UCG ( United Cabbies Group) response to TfL Taxi Age Limit Proposals 
 
The London taxi trade is committed to reducing its contribution to NOx emissions and meeting its obligation to reduce these harmful levels of emissions and help clean up the air all Londoners breath . Our members are breathing this in daily. 
 
The Taxi trade is contributing to cleaning up London’s air, with the introduction of LEVC’s ZEC taxi . 
 
From January 2018 the only vehicle available to the trade was the LEVC . This is a Vehicle that the majority of the trade cannot afford. This vehicle was introduced before the infrastructure was in place, over 1,400 TXE’s are now out on London’s streets, and many more will be on the streets in the years to come .
 
The UCG welcome the news that the Mayor and TfL have reinstated £24 million to the taxi delicensing scheme earlier this year. These additional grants will go some way in helping those cabbies who want to invest in purchasing a ZEC taxi.
 
The UCG are greatly concerned that TfL’s proposals to reduce the maximum age limit for taxis will have a massive detrimental impact on the trade, if these proposals are implemented we believe the impact will be immeasurable with figures ranging from 45- 70 million being wiped off the value of the fleet . This would be devastating to the London Taxi Trade who are watching the erosion of our working practices with PH P4H via and app and the long term viability of the two tier system becoming questionable. 
 
The UCG firmly believes there is an alternative to TfL’s current proposals which would deliver greater NOx emissions savings from black cabs and protect the future of the London Taxi Trade. 
 
The UCG strongly disagree with TfL’s proposals to reduce taxi NOx emissions through a phased reduction in the maximum taxi age limit for Euro III, IV and V vehicles to 12 years by 2022, and to mandate the maximum taxi operating age, we believe that it is not the most effective way to reduce the trade’s contribution to NOx emissions in London, we believe it will have have a disproportionally negative impact on our members and the wider trades livelihoods .
 
TFl announced these proposals in December 2018 , since then the trade has experienced a significant fall in the second-hand value of London taxis, at the expense to their owners. The pre- owned market has been badly hit as potential buyers have been put of from buying a cab that may lose its value overnight if the proposals come into fruition. Under the current proposals, not only will taxi owner drivers see the equity in their existing vehicles fall dramatically, those drivers who rent will see their costs rise as the fleets shrink in size. This will see a decline in the value for older vehicles , and means that cabbies would need to find even more money to buy a new ZEC or Euro VI taxi, increasing the barriers to upgrading cabs and keeping many people driving older vehicles. Many of our members have planned their future taxi investments based on the value of their existing taxi ,and its expected licensing expiration age of 15 years. If these proposals are implemented it would put many drivers’ future financial security at risk and threaten their future livelihoods and their retirement plans.
 
The UCG does not agree with the proposals to remove the alternative fuel, historic and classic/niche, and hardship taxi age limit exemptions. We believe by removing these exemptions it would have a serious negative impact on the drivers of these vehicles , many of these are older members of the trade who do less mileage and do not serve central London, but they still rely on the income received from the passenger journeys that they carry out. Because these drivers work less hours they contribute a minimal amount to the trade’s emissions as a whole, and because of that removing these exemptions it is unlikely to deliver the significant emissions reductions that Tfl are seeking. It would have a major adverse impact on the livelihoods of these drivers. 
 
The UCG believes that by exploring things like retrofitting all licensed Euro V diesel taxis in London to a certified Euro VI standard, or encouraging more to look into LPG ,and also having the choice of more than one vehicle it would mean that more NOx emissions will be saved than if TfL reduces the taxi licence age limit from 15 to 12 years. 
 
The UCG recognise that Tfl have a duty of care to the wellbeing of Londoners and the toxic levels of pollution in London is a worry for us all and some action needs to be taken , we don’t believe TFL’s proposals of reducing the age limit of Taxis to be the best way forward, we believe there are viable alternatives 
 
It’s also worth noting that the UCG also acknowledges that Tfl have no duty of care to individual taxi drivers, but it does have a duty of care to the London Taxi Trade in its role as the regulator.The UCG believe that if Tfl implement these proposals it will bring into question just what duty of care TFL are affording the London Taxi Trade. The issue of TFL’s duty of care is an issue for a later date and to quote Mott McDonald is likely to be settled by a court of law. In closing the UCG are totally opposed to TFL’s proposals to reduce the age limits . 
 
Trevor Merralls
 
General Secretary 
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