LC; Genuine Fears

captain cab · **Posted:** Fri May 18, 2012 11:50 pm

Chris the Fish wrote:

Will the standard include the larger battery to power the film studio and sound recording engineering?

?

Chris the Fish · **Posted:** Fri May 18, 2012 11:59 pm

The thread that you instigated refers....

viewtopic.php?f=2&t=18904

Aint so funny when you have to explain it.

captain cab · **Posted:** Sat May 19, 2012 12:07 am

Chris the Fish wrote:

The thread that you instigated refers....

viewtopic.php?f=2&t=18904

Aint so funny when you have to explain it.

i didnt post that link

Chris the Fish · **Posted:** Sat May 19, 2012 12:09 am

No, you started the thread.

Dusty Bin · **Joined:** Wed Sep 03, 2003 3:20 pm **Posts:** 3272

captain cab wrote:

Again, to underline my point, this indirectly leads to the secret national standards they regularly mention - they rationalise the national standard by explaining that cross border doesnt matter because the standard of driver and vehicle will be the same countrywide......in other words if you agree we should have national standards, it follows that we should have cross border.

Well I've only read about half the Impact Assessment yet and only the first section of the main document :oops:

, but I think you've maybe got the LC's rationale for national PH standards wrong, or at least you're only partially outlining the LC's rationale for national standards.

Thus it seems to me that the rationale for national standards is that the LC thinks competition in the PH market is sufficiently good such that it only needs to be lightly regulated. Thus if customers want to pay rock bottom fares for bog standard PH then that's up to them, according to the LC. And if any operator wants to provide a better service and customers want to pay more for it then that's up to them as well. The national standard would be a minimum - operators wouldn't have to adhere to it if they wanted to provide a higher-quality service.

On the other hand, the LC is saying that competition in the taxi market - ie the rank and hail market - isn't good, so they're leaving it to LAs to impose local standards and fares.

So the LC may be making a link between national standards and the cross-border issue - but I haven't got to that bit yet - but they are linking the minimal national licensing standard for PH to the more competitive environment in the PH market, a fact that you haven't mentioned in your piece.

I can see their argument regarding a more competitive environment in the pre-booked market - although I only partially agree with it - but I can't really see the link between this and allowing cross-border hires, but it'll be interesting to read any argument that they do make in this regard.

captain cab · **Posted:** Sat May 19, 2012 9:06 am

Dusty Bin wrote:

captain cab wrote:

Again, to underline my point, this indirectly leads to the secret national standards they regularly mention - they rationalise the national standard by explaining that cross border doesnt matter because the standard of driver and vehicle will be the same countrywide......in other words if you agree we should have national standards, it follows that we should have cross border.

Well I've only read about half the Impact Assessment yet and only the first section of the main document :oops:

, but I think you've maybe got the LC's rationale for national PH standards wrong, or at least you're only partially outlining the LC's rationale for national standards.

Thus it seems to me that the rationale for national standards is that the LC thinks competition in the PH market is sufficiently good such that it only needs to be lightly regulated. Thus if customers want to pay rock bottom fares for bog standard PH then that's up to them, according to the LC. And if any operator wants to provide a better service and customers want to pay more for it then that's up to them as well. The national standard would be a minimum - operators wouldn't have to adhere to it if they wanted to provide a higher-quality service.

On the other hand, the LC is saying that competition in the taxi market - ie the rank and hail market - isn't good, so they're leaving it to LAs to impose local standards and fares.

So the LC may be making a link between national standards and the cross-border issue - but I haven't got to that bit yet - but they are linking the minimal national licensing standard for PH to the more competitive environment in the PH market, a fact that you haven't mentioned in your piece.

I can see their argument regarding a more competitive environment in the pre-booked market - although I only partially agree with it - but I can't really see the link between this and allowing cross-border hires, but it'll be interesting to read any argument that they do make in this regard.

I am referring to PH not taxi (for point of clarification).

The way I read it was that the LC intend to have a national maximum standard that a council cannot locally issue conditions contrary to or beyond.

A ph company can go beyond the national maximum standard, but not below it.

I was pointing out that they havent told anyone what the national standard will be, they dont know yet, however, they are basing almost an entire document on something they have neither told people about or dont know themselves. So people are merely guessing.

I think the two stories post above, where councils have licensed smart cars, will give a clue to the maximum standard as set by the LC......the maximum will be 2 doors, but as a company you may wish for more.

Dusty Bin · **Joined:** Wed Sep 03, 2003 3:20 pm **Posts:** 3272

captain cab wrote:

I was pointing out that they havent told anyone what the national standard will be, they dont know yet, however, they are basing almost an entire document on something they have neither told people about or dont know themselves. So people are merely guessing.

I think the two stories post above, where councils have licensed smart cars, will give a clue to the maximum standard as set by the LC......the maximum will be 2 doors, but as a company you may wish for more.

Well the Impact Assessment says this:

The Law Commission wrote:

These standards include, but would not be limited to:

1) for drivers: “fit and proper” person, medical, CRB checks, and disability awareness training.

2) for vehicles: roadworthiness standards and potentially accessibility for particular vehicles; and

3) for operators: “fit and proper” person.

In respect of PHVs which operate exclusively on a pre-booked basis, competitive forces work
reasonably well, and the argument for intervention beyond safety is not strong. We therefore
propose the national standards above would be mandatory so that local authorities could not
impose more stringent conditions and fees for issuing PHV driver and vehicle licences would be
set nationally. We would propose to maintain operator licensing as a useful layer of enforcement
and information gathering in respect of licensing functions for local authorities.

Clearly for PH drivers topo tests and the DSA test wouldn't be applicable. Thus it would just be a CRB and a medical. The disability awareness training would be a 'turn up and tick a few boxes' type of thing.

For PH vehicles presumably age and size rules and colour codes and the like would be out.

But the document is about the broad principles of regulation rather than the minutiae of how it would be implemented, so you don't really need to know every detail of what the standard should be.

At this stage it just looks a bit like nitpicking to question the validity of the whole thing just because every minor detail isn't outlined.

You should be critiquing and questioning the proposals at the level of broad principle rather than your approach above, as I assume the consultation questions aim towards. The details will come at a later stage.

If you don't like the idea of things like a very basic standard for PH or no cross-border rules then say so, rather than getting bogged down with what the minimum width of the back seat of a PHV might be, for example.

If you're not satisfied with the lack of detail at this stage then by all means you could try asking the LC for more information, but if you submit to the consultation complaining about a lack of detail rather than dealing with the substantive principles then it'll just look like you're trying to dodge the issues. :wink:

toots · **Posted:** Sat May 19, 2012 9:43 am

DB wrote:

Thus it seems to me that the rationale for national standards is that the LC thinks competition in the PH market is sufficiently good such that it only needs to be lightly regulated. Thus if customers want to pay rock bottom fares for bog standard PH then that's up to them, according to the LC. And if any operator wants to provide a better service and customers want to pay more for it then that's up to them as well. The national standard would be a minimum - operators wouldn't have to adhere to it if they wanted to provide a higher-quality service.

Most operator companies work on the basis that if they offer the cheapest fares and the fastest pick up times that is what the customer wants. They flood markets with vehicles and drivers who work long, unsafe hours. If you leave it to those operators to decide what standard of vehicle is required on their system to pay the £100 fee to work, do you really think they care. Do you think that companies will be 'self regulating' because that is what you suggesting will happen

captain cab · **Posted:** Sat May 19, 2012 9:49 am

Dusty Bin wrote:

Clearly for PH drivers topo tests and the DSA test wouldn't be applicable. Thus it would just be a CRB and a medical. The disability awareness training would be a 'turn up and tick a few boxes' type of thing.

For PH vehicles presumably age and size rules and colour codes and the like would be out.

But the document is about the broad principles of regulation rather than the minuatiae of how it would be implemented, so you don't really need to know every detail of what the standard should be.

At this stage it just looks a bit like nitpicking to question the validity of the whole thing just because every minor detail isn't outlined.

You should be critiquing and questioning the proposals at the levels of broad principle rather than your approach above, as I assume the consultation questions aim towards. The details will come at a later stage.

If you don't like the idea of things like a very basic standard for PH or no cross-border rules then say so, rather than getting bogged down with what the minimum width of the back seat of a PHV might be, for example.

If you're not satisfied with the lack of detail at this stage then by all means you could try asking the LC for more information, but if you submit to the consultation complaining about a lack of detail rather than dealing with the substantive principles then it'll just look like you're trying to dodge the issues. :wink:

I dont think its nitpicking, I think its being rather concerned the people deciding my future dont seem to be interested in the mechanics of the trades, sadly I'll still be here when they're busy on another project.

It suggests they aint particularly interested or knowledgable about certain issues.

Dusty Bin · **Joined:** Wed Sep 03, 2003 3:20 pm **Posts:** 3272

captain cab wrote:

I dont think its nitpicking, I think its being rather concerned the people deciding my future dont seem to be interested in the mechanics of the trades, sadly I'll still be here when they're busy on another project.

It suggests they aint particularly interested or knowledgable about certain issues.

Well you may have a point or two there, but on the other hand it would be ridiculous in a document of this type if precise specifications for vehicle and driver standards of this type were included.

And to be fair to the LC, who would you prefer to carry out such investigations and produce such reports?

I suspect you'd be making the complaints you outline above whichever body was looking into the trade.

Unless of course they come up with the 'right' answer :lol:

Dusty Bin · **Joined:** Wed Sep 03, 2003 3:20 pm **Posts:** 3272

toots wrote:

Most operator companies work on the basis that if they offer the cheapest fares and the fastest pick up times that is what the customer wants. They flood markets with vehicles and drivers who work long, unsafe hours. If you leave it to those operators to decide what standard of vehicle is required on their system to pay the £100 fee to work, do you really think they care. Do you think that companies will be 'self regulating' because that is what you suggesting will happen

You seem to be confusing the view of the LC with my own, Toots, but it wouldn't be the first time that the messenger gets shot in a scenario such as this.

Yes, many firms do compete merely on the basis simply of price and availability, but the LC's view seems to be that if that's what the customer wants then that's what they get. And if any customers want a better service at a higher price then that too is up to them and operators.

However, I'm inclined to agree with you about safety and the low wages as a consequence of light-touch regulation, but the LC seem to be taking a consumer-orientated approach to the various issues, so it's up to people like yourself to persuade them otherwise.

Assuming as the LC does that the market for PH services work well for consumers then perhaps it doesn't work so well from the point of view of the labour market, and that's essentially an argument between those who think that free markets work best and those who think that there should be some market intervention to ensure that wages and conditions conform to a certain minimum standard, ie essentially a right-wing versus left-wing stance from the political perspective.

On the plus side as I pointed out the LC has made some positive noises regarding the employmennt status of drivers, but how that will pan out remains to be seen.

Of course, in the end it'll all be down to the politicians, so there's a long way to go yet.

toots · **Posted:** Sun May 20, 2012 12:40 am

Dusty Bin wrote:

toots wrote:

Most operator companies work on the basis that if they offer the cheapest fares and the fastest pick up times that is what the customer wants. They flood markets with vehicles and drivers who work long, unsafe hours. If you leave it to those operators to decide what standard of vehicle is required on their system to pay the £100 fee to work, do you really think they care. Do you think that companies will be 'self regulating' because that is what you suggesting will happen

You seem to be confusing the view of the LC with my own, Toots, but it wouldn't be the first time that the messenger gets shot in a scenario such as this.

Yes, many firms do compete merely on the basis simply of price and availability, but the LC's view seems to be that if that's what the customer wants then that's what they get. And if any customers want a better service at a higher price then that too is up to them and operators.

However, I'm inclined to agree with you about safety and the low wages as a consequence of light-touch regulation, but the LC seem to be taking a consumer-orientated approach to the various issues, so it's up to people like yourself to persuade them otherwise.

Assuming as the LC does that the market for PH services work well for consumers then perhaps it doesn't work so well from the point of view of the labour market, and that's essentially an argument between those who think that free markets work best and those who think that there should be some market intervention to ensure that wages and conditions conform to a certain minimum standard, ie essentially a right-wing versus left-wing stance from the political perspective.

On the plus side as I pointed out the LC has made some positive noises regarding the employmennt status of drivers, but how that will pan out remains to be seen.

Of course, in the end it'll all be down to the politicians, so there's a long way to go yet.

You're right it doesn't take much to confuse me especially in threads of this nature. Having written to the LC regarding the employment issue of ph drivers and receiving their reply, it doesn't really matter how positive the noise is they make they are not looking into this issue and have said so. There is no other trade that allows it's drivers to work such long hours for relatively poor pay as they do in the ph sector. I'm all for a free market so long as that free market isn't dangerous.

Dusty Bin · **Joined:** Wed Sep 03, 2003 3:20 pm **Posts:** 3272

toots wrote:

You're right it doesn't take much to confuse me especially in threads of this nature. Having written to the LC regarding the employment issue of ph drivers and receiving their reply, it doesn't really matter how positive the noise is they make they are not looking into this issue and have said so. There is no other trade that allows it's drivers to work such long hours for relatively poor pay as they do in the ph sector. I'm all for a free market so long as that free market isn't dangerous.

Which once again is really just reiterating your previous point rather than addressing what I said in responsse.

As for the employment status issue, that's not really anything directly to do with licensing law, so to that extent I think it's an achievement that the LC have raised it at all.

captain cab · **Posted:** Mon May 21, 2012 8:34 am

Dusty Bin wrote:

As for the employment status issue, that's not really anything directly to do with licensing law, so to that extent I think it's an achievement that the LC have raised it at all.

Yeah, for documents relating to the future of taxis not to refer to licensing fees (save for 3 paragraphs) or taxi ranks or national standards is a mighty achievement. :roll:

toots · **Posted:** Mon May 21, 2012 8:39 am

DustyBin wrote:

Which once again is really just reiterating your previous point rather than addressing what I said in responsse

If I haven't addressed it then it's cos I didn't see any difference in what you've already said :wink:

Taxi Driver Online

LC; Genuine Fears

Who is online