Report on Unmet Demand Survey and Public Consultation

Perth and Kinross Council · 6 October 2025
Back to Licensing Committee — 6 October 2025 and its agenda

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Our vision is a Perth and Kinross where everyone can live life well,
free from poverty and inequality 
Committee or Board: Licensing Committee
Date of Meeting:  6 October 2025
Report Title:  Report on Unmet Demand Survey and Public
Consultation 
Report Number:  25/260
Report Author: Sarah Rodger, Legal Manager
Organisational Lead: Lisa Simpson, Strategic Lead, Legal and
Governance 
___________________________________________________________________
1. Purpose
1.1 The purpose of the report is to agree measures to address the unmet demand
for taxis in Perth identified by the independent assessment carried out by
LVSA (Licensed Vehicle Surveys & Assessment)
1.2 Sections
1. Purpose
2. Recommendations
3. Background/Main Issues 
4. Impact Value Assessment
5. Appendices
2. Recommendations 
It is recommended that the Committee:
2.1 Notes the information and public consultation responses received.
2.2 Notes that no evidence has been presented which calls into question the
independent survey findings regarding demand and accepts that there
continues to be significant unmet demand for taxis in Perth.

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2.3 Agrees to increase the current limit on taxi licences in Perth by a further 24
licences in order to address the established unmet demand for taxis.
2.4 Requests that the Head of Legal and Governance Services bring forward a
further report to Licensing Committee as soon as possible in relation to
recommendations for the phasing in of an increase in the limit and any
requirements to be met in relation to new licences.
3. Background/Main Issues 
The Legislation
3.1 The Council is responsible for regulating taxi and private hire operators and
drivers in the Perth and Kinross area. A taxi is permitted to pick up fares from
a taxi rank or on the street when hailed. A private hire car cannot pick up fares
from a taxi rank or on the street and journeys must be pre-booked. This report
relates to taxis rather than private hire cars. 
3.2 The legal position is that, in general, applications for taxi operator licences
must be granted unless a ground of refusal exists. This would include, for
example, cases where the applicant is not considered a fit and proper person
to hold a licence.  
3.3 In relation to taxi operator licences, there is an additional provision in the
legislation that, in certain circumstances, may allow for a new application for a
taxi operator licence to be refused. Section 10 (3) of the Civic Government
(Scotland) Act 1982, states that an application for the grant of a taxi licence
may be refused by a licensing authority for the purpose of limiting the
number of taxis in respect of which licences are granted. Applications can
only be refused on this ground if the Council is satisfied that there is no
significant demand for the services of taxis in their area which is unmet.  
3.4 Before the Council can consider refusing an application for a taxi operator
licence under section 10(3), there must be evidence that there is no significant
demand for taxis in its area which is unmet. If this cannot be established, then
the Council may not refuse an application for a licence under section 10(3).
The most appropriate way for Councils to assess whether there is significant
demand which is unmet, is to carry out a survey at regular intervals to
determine the level of demand. This is generally carried out every three years.
The purpose of a survey is to assess and review consumer demand against
the current limits and recommend any changes to these limits (if necessary) in
a way that will support the continued offering of safe and reliable services for
the public. 
3.5 The survey allows the Council to consider whether there should be a limit
placed on taxi numbers as a policy decision and what that limit should be.
This provides a clear framework against which decisions can be made about
individual applications. This is important, as where there is a limit, that does
not prevent an individual from applying for a new licence. In such cases, the
survey, agreed limit, and any other evidence available to it would be

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considered in deciding whether to grant or refuse that application under
section 10(3). 
3.6 The Council limits the number of taxi operator licences for Perth and has done
so for many years. Unmet Demand Surveys have been carried out
approximately every three years to establish whether there is any unmet
demand for taxi services.
4. The 2024/25 Survey 
Methodology
4.1 In May 2024, the Council carried out a procurement exercise and appointed
Licensed Vehicle Surveys & Assessment (LVSA) to undertake a survey.
LVSA also conducted the surveys in 2017 and 2021 and have carried out
surveys in other local authority areas. 
4.2 The survey was carried out according to best practice in this field, in line with
the Scottish Government Guidance (Best Practice Guidance for Taxi and
Private Hire Licensing, May 2023), and in a way which is consistent with the
previous surveys undertaken by LVSA for the Council. It is also consistent
with surveys undertaken by other contractors on behalf of other local
authorities.  A copy of the report issued following the survey is attached as
Appendix A.
Outcome of the Survey
4.3 The outcome and findings of the Survey were previously reported to the
Licensing Committee on 25 March 2025 (Report No. 25/63 refers). The
conclusion of the 2024 survey is that the ISUD value for Perth is 2,143.5. This
is significantly greater than the value of 80 that is used to indicate that unmet
demand might be significant. Consequently, the Survey concludes that there
is significant unmet demand for taxi services within Perth. The result indicates
that “there are not sufficient taxis available at the taxi ranks or by hailing, to
satisfy demand and avoid the need for intending passengers to wait for
extended periods to hire a taxi at a rank or by hailing.”
4.4 At that meeting, the Committee noted the findings of the survey and agreed
that a consultation with the public and the taxi and private hire trade be
undertaken regarding either the issuing of a further 24 taxi licences or the
removal of any limit on the numbers of taxis that may operate, in Perth. 
5. The Consultation
5.1 The Consultation was published on 28 April 2025, on the Council’s website. A
range of information was provided within the consultation to assist those
responding. This included:
• A copy of the Unmet Demand Survey of December 2024. 
• A summary of the main findings of the Survey and an explanation of the
difference between a taxi and a private hire.

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• Information on the purpose of the survey and possible outcomes. The
consultation sought views on the two recommended options for
addressing the unmet demand. Respondents were provided with an
opportunity to provide any comments about the reason why they had
selected their preferred option. 
5.2 The consultation initially ran for five weeks and was extended by a further two
weeks. This was to ensure that all interested parties had sufficient time to
consider and provide a full response, particularly as it was recognised that the
two options suggested in the Survey could impact on those who currently hold
licences. Questions had been raised by some respondents in the taxi trade
and answers to these questions were provided in the form at Appendix B. The
time limit was extended to give respondents in the trade further time to submit
their responses.  
5.3 During the consultation, a number of representations were made reflecting a
desire by parts of the trade to maintain the status quo, and challenging the
validity of the independent survey findings despite further information and
clarification being provided by LVSA.  To ensure transparency, in July 2025,
the consultation was extended for a further five weeks to allow individuals and
particularly representatives of the trade to provide any additional information
or evidence which would contradict the independent assessment finding of
unmet demand in Perth. 
6. Results of the Consultation
6.1 There were 458 responses received in relation to the two options set out in
the consultation (additional 24 licences or removing the limit). Overall, out of
those responses which indicated preference for one of these options, 72%
preferred removing the limit and 28% preferred an additional 24 licences. The
main issues raised in these responses are set out below in section 7 and
more fully summarised in Appendix C.
6.2 There were 266 responses received in relation to the expanded consultation,
which sought views in relation to information and evidence to contradict the
findings of the independent survey. Of these responses, 92 were identical in
their terms. As indicated above, the primary purpose of the expanded
consultation was to allow individuals who disagreed with the findings of the
Survey to provide information and evidence to support their views. The vast
majority of responses provided comments or views rather than evidence or
factual information specifically related to the findings of the Survey. Only two
responses were received which provide specific additional information relating
to the findings of the Survey:
• Two written responses on behalf of the Perth Taxi Association, which are
attached at Appendix D.
• A single, undated photograph showing Murray Street taxi rank during
daylight hours with all spaces occupied by taxis. 
The main issues raised in these responses are set out below in section 7 and
are more fully summarised in Appendix C.

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7. Issues raised by Respondents to the Consultation
7.1 The main issues raised by respondents to the consultation are set out below.
These are more fully summarised in Appendix C.
7.2 Those wishing a change to licence numbers raised issues about:
• Plate/Licence “leasing” and “monopoly practices” including weekly
licence rentals and sale of licences
• Drivers struggling to earn minimum wage despite long working hours
• Frustration at lack of accessibility and inclusivity for disabled persons
and aging population 
• Public safety due to lack of available taxis, particularly at night and for
women traveling alone
7.3 Those who did not want any change to licence numbers raised issues about:
• Dissatisfaction with Survey design and outcomes
• Dissatisfaction with Consultation 
• Driver shortages being a greater concern than number of vehicles
• Economic impact on existing licence holders, including those who cite
the leasing of licences contributing to their income which would be
impacted by additional licences being granted
Submission by Perth Taxi Association
7.4 Two representations were received from the Perth Taxi Association on behalf
of the taxi trade which make a number of comments on the accuracy of the
survey or the methodology used. These submissions are set out in
Appendix D. A number of respondents raised similar issues, albeit in less
depth. LVSA were asked to provide an opinion on the issues raised. The main
issues are responded to below. 
7.5 The Taxi Association has expressed concern about the method of calculation
of the ISUD figure of 2143.5. LVSA has provided assurance that the
methodology is in line with good practice and Scottish Government guidance.
It is also consistent with other surveys conducted by LVSA for the Council in
past years, surveys they have conducted for other Councils and with surveys
conducted by other organisations for local authorities. LVSA have provided
further clarification in relation to the methodology which is set out in
Appendix E. This clarification provides assurance that the methodology used
is appropriate and in line with good practice.
7.6 The Association also commented on the inclusion of population data for the
whole Perth and Kinross area and not just Perth. It should be noted that
population data is included in the survey report as background information
only and is not used to calculate the ISUD figure. 
7.7 Prior to the Consultation being published the Association questioned the
inclusion of the Railway Station Rank in the rank survey as it is a private rank.
LVSA were asked to consider that, clarify whether they were aware of the

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different status of the rank and provide an explanation for its inclusion in the
rank survey. This was provided and is included as part of Appendix A. 
7.8 It should be noted that LVSA also provided an ISUD figure based on the
Railway Station rank being excluded, for illustrative purposes. The ISUD value
dropped to 1,614.9. This value remains well in excess of the threshold value
of 80, which suggests that the level of unmet demand remains significant
even if the Railway Station rank were to be removed.
7.9 The Association questioned the data collected in relation to the Loft Rank. No
evidence has been provided which supports any suggestion that there has
been an error in collection of the data. LVSA has been asked to confirm the
accuracy of that data and has confirmed that the Survey accurately reflects
the data collected.
8. Decision in relation to the Survey
8.1 The Committee requires to decide whether as a result of the consultation
exercise there has been any information or evidence which would contradict
the finding of the independent survey that there is significant unmet demand
for taxis in Perth. Very limited information or evidence has been provided.
LVSA has responded to issues which have been raised, and this provides
assurance about the findings of the Survey report (see section 7 above and
Appendices B, C and F).  
8.2 In the absence of any information or evidence that contradicts the findings of
the Survey it is recommend that the Committee accepts that there remains
significant unmet demand which requires to be addressed. The Committee is
then required to consider what action to take to address the unmet demand. 
9. Actions to address Unmet Demand for Taxis in Perth
9.1 The Council has limited options available to it to address the significant unmet
demand which has been identified in the Survey. Any action taken by the
Council to address unmet demand should be directed towards improving the
availability of taxi services for the public.
9.2 The Council has no direct input or control over how many taxis are in
operation at any given time. While the Council may grant a licence to operate
a taxi and also grants licences for taxi drivers, there is no control over when
taxis would be operated or indeed the type of hires which would be
undertaken by taxis. The Council has no control over when and how a taxi
driver may choose to drive a taxi. The Taxi Association raised a number of
challenges which drivers currently face, for example in relation to passenger
behaviour. Licensing staff are aware of these issues and the impact that these
have on drivers and operators. Officers will take steps to raise these with
Police Scotland and other stakeholders to identify whether any action can be
taken to support the trade to address these issues. However, these issues are
not directly related to the question of what action the Council needs to take to
address unmet demand.

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9.3 The Survey report indicates that the only realistic options available to the
Council to address the unmet demand are to either increase the limit on taxi
numbers or remove the limit altogether. There is concern among the existing
trade about the impact that increasing the number of licences may have on
the sustainability of their businesses and the availability of drivers. The Survey
report indicates that an increase is likely to have some impact on those
currently operating taxis, and that this impact cannot be predicted. It is not
known how many people may apply for a licence if the limit is increased,
whether these may be existing drivers or whether they may be private hire
operators who would simply be moving their vehicle from one type of licence
to another. 
9.4 A greater proportion of those who were in favour of a change to taxi numbers
preferred removing the limit to an increase in numbers. Appendix C highlights
some of the responses that were received in relation to this option, and those
responses were largely driven by a view that this would “open up” the trade to
new entrants. Those views highlight some of the perceived challenges faced
by those wishing to operate a taxi. Whilst the Survey notes that where limits
are removed market forces would then over time regulate the supply (as is the
case in other parts of Perth and Kinross, where there are no limits on taxi
numbers), this inevitably introduces greater uncertainty in terms of the impact
on taxi services for the public. It also makes it more difficult to reintroduce a
limit if it is later decided that this is required to ensure availability of taxi
services to the public.  
9.5 Increasing the limit by 24 licences would ensure that the Council’s position is
clearly set out in relation to the maximum number of licences which can be
granted before there will no longer be considered to be any unmet demand. It
should be noted that once the limit is reached an individual may still apply for
a new licence, but the Committee would need to be satisfied that there
continued to be an unmet demand, notwithstanding the findings of the Survey. 
9.6 Increasing the number of licences by 24 would better allow for the impact of
the increase on taxi services for the public to be kept under review. A further
survey of unmet demand would also be carried out in due course, which
would provide evidence as to the impact. Further changes could be made at
that point if unmet demand remains high. It is recommended that increasing
the number of licences by 24 to address the unmet demand is likely to be a
more prudent and proportionate approach than progressing directly to
removing the limit given the uncertainty about the extent to which that will
improve the availability of taxis. 
9.7 While a number of respondents suggested that the current limit should not be
changed, leaving the limit unchanged would not mean that no new licences
would be issued. It would mean that the question of unmet demand would be
considered on a case-by-case basis when a new application is received.
Individuals could apply for a new taxi operator licence, and the Committee
would be required to consider each of these applications on a case-by-case
basis. It is also unlikely that potential new applicants would be inclined to
apply for a licence when there is no clarity about what the Council’s position is
on taxi numbers in Perth. It is recommended that this approach would be an

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insufficiently robust response to address the significant unmet demand which
is evidenced by the Survey. 
9.8 There are a number of additional matters which would need to be considered
in relation to any increase in taxi numbers. The Survey highlights again the
lack of availability of wheelchair accessible taxis. There is also a need to
consider how best to release any new licences, in terms of timing/phasing in,
requirements as to vehicle type and any other measures which can be
considered which may encourage applications for new licences. It is
recommended that a separate report be brought back to Committee to
address these matters as soon as possible.
10. Assessments
10.1 An Impact Value Assessment has been completed and is attached as
Appendix F. 
10.2 An Equality and Fairness Impact Assessment has been completed and is
attached as Appendix G.
11. Appendices
Appendix A -  Taxi Unmet Demand Survey
Appendix B -  Supplementary Questions and Answers 
Appendix C - Summary of Consultation Responses
Appendix D - Representations from Perth Taxi Association
Appendix E - LVSA Unmet Demand Survey methodology clarification
Appendix F - Impact Value Assessment
Appendix G - Equality and Fairness Impact Assessment