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Mr Mark Toohey
Principal Trading Standards Officer
Trading Standards & Licensing
Magdalen House
30 Trinity Road
Bootle Thursday, 19 June 2014
Liverpool, L20 3NJ
Ref: SEFTON KNOWLEDGE TEST
AGENDA ITEM for TRADE GROUP MEETING 29th July 2014
THE KNOWLEDGE TEST
Delta proposes scrapping the knowledge test for private hire drivers whilst retaining and updating the test for hackney carriage drivers. On face value, the need for a knowledge test for both tiers of driver would appear obvious and self evident. By the end of this document however I hope to convince you otherwise…
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WHY NOW?
The Law Commission's long awaited and recently published taxi and private hire report heralds a new Age of Enlightenment for the hire and reward industry. Honouring the cultural movement of intellectuals that began in late 17th-century Europe, it's authors seek to reform our legislature using reason, to challenge ideas grounded in tradition and to advance public and private hire services through an altogether more scientific approach.
In doing so, Law Commission analysts set out their stall from the very outset by cutting straight to the heart of the fundamental difference between taxi and private hire services. They observe that the pre-booked market works well as a competitive market and conclude therefore that we can leave it to market forces to regulate pre-booking price and quality. Hailing and ranking, however, cannot operate in a normal competitive way, because of the nature of the transaction. In hailing and ranking, the consumer, at the actual moment they engage the taxi, is in practice facing a monopoly supplier, justifying higher levels of regulation both in relation to price and quality.
Nowadays, whenever pre-booked passengers use their landline, smart phone or computer to 'summon' a taxi or private hire vehicle, they quite literally have access to an entire world of competing suitors, where market forces will inevitably and unwaveringly drive standards and costs in the direction of consumer interest. Fierce competition must of course never be allowed to compromise public safety, hence the Commission's core recommendation to impose an all encompassing safety standard across both tiers of the trade.
Once you grasp their clearly stated principal of the 'there and then' hiring versus the 'shop around' hiring, the Commission’s recommendation to apply variable levels of regulation to both tiers of the trade makes perfect sense.
There and then hirings require quality control at a regulatory level whilst the quality measures applied to advanced bookings can and should be left entirely to market forces.
If there are passengers out there who genuinely want cheaper drivers with limited road knowledge and a Sat Nav then why should locally adopted conditions of licence deny consumers that freedom of choice? Sefton residents can and do order Liverpool licensed drivers who haven’t been tested on the Sefton area so why can’t they order Sefton licensed drivers who also haven’t been tested on the Sefton area?
Granted, the recommendations contained within the Law Commission’s report may or may not go on to become statute, but one cannot deny the flawless logic of the brilliant minds that have spent the last few years analysing our industry to higher levels of sophistication than ever previously witnessed.
Whatever the outcome of the report, scrapping the knowledge test for private hire drivers (in keeping with Law Commission recommendations) is within the power of our local authority ALREADY, RIGHT NOW. If the Law Commission’s cleverly thought out justification for doing so isn’t in itself already enough to convince members to scrap the private hire knowledge test then please read on…
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QUALITY CONTROL or QUANTITY CONTROL?
Whilst it may appear desirable to licence only drivers who can demonstrate great feats of memorising pre-determined routes, the undeniable consequence is the detrimental impact this has on the number of applicants successfully entering the trade. Shortly before the test’s introduction Mr John Birchall from Sefton’s legal department revealed to the Liverpool Echo “Neighbouring authorities like Liverpool and Knowsley have a test which they say helps restrict the number of licences.” (Published 16.12.1991). He was spot on … figures I obtained from Sefton 6 months after the test was introduced confirmed that new recruits had fallen by 86% when compared with the same period the year before.
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HOW GOOD IS THE TEST?
In a word… useless!
In all honesty it is no more than a memory test, which has absolutely no bearing on a drivers’ ability to navigate. You memorise the routes in advance and regurgitate them back onto a piece of paper. It is a tick-box exercise applicants must complete to get their badge; an exercise which has zero practical benefits for drivers or customers (though it must be said that drivers who are already licensed might argue that it protects their financial interests by restricting others coming into the trade to share their spoils). To illustrate just how futile such tests are as a quality control, I asked one of our experienced drivers to provide me with a critique of the Sefton test in its current format. Out of all 40 routes he was able to immediately identify no fewer than 30 that were flawed in one way or another… some of them had shorter routes available, some were using obsolete place names, some had roads missing entirely from the route whilst others gave directions to or from places that no longer exist (such as Walton Hospital). A mere quarter of the routes were correct and fit for purpose, yet this has remained the so called benchmark of quality within Sefton for over two decades!
We lay no blame or complaint with the Council for failing to update the routes, I raise this merely as testament to how valueless such tests are, and why the Law Commission’s appraisal presents us with the perfect opportunity to finally do something about it.
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WHICH AREAS SHOULD BE TESTED?
Sefton Hackney Carriage vehicles may ONLY be flagged down within Sefton. Hailing is a local provision which therefore lends itself to local knowledge testing. But for private hire drivers who can (and regularly do) service customers throughout the rest of the country, which areas if any should you include on their test? It simply isn’t practical to test them on the whole of the UK, and if our drivers can manage perfectly well OUTSIDE of Sefton where they haven’t been tested, why is it so important to test them on areas INSIDE of Sefton? Our best growth areas are all in the South of Liverpool, completely beyond the scope of the Sefton test. If our drivers, who haven’t been tested on South Liverpool, can continue winning work off Liverpool licensed drivers who HAVE been tested on South Liverpool, doesn’t this prove categorically that knowledge tests aren’t the be all end all for customers?
As already mentioned, Sefton residents do of course on occasion pre-book drivers licensed by neighbouring authorities such as Liverpool, Knowsley, Wirral and West Lancs, none of which have passed a Sefton Knowledge test. If their drivers can service Sefton without a Sefton test then why shouldn’t our drivers be able to do the same?
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SAT NAV
Computer aided navigation has moved on immeasurably in the 22 years since the test was introduced and has totally transformed our industry. In bygone days, radio controllers had to be highly experienced taxi drivers with bulging brains crammed with data so as to be able to direct drivers radioing in for assistance. That’s now a thing of the past. New age radio controllers have lightening fast fingers to access Google street maps and other comprehensive street directory data modules collated from tens of millions of journeys. Such operators need computer skills, not memorised road knowledge, so that within seconds they can locate pretty much anywhere on the planet and map you a variety of routes to anywhere else.
As well as having constant access to hi-tech radio controllers, our drivers are all supplied with a perfectly adequate Sat Nav to supplement their road knowledge. If customers had to choose between a knowledgeable driver and an inexperienced driver with a Sat Nav, then no doubt they would opt for the knowledgeable driver. But given the choice of an inexperienced driver with a Sat Nav, or no driver at all, what would you prefer on a Saturday night?
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HOW IMPORTANT IS ROAD KNOWLEDGE?
With the greatest respect to fellow trade and committee members, the people best placed to decide the quality control measures that will benefit our customers the most is the service providers themselves. Service providers will quite naturally have a far more intimate understanding of their customers’ needs than anyone outside of their operation. We re-iterate, safety is paramount and as suggested by the Law Commission must always remain mandatory across both sides of the trade. Quality control measures such a knowledge tests on the other hand can and indeed should be left to market forces when it comes to pre-booked journeys. An example of market forces in action is the fact that Delta has invested hundreds of thousands of pounds into training its drivers in skills such as the safeguarding of vulnerable adults and vulnerable children, visual and hearing impairment awareness training, emergency first aid and the transportation of bloods and specimens. We do not do this because of locally imposed conditions, we do it because we believe these skills are valued by our customers and they are skills which cannot be supplemented by technology. Road knowledge can however be supplemented by technology so we continue to invest millions of pounds in navigational equipment rather than navigational memory tests.
Sefton’s current private hire driver licence conditions are therefore in effect forcing us to operate with too small a volume of drivers (all knowledge test graduates), which renders us unable to adequately service our customers during peak periods. What we believe our customers would prefer is a large volume of Sat Nav drivers who haven’t passed a test but who ARE fully supervised by radio controllers in exactly the same way as police, ambulance or fire engine drivers, and who are more likely to service the more unsociable times of peak demand.
If there are customers out there who do genuinely do value the knowledge test they will still of course be able to order hackney carriage vehicles driven by drivers who have passed the local test, which should remain in whatever format the Council deems fit. Who knows, if it provides anywhere near as much quality as their trade representatives might suggest, it could even spark a positive revival for their business.
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WHAT IF SOMETHING GOES WRONG?
Customers pre-booking via an operator are protected in law to seek compensation from the operator itself and not the driver. We record every journey and indeed every route taken and can therefore provide all necessary after sales resolution in the event of passengers being taken the wrong way. This is probably why Sefton licensing officers were able to confirm to me back in the 1990s that they didn’t have one single complaint on record pertaining to private hire drivers getting lost for the 6 years prior to the introduction of the knowledge test in 1992.
Hackney carriage drivers however are not required to record journey details, nor do they have to work via an operator. Unlike private hire drivers they may engage DIRECTLY with passengers so their after sales queries have to be dealt with by the Council itself (provided of course the customer had the presence of mind to take a note of the cab’s number before it drove off). It therefore makes perfect sense to regulate the hackney carriage industry of Sefton with a knowledge test that is regularly updated and made even more stringent for the protection of passengers exposed to the inherent risks of such provision. This is not the case with pre-booked private hire services for all the reasons given above.
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CUSTOMER CHOICE.
Sefton’s outdated knowledge test takes away from Sefton private hire operators the flexibility we need to tailor the quality of our product to the overriding needs of our customers. How much longer can we justify an obsolete condition of licence that serves no other purpose than to restrict availability for customers during peak demand?
Please, give us back the freedom to make our own business decisions in respect of what we believe constitutes quality and value, and let customers make their own informed choice between cheaper Sat Nav drivers or more expensive drivers who have memorised a string of Council approved routes.
In the fullness of time I personally think it will be inevitable that the Law Commission’s proposals will sweep away private hire knowledge tests from the whole of the country anyway, so why not just sit back and wait? Because business success doesn’t come about by waiting for things to happen, we need to seize the initiative now, we need Sefton’s elected committee members to support local businesses now. At a time when the Mayor of Liverpool sees fit to publicly call for a boycott of Sefton private hire services, Sefton operators need all the support they can get.
Yours faithfully
Paul McLaughlin
Company Secretary
Delta Taxis
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FAQ
can that really be good for business, to have the average quality and commitment of drivers take a nosedive? Besides, if the current test is simply a case of memorising some road names and has no bearing on local NAVIGATION (which it doesn't) then it shouldn't be too much of a barrier to entry anyway. It certainly wasn't for me.
