Issues relating to the licensing of taxis and private hire vehicles

Written evidence from Guide Dogs for the Blind Association (TPH 42)

1. About Guide Dogs

1.1. The ability to get around is vital in order to live a full life yet thousands of blind and partially sighted people never leave home alone. Guide Dogs empowers visually impaired people to do that and relies on the support of the public to fund its services.

1.2. We breed and train guide dogs which provide life changing mobility and there are currently 4,500 working guide dog partnerships in the UK. Guide dog owners only have to pay a nominal 50p for their dog to ensure no-one is prevented from having one due to a lack of funds. The full lifetime cost of a guide dog from birth to retirement is £48,500.

1.3. We also provide a range of mobility and other rehabilitation services such as white cane training as well as campaigning passionately to break down barriers – both physical and legal – to enable blind and partially sighted people to get around on their own.

2. Executive summary

2.1. The Guide Dogs for the Blind Association welcomes this enquiry and would like to raise some issues about how the licensing regime can make journeys safe, comfortable and accessible for blind and partially sighted people.

2.2. There are three areas of particular concern: making sure that the legal requirements to take registered guide and assistance dogs and their owners at no extra charge are fully enforced as a failure to do so can lead to blind and partially sighted people being left stranded and in a very vulnerable position; a requirement to have talking taxi meters so that blind and partially sighted people know that they are being charged the correct amount; and taxi and private hire vehicle drivers need to be provided with compulsory disability equality training so that they know how to transport disabled people in safety and comfort.

3. Carriage of Guide and Assistance Dogs

3.1. Guide Dogs runs an access helpline and takes calls which cover a wide number of issues including refusal by taxis and private hire vehicles to take guide and assistance dog owners with their service dogs. Since starting the logging system at Guide Dogs in 2008 we have registered a total of 140 enquiries about taxis. Of these 91 were complaints - most of them due to the taxi driver refusing to carry the guide dog owner and their dog. Some are where the taxi driver has charged extra for the dog.

3.2. The response from taxi licensing authorities to the complaints which we have referred on has varied. In some cases the licensing authority has responded well. For example, Marion Spruce from Halifax said, "The taxi licensing office in Halifax were most helpful and determined that this should not be the practice of Halifax taxi drivers. They interviewed the guy who told them that he didn’t speak any English, they got an interpreter in and when he was asked about the incident denied that it ever happened. I had an independent witness who … took me and my blind friend home, she is prepared to come to court, and the licensing [authority) are taking him to court. They have already put a warning on his licences." So this case will be coming to court in the near future. Ms Spruce is very pleased with the way in which this complaint was treated.

3.3. However, some licensing authorities have not been as helpful. Some take a long time to get back to our clients and some refuse to take complaints on the phone and ask our clients to write in with the obvious difficulties this poses for blind and partially sighted people. Even where a case is taken to court it is not always treated seriously, one offender was even let off a fine because he was a "family man."

3.4 Licensing authorities should be supportive when blind people report incidents and be flexible by, for instance, not requiring complaints to be in writing. It can be very difficult for blind and partially sighted people to record and report offences such as refusal to stop or to carry them, poor driver or operator attitudes or refusal to carry a guide dog. Providing evidence is often impossible when travelling alone. Licensing authorities must therefore pro-actively monitor and enforce this and should carry out mystery shopping exercises to ensure compliance.

3.5 Government guidance to licensing authorities should include initiatives to monitor and enforce requirements such as the carriage of guide dogs and other assistance dogs, for instance through mystery shopping exercises. Guidance for the taxi industry should raise awareness about guide dogs and other assistance dogs. Guide Dogs produce a leaflet called "Access to taxis, private hire vehicles and private hire cars guide dog owners," which maybe helpful in producing such guidance. There are pockets of good practice where licensing authorities have raised awareness about this issue and have provided or required training, which should be publicised and shared.

3.6 With regard to licensing authorities, the Department for Transport should collect evidence of the number and geographical spread of exemptions from carrying assistance dogs, to make sure that there are not a disproportionate number of exemptions in some areas and to use this to consider action to limit these should this prove necessary.

3.7 Appropriate sanctions should be in place. Compulsory disability equality and awareness training may be appropriate for some first offences. Thereafter a system of sanctions including realistic fines and revocation of licenses should be used.

4 Talking Taxi Meters

4.1 Guide Dogs has called for the introduction of talking meters for a number of years. The technology for a talking meter is available and it is an important feature for blind and partially sighted people, providing an assurance that they will be fairly and accurately charged the correct fare. Both the rail and public vehicle accessibility regulations include features to enable access and enhance accessibility for people with sensory impairments so we see no reason why this should not be the same for taxis. Until then we call on licensing authorities to consider using their powers to require or encourage taxi meters as they did to require the carriage of guide and assistance dogs in private hire vehicles before the Disability Discrimination Act was changed to require this.

5 Compulsory Disability Equality Training for Drivers

5.1 To improve driver behaviour and attitude, a compulsory disability awareness training programme should be put in place and this should become an integral part of the driver licensing procedure.

5.2 The training should be based around the principles in DPTAC’s Disability Equality and Awareness Training Framework for Transport Staff.

5.3 Training should include:

5.3.1 Awareness of the range of disabled people – including hidden/less visible disabilities

5.3.2 Basic sighted guide training and training in communications skills for customers who are deaf, hard of hearing or deafblind

5.3.3 Awareness of and familiarity with guide dogs and other assistance dogs

December 2010