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I did ask the question on another thread regarding what license the driver would need. It may be that a D1 would no longer be required and a Private Hire drivers badge would be acceptable if the vehicle is going to be licensed as a PH. If a 16 passenger vehicle is used on a restricted PCV license then it can't be booked in the same way as a private hire vehicle. This is probably one reason why the change is being proposed. Currently all seats have to be offered for passengers at separate fares and all seats must be available. You can't just book a party of 12 in the vehicle without the remaining seats being offered to the general public.
I ran a Minibus for a few years under a restricted Licence (Orange Disc) and it was pre-booked in the same way as my PH Vehicles were.
The Only stipulation to running up to 2 Minibuses on a Restricted Licence was that they were not your main source of Income and run as a sideline to your main business..In my case PH. I had to pass a D1 PCV test, Licence the Minibus with VOSA and the Traffic Commissioners and have a COIF for the Minibus.
Bookings were taken no differently to my PH bookings though I did trade under a Different trading name to my PH business but only so as i could become voluntarily VAT registered for the Minibus business not for the PH side of things. This meant I was VAT registered but did not have to charge VAT on the Hire costs but still could reclaim VAT back on fuel.