Letter to the Mayor Regarding Taxi Age Limit... by Alan Fleming.

THESE ARE THE MEN WHO SIGNED THE AGE LIMIT

  DEATH WARRANT

Last Supper for the Fairway.

Left to Right Steve Mcnamara, LTDA, Ivan Kovler LMCPA, Rob Laidler LTI, Geoffrey Riesel RTL, Malcolm Paice Com Cab, Mike Hedges UNITE, Brian Rice DaC, Eddie Crossley LMCPA, Peter Da Costa KPM. Spot the Taxi Driver...


The Mayor of London
Mr.  Boris  Johnson
City  Hall 
The Queens Walk
SE 1  2 AA


7 / 11/ 2011


Dear Boris.
Re your taxi age limit policy starting on Jan 2012
There are many reasons why I think you should reconsider this decision which are set out below and I have highlighted the points that you should be made aware of.
There is no need for an age limit as there is a retrofit system that brings a taxi up to the Euro 4 emissions standard, and therefore reduces emissions pollution.
The system is made by HJS Emissions Technology a German company. This system has been widely used by car manufacturers all over Europe since 2004, and has been approved by the German vehicle inspectorate. This system was approved by the UK  Vehicle Certification Agency (VCA) on 28th Jan 2011, and accepted by TFL. TFL have approved it for buses coaches and vehicles of taxation class N1 N2 N3, the taxation class for London taxis being N3.  However, TFL will not approve the system for London taxis, the question is why not?  


This system reduces NOX from  89 grams per 100 miles to 16 grams per 100 miles which is far better than the current euro 4  taxis. The system will bring those older cabs up to the Euro 4 emissions standard. . So as TFL have approved the system to be fitted to the old London buses to bring them up to the Euro 4 emissions standard, they should approve it for the old London taxis. The bus engine is a 9 litre engine which is three times bigger than the 2.7 litre taxi engine, so if buses can be retrofitted with this system, so once again why not taxis.? 


Further TFL have announced that  from Jan 1st 2012 all commercial diesel vehicles entering London That weigh between 1.25 tons and 3.5 tons must be a minimum of Euro 3 emissions standards, so why are London taxis not afforded the same right, as taxis come within this weight as they are 2.25 tons, and further all London taxis are minimum of Euro 3
Many  of the old  London  buses   range between  20/40 years the oldest London taxi is 23.  John  Mason  Director  of  Taxi & Private Hire states that the policy is not only linked to air quality but to the quality of the taxi fleet itself. The reason being that a significant proportion of the taxi fleet is quite old.  And the replacement of the older taxis will improve the safety for drivers and passengers that the more modern vehicle provides. If this is correct then  the more modern buses must offer better safety facilities than the older buses, therefore the old London buses should  be scrapped also. This is double standards and discriminatory. 


It has been announced by TFL  that all new cabs entering the fleet from Jan 2012 must be Euro 5. So what will happen to those Euro 4 cabs that  (M&O) Mann & Overton the main dealer currently have in stock? For according to TFL’s  decision those vehicles cannot enter London‘s taxi fleet in 2012.  However, M&O are converting these engines to bring them up to Euro 5. They are doing this by changing  the (EGR ) valve, exhaust gas re-circulation. Also a filter trap is being installed into the exhaust and a new electronic control unit. Therefore if this is allowed by TFL they should allow this for the older Euro 3 taxis, again double standards are being applied.


In  2007  the previous mayor Ken Livingston ordered that all taxis must meet the Euro 3 emissions standard. 10.000 taxis had to be retrofitted at a cost of  £2000 each. Now 4 years later you as  mayor have decided that those taxis will not be  re- licensed when they are 15 years old. This is an illogical decision and also unfair to the owners of these vehicles. They spent thousands converting those cabs and are know being told they will not be re-licensed. Thousands of drivers are going to be put out of work and many fleet owners will close down. This at a time when it has been announced that London  has the worst unemployment figures in the UK. London’s taxi trade has played its part in cleaning up London’s air quality and should not be further penalised in this way. The age of the cab is irrelevant as it is the engine that produces the emissions. Your policy states that no taxi over 15 years will be licensed except by special exemption, but does not state what those exemptions are. Our solicitors contacted them and asked what those exemptions where. TFL then consulted with the trade and stated that  taxis would be able to continue in service for a further 5 years, if they converted to LPG, CNG, or Bio-methane. These exemptions are to rigid and is not much of an alternative. The reason being that LPG is unreliable, CNG cannot be purchased in the UK let alone London, and further Bio-methane is also not readily available 


However, in the policy it makes no mention  of extending the life of the cab. Therefore if the cab is converted to any one of these exemptions its life should be unlimited. Further your policy is in conflict with the Govt, as Govt policy states in its best practise guidance that, an age limit should not be placed on London taxis, and that each taxi should be licensed on its own individual merits.
TFL claim that  drivers can by a new cab which is not feasible as most of these older cabs are owned or rented by the older drivers, who work part time to supplement their pensions. There are currently 6000 drivers between the age of 65 to 75, and they would not want to take on a debt of £36k at that age. TFL will say they could buy a newer cab this is an irrational statement.  As the driver would be buying a cab which is of the same emissions standard as the one they are being forced to scrap. Renting a cab would not be an option as garages will only rent cabs on a weekly basis. Therefore those drivers are being deprived of their right to work which is a breach of their Human Rights. Further. this discriminates against the older driver and is age discrimination. 


TFL have also claimed that those cabs that are being taken out of service will be replaced. However, I do not believe this will happen for the following reason. Before the age limits where announced a 7 or 8  year old cab could have been sold for approximately  8K  now they would not raise half that amount.  So drivers contemplating buying a new cab will have less money for a deposit, therefore their repayments will be much higher. This I think will put them of from buying a new cab. Further it was announced this year that all vehicles registered from 2008 must meet a new smoke test. It has been reduced from 2.5 to 1.5, but this does not apply to vehicles registered before that date. Therefore we have to assume that it is recognised that the older vehicles are cleaner than the newer ones.


By  the end of 2012 over 3500 cabs will be of the road due to this policy, this will cause problems for public transport.
When the games start there will be 2400 cabs of the road and as each cab carries 30 passengers a day, this will mean over 70.000 people each day having to turn to public transport. Considering the number of visitors who will be here for the games  public transport will not be able to cope. Further  disabled people especially  wheelchair users will be the most affected, as taxis are the only vehicles adapted to carry wheelchairs. The Paralympics will also be affected for those who wish to see the events and they will find it extremely difficult to make journeys to the games. I therefore think that the start date of your decision should be put on hold until after the games.


Your decision  will put thousands of drivers out of work. And the fleet owners will have to lay of staff as there will be less cabs to maintain.
The rent on those older cabs was invested in new cabs as this income will no longer be available new cabs will not be viable. The mayor should consider this decision and postpone the start date for one year, to allow fleet owners and drivers to make new arrangements.


Finally you claim that taxis are responsible for 30% of emissions pollution,
I believe this is an inaccurate figure. And I would like to know what tests have been carried out to support this claim.
The London Atmospheric Emissions  Inventory commissioned by the London Assembly in 2004 states that road transport would be responsible for 31% of total NOx  emissions in 2010,  so it is illogical to claim that taxis are responsible for 30% of that figure.
Cars and rigid HGV’s  are the 1st and 2nd largest contributors to the total NOx from road transport. Regarding PM10, particulate matter cars and HGVs are again the 1st and 2nd largest contributors in 2010, cars being responsible for 60%  and HGVs 19%. So how do you and your advisers come to the conclusion that taxis are responsible for 38% of PM10 emissions as the figures do not add up.
You once said in a letter to me that you would welcome my advice on the cab trade, I am therefore requesting that we meet to discuss this matter.
Yours faithfully


Alan Fleming
Director
Taxi Drivers &Owners Legal Protection.


Editorial Comment:
As of yet the Mayor has not replied...