election looming and many vested interests seeking funding, total uncertainty was the outcome that was concluded. With the current Government seeking £12b in cuts, the funding and support outlook is bleak at best.

What was clear was very little funding would reach the PHV Industry outside what has already been committed to assist the extra cost of getting a Zero Emissions Capable Vehicle.

With Local Authorities applying for infrastructure funding, alongside mooted scrapping schemes for the filthiest vehicles, we see little or nothing being available for Private Hire.

London's Private Hire industry therefore urges Transport for London to rethink on Ultra Low Emission Zone plans for PHVs

Alongside the Society of Motor Manufacturers and Traders (SMMT) and others the LPHCA strongly believes that there needs to be a re-think on the current Ultra Low Emission Zone proposals.

The prospect of introducing ‘Zero Emissions Capable’ requirement for Private Hire Vehicles in 2018 is neither a realistic, viable nor an appropriate method to secure the objectives put forward within the proposed Ultra Low Emission Zone consultation document.

Private Hire is neither the problem nor the solution

Looking at our Industry's contribution to Emissions in London we are not the problem, in fact we are exemplary amongst the fleets in public transport having demonstrated a 'year on year' reduction in the age of and the emissions output from Licensed PHVs, since the inception of licensing.

We have embraced Hybrid Vehicles (where they are readily available and fit for purpose) and we contribute a minuscule amount towards London's Carbon footprint, being far cleaner than most of London's Buses, Taxis, Lorries and Private Motorist's Vehicles.

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Taxis and Buses are the real problem

Just prior to completing this consultation (early 2015) we have received the news that London’s Oxford Street has, after just 5 days of the New Year, exceeded the national allowances for levels of nitrogen dioxide pollution that are set for the whole of 2015.

According to the King’s College London’s (KCL) air quality monitoring statistics, Oxford Street has exceeded the hourly nitrogen dioxide mean objective of 200ug3 (microgrammes per cubic metre) on 19 occasions so far this year.

Oxford Street in London has some of the highest levels of nitrogen dioxide in the UK. KCL’s London Air website shows that the hourly mean objective for nitrogen dioxide on Oxford Street was exceeded on 1,361 occasions in 2014.

The above facts conclusively show where the blame for the Poor Air Quality lies as Oxford Street is a Buses, Taxis and ‘delivery only’ vehicles area and PHVs are not currently permitted.

Government Assistance

We believe assistance should come from Government to facilitate and encourage the uptake of greener vehicles.

It has been suggested that some of the limited funding available could be used for vehicle scrappage schemes however we believe this is not appropriate for a number of reasons.

Whilst scrapping an environmental unfriendly vehicle removes it from the road there is no certainty that it will be replaced with a new more Environmentally Friendly vehicle.

The Private Hire Industry would far prefer alternative incentives to vehicle scrapping schemes as this would guarantee improved air quality.

We would like TfL to seek more assistance from Government regarding things like increasing the Capital Allowances for the purchase of new Environmentally Friendly vehicles that deliver better Air Quality’, than a ‘pay-out’ for what are at the end of the day in the main, our competitors in the Taxi Industry, to scrap some very old vehicles.

We want any assistance to go towards the new, not the old and we don’t agree with the concept that the owners of very old taxis should get scrappage payments.

Fines for Non Compliance

Punitively punishing the PHV sector (and others for that matter) with fines will not overcome the shortfall in the production and availability of appropriate greener vehicles and will not reduce emissions or improve Air Quality.

Timescales

2018 is a non-starter for our industry as a date because of the availability of appropriate vehicles, the exorbitant costs and the futility of getting an industry to have 'Electric Operational Capability' when the logistics of charging such vehicles is near to impossible without the availability appropriate infrastructure being in place. 2018 is also out of sync with the main Air Quality initiatives in Europe, which are working towards 2020, something Mercedes-Benz pointed out to us.

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‘A sledge-hammer is being proposed to be taken to crack the wrong nut!’

The Society of Motor Manufacturers and Traders has called for a rethink of the current proposals set out by Transport for London (TfL) to enforce the latest emission standards for both petrol and diesel vehicles.

The Private Hire Industry has been encouraged in recent years to gear its fleets to have a lower carbon footprint and that has been achieved by moving to Hybrid where possible and moving to Diesel vehicles built today that are the cleanest ever made, which now capture over 99% of particulates.

Working towards a Euro-6 standard for both petrol and diesel PHVs would bring more of the desired air quality benefits far more effectively than the proposals set out in the Ultra Low Emission Zone consultation.

Having been encouraged to take up diesel, it is far too simplistic to now say 'Diesel is Dirty' and move the goalposts. 15 year old diesels yes, today's diesels no and it should not be forgotten that today's diesel engines do far more Miles to the gallon (MPG) than equivalent petrol engines.

The Society of Motor Manufacturers and Traders have said:

“Today’s diesel vehicles are light-years away from those built just a decade ago. Intelligent engine design and highly efficient exhaust ‘after-treatments’, including particulate filters, capture over 99% of particulates and around two-thirds of NOx emissions. ULEZ proposals should support the introduction of these technologies now, technologies which are being introduced ahead of the ever-tougher legislative requirements, which will be implemented over the next few years.

The current proposals for an ULEZ for London dictate the 2006-standard Euro-4 for petrol vehicles and the latest Euro-6 for diesel vehicles. Given the introduction date of 2020, it would therefore allow petrol vehicles of up to 14 years of age to enter without penalty".

We concur with the SMMT that London has to get it right, we also share their view that under the current proposal, the ULEZ gives access to 2006-standard Euro 4 for petrol vehicles and the latest Euro 6 for diesel and this is a missed opportunity.

It makes no sense to allow petrol vehicles of up to 14 years of age to enter the proposed ULEZ without penalty.

London's PHV industry is not using 14 year old Euro 4 petrol cars and would be far better placed opting for Euro 6 petrol and diesel vehicles that are on sale now and will become mandatory this year. A stepping stone approach could be used to get the PHV industry to continue on its 'very clean' air quality credentials path.

It is an important fact that many of the vehicles that enter the industry from new are passed on from the major fleets to new drivers entering the PHV Industry as well as to Londoners as affordable options, so why break what already works well?

The proposals in the short term need simplifying towards Euro 6 and moving away from the Zero Emissions Capability thinking. Electric capable and fully electric vehicle options are hailed as a panacea that we should strive towards but not necessarily something to totally commit to, especially as the infrastructure is not there to support it and other options are becoming available.

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In the Appendix section we have included some of the letters received from LPHCA Members, whilst other Members have supplied their own submissions and concerns directly.

Regulatory Impact

The potential Regulatory Impact on the PHV Industry in London in our view would be catastrophic with many unforeseen problems and dangers.

We are not convinced that such draconian proposals for a sector should be proposed via regulatory powers that are in our view on the ‘Extreme Edge of the scope of the Licensing Requirements for PHV’. Furthermore we are absolutely concerned at the lack of understanding of our Industry and the quality of the ULEZ Economic and Business Impact Assessment.

https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-iia_ebia_final.pdf

Some of the errors in that assessment are so serious that our Political Advisor Robin Hulf says “They are likely to mislead decision makers because the information is just plain wrong. The assessment states quite openly that the figures for the PHV industry are based on 2009 numbers” (para 7.6.16). Most of the data in this section is taken from Taxi/PHV Diary Survey 2009 prepared for TfL by GfK Consumer Services in January 2010 over 5 years ago!Using data this old is shocking and the quality of section 7 of the Economic and Business Impact Assessment is lamentable and extremely poor in our view.

It is clear that a few old figures have been cobbled together and absolutely no real consideration for Regulatory Impact has been undertaken for the PHV Industry.

We believe the Regulatory Impact on the PHV Industry in London financially would be many hundreds of millions of pounds. The potential socio-economic and supply & demand impacts are hardly covered alongside the subsequent consequences, which we believe will be increased illegal activity like Touting and Bogus Cabs.

Such draconian Regulatory proposals demand a proper Regulatory Impact Assessment not a set of re-cycled, out of date statistics that fail to look at and consider the true outcomes and consequences.

SUMMARY

The LPHCA absolutely believes that an Ultra Low Emissions Zone is not only a good idea but is absolutely essential for London. We do however feel that there are much better ways of achieving this and the ULEZ as proposed for Private Hire and others in the consultation is not the way forward.

As a responsible Trade Body we will work with everyone to achieve the right solutions and we pledge to do so going forward.

There often must be pain to achieve gain but the pain far outweighs the gain within these proposals, which in our considered view will not meet the objectives outlined in the consultation.

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RECOMMENDATIONS

Not to pursue the unworkable and unviable proposals set out for Licensed Private Hire Vehicles

Drop the start date of 2018

Deal with the main polluters first (buses and taxis)

Convene a think tank with the Private Hire Industry and its Vehicle suppliers to look at what is possible and how to achieve the ULEZ objectives, with a structured and achievable timeline.

Only consider Electric Solutions when the infrastructure is in place and the technology is capable of delivering it affordably and efficiently.

Let Private Hire naturally progress to lower emissions (as it has currently done) and only when appropriate, affordable vehicles are available, consider mandating specific requirements in regulations.

Use Euro values to achieve better emissions from PHVs, Taxis and Buses rather than age limits on vehicles. The same could apply to Private and Commercial Vehicles.

Undertake a proper Regulatory Impact Assessment

Potential quicker solutions to improve Air Quality Include:- Better utilisation of road space by providing more parking spaces and utilising

empty residential bays

- Removing unnecessary bus lanes

- Turn off many Traffic Lights at night

- Utilise ‘Smart’ toll collection methods like the Dartford Crossing

- Removing more un-necessary Traffic Lights

- Replace ‘force stop’ traffic light pedestrian crossings

- Re-introduce more Zebra Crossings

- Use Cameras rather than road humps

- Mandate ‘Cleaner fuels only’ on sale in London

- Seriously consider Tunnelling like Paris, Brussels, Antwerp, etc.

- Remove poor traffic management schemes and markings

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Appendix – Four Letters from LPHCA Members

Crawford Cars

Dear Steve,

As you are our chairman of the LPHCA, I feel compelled to express to you, our grave concerns as to the detrimental impact the Ultra Low Emission Zone (ULEZ) proposal will have, not only on our business, but to our industry as a whole.

As you know we are a high end corporate and chauffeur licensed private hire company, we have built a business and reputation around the supply of high end corporate and chauffeur vehicles.

The proposals state that from January 2018, all newly manufactured vehicles presented for licensing as private hire vehicles, must be zero emission capable. Our fleet of Mercedes Benz E-Class, S-Class and BMW 7 Series, will not satisfy the zero emission capability requirement, even though every year these 2 manufacturers manage to produce an even greener and lower emissions vehicle. These vehicles have never been as environmentally friendly as what they are now.

Our clientele are captains of British industry, successful business people, in the media celebrities, show-business and sporting personalities. As a result of their success, they are also major contributors to this country's economic growth via the corporation and personal tax that they pay. Our clientele come to us purely because of the vehicles we operate and they will not travel in anything other than these vehicles.

In many instances, we have agreements in place to supply a certain type and standard of vehicle. With the ULEZ proposal we will be unable to fulfil our obligations to our clients, leaving us in breach of our agreements. Furthermore, we believe there are no high end vehicles available from these or other manufacturers which are competitively priced to meet the ULEZ proposal, along with, and at the same time, satisfying customer requirements and enabling our business to remain profitable.

Even if this was not the case, we feel that the mileage range within electric vehicles is not sufficient for the long journeys our clients require without the need to recharge the vehicle battery. Within London there simply does not appear to be enough charging points to satisfy the demand of the private hire industry. Our drivers will be unable to sustain a living due to the ‘down time’ taken and costs incurred, to recharge their vehicle batteries.

It is felt that the private hire industry is being unfairly pressurised to assist in resolving a problem which it is not the cause of. Our trade and the vehicles we operate are not the biggest problem. Crawford’s vehicles are no more than 3 years old and many private hire vehicles, within the trade, are no more than 5 years old. This cannot be said for black taxis, this is neither fair nor helping to improve the air quality and reduce C02 emissions.

There is a proposal to charge non-compliant vehicles from entering the low emission zone. I understand this to be £12.50 per vehicle per day for vehicles such as the ones on our fleet. I fail to see how this daily charge would actually improve air quality and reduce C02 emissions. Therefore it becomes no more than yet another method of collecting revenue and can only be interpreted as another indirect tax.

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When all is said and done, should these proposals become law, it will be almost impossible to operate as a business at our end of the market. Drivers will leave in their droves and we would be unable to provide a service to our clients, therefore leaving us with no business. This will result in businesses such as ours, being unable to exist and many thousands of staff losing their jobs and their much relied upon income.

We are of the opinion that TfL should reconsider these initial proposals so that changes are made, else the private hire industry will be ruined. This would leave a serious shortfall in a public service, along with the unemployment impact I referred to earlier within this letter.

Finally, I would urge you to highlight our concerns to TfL as an absolute matter of urgency.

Yours sincerely,

Jimmy Lazarou CEO Crawford Cars

Cruise Minibuses Ltd

Dear Steve,

My concern with the proposal is the requirement for all new PHVs to be ULEZ compliant by 2018 regardless of location.

As you may remember we have a large number of Wheelchair Accessible Vehicles and have already invested a lot of money to make these compliant with previous requirements such as having them all inspected by VOSA. These vehicles will not meet Euro 6 requirements.

Will there be an exemption for wheelchair accessible vehicles as there has been previously with the age limit for example?

We operate on the outskirts of London in Hillingdon and Ealing, a long way from the proposed ULEZ.

I am very concerned this potentially could put us out of business.

Also should they decide this is a requirement, how much notice are we going to get, with previous changes in the licensing rules we have not been informed of them until we have taken a vehicle for licensing and they have failed it, only then we are informed of the new requirements, this is obviously not acceptable. For a significant change such as this we would require a lot of time to cope with replacing or modifying over 60 vehicles.

Yours sincerely,

John Gander Company Director Cruise Minibuses Ltd

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Greater London Hire Ltd (GLH)

Dear Steve,

At the last LPHCA Platinum meeting, you asked members to write to you with regards to how the new ULEZ proposals would affect their business. We also spoke over the telephone about the matter.

I should begin by stating I am relatively sympathetic with TfL on this issue. I think electric is the way to go in the future. Due to further investigation, I have discovered there may be sources developed in the future to make electricity sustainable, such as solar power batteries. I also believe something needs to happen to cut congestion. As a long term initiative, I am broadly supportive.

However, at the moment a framework is not in place to support so many new electric vehicles. I would question why the ULEZ proposals are being put forward so severely when the supporting framework i.e. chargers are not in place and there is no real guarantee of them being put in place. For example, at present, there are six fast chargers for Tesla vehicles in London. What sort of guarantees would be in place that London would have the facility to charge these vehicles, bearing in mind the majority of Londoners do not have a private drive in which they can charge a vehicle overnight? We are considering around 40000 vehicles potentially! I should add that at the moment in our area, there have been numerous power cuts especially in the winter months presumably due to the fact that there is so much electricity being used! Could London in 3 years’ time support charging all these vehicles as well?

I would also question why PHV vehicles are the only ones which MUST have vehicles, which meet the criteria set by TfL (and I am still precisely unsure on what that criteria is before entering the zone) whereas private road users could still enter in any vehicle and get away with a charge of some sort. Surely, it should be one rule for all?

On that point, I believe TfL should be setting the best example and making sure their vehicles are emissions free before asking other sectors to follow suit. When I say their vehicles, I am referring to buses. They should be leading by example, not asking the private hire trade to do as they are not themselves seemingly prepared to do!

As there is a very limited pool of vehicles, which would seemingly fulfil no emissions criteria at present, it is difficult to cost the affect it would have upon us as a company, but the new Toyota Prius coming out this year which runs to about 80 miles on a charge is roughly 30% more than a normal Prius, so one could argue costs may go up by that amount in general. At present, there are no emissions free people carriers or larger vehicles. At present, there are also no real alternatives for the executive market.

Whilst one may be pinning their hopes on Tesla technology, surely it is a little presumptive to be basing a policy on ifs and maybes before anything is actually guaranteed as being for certain. Would there be tax incentives or indeed funding from TfL to help companies or individual drivers afford these vehicles?

I am still unclear as to courier vehicles, but at present, there is one van I am aware of which fulfils some sort of no-emissions criteria and that is roughly double the cost of a standard petrol van of the same size.

In general, I would suggest the cut-off point is graded to allow companies and individual drivers to comply with regulations over a period of years rather than just guillotining on a certain date. It seems rather unfair to have different rules for different types of road user and also to set rules without actually having any concrete policies in place for the eventuality of this actually happening. The policy seems to be based on hypothesis, unless there is a lot going on in the background to which we are not privy!

Yours sincerely,

Robert Scott Managing Director Greater London Hire Ltd (GLH)

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Spotty Cars

Dear Steve,

As our representative for the Private Hire Industry I would like to forward to you my thoughts on the proposed ULEZ legislation.

Whilst I wholeheartedly agree that reducing emissions within London is a good plan, I believe the timescales proposed by the TfL are not feasible.

If you consider that the Toyota Prius Hybrid has been on the market for over 10 years there are still very few Hybrid cars available that would be suitable for the Private Hire Industry. Electric cars are relatively new and there is very little availability for Private Hire use, I cannot envisage this changing very much in the next 3 years. The limited availability and the increased cost whether it be in purchasing new, more expensive cars or paying the fine, will put a heavy burden on the industry.

I feel this will result in less drivers available for Private Hire or perhaps an increase in touting as drivers find ways to reduce other costs. Also if there is an option to pay a fee, there is actually no reduction in emissions.

I estimate that the cost of purchasing a car will increase about 30% and this will of course be passed on to the end user, i.e. Members of the general public.

Added to this how will a driver be able to charge his car? If the car is capable of 50 miles with no emissions realistically he will only be able to do 35-40 miles and will need to recharge. This means that every 2-3 jobs the driver will need to charge his or her car, during which time he or she will not be able to work.

Currently there are no rapid charging points in London and if 70,000 private Hire vehicles are charging their car, can the grid take the additional volume of power being used?

Also I believe that the same standards need to be applied to Black Taxis and Private Hire vehicles, especially since Black Taxis are one of the biggest contributors to emissions in London. According to the proposal, the Private Hire Industry contributes 4% of the total emissions with black cabs contributing 18%, so surely it makes sense to first deal with the black cabs and then move to the Private Hire industry?

The Private Hire industry has voluntarily shifted to hybrid and low emission cars without any legislation. For example 1/3 of our fleet are hybrid cars. As the technology evolves and the cars become suitable for Private Hire, the industry will naturally move towards low emission cars and legislation will not be necessary.

Overall this proposal will be disastrous for the whole industry and definitely needs more time and planning before going ahead.

Kind Regards,

Jackie Fletcher Spotty Cars

Appendix summary

These letters were received following our Platinum Members meeting in December 2014. They all illustrate the fears that the ULEZ proposals for Private Hire have caused.

Add to that the uncertainty and confusion within these proposals and you begin to understand just why we have yet to hear from anyone in the Industry endorsing the ideas set out therein.

By chance, the four companies that have written directly to us so far have over 150 years of trading in the Private Hire Industry between them, one with 50 plus years in the sector.

Steve Wright MBE Chairman LPHCA - 9th January 2015

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