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And Then There Were None.....
The Jacobs Report
LCDC
FEBRUARY 2017
1
THE JACOBS REPORT
On December 8th, 2016, Grant Davis and I attended the quarterly Licensing and
Compliance Meeting at 230, Blackfriars Rd, SE1, during which Lilli Matson and her
two colleagues gave a presentation on ULEZ.
After the meeting, an email was sent to Lilli Matson, TfL's Head of Strategy and
Outcome Planning.
Dear Lilli,
During the recent TPH Licensing Meeting, your colleagues, Sam & Oliver gave Taxi
Trade Reps a presentation on TfL's plans for ULEZ that was extremely unconvincing.
Towards the end of the meeting I emailed everyone the Jacob's Report a.k.a The Ultra
Low Emission Zone Integrated Impact Assessment (Economic and Business Impact
Assessment) from October 2014 which you all denied was current TPH Policy.
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-
iia_ebia_fi nal.pdf
It may not be policy now to drop the age limit from 15 years to 10, but it has obviously
shaped certain previous policies and should have served as a warning to anyone reading
it. Are you honestly saying that you and your colleagues have no knowledge of the
contents or the implications for the Cab Trade?
We've had the impact of
Uber
on the taxi trade for over two years, now, since this report
was written. The data used is even older and I would think extremely unreliable. It's
quite clear that almost 120,000 PHV's all converging on Central London, and
encouraged by the PH Operator Über to c
luster
around major transport hubs and
Terminals, mainly parked illegally, does nothing to help congestion.
In fact, it's doing everything to harm the traffi c flow causing people to avoid taking a
bus or getting a taxi and forcing them onto an already over-crowded Tube system. One
must fi rst reduce car ownership and usage before building up a fleet of vehicles to
replace it.
What TFL have done is allow PH Licences to explode into the taxi market by stealth
and then apply market forces to be used in the taxi market for the very fi rst time,
exploiting a weak regulator who still expects high standards from the present
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THE JACOBS REPORT
incumbents. It's not a level playing fi eld and the regulator was, according to the Tories
in the Assembly, 'an absentee' one. The ironic thing is, the previous Mayor and
regulator was a Conservative one!
'TfL has consistently been charged with being an absentee regulator.' Section 3.
http://glaconservatives.co.uk/wp-content/uploads/2015/12/saving-an-icon.pdf
Lilli, despite Silka Kennedy Todd's protestations that these concerns have been
addressed in correspondence and meetings, that is simply untrue. I intend to print this
email in our Trade newspaper, The Badge, which we also send to a number of London
Assembly Members and MP's. It will also go to the TfL Board in due course.
As of yet, we have had no reply to our concerns. We'd very much like a response from
TfL and some chronological data of your plans for the implementation of infrastructure,
and how Taxi Drivers will be able to afford to purchase a vehicle which is expected to
cost in the region of £50-60,000 with a grant, on average of £7,500 but possibly up to
£12,500.
Quite frankly, and excuse my plain speaking, but based on your presentations, your
plans are laughable!
Your policies have brought London to a standstill and our Trade has been decimated.
Speeds across London are slower than a
Horse & Cart and I'm constantly apologising to
customers about the congestion you have created at Midnight!
Prior to the meeting, I asked you to justify TfL's Wheelchair Accessible Vehicle policy.
Instead of replying to me, you passed my correspondence back to Silka, like an irritated
elephant would swat a fly. One of the direct consequences of your policies will be the
death of the WCA Taxi. Do you realise that?
Please do not do disregard this email. I expect you and your colleagues to show my
colleagues and I some courtesy and respect when we ask you to justify the policies that
affect our businesses.
The bigger picture here, is that we are amongst the worst affected by the pollution and
congestion that we sit in. Its affecting all of our Members, who are dying prematurely
and suffering health risks.
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THE JACOBS REPORT
I look forward to a prompt reply. We go to print in mid-January.
Yours sincerely
,
Mark White
(LCDC
)
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THE JACOBS REPORT
Ultra Low Emission Zone Integrated Impact Assessment:
Economic and Business Impact Assessment
October 2014
https://consultations.tfl.gov.uk/environment/ultra-low-emission-zone/user_uploads/ulez-
iia_ebia_fi nal.pdf
The relevant section is:
7.6 Taxis and PHV4
(a) Taxis
7.6.2 In London, all taxi (black cabs) and private hire services have to be licensed by
TfL. Taxis can be hailed in the street, hired from ranks throughout the city or pre-
booked. All are accessible. PHVs can only be pre-booked and are not wheelchair
accessible, except for a small proportion of specially adapted vehicles. Under the present
proposals, from 2018 all new taxis and PHVs (including minicabs) must be zero
emission capable alongside an accompanying reduction in the maximum vehicle age
limit for taxis in 2020. However, TfL proposes to exempt taxis from the ULEZ charge.
7.6.3 There are more than 22,000 licensed taxis in London and nearly 25,000 taxi
drivers, the vast majority of which operate within central London. Of these 25,000
drivers, there are approximately 3,600 suburban drivers that can only collect fares in
the area they are licensed for, they can take passengers anywhere in London but then
must return to their licence area to accept another fare. Whilst almost 50 per cent of
taxis enter the proposed ULEZ over 200 times a year, 18 per cent enter ten times a year
or less, which broadly equates to the suburban drivers.
7.6.4 Taxis are principally a central London transport mode, with 84 per cent of all taxi
trips taking place within, to or from central London, and 30 per cent beginning and
ending within it. On an average day, about 185,000 passenger-carrying taxi journeys are
made carrying 278,000 passengers.
7.6.5 Taxi use by time of day and day of week is shown in Table 7-D. As can be seen, the
majority of trips are during the Monday to Friday working day, with relatively few
trips at night or at weekends.
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THE JACOBS REPORT
7.6.6
A signifi cant proportion of taxi trips at all times are to and from work (around a
quarter), particularly between 20:00 and 06:00. A number of employers will pay for
taxis for employees working anti-social hours, while some employees will use them to
avoid public transport at these hours. In total, around 40 per cent of taxi trips are work-
related. The remainder are for leisure, shopping and personal business.
7.6.7 It is estimated that around a fi fth of taxi passenger trips are made by overseas
visitors and a further fi fth by domestic visitors to London.
7.6.8 The reduction in the maximum age of non-zero emission capable taxis from 15 to
10 years, as required by ULEZ, will require around a third of vehicles to be replaced
sooner than would normally be the case. Taxi drivers with older vehicles can: invest in
new vehicles, including second hand that meet the age limit but availability of the latter
is expected to be virtually nil; or withdraw from the market.
7.6.9 Virtually all taxi drivers are self-employed and would therefore have to bear the
cost of a new vehicle themselves while at the same time seeing the value of their present
taxi diminishing. With a new zero emission vehicle costing approximately £40,000, and a
high proportion of drivers over the age of 50, there is a risk, even with mitigation, of an
exit of drivers and vehicles from the market.
7.6.10 The alternative view is that there will be a greater sharing of taxis – at present
there are around 13 per cent more drivers than taxis. However, as peak demand for
taxis is during the working day, an overall reduction in taxi availability could still have
an impact. It is also worth noting that the number of drivers continues to increase
despite restrictions, such as the 15-year taxi age limit (introduced in 2012), being
implemented.
7.6.11 If data on the number of registered drivers is a good indicator of relevant market
share, it would appear that taxis have been challenged by PHVs in London over the last
decade.
7.6.12 With the growing use of mobile apps to pre-book PHVs, the pressure on taxis is
likely to continue, although nearly half of all taxi trips start from being hailed on-street.
Outside central London, the suburban taxi market, where earnings tend to be lower and
competition from PHVs higher, could see the biggest decline in taxi availability, if
drivers decide that the ability to make a reasonable return on a substantial investment
declines.
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THE JACOBS REPORT
7.6.13 TfL is proposing mitigation measures that will compensate taxi drivers who need
to replace their vehicle earlier than expected. At this stage it is not clear what the take
up of this measure will be and it would be prudent to assume some drivers may decide
to leave the sector. With enough advance warning of the proposed changes, it is
anticipated that the supply industry will be able to cope with increased demand for new
vehicles.
7.6.14 A reduction in taxi availability will have an impact on business to business travel
and tourism travel, making central London a slightly less attractive location to do
business or visit, but this is not expected to be material.
7.6.15 As taxi drivers are self-employed the impact is considered by the EqIA. There are
a number of SMEs that depend on taxis, from owners of fleets to those who maintain
and service vehicles. A reduction in taxi numbers will impact on these businesses.
However, it is envisaged that any reduction in taxi numbers will be offset by increased
numbers of PHVs leading to off- setting benefi ts elsewhere.
(b) PHV's
7.6.16 There has been a substantial increase in the number and, hence, presumably the
use of PHVs in recent years (see Table 7-E). Much of the data presented below, which
comes from 2009, is likely to underestimate the present position. It does however
provide a comparison with the taxi data above. The market has been split into two sub-
sectors; standard minicab operations and chauffeur/executive services.
7.6.17 Minicabs are estimated to carry around 230,000 passengers a day and chauffeur/
executive services a further 50,000 a day. Therefore, these services carry broadly the
same number of passengers as taxis, but in different parts of London. While taxis are
concentrated in central London, minicabs are predominately used in outer London,
with over half of minicab journeys taking place within the outer London boroughs.
7.6.18 Executive services are more dispersed, although there is a high proportion of
airport related trips and trips to outside greater London.
7.6.19 There are other major differences between taxi and PHV use with the latter used
far more at night.
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THE JACOBS REPORT
7.6.20 As with taxis, around a quarter of all PHV trips are to and from work, including
those undertaken at night. In-work trips account for a further 10 per cent of PHV trips
and 40 per cent of executive/chauffeur trips.
7.6.21 Minicabs are used less by visitors and tourists than taxis, accounting for just 11
per cent of trips. However, for executive/chauffeur services they account for 39 per cent,
reflecting a high proportion of airport-related work.
7.6.22 Given the younger age profi le of most PHVs compared to taxis, a higher
proportion of vehicles are expected to be compliant. In addition, there is a wide range of
alternative vehicles, including second hand petrol vehicles, enabling drivers to change
vehicles if needed.
7.6.23 The majority of minicab trips do not enter the proposed ULEZ and large fleet
operators may have some flexibility in moving vehicles around, although most drivers
are self-employed and there may well be earning implications for individuals. So while
there will be an impact on individual drivers, it is not anticipated that there will be a
material impact on the availability of minicabs in central London, and hence no impact
on London’s economy or SMEs.
7.6.24 There are also other PHV operators, in particular tour guides and those who
operate contracts for local authorities (e.g. for travel to and from school). These may use
different types of vehicles to those commonly used for minicab purposes given the
nature of the work they do and new vehicles that are compliant with the requirements
for newly licensed PHVs may not be available in 2018 or may be too expensive for some
PHV operators and drivers. While some individuals may be impacted by the ULEZ, the
likely impact on London’s economy as a whole is minor.
7.6.25 PHV operators and drivers, who need to replace vehicles to become compliant
with ULEZ proposals, are able to access the plug-in car and van grants from the Offi ce
for Low Emission Vehicles (OLEV). This is a grant of 25 per cent towards the cost of the
vehicle, up to a maximum of £5,000, when purchasing a qualifying ultra-low emission
car and registering it for the fi rst time in the UK.
(Most of the data in this section is taken from Taxi/PHV Diary Survey 2009 prepared
for TfL by GfK Consumer Services January 2010)
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THE JACOBS REPORT
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THE JACOBS REPORT
