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From: Paul Harper (Cllr) <>
Sent: 14 January 2021 16:08
To: Lorraine Neale <>
Subject: Re: Taxi Policy Consultation - Maidstone Borough Council


​They should be implemented in September 2022


Paul Harper
Labour Councillor for Fant

Chair Economic Regeneration and Leisure Committee
Deputy Leader Maidstone Labour Group



From: Michael Moss
Sent: 15 January 2021 12:34
To: Lorraine Neale <>
Subject: RE: Taxi Policy Consultation - Maidstone Borough Council


Hello Lorraine


Thank for you including the Hub in the MBC Taxi Policy consultation.


There were a few things I wanted to bring to your attention, not necessarily formally but some bits you might want to check, amend or discuss. J


Page 4

Reading it gave the impression the DBS checks would be every 3 years and not every 6 months.

Page 6

Reading implied the DBS supporting documents could also be provided as scanned/ photocopied document (they must be originals)

I would also like to discourage photos being provided as supporting documents – while I would be happy for a DVLA Driving Licence to be a photo, something like an Insurance Certificate should really be provided as a PDF document.

Page 7

DVLA Mandate is no longer used and instead should read DVLA Check Code (I would recommend doing a Hyperlink to DVLA page)

Page 8

(9) You have specified DBS application or current valid disclosure certificate. There is not validity period on a DBS certificate only by what is set under our own Policies. This could imply that a certificate within 6 months (the frequency in which they are checked) would constitute a valid period. This may need to be made clearer if the customer needs to be informed the certificate is not valid after one calendar month (if that is your limit).

Page 8

The Link provided for the DBS should be a Hyperlink under the word ‘Register’.

Page 8

The new information about the Certificate of Good Conduct is provided under the heading DBS, should it have its own heading or should the DBS heading be amended to say something generic like ‘Criminal Record Checks’.

Page 8

The information regarding the Certificate of Good Conduct is almost repeated from section (10) directly above.

Page 8

The information regarding proof of address is repeated from section (12) directly above.

Page 8

The request for proof of NINO is listed under the DBS heading, should this not be moved above?

Page 8

Should the EQUO information have its own heading (as it doesn’t fall under DBS or Criminal Record Checks) or moved to the section above (the same as the NINO information)?

Page 9

3.1 Fee: Outstanding application of more than 12 months will be cancelled and a new DBS  sought, does this mean if someone submits a DBS at the start of their application but takes 11 months to complete, that we will still accept that DBS from 11 months ago? If not, then this is a little misleading for the reader.

Page 12

3.6 – I’m more curious really – have you got the training material for the EUQO training? It’s an Officers issue but I haven’t seen  anything yet. I assume some will be provided but it not, this section implies that training material will be provided.

Page 14

Given the context of what is being discussed, I think it should read DVLA Driving Licence as it could be confused with the Taxi Drivers Licence.

Page 15

Unmet demand survey states it is review every three year, but was last completed in 2016 – should this be 2019?

Page 16

The Service Standards has recently been changed to 12 working days… however, the application is not valid until receipt of the garage compliance test and The Hub Team have 12 working days from that date in order to produce the licence and 5 working days to produce the plate (for renewals these are made up in advance). I would be grateful if this could be amended to encourage the trade to get the vehicles tested sooner as many leave it to the day before expiry to book the vehicle in and this causes undue pressure on the Hub Team – and gives the trade unrealistic expectations.

Page 16

4.1: A hyperlink is needed for the link under the word ‘Application Fee’.

Page 17

You have mentioned continuous insurance. As per our previous discussion and my recommendation to SB, the Hub is proposing to stop chasing & uploading Insurance Certificates. However if your intention to keep this task in-house (will become the responsibility of MBC to chase and upload) then obviously the information can stay within the Policy.

Page 18

More curious about this one – should or did you want Uniform to be able to easily identify these SEVs as I assume they are currently recorded as a PH? If you do (for reporting purposes) then I can make arrangements to do this.

Page 19

At the bottom of the page you changed the Unmet Demand survey from 2016 to 2019, but the next line reads 2016.

Page 20

4.9: Completely up to you – but thought you might want to mention the weekly submissions to DEFRA regarding Air Quality? Also an opportunity to advise your trade on how their information is being used.

Page 22

You have provided a list of requirements imposed on a PH Operator… having been out of the Officers loop for a while I don’t know if this is all taken from the new National Standards? I am curious, as the PH Operator is required to notify of any changes (in vehicles and drivers) and this notification would need to be recorded on Uniform – is the assumption that The Hub would deal with this? As that could lead to a significant increase in work which hasn’t yet been agreed or resourced? Just curious to know your understanding of the situation so I can start making some plans?

Page 23

States “available from the Council”…. Should this say Council website or offices? The link provided should be made a Hyperlink on the word ‘Council Website/Office’.


There are a couple of links which I have recommended being made Hyperlinks (to make the document more accessible online). Just in case you are unsure how to do this (and it is really easy once you know), you just need to do the following:


1.    Cut the link (or in the case of the DVLA Check Code page, copy the web link from Internet Explorer)

2.    Find a word(s) in the sentence where the link should be made (for example: Please refer to our website for details of our application fees)

3.    Right click on the selected word(s) and select Hyperlink

4.    Then in the address bar (shown below) paste the web link stored (or the one taken from your policy) and click OK.

5.    That’s it. J



Creating hyperlinks means that individuals having to use a screen reader can get the information without it reading out long winded text (such as web links). I did raise in my Accessibility Training the need for this under Taxi Licensing, as surely those accessing the information need to be able to see to be a taxi driver, but quite rightly I was challenged when asked, but what if a blind Solicitor is looking into a case and needs access to the same information… fair point. Haha.


I hope the above has been useful and not seen as me picking holes. If you need to discuss then do not hesitate to contact me.


Kind regards


Michael Moss

Licensing Partnership Manager

Sevenoaks District Council


Sent: 23 February 2021 09:27
To: Lorraine Neale <>; neilccox
Subject: Fwd:Taxi Policy


Hi Lorraine

I hope all is well. Please see the attached proposals from Neil Cox. I’ve looked through these and think all of his comments are very valid.

These are very difficult times indeed for operators of taxi/ph vehicles.

Anyway I know Neil is planning to put these forward or at least most of them and I thought it would be a good idea if there were some agreement before the upcoming meeting.

I’ve copied Neil in and hope you might find time to discuss things with him so going into the meeting you might both have the same start point.

I have to agree with Neil that P/H drivers have a chance to plan their route prior to pick up including points of interest before collecting customers, the knowledge test in any form is prohibitive. I would also suggest that it would be a very good idea if the local taxi policy and safeguards be a document that was signed on the granting of licenses, binding drivers to adhere, the main points could be bold and signed for separately. The drivers would of course need a DBS and medical but this would mean a much easier route to licence . The licence could be probationary for a period to keep check on new drivers. Drivers could also possibly be attached to a company for a short period so they have support and advice going forward and the council know where they are.

As far as Neils comments on vehicles especially bigger seating capacities, all this is very relevant, all points have my full support.

I hope this can be the way forward and we can get vehicles moving ASAP after the relaxation of restrictions. At this moment we have 40% of vehicles empty and of course unless we get drivers these vehicles will be disposed of.

I really hope You can support the trade to recover.

Kind Regards

John Iandolo


From: shukbahadur gurung
Sent: 07 March 2021 18:25
To: Licensing (MBC) <>
Subject: Taxi Policy


Sir/ Madam,

I would prefer if we started from September 2023, other than that I have no other comments to make nor add. 


Kind regards,

Shukbahadur Gurung 



From: Neil Cox
Sent: 07 March 2021 15:25
To: Licensing (MBC) <>
Subject: Consultation


Good afternoon Licensing,


Please find attached the response of the Maidstone Taxi Association to the Consultation in respect of the revised Hackney Carriage and Private Hire Policy as well as the Carbon Neutral proposals.


Kind Regards


Neil Cox

Maidstone Taxi Association




Mr Neil C Cox                                                                                                  Maidstone Borough Council

                                                                                                                        Licensing Department

                                                                                                                        Maidstone House

                                                                                                                        King St



Good morning Licensing,


Please find below the response of the Maidstone Taxi Association to the proposed Hackney Carriage and Private Hire Taxi Policy Consultation. It also includes our response to the Carbon Neutral Policy in respect of Licensed Vehicles.


I will go through the document page by page. Where we have an alternative proposal to the one you suggest we will detail it so that you can compare more easily.


Page 6.

The introduction of online forms, payment and delivery by post of new license plates is a massive step forward which most licensees welcome. Once the COVID 19 crisis is over can we keep to this arrangement as it is such a time saver? I do however have some members who wish to retain paper forms and payment by cheque due to lack of online knowledge and access to the internet.


Page 7.

There is often a substantial delay in getting drivers tests, knowledge tests, DBS checks and medicals on initial application which leads many applicants to give up and drive for a parcel or food delivery company or similar which impose no similar restrictions and they can drive any vehicle of any age. This is a chokehold on the trade and we would like a review on the entry mechanism to our trade to encourage more people to take up taxi driving.

Our suggestion is that new applicants should be able to drive a licensed Private Hire vehicle provisionally once a DBS, DVLA check and Group 2 medical have been completed. An applicant will already have passed a driving test and the addition of another driving test seems pointless.

The Knowledge test for PH drivers is outdated in an age of SatNavs. Fares are often prepaid or fares set prior to the journey. Uber drivers do not know their way around London and elsewhere but seem to manage with a Satnav and the public seem to like their service. They are by far the largest taxi operator in the land! We are aware this is a step change but believe technological change should be met with similarly imaginative changes to the regulatory environment.


Page 10.

We request that Group 2 Medicals should be carried out at 5 yearly intervals rather than 3. Historically it used to be a 5 yearly requirement but was reduced to 3 years because all the other checks were done at this interval. Now that DBS & DVLA checks can be done much more regularly online we believe that medicals should return to 5 yearly intervals as they are for bus and lorry drivers. This would have no impact on Licensing Dept funds.


Page 12.

EQUO Test. The cost of £66 seems excessive. Whilst we are not against any knowledge that may be gleaned from this test it is yet another hurdle to getting a driver working. Could it not be stipulated that an applicant must pass this test within a year of starting work and would help to spread the cost of becoming a licensed driver?




Page 17.

Currently a vehicle can only be Compliance tested at Oakwoods Garage, Dean St.  In short, we would like a greater choice of garage. We believe TMBC stipulate a minimum of 6 garages.


Where a vehicle fails its Compliance Test or cannot be put up for test because of accident repairs or shortages of available parts for repair we would like that vehicle to be treated as relicenseable once it passes its test assuming its licence expires and that this is written into the Taxi Policy.


Also, we would like brand new and delivery mileage vehicles to be licensed without a Compliance Test as they have just come off the production line and all parts are new. This would save licensees £57 per new vehicle and would have no impact on Licensing Department funds.


Page 30.

NR3. As we have a DBS checking system we are bound to ask what is the point of another database? We understand this will be put out to another consultation in the near future.


Page 31 & 45.

It is currently the case that no vehicle that has been written off can be licensed. We understand the reasoning in terms of seriously damaged vehicles but many vehicles are written off due to little more than cosmetic damage whose repair costs exceed the value of the vehicle. Sometimes if the cost of repairs exceeds 60% of the value of the vehicle it is written off. Such vehicles currently come under Category N. These are NOT ‘Cut and Shut’ vehicles. We believe these vehicles are no danger to the public, should be licensable and a Compliance Test would reveal any safety issues.  


Page 37.

Why is the maximum width of an HC limited to 1.778m and the length to 4.575m? This seems curiously exact! The interior dimensions are equally bizarre. Why is a roof rack not permitted on an HC but is on a PH? Why is 38cm the value set for step height? Are we ever likely to need such detailed restrictions and are Licensing ever likely to enforce them? May we suggest a review of all of the internal and external measurements. Are they even necessary?


Page 40.

The current regulations prevent use of any significant tinting at all. This precludes the use of many vehicles that in other respects are perfectly usable. Many cars have tinted rear side and rear windows but untinted front windows. We understand the reasoning behind the current rules but feel this has been taken too far to the detriment of vehicle choice. We believe the standard windows in the fully electric Nissan Leaf are heavily tinted and would therefore not be licensable. We would agree that totally blacked out windows are unacceptable but beyond that some tinting should be considered proportionate. TMBC have 50% tint as the minimum light transmission for rear side and rear windows.


Page 41.

In an age where everything is done online and by e mail it seems old fashioned for a taxi to need to have a paper copy of its insurance certificate on board at all times and clearly visible from the passenger compartment. This information is easily accessible online by anyone who is interested including the Licensing Dept. Having one in the vehicle is not evidence that a vehicle is insured.


Page 47.

Mobile Telephones are invariably connected to the vehicle by Bluetooth these days and hands free is the norm. Hard wired is out of date. We suggest specifying a Bluetooth connection for hands free operation rather than hard wired connection.



Bye Laws.

Drivers Badges: Currently Drivers Badges include our names, number and image which are highly visible. We propose that only our images and badge number are included and the words ‘Drivers Name withheld by Licensing Authority’. Unfortunately, some of our clientele have been known to track down drivers by their names to their home addresses which is rather concerning!



The switch to Fully Electric and Hybrid vehicles.


At present a vehicle must be under 3 years old and have done less than 30,000 miles when it is licensed for the first time. A PH vehicle can be tested up till the 6th anniversary of date of first registration and an HC its 15th. When that licence runs out it can no longer be used as a taxi. Nearly all vehicles are powered by an internal combustion engine at present, albeit at Euro 6 emissions standard.


The MBC proposal seems to be that come a given date (Sept 22 through to Sept 23) all vehicles that are replaced from that date will have to be fully electric in the case of PHs and hybrid or fully electric in the case of HCs.


We have some issues with these proposals given the Covid19 crisis which has done the taxi trade so much harm. For the last year or so the night time economy has been non-existent, shops have been shut for much of the time and local authority, KCC work has been extremely limited and social service transport has never resumed. We understand many drivers have not renewed their badges or vehicle licences. We do not recall a worse year for work or income in our entire working lives.


Whilst many of us are still financially afloat due to SEISS payments (between 70% and 80% of trading profits) our incomes have been shredded and it is now that we are expected to make the leap to new, expensive tech.


Whilst we are aware of the pressures the MBC are under from government and media to go forward with proposals to tackle climate change the taxi trade here and elsewhere are faced with having to replace vehicles that may not be replaceable with low emission affordable alternatives.


In terms of HCs, we currently have 2 options that currently fit the new criteria, the LEVC hybrid (London Taxi), the fully electric Nissan NV200 and we believe an Hybrid Mercedes Vito is on the way. All cost in excess of £55,000 new and all need charging far too frequently.   


In terms of PHs there are a few fully electric (BEV) options. Nissan Leaf, 168-239 mile range from £26,845, Seat Mii from £19,800 160 mile range, Vauxhall Corsa E 209 mile range £26,490, Kia E Niro 282 mile range £26,829. There are others but you get the picture. The ones with the greatest range tend to be small saloons. There aren’t that many at present. There is a much greater choice of hybrids (REEV).


I can find 4 zero emission (BEV) fully electric 5,6,7 or 8 seater vehicles on the market at present including Tesla model S and X from £83,980, Nissan E-NV200 Combi £29,755 and Mercedes EQV £70,665. Much of our current workload including school transport involves vehicles with these seating capacities. The new criteria will devastate this part of the market.


Given the above our suggestions for future vehicle type licensing policy are as follows.


1. That the date for this new low emissions policy be put back beyond September 2023 given the lack of availability, choice and affordability of vehicles, the lack of range of those available and the lack of charging infrastructure. We do not understand why September 2023 is the last option offered when vehicles powered by internal combustion engines will be on sale until 2030.


2. That replacement Private Hire vehicles from the specified date should include hybrid vehicles as well as fully electric ones. This is especially important for larger seating capacity saloons and small non pcv minibuses.


3.We would request that the existing fleet of licensed vehicles can be licensed for an extra 15 months due to the Covid19 crisis which we may want to see extended if the situation and restrictions continue. The current date for the lifting of restrictions is 21st June 2021 which would mean 15 months of severely restricted operations for us.


4.  Another suggestion is that replacement vehicles that are BEV or REEV do not have to meet the 3 year, 30,000 mile rule. As an example, there are a number of LEVC taxis for sale second hand that are coming up to 3 years old and have over 30,000 miles on the clock but are currently out of reach for those who may wish to buy them.


We therefore propose that the 3 year, 30,000 mile rule at first licensing for both HCs and PHs be amended to a 5 year, 100,000 mile rule for BEV and REEV vehicles to encourage take up. No minimum engine size should apply in the choice of REEV.


5.  We suggest that for HCs any vehicle that is wheelchair accessible, is right hand drive, has 4 wheels, can carry up to 8 passengers, has 4 or 5 doors, has an internal combustion engine capacity of any size when acting as the source of energy for an electric motor, has a partition between driver and passengers can be used as an HC.  


We would like this to become the default position in the choice of vehicle and we as HC operators would not need to present a potential vehicle to licensing before purchasing as we do at present. This is not the case for PHs.


We suspect that technological progress may well render this discussion irrelevant but, in the meantime, we must deal with the world as it is rather than how we may want it to be. Once this new tech is commercially viable we won’t need a given set of regulations to encourage us to switch.


Kind Regards


Neil Cox

Chair Maidstone Taxi Association