Your Councillors

4. Hackney Carriage / Private Hire Vehicle Licences

Section 47(2) of the Town Police Clauses Act 1847 permits a Borough Council

to require that a hackney carriage licensed by them under the Act of 1847 to

be of such design or appearance or bear such distinguishing marks as shall

clearly identify it as a hackney carriage.

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Numbers Limit

No powers exist for licensing authorities to limit the number of private hire vehicles that they licence. The present legal provisions on quantity restrictions for hackney vehicles are set out in section 16 of the Transport Act 1985. This provides that the grant of a taxi licence may be refused, for the purpose of limiting the number of licensed taxis �if, but only if, the local Authority is satisfied that there is no significant demand for the services of hackney carriages (within the area to which the licence would apply) which is unmet�.� In the event of a challenge to a decision to refuse a licence, it would, therefore, have to be established that the authority had reasonably been satisfied that there was no significant unmet demand.

Maidstone Borough Council has a policy of limiting Hackney Carriage Vehicle numbers and that number currently stands at 48. Unmet Demand Surveys are undertaken every three years to reassess the situation and the results of the survey decides the increase and the issuing of further Hackney Carriage Vehicle licenses, if there are to be any. The last Unmet Demand Survey was completed in 2013 and no demand was found.

Section 48 of the Local Government (Miscellaneous Provisions) Act 1976

states that the Council shall grant a private hire vehicle licence provided the

Council is satisfied that the vehicle is

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. Suitable in type, size and design for the use of a Private Hire Vehicle;

. Not of such a design and appearance as to lead any person to believe

� that the vehicle is a Hackney Carriage;

. In a suitable mechanical condition;

. Safe; and

. Comfortable;

. That there is in force in relation to the use of the vehicle a policy of

�� insurance that complies with the Road Traffic Act 1988.

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Once licensed, a hackney carriage or private hire vehicle remains a hackney carriage or private hire vehicle until the licence either expires, is suspended or revoked. A licensed vehicle can, subject to very limited exemptions, only ever be legally driven by a driver who holds the relevant hackney carriage or private hire drivers� licence and appropriate insurance.

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With regard to hackney carriages, it is currently the policy of Maidstone Council to only license purpose built hackney carriages, the Mercedes Vito Taxi and the Peugeot E7 which are wheelchair accessible and fitted with a partition between the driver and passenger compartments and which also follow the Conditions of Fitness set by the London Carriage Office.

Some of the vehicles that we currently licence may not cater to some specific wheelchair users. In view of this information the Head of Housing and Community Services will consider any additional Hackney Carriage Vehicles to be approved on a case by case basis in order to be added to an agreed list.

All applications submitted for the initial grant of a licence are advised to apply at least 10 working days before the licence is required to allow time for the vehicle to be tested and the licence to be processed.�

Application forms must be completed in full, accompanied by all required documents and signed by the applicant and the operator where relevant. Any

incomplete forms will be deemed invalid and returned immediately to the applicant.

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Applications will only be acceptable as valid if they include and/or are accompanied by the following:

�1. Application form provided by the Council completed in its entirety and signed by the applicant and operator where relevant .

2. The appropriate fee.

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3. Original vehicle registration document showing the applicant to be the

registered keeper or other acceptable proof of ownership (the V5 New Keeper Supplement completed by the applicant or an official receipt from a registered company in the case of newly manufactured vehicles)�

5. Certificate of insurance for the vehicle which covers the activity required (i.e. public or private hire - para.4.2) and which is valid on the date that the licence is due to come into force.

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4.1 Licence Fee

All applications must be accompanied by the appropriate fee as prescribed by the Council; the current scale of fees is available from the Council or at http://www.maidstone.gov.uk/business/licensing-and-permits/taxis-and-private-hire

Licensing fees are reviewed on an annual basis and adopted by the Council

following advertisement by a notice in a local newspaper. The notice will also

be displayed at the Council Offices to allow for any comments to be made.

In the event of the surrender of a vehicle licence before its expiry there is no refund made.

4.2 Insurance

All hackney carriage and private hire vehicles must be insured for public hire

and reward, such insurance to provide as a minimum requirement insurance

cover for third party fire and theft and also to include legal liability for passengers and luggage.�

The Council considers vehicle insurance to be a high priority and, therefore, requires all proprietors to provide evidence of continuous insurance cover

throughout the period of the licence. Failure to provide evidence of insurance

will result in the vehicle licence being suspended.�

Appendix 5: A

MAIDSTONE BOROUGH COUNCIL

SPECIFICATION RELATING TO HACKNEY CARRIAGE VEHICLES

�� No vehicle shall be licensed as a hackney carriage unless it is fit for �� public service and complies with the specifications set out below.

1. GENERAL��

(i) �� All hackney carriages must have a minimum of four wheels and must have at least four doors, excluding the tailgate.

(ii) �� All Hackney vehicles must be right hand drive��

(iii) �� The engine capacity of all vehicles submitted to be tested for the first time shall not be less than 1400cc. However, in some instances vehicles may be assessed on a case by case basis.��

(iii) �� No hackney carriage shall be accepted for testing for the first time if the vehicle is over three years old or has mileage of more than 30,000 miles.

(iv) �� Vehicles should have no damage affecting the structural safety of the vehicle and must not have been written off for insurance purposes at any time. For example vehicles that are known in the trade as �cut & shut� will not be licensed.

NOTES:

1)�� Vehicles submitted for testing for the first time must comply with the age specifications. Any vehicle currently compliance tested, shall, at the expiry of that compliance period, if the vehicle falls outside of the age policy, not be re-licenced.

2)�� Once the expiry date of any vehicle compliance has expired, if the vehicle specifications are outside of the policy where age is concerned as set out in these specifications, the vehicle may not be re-licensed.

3)�� A compliance test may be arranged for a vehicle and carried out up to one month prior to the expiry date of its current compliance certificate. If the vehicle passes the compliance test, a certificate may be issued for a period of up to thirteen months (in line with Department of transport procedure) or whatever period within the month prior to its expiry, so long as the period does not exceed thirteen months and so long as the current compliance certificate is produced for inspection by the vehicle examiner.

2. GENERAL CONSTRUCTION��

(i)�� Every vehicle must comply in all respects with the �� requirements of any Acts and Regulations relating to motor �� vehicles in force at the time of licensing.

(ii)�� Vehicles offered for type approval must be so constructed as to facilitate the carriage of disabled persons and be capable of

�� accommodating a disabled person in a wheelchair within the passenger compartment.

3. STEERING��

(i)�� The steering wheel must be on the offside of the vehicle.

(ii) The steering mechanism must be so constructed or arranged that no overlock is possible and the road wheels do not in any circumstances foul any part of the vehicle.

(iii)�� The steering arms and connections must be of adequate strength and as far as possible protected from damage by collision.

4. BRAKE AND STEERING CONNECTIONS

�� Where brake and steering connections are secured with bolts or pins, the bolts or pins must be fitted with approved locking devices and they must be so placed that, when in any position other than horizontal, the head of the bolt pin is uppermost.

~~5. TURNING CIRCLE~~

�(i)�� The vehicle must be capable of being turned on either lock as to proceed in the opposite direction without reversing between two vertical parallel plans not more than 8.535 metres apart. (28.19 feet)

~~�(ii)�� The wheel turning circle kerb to kerb on either lock must not be less than 7.62 metres in diameter. (25 feet)��~~ ��

6. TYRES

�� All tyres at normal pressure under load must be approved as having suitable minimum circumference for correct operation of the taximeter.

7. BRAKES

�(i)�� All brakes must act directly on the wheels of the vehicle.

�(ii)�� The brakes of one of the braking systems must be applied by pedal.

�(iii)�� The pedal operated braking system must be so designed that �� notwithstanding the failure of the brakes on any pair of wheels, either �� on one axle or diagonally opposite, there must still be available for �� application brakes on the other pair sufficient to bring the vehicle to rest within a reasonable distance.

�(iv)�� Cable connections are not permitted in the pedal operated system.

8. SUSPENSION

�(i)�� Every vehicle must be fitted with an efficient suspension system so designed and constructed that there is no excessive roll or pitch.

(ii)�� Every vehicle must be so constructed or adapted that a failure of a spring, torsion bar or other similar component of the suspension

�� system is not likely to cause the driver to lose directional control of the vehicle.

(iii)�� When the vehicle is complete and fully equipped for service and loaded with �� weights placed in the correct relative positions to represent the driver and � a full complement of passengers and luggage and is placed on a plane surface it must not overturn when the plane is tilted to either side to an angle of 4 degrees from the horizontal.��

NOTE:

(a)�� For the purpose of this condition 65 kilograms shall be deemed to represent the weight of one person and 65 kilograms the weight of a full complement of luggage.��

(b)�� For the purposes of conducting tests of stability the height of any stop used to prevent a wheel from slipping sideways must not be greater than two-thirds of the distance between the surface upon which the vehicle stands before it is tilted and that part of the rim of that wheel which is then nearest to such surface when the vehicle is loaded.��

9. TRANSMISSION

�� Cabs using automatic or semi-automatic transmission must be fitted with a device to prevent the engine starting with the transmission selector in a DRIVE or REVERSE position.

10. BOLTS AND NUTS

�� All moving parts and parts subject to severs vibration connected by bolts or studs and nuts must be fitted with an approved locking device.

11. FUEL TANKS

�(i)�� Fuel tanks must not be placed under the bonnet and must be adequately protected from damage by collision .

(ii)�� All fuel tanks and all apparatus supplying fuel to the engine must be so placed or shielded that no fuel overflowing or leaking from there can fall or accumulate upon any part or fitting where it is capable of being readily ignited or can fall into any receptacle where it might accumulate.

(iii)�� The filling points for all fuel tanks must be accessible only from the outside of the vehicle and filler caps must be so designed and constructed that they cannot be dislodged by accident.

(iii) A device must be provided by means of which the supply of fuel to the engine may be immediately cut off. It�s location together with the means of operation and �off �position must be clearly marked on the outside of the vehicle. In the case of an engine powered by LPG or petrol the device must be visible and readily accessible at all times from outside the vehicle.

12. INTERIOR LIGHTING

�� Adequate lighting must be provided for the driver and passengers. Separate lighting controls for both passenger and driver must be provided. In the case of the passengers compartment an illuminated control switch must be fitted in an approved position. Lighting must also be provided at floor level to every passenger door and be actuated by the opening of those doors.

13. ELECTRICAL EQUIPMENT

�(i)�� All electrical leads and cables must be adequately insulated and�� where liable to be affected by exposure to water, petrol or oil, �� must be adequately protected.

(ii)�� All electrical circuits must be protected by suitable fuses.

(iii) Batteries must be so placed and protected that they cannot be �� a source of danger.

(iv)

14. EXHAUST PIPE

�� The exhaust pipe must be so fitted or shielded that no inflammable material can fall or be thrown upon it from any part of the vehicle and that it is not likely to cause a fire through proximity to any inflammable material on the vehicle. The outlet must be placed at the rear of the vehicle on the off-side and in such a position as to prevent fumes from entering the vehicle.

15. BODY

�(i)�� The body must be of the fixed head type with a partially glazed partition separating the passenger from the driver.

(ii)�� (a) Outside dimensions

(1) The overall width of the vehicle exclusive of driving �� mirrors must not exceed 1.778 metres.��

(2) The overall length must not exceed 4.575 metres.

(b) Inside dimensions of passenger� compartment.

�� (1) The vertical distance between the point of maximum �� deflection of the seat cushion when a passenger is �� seated to the roof immediately above the point must not �� be less than 96.5 centimetres

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(2) The width across the rear seat cushion must not be less �� than 1.7 metres.

(iii)�� Any curvature of the floor of the passenger� compartment must �� be continuous and must not exceed 2 centimetres at the �� partition and 5 centimetres at the base of the rear seat when �� measured between the centre line and sills.

(iv)�� The door and doorway must be so constructed as to permit an �� unrestricted opening across the doorway of at least 75 �� centimetres. The minimum angle of the door when opened must be 9 degrees��

(v)�� The clear height of the doorway must not be less than 1.195 �� metres.

(vi)�� Grab handles must be placed at door entrances to assist the �� elderly and disabled.

(vii)�� Where a boot lid is hinged at the bottom a restriction must be fitted to �� prevent the boot lid serving as a luggage platform.

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(viii)�� No roof rack shall be fitted.

16. STEPS

�(i)�� The top of the tread for any entrance must be at the level of the floor of the passenger compartment and must not exceed 38 centimetres above ground level when the vehicle is unladen.

(ii)�� The outer edge of the floor at each entrance must be fitted with non-slip treads. If a colour contrast is used to aid a partially sighted person it must be of an approved type.

17. WHEELCHAIR FACILITIES

�(i)�� Approved anchorage must be provided for the wheelchair and chairbound disabled person. This anchorage�s must be either chassis or floor linked. If floor linked they must be affixed in such a manner that the forces are distributed evenly throughout the floor area by means of a suitable galvanised plate of minimum dimensions 2x2mm which must be used beneath the floor.

�� Restraints for a wheelchair and a person seated therein must be independent of each other. Anchorage must also be provided for the safe stowage of a wheelchair when not in use whether folded or otherwise if carried within the passenger compartment. All anchorage and restraints must be so designed that they do not cause a foreseeable danger to other passengers.

(ii)�� A ramp or ramps for the loading of the wheelchair and occupants must be available at all times for use at the near side passengers� door. An adequate locating device must be fitted to ensure that the ramp/ramps do not slip or tilt when in use. The ramp/ramps must be capable of being stowed safely when not in use.

18. PAINTWORK AND BODY FINISH

�� The paintwork and body finish should be maintained to the original �� manufacturer specification.��

19. PASSENGERS� SEATS

�(i)�� The measurements from the upholstery at the back of the front edge of the back seat must be at least 4 centimetres and for each adult person carried a minimum of 4 centimetres must be available when measured along the front parallel edge of the seat cushion.

� (ii)�� The width of each front seat must not be less than 40 centimetres and such seats must be at least 35.5 centimetres when measured from the back to the front of the upholstery.

� (iii)�� The vertical distance between the highest point of the undeflected seat cushion and the top of the floor covering must not be less than 35.5 centimetres.

�(iv)�� Where seats are placed facing each other there must be a clear space of 48 centimetres between any part of the front of a seat and any part of any other seat, which faces it. The measurement may be reduced to 43.5 centimetres provided adequate foot room is maintained at floor level. Where all seats are placed facing to the front of the vehicle there must be a clear space of at least 66 centimetres in front of every part of each seat squab.

�� (v)�� Front seats must be so arranged as to rise automatically when not in use. They must be symmetrically placed and at least 4 centimetres apart. When not in use front seats must not obstruct doorways.

� (vi)�� Suitable means must be provided to assist persons to rise from the rear seat with particular attention to the needs of the elderly and disabled.

20. DRIVER�S COMPARTMENT

�� (i)�� The driver�s compartment must be so designed that the driver has adequate room, can easily reach and quickly operate the controls and give hand signals on the offside of the �� vehicle.

�� (ii)�� The controls must be so placed as to allow reasonable access to the driver�s seat and, when centrally placed, must be properly protected from contact with luggage.

�� (iii)�� The driver�s seat must be designed to accommodate the driver only and be adjustable for height and reach.

�� (iv)�� The vehicle must be fitted with adequate devices for demisting, defrosting and washing the windscreen and the sun visor adjustable by the driver.

�� (v)�� Direction indicators of an approved type must be fitted.

�� (vi)�� Every cab must be provided with an approved means of communication between passenger and the driver. When a sliding window is fitted at the rear of the driver�s compartment, the maximum width of the opening must not excee1.5 centimetres.

21. WINDOWS

�� (i)�� Windows must be provided at the sides and at the rear.

�� (ii)�� Passenger door windows must be capable of being opened easily by passengers when sealed. The control for opening a door window must be easily identified so as not to be mistaken for any other control.

22. HEATING AND VENTILATION

(i) �� An adequate heating and ventilation system must be fitted for the �� driver and passengers and means provided for independent control by the driver and passengers.

(ii) �� Windows must be provided at the rear and sides along with means of �� opening and closing not less than one window on either side.

(iii) �� Rear passenger windows must be capable of being opened by � passengers when seated, unless air conditioning is available for the comfort of the passenger.

23. ADVERTISING

(i) �� Advertisements may be displayed on the outside of the vehicle on the lower door panels only and prior to their placement must have been approved by the local authority.

(ii) �� No sign or advertisement shall obliterate or be confused with the vehicle�s licence plate or the number plates of the vehicle.

�(iii) �� A sign shall be affixed to the outside or inside of the vehicle indicating that smoking is prohibited in the vehicle or requesting passengers to refrain from smoking inside the vehicle.

24. TINTED WINDOWS��

�� Glass allowing a minimum of 75% light ingress on front windscreens and not less than 70% light ingress on all side and rear passenger windows, which does not inhibit the ability to see passengers or the driver from the outside of the vehicle, is required.

�� A Light Transmission Detector, which measures light transmission through any type of glass is used to test and determine visibility and provides a read out of the suitability of proposed vehicles for use as licensed private hire vehicles in the district. (It will not apply to Hackney vehicles)

25. DOOR FITTINGS

�(i)�� An approved type of automatic door locking device must be fitted to passenger doors. When the vehicle is stationary the passenger doors must be capable of being readily opened from the inside and outside the vehicle by one operation of the latch mechanism. The

�� interior door �� handle must be easily identified so as not to be mistaken for any other control.

(ii)�� Double catches of approved type must be fitted to all doors.

26. INSURANCE CERTIFICATES AND INTERNAL PLATE

�� A current insurance certificate and an internal plate showing the local authority�s licence number for the vehicle and the number of passengers allowed to be carried must be displayed within the vehicle, all to be clearly visible from the passenger compartment.

27. FLOOR COVERING

�� The floor of the passenger�s compartment must be covered with non-slip material, which can easily be cleaned.

28. LUGGAGE

(i)�� Adequate storage for passenger luggage separated from the �� passenger compartment without obstructing any emergency exits �� must be available. Luggage carried must be suitably secured in �� place.

(ii)�� Provision must be made for carrying luggage sufficient for the �� number of �� persons for which the vehicle is licensed.

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29. HORN

�� A horn of approved pattern must be fitted.

30. TAXIMETER AND FARE CHART

(i) �� A taximeter must be fitted in an approved position.

(ii) �� A taximeter must be fitted and must be correctly calibrated, sealed and fully functional in accordance showing the current hackney tariff and be easily visible to passengers.

�(iii) �� The taximeter and all the fittings thereof shall be so affixed to the carriage with seals or other appliances, so as not to be practicable for any person to tamper with them except by breaking, damaging or permanently displacing the seals or other appliances.

�(iv) �� The taximeter shall be positioned so that all letters and figures on the face thereof may be at all times plainly visible to any person being conveyed in the vehicle. The dial of the taximeter shall be kept properly illuminated throughout any part of the hiring which is during the hours of darkness as defined for the purposes of the Road Transport Act 1988 and also at any time at the request of the hirer.

(v) �� When the meter is operating there shall be recorded on the face of the meter in clearly legible figures a fare not exceeding the maximum fare that may be charged for a journey.

�(vi) �� If the taximeter has been altered for whatever reason, the proprietor of the vehicle shall forthwith report the alteration to the licensing department so that arrangements for resetting and resealing may be made.

(vii) �� An official copy of the Council�s fare chart must be clearly displayed in the vehicle so as to be plainly visible to passengers carried therein.

(viii) �� The vehicle taximeter shall be brought into operation at the commencement of the journey and the fare demanded by the driver shall not be greater than that fixed by this Council in connection with the hire of hackney carriages.� In the event of such a journey commencing in but ending outside the Maidstone district there may be charged for the journey such fare or rate of fare, if any, as was agreed before the hiring was effected, if no such agreement was made then the fare to be charged should be no greater than that fixed by the Council in connection with the hire of hackney carriages.

31. TAXI SIGN

�� A �TAXI� sign clearly visible both by day and by night when the cab is not hired, must be fitted.

32. RADIO APPARATUS

�(i)�� Where apparatus for the operation of a two-way radio system is fitted to a cab, no part of the apparatus may be fixed in the passenger�s compartment or in the rear boot compartment if LPG tanks or equipment are situated therein.

�� (ii) Any other radio equipment either in the passenger or driver �� compartment, must be approved.

33. FITTINGS

�� No fittings other than those approved may be attached to or carried upon the inside or outside of the Hackney Carriage.

34. MAINTENANCE

�� The Hackney Carriage vehicle, including all fittings, fixtures, advertisements etc, must be well maintained and kept clean and in good working order. The vehicle will at all times be subject to test and inspection and should it be found that any part or fitting is not well maintained, clean and in good working order, a notice will be served on the owner prohibiting him from using the vehicle until the defect has been rectified.

35.�� VEHICLES POWERED BY LIQUID PROPANE GAS (LPG)

(i) An applicant for a licence involving a vehicle that has been converted to run on LPG is required to produce, prior to a licence being issued, a certificate issued by a member of the LPG Association confirming satisfactory installation, examination and testing of the vehicle in accordance with LPG Association Code of Practice; and that the vehicle is therefore considered Safe.

(ii) If an LPG conversion involves installation of an LPG fuel tank in a �� vehicle�s boot space (and possible relocation of the spare wheel) it �� shall be a requirement that an amount of space shall remain free for �� the stowage of a reasonable amount of luggage and any spare wheel �� displaced as a result must be stowed in a location that does not �� impinge on the passenger carrying area of a vehicle.

36.�� SEAT BELTS��

�� All vehicles must be fitted with fully operational seat belts, one for �� each passenger to be carried, fully compliant with British Standards �� except where the law specifically provides an exemption. It is the �� driver�s responsibility to ensure that all passengers under 14 years of �� age use an appropriate child restraint or wear a seat belt.

37.�� FIRST AID KIT

�� There shall be provided in such a position as to be readily available �� at� all times when the vehicle is used for hire, a suitable First Aid �� Kit containing appropriate dressings and appliances for �� immediate use in an emergency for the drivers use only.� A first aid �� kit is mandatory for self employed drivers for their personal use.

38�� LICENCE PLATES AND STICKERS

(i) At all times while the vehicle is being used as a hackney there shall be securely fixed to the rear of the vehicle the appropriate vehicle licence plate supplied by the Council.

(ii) The number of persons licensed to be carried in the vehicle shall be exhibited outside the vehicle on the Vehicle Licence Plate referred to above. (For these purposes children (of any age) are counted as one person).

(iii) At all times while the vehicle is being used as a hackney carriage there shall be displayed on the windscreen of such vehicle (top left-hand corner of the windscreen) the internal licence plate, which identifies the vehicle as either a private hire or hackney carriage vehicle.� On this will be displayed the registration number of the vehicle and the number of passengers permitted to be carried.

39�� CHANGES / TRANSFER

(i) Notice in writing of any transfer of licence must be given notified within 14 days the Licensing Authority as per section 49 LGMPA 1976.

�(ii) When the holder of a vehicle licence wishes to transfer the licence to another person he must notify the new proprietor that it is their responsibility to notify the Council, in writing, as failure to do so is an offence.

40�� INSPECTION

�� The vehicle licence must be available for inspection at all times on request � by any authorised officer of the Council or any Police Officer.

41�� UNAUTHORISED USE

The licensee shall be satisfied that every driver engaged/allowed by him/her to drive the licensed vehicle is the holder of an appropriate and current� European Driver's Licence and a Hackney Carriage/Private Hire Drivers Licence issued by the Council.� The licensee shall also ensure that the Driver's Badge is worn in accordance with the conditions/byelaws attached to the Hackney Carriage/Private Hire Driver's Licence.

42�� ACCIDENT REPORTING

(i) If a licensed hackney carriage or private hire vehicle is involved in an accident, this must be reported to the Council within 72 hours of the occurrence.

�(ii) Where, following an accident or damage to a licensed vehicle, it is the intention of the owner or operator to continue licensed use, the vehicle must be inspected (at the owner�s or operator�s expense) to determine its fitness for continued use.� A Licensing Officer may use delegated powers to suspend the use of a licensed vehicle until it is suitably repaired.

(iii) A licensed vehicle which has suffered major accident damage or requires substantial mechanical repair may be replaced by a hire vehicle, provided:

� the damage to, or defect in, the vehicle has been reported;

� application is made in the usual way for a change of vehicle �� (albeit temporarily);

� the replacement vehicle meets the licensing criteria and is �� suitable to be used for hire purposes;

� the hiring of the hire vehicle is organised and paid for by the �� affected licensed owner or operator.

43�� MISCELLANEOUS

�� The proprietor shall not knowingly cause or permit the vehicle to be used �� for any illegal purpose whatsoever.

44�� DISPENSATION/ VARIATION OF CONDITIONS

�� The Council may in exceptional circumstances by way of special condition �� dispense with or vary any of the conditions set out herein.

NOTE: �� The word �approved� throughout this specification means, approved by Maidstone Borough Council. No application shall be considered where the proposed vehicle is already licensed by another licensing authority (commonly referred to as �dual plating�).