Thank you for the consultation document. While we broadly support your aim to increase public safety, this cannot be to the detriment of the local licensed trade. As such, we would like to bring to your attention the following points.

Disciplinary and Enforcement Measures:

• We welcome well-directed enforcement activity, but would like to know what percentage of this activity is likely to take place outside traditional working hours. Frequently, problems arise during our busiest times, particularly on weekends at night, when enforcement is less likely.

• Within the penalty points scheme, evidence of smoking or vaping in the vehicle attracts 3 points for the driver (27).

The policy does not specify whether it refers only to smoking and vaping by the driver. Although it is not legal to smoke in our vehicles and it is undesirable to allow vaping, it has to be accepted that it can be difficult for a driver to stop a passenger from doing so without risking their safety.

• Likewise evidence of food or drink in the vehicle attracts 3 points (28) but makes no allowance for the drivers entitlement to a break. It is not unreasonable to suggest a driver may want to carry a sandwich box in the boot and a drinks bottle in the locked glovebox, as hydration is vital during the summer months.

• Within the penalty points table (8,9,10, 20, 21 & 48), you are awarding points to proprietors and operators for things that are beyond their control. We, as a company, have a strict written policy that stipulates drivers must maintain the cleanliness of the vehicle at all times and that they must check items like tyres and lights before beginning work. In reality, although we do run random checks on the vehicles, we do not own the majority of them and do not see them on a day-to-day basis. As we support the spirit of this legislation, we would be more than willing to create a message on the driver's PDA so that they could acknowledge they had completed all of these checks before they could begin work.

• You are awarding operators and proprietors 6 points for failure to notify you of any motoring or criminal convictions or DVLA licence points within 3 days (48). Please clarify that you mean their personal information and not that of the driver, since we do not have access to this information.

• We understand the needs of those who use assistance dogs and wish to support them (31). We can exclude drivers that hold exemption certificates, making sure that a vehicle that can take the fare is dispatched at the first attempt, if you would be willing to share the exemption certificates with us.

Private Hire Drivers

• We note sections 2.1 (a, b, c & j). Enforcement of these sections must be across the board and must equally apply to private hire vehicles licenced in other areas that are operating in ours. Not doing so would disadvantage our local drivers and expose the public to unnecessary risk. We would suggest extending Geo Fencing to include Church Street, Newdigate Street and the rear of the Harefield Road rank.

• We would like to remind you that you do not have the power to attach conditions to the licences of taxi drivers. All conditions attached to licences have to pass the "reasonably necessary" test. Furthermore, by way of example, the council needs to provide firm evidence, beyond the mere subjective desires of either elected members or licensing officials, that carrying food and drink in the vehicle for consumption by the driver during the working day is a public safety issue.

• We reserve the right of appeal in the Magistrates' Court against any conditions attached to licences that fail the reasonably necessary test, in accordance with sections 47,48 and 51 of the LGMPA 1976.

• We want to take this opportunity to ask if you have considered our previous request to change the age limit for wheelchair accessible vehicles to 5 years. Accessibility for people with disabilities is becoming more difficult as the cost of these vehicles has increased.

Regards

Mr John Igoe

Mi Taxis Nuneaton

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