I notice that the revised Impact Assessment is now on the Law Commission's website

:
http://lawcommission.justice.gov.uk/doc ... ssment.pdfVersion 2 stated that there are 300,000 taxi and PH badgeholders, but that industry employment is 250,000, because "industry evidence suggests this to be a reasonable estimate of those actively engaged".
The revised figure is the same, but it's been refined to the extent that it now refers to 250,000
full-time equivalent active drivers:
Law Commission wrote:
Although there are approximately 300,000 licensed drivers, this includes both part time drivers and those who still have a licence but are inactive. Coming to a realistic figure for the total of full-time equivalent active drivers is not easy, and there is little data available. We accept that the concept of full-time equivalent active drivers is itself speculative given the wide variety of working patterns present within the trades. We suggest a range of active drivers between 200,000 and 300,000 with a best estimate of 250,000 full-time equivalent active drivers. We refer to this figure for the purposes of estimating the total revenue for the trades. However for the purposes of estimating training costs for example we have used a conservative figure including all licence holders.
We estimate current industry full-time equivalent employment to be around 250,000. This would accord with estimates from industry sources. As we have endeavoured to make clear, this figure is not based on very robust data, and we particularly welcome views on whether it is a reasonable estimate or not.
"Full-time equivalent active drivers" is an interesting idea. For a start I wonder what their assumption is regarding full-time hours, which presumably provides the basis for the full-time equivalent number of drivers?
For example, if three drivers worked 20 hours each per week, then if a full-time driver was assumed to do 40 hours then the three drivers would be treated as one and a half full-time equivalents. But if the full-time hours were assumed to be 60 per week, then the three part-timers would only be regarded as one full-time equivalent driver
And could one driver doing eighty hours (say) be regarded as two-full time equivalents? In which case it's possible that the LC could have come up with a figure stating there are more 'full-time equivalent' drivers than there are badges
And I wonder how they quantifed the amount of hours drivers were doing and how many of them there were doing however many hours per week.
Anyway, again they used the Office of National Statistics for
UK consumer spending on taxis and PH and have used the population figures to quantify a pro rata figure for England and Wales only.
Then they've used various hugely convoluted techniques to come to a total revenue figure (ie including business and tourist spending), and it seems that they've used four different methods, using the driver number figure above and also a quantification based on average taxi fares which also contains numerous assumptions.
Anyway, the whole thing looks very complicated, and a full critique would clearly take some time, assuming anyone has the time and inclination to have a look.
But even glancing through it it looks like it wouldn't be difficult to pick holes in the various figures and assumptions, but the language the LC uses clearly indicates that they know the figures will never be much better than rough estimates, and there's caveats all over the place, but most importantly:
Law Commission wrote:
There is currently no robust estimate of industry revenue which we feel confident in using. We have therefore attempted to estimate total revenue by using four different methods, We put the resulting figures forward as a basis for consultation. The critique to which our earlier approach to industry revenue was subjected has been very helpful in developing our current approach, and we hope that consultation will result in improvements to the assumptions we make. Because of our uncertainty over this critical figure, we have accepted the need for a large range.
So anyone attempting any kind of reasoned critique should have great fun, but I suspect a bit of abuse is the more likely response in this thread
