CONDITIONS OF FITNESS REVIEW
The law requires that taxis in London must conform to “Conditions of Fitness”.
Since 2000, Transport for London (“TfL”) has had responsibility for deciding on
changes to the Conditions of Fitness. Although they have been modified on a
number of occasions over the years, there had been no comprehensive review of
the Conditions of Fitness since 1961.
In 2002-3, TfL, through the Public Carriage Office (“PCO”), conducted a review
of the Conditions of Fitness. On the basis of the information collected during
the review, and certain other information submitted by consultees or otherwise
known to the PCO, TfL announced on 4 June 2003 that the Conditions of Fitness
would remain largely unchanged. In particular, it was decided that the existing
turning circle requirement (i.e. the requirement that vehicles must be capable
of turning on either steering lock so as to proceed in the opposite direction
without reversing between two parallel planes of not more than 8.535 metres
apart) should be retained. The decision and the reasons for it were explained in
PCO Notice 10/03. Some further explanation, and responses to contrary arguments,
were given in a letter dated 25 June 2003 to the taxi trade from Ed Thompson,
Taxi and Private Hire Director.
On 4 September 2003, Allied Vehicles Ltd (“Allied”), a company which
manufactures taxis that do not comply with the existing turning circle
requirement, issued proceedings seeking judicial review of the PCO’s decision on
various grounds. TfL has considered carefully, with the benefit of independent
legal advice, the arguments put by Allied. In the light of that, we have
concluded that our decisions in respect of three of the conditions of fitness –
the turning circle requirement, the requirement that sliding doors be
power-assisted and the requirement for a one-piece rear window – must be
reconsidered on the basis of further factual information.
As a consequence, TfL will:
* collect more information so that it is adequately informed of all the pros and
cons of the three requirements in question;
* undertake a further short consultation exercise to ascertain the views of all
interested parties (which will include taxi users, drivers and manufacturers) on
these three requirements; and
* in the light of this information and the information it currently has,
reconsider its decision on these three requirements.
The first stage in the reconsideration process is for TfL to work out the terms
of reference for the reconsideration process – i.e. list of questions which TfL
needs to answer in order properly to inform itself of the pros and cons of the
three requirements. TfL has already produced a provisional list (attached), but
wishes to hear from interested parties within 21 days of today whether there is
anything that should be added to or deleted from that list.
Once these responses are received, TfL will publish its final terms of reference
and the further information it proposes to obtain.
As soon as it has obtained the further information it needs, TfL will consider
the totality of the information available to it and announce its new decision.
Throughout the reconsideration process, TfL will keep an entirely open mind as
to whether the three requirements should be retained, modified or scrapped. TfL
has no vested interest in any particular result. Its prime concern is to arrive
at a decision, in accordance with its legal obligations, which best serves
London’s taxi users and drivers.
TfL is also well aware that both drivers and manufacturers need to know the
outcome of the reconsideration process as soon as possible. To that end, TfL
hopes to be in a position to complete the process within 6 months.