Jim please find below, part of my response to the Private Hire consultation.
PRIVATE HIRE OPERATORS
2. Do you agree with our proposal for a time delay between journey booking and commencement?
If you don’t agree, please explain why. :
This proposal will do nothing to re-establish a very necessary differential between taxis and private hire. The situation at present is that there is no appreciable division between taxis and private hire as the taxi trade has effectively been de-regulated by the licensing of Uber who operate an immediate demand service.
In the absence of any current plans for Parliamentary action to re-calibrate the cab industry on a fair and equitable basis this review may be the only opportunity to prevent the taxi trade from being totally subsumed in the Tsunami of Uber expansion.
This un-precendented growth has led to severe congestion at many places in London, Soho and the West End generally suffer from gridlock at times and at other locations such as St Pancras and Victoria stations, amongst many, traffic is impeded by the double parking and illegal stopping that has become the hallmark of the App driven on demand market.
A far more constructive approach would be to limit access to the Congestion Charge Zone only to PHV drivers engaged in taking passengers into the Zone or those allocated a booking to pick up. This restriction should apply 24/7 as a 30 fold plus and rising increase in PHV movements in the CCZ cannot be sustained without gridlock of third world proportions becoming a daily ( and nightly ) occurence.
Empty PHV's should be obliged to leave the CCZ and park in an adjacent Zone.
For the purposes of this example I will use the existing Underground Zoning areas although this might not be wholly appropriate if further consideration is given to a plan which might be called 'Concentric Displacement'.
In this model drivers parked in Zone 1 but outside the Congestion Charge area could be allocated a job in the CC area or in Zone 2 but not in Zone 1. Similarly drivers parked in Zone 2 would qualify for work generated in Zone 1 inc the CC area and Zone 3 and so on.
An alternative to this would be the creation of an individual 'exclusion zone' around each vehicle in which no job could be allocated, what that radius that might be is a subject for further consideration but overall this measure would prevent opportunistic positioning by drivers as noted above, loitering around known hotspots and creating unnecessary congestion and curb the behavior of the public to wave an illuminated smartphone at traffic and then engage in the ordering process with the first driver to stop.
This would prevent the tendency of PHV drivers to congregate or cluster close to where work is known to originate - in the case of Heathrow the area could modeled on the Local Journey return area as presently applied to taxi hirings from the ranks, roughly an area bounded by the M25, A3, NCR & A40 although a somewhat smaller zone might be appropriate
More centrally the writer has experienced considerable difficulty removing Uber cars from taxi ranks, the Shepherds Bush Taxi Rank at night it has become an ongoing problem.
In the proposal the concern that would be passengers might be 'unecessarily inconvenienced' is mention twice in a short text. There is no need for anyone to be inconvenienced by this solution - if an immediate service is required then a licensed taxi becomes the default service to access. If an alternative is sought then the customer has the option to prebook a car for a specific time or wait for the response time advised by the operator.
A booking would be allocated to the driver in the form of a pickup location but with no other detail, once in position the name and contact details would be revealed at the booked time and similarly the vehicle registration number and driver contact information released to the passenger.
In addition drivers must be stationary when being allocated a booking as the current practice of drivers being distracted by their mobile phone whilst moving is unsafe and has surely been the trigger for the many accidents involving Uber Prius vehicles, indeed TfL's own PR Dept has issued warnings to motorists of the perils of such action.
A time delay whether it be 5 or 15mins will be perceived as a clumsy and partisan measure by TfL to obstruct Uber.
A far more elegant solution would be to impose the above measures on the wholly justifiable grounds of combatting unacceptable levels of congestion in the CCZ and the prevention of unacceptable clustering around points of known demand in other places.- that the necessary time delay needed by the licensed taxi sector to re-establish some significant differential arises as a by-product of this instrument is a fortunate serendipity.
1) No PHV's allowed in CCZ 24/7 unless POB, empty PHV's in the CCZ will be unable to accept hirings until outside zone.
2) PHV's not to be allocated work whilst moving.
3) Individual 'exclusion zone' or 'proximity buffer' to prevent access to hirings within sight of the driver to prevent opportunistic plying for hire.
4) All above requirements to be driven by App modification, solution should be self policing.
The current Alice in Wonderland environment where a 'booking' is legerdemain for an immediate hiring and a 'Meter' is not a Meter needs to be returned to reality.
Private Hire is or should be a 'Private' contractual arrangement between 2 parties whereby a service is provided for an agreed price.
A price should be quoted on the basis of the shortest map route and take into account traffic loadings as currently available on App driven mapping.
This would be binding on the driver and at a stroke prevent the abuse we have all seen of Uber drivers taking wildly circuitous routes and charging outrageous fares to the dismay of deceived passengers who then have no resort to effective complaint.