Outcome of the Conditions of Fitness review

The recent review of the Conditions of Fitness, the first full review since 1961, has now been concluded. As part of the review the Transport Research Laboratory conducted a study in three parts:

  1. Consultation with users (including the London Transport Users Committee, disability groups, RoSPA, and the Metropolitan Police); providers (taxi trade associations representing drivers, proprietors, and radio circuits); and manufacturers/adaptors (including; LTI, Metrocab, CMAK, Jubilee Automotive Group);
  2. review of the existing Conditions of Fitness; and,
  3. review of the turning circle requirement.

In addition, TfL has undertaken some research into passengers' assessments of various vehicles; an industry analysis (including drivers' views of a range of vehicles) and has received numerous representations from a range of stakeholders.

Outcome

The outcome of the review is as follows. Where no change is indicated the existing requirements remain. A revised Conditions of Fitness will be published as soon as possible.

  • Dimensions relating to length, width and turning circle remain unchanged.
  • Dimensions relating to step height, door opening and door height remain unchanged pending regulations (expected next year) to be made by the Department for Transport under the Disability Discrimination Act 1995.
  • All vehicles must have European Whole Vehicle Type Approval to M1 standard in taxi configuration (in exceptional circumstances a lower standard of type approval may be accepted for a limited period where developmental or environmental benefits can be accommodated without sacrificing safety).
  • No left hand drive vehicles permitted.
  • If not fitted with 'taxi' tyres, vehicle tyres must be of appropriate speed and weight rating and compatible with meter (also see 'meters' below).
  • Braking assistance, e.g. ABS, to be fitted:
    • immediately for new models, i.e. models not currently approved for licensing;
    • from January 2007 for existing models, i.e. new vehicles of a design/type which is currently approved for licensing.
  • Enhanced interior lighting specifications.
  • Passenger compartment light switches and window controls to be within reach of wheelchair passengers.
  • Fire extinguisher not mandatory (following fire brigade advice that, for safety reasons, vehicle fires should be dealt with by professional fire-fighters).
  • Emissions proposals (subject to current final round of consultation):
    • 15 year vehicle age limit reducing (except for LPG vehicles) over 3 years to a 12 year age limit;
    • possible requirement for PM and NOx reduction equipment to be fitted on pre-Euro 3 vehicles.
  • Lap and diagonal seatbelts to be fitted on all, including rear facing seats:
    • immediately for new models;
    • from January 2007 for existing models.
  • Head restraints for all (forward and rear facing) seats:
    • immediately for new models;
    • from January 2007 for existing models.
  • Colour contrasting sight patches on all passenger seats:
    • immediately for new models;
    • from January 2004 for existing models.
  • Colour contrasting grab handles mandatory
  • Wheelchair anchorages to have been tested to TRL recommended standards pending DDA requirements:
    • immediately for new models;
    • from January 2007 for existing models.
  • Induction loop system (or equivalent) to be fitted:
    • immediately for new models;
    • from January 2007 for existing models.
  • Intercom (or equivalent) to be fitted:
    • immediately for new models;
    • from January 2004 for existing models;
  • Windows to permit maximum visibility into, and out of, the vehicle.
  • One-piece whole width rear window.
  • Windows to have no more than 25% tint value.
  • Sliding doors, if fitted, to be power operated or power assisted (with emergency override).
  • Enhanced floor covering standards formalised.
  • Floor covering not to impede movement of wheelchairs
  • Meters - designated taximeter pulse output point to be provided and pulse output to be compatible with meter:
    • new vehicles from a date to be determined.
  • Meters to print receipts containing prescribed details:
    • all meters from January 2005.
  • Key information on insurance certificates to be not less than 12 pitch font size.

Dates above are subject to confirmation. Dates will be brought forward where this is found to be possible.

Changes to vehicles should not be made on the basis of the above without first obtaining details of the precise specifications from the PCO Head of Vehicle Inspections and Standards.

In addition it is proposed that:

  • the taximeter regulations will be reviewed; and,
  • the 'for hire' light will be redesigned with, possibly,
    • the sign displayed, as with the licence plate, remaining the property of TfL/PCO and is removed when the cab is unlicensed thereby minimising the risk of unlicensed vehicles being mistaken for licensed taxis;
    • the display being larger and more visible to the public and enforcement/compliance personnel.

The turning circle

The Conditions are primarily concerned with the safety and convenience of taxi passengers and their drivers. The tight turning circle of London taxis enables taxi drivers to manoeuvre in congested traffic or do a U-turn (as opposed to a three-point turn) on most London roads. Its retention will ensure that passengers, in particular the elderly, disabled, carers with buggies, and people encumbered with luggage, will continue to have the benefits of:

  • drivers picking them up safely if they are on the opposite side of the road;
  • easy turning to go in the opposite direction once passengers are on board;
  • safe and convenient drop off for passengers where the destination is on the other side of the road.

About half of London's annual 90 million taxi trips are hailed on the street, and this is where the turning circle is useful for both drivers and passengers.

London is unique

Outside London, taxi pickups are predominantly from taxi ranks. Without the turning circle, many of London's ranks would have to be relocated or redesigned as they would not be practical or safe if taxis had to do three-point turns. Such vehicles would have difficulty accessing places such as Euston Station, East Croydon Station, Clapham Junction Station, and the Savoy Hotel. The major risk of abolishing the turning circle requirement was that there would be a rapid reduction in vehicles with the facility in favour of those with cheaper upfront costs but without the manoeuvrability. Over time it is very likely that there would be no vehicles with the tight turning circle with the consequential loss of the customer benefits noted above. The greater choice sought by drivers would be short-lived with there ultimately being no more choice than now.

Consulting stakeholders

A consultation exercise carried out for TfL by the Transport Research Laboratory, involved taxi user groups, taxi driver organisations, operators and fleet owners. Views varied considerably. Some drivers' groups favoured more choice of vehicle while others preferred to stick with the current turning circle requirement. Groups representing disabled people strongly favoured the current arrangement with all taxis able to manoeuvre to pick up and drop off passengers at the passengers' convenience.

Costs to drivers and customers

TfL was well aware of the argument that the existing vehicles are expensive to buy and drivers might like more choice of price and quality. However, London's taxis currently last for over 15 years, are available on low interest packages and have relatively high re-sale values. Cheaper vehicles generally have a shorter life but would probably have similar annual costs and lower resale values. The introduction of cheaper, but shorter life, vehicles, would be likely to bring down re-sale values of existing vehicles. If there were any real reduction in annual vehicle costs, the standard Cost of Living index upon which the annual taxi fare changes are based, would fall by that amount. The conclusion is that any major change would make little difference to driver and passenger costs.

Stronger regulation

Retaining the turning circle requirement has the effect of limiting the number of suppliers of London taxis in the short term (until other manufacturers produce vehicles which comply) to two, with one very dominant. It is proposed to exercise stronger oversight of these suppliers to ensure that their vehicles meet the needs of both passengers and drivers. It is also proposed to encourage the two manufacturers to work closely with driver and passenger representatives to improve comfort and ergonomics, and to remedy shortcomings of existing designs. If they are deemed to be abusing their duopoly position, this will result in a further review of the Conditions of Fitness to confirm that the best interests of London are being served.

Mayor of London, Ken Livingstone said:

"London has the best taxi service in the world and having looked carefully at the Conditions of Fitness I've decided to go for useful improvements rather than a major change. This will safeguard service quality, especially for disabled people, and the investment that thousands of taxi drivers have made in their vehicles. I am already looking forward to the next generation of taxis which I expect to build on the current features to provide better comfort for both drivers and passengers including better suspension, better accessibility for wheelchair users and people who are disabled, and improved environmental performance."

It is now intended that another review of the Conditions of Fitness will be conducted not later than 2013.

R Ellis
Head of the Public Carriage Office
4 June 2003