The consultation designed for only one outcome.......
Firstly May I wish you all Happy New Year, I must apologise yet again for the lack of communication to our membership.
We have been very busy doing, but very tardy in telling... Over the next few days I will update you all on the work we have been doing. There's been a lot happening.
Hopefully now in the Kipper season we the committe of the UCG can draw breath and we can get the communicaton out just what we have been working on.
I can almost guess your response, because there are no options that suit us and no "other please explain" boxes.
There are only a few days left to register your response to the TfL Consultation on the "proposed" ULEZ.
If you haven't been to the consultation site yet, here's the link....
It'll take you all of 5 minutes, because thats all they (TfL and the Mayor) don't want you to object, this is a contrived consultation with loaded questions that will leave you without the ability to question anything. It's a "closed questionaire"
They ignore all the scientific evidence...
But We in the UCG have worked closely with David Davis of Cabbies Against Boris to bring you the story behind the story....
Before Christmas both David Davis and the UCG both made a formal complaint to the Competitions and Markets Authority (The newly merged Competition Commission and Trading Standards Office)
Our complaint will be discussed by the Competitions and Markets Authority shortly.
Our complaint is very similar to David Davis' and many of the facts shared across both complaints.
That complaint forms the backbone of our Written submission to TfL regarding the ULEZ.
I will post the full submission shortly on Totally Failling London.
For this reason a formal written response has been submitted.
Below is our "response in the only available comments field” that we felt could not be taken as acceptance of this ill thought out farce.
Feel free to copy and paste this into your response if you agree.
Q25 Please write in the box below if you wish to make any other comments about any aspect of the ULEZ proposal including any potential exemptions or expand on any of your responses above.
Every Question Contained herein is a leading question without "Other please explain" options. None of the options and comments I wish to make are catered for in this very restricted "consultation" questionnaire. This has been designed to stifle debate and force answers in support of this woefully thoughtout proposal. I shall also submit a separate document outlining the farce that is being pulled on Londoners who will not have access to the scientific evidence that shows this consultation to be a totally misleading farce.
Where I felt that the question is a "Leading Question" I have answered either Neither Support or Oppose OR No Opinion.
The UCG does have an opinion But there was no options available as this consultation is purposely too restrictive to express reasoned debate.
Question 22 is particularly "leading"
Do you support the proposals to reduce emissions from taxis and private hire vehicles by:
b) Reducing the Londonwide age limit for non zero emission capable taxis to 10 years and exempting all licensed taxis from the ULEZ standards (and therefore daily charge)
This suggests that you propose a "Take it or leave it" attitude to imposing a ten year age limit despite a very significant amount of scientific research that proves that the later Euro standards IE Euro 4, 5 and 6 are creating as much as 5 times more pollution than the Euro 3 vehicles you are about to penalise. This will be far worse than TfL anticipate because "ALL" diesel vehicles will be emitting 5 times as much pollution in future, not just Taxis. You are about to create a bigger problem than the one you are trying to tackle.
Zero Emissions Taxis..... The IT industry call these proposals "Vaporware" all talk and promises but no actual product. Zero Emission Taxis are "Vaporware"
There are no Zero emissions Taxis available to buy at 9th January 2014 (Closing date for this consultation) [Yes I know there are some hybrids on test, but they aren't in service, they aren't in volume production and the long term reliability is an unknown]
How can legislation be passed to mandate the use of a Non existent vehicle?
How will Taxi drivers Charge their vehicles?
There is not one single fast Charging point in London.
Where will you find space for charging points for 23,000 Taxis?
You TfL cannot and will not keep our charging points clear of illegally parked vehicles and PHV (this is demonstrated by a complete disregard by Enforcement of the existing Taxi Ranks) Has it occured that there are peak times and slack times.... All working Taxis will seek to charge their vehicles at the same time, "Slack time" which is the same time for every Taxi, you can't "Take it in turns" when you need to work busy periods and charge-up the batteries in slack periods.
Does the Underground Electricity Network have the additional capacity to charge electric vehicles Taxis and PHV...?
Has any research into the capacity of the Electricity supply been undertaken?
Have TfL even spoken to the power supply companies to enquire if they can supply this much power?
Who pays for the electricity at these points?
Will the price per KWH be regulated?
subject to price consultation?
Have TfL Spoken to the local councils about providing thousands of spaces for vehicles being charged?
A Taxi driver that lives in a block of flats or has no parking outside his home cannot charge his vehicle.
What if a desperate passenger needs to get home to the suburbs and a Taxi stops for a Hail, but the passenger wants to travel in the opposite direction to the drivers home, the driver realises he has enough power to travel to the passengers destination, but not back home or even make it to a charging point.... Is this a refusal of a fare?
In Japan they have trialled the use of these zero emissions vehicles and the frequent use of fast charging points is destroying the batteries. Disposal of rechargeable batteries is an environmental disaster, Will TfL pay compensation for prematurely failed batteries?
This is the most ill-conceived and poorly thought through of your consultations to date.
It is an embarrassment that I should have to point out the obvious shortcomings of this proposal. These are such glaringly obvious mistakes it proves once again that TfL have no understanding of how to operate a privately owned fleet of vehicles that isn't subject to massive taxpayer subsidies to make it work.
If I have one comment to make that you may understand.....
Go back to the drawing board..... This is unworkable. There are no vehicles available that meet your criteria, There are no charging points in London and Taxi drivers who live in homes without off street parking? You will create claims for constructive restraint of trade as they will not be able to work.
Nordenfelt v Maxim Nordenfelt Guns and Ammunition Co Ltd
This is the bedrock of restraint of trade claims.
If TfL prevent Taxi drivers from earning a living due to enforcing unreasonably high barriers to licensing then the Taxi trade will have no option but to take legal action.
On behalf of the UCG I will also submit a fully reasoned and evidence supported submission "Off line" via email.
For and on Behalf of the UCG
Get your responses in guys.....
In the next couple of days we will update the Totally Failing Website With Our written representation against the 10yr Age Limit.....
Remember, 15yrs became 10.... will become 7...... Get your objections in now and copy in the text into the comments box in question 25.
And... Happy New Year