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Agenda Document Pack - Licensing Committee - 06/10/2025

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

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Ambition | Compassion | Integrity 
Our vision is for 
a Perth and Kinross where everyone can live life
well, free from poverty and inequality 
Council Building
2 High Street
Perth
PH1 5PH 
29/09/2025 
A hybrid special meeting of the Licensing Committee will be held in the Council
Chamber on Monday, 06 October 2025 at 13:00. 
If you have any queries please contact Committee Services on (01738) 475000 or
email Committee@pkc.gov.uk. 
THOMAS GLEN
Chief Executive 
Those attending the meeting are requested to ensure that all notifications are
silent on their device and other devices are in silent mode. 
Please note that the meeting will be broadcast online and recorded.  The
recording will be publicly available on the Council’s website following the
meeting. 
Members:
Bailie Mike Williamson  (Convener)
Councillor Iain MacPherson  (Vice-Convener)
Councillor Keith Allan
Councillor Hugh Anderson
Councillor Bob Brawn
Bailie Rhona Brock
Councillor Steven Carr
Councillor Michelle Frampton
Councillor Neil Freshwater
Councillor Ken Harvey
Councillor Carol Mair
Councillor Willie Robertson
Councillor Alan Watt
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Licensing Committee 
Monday, 06 October 2025 
AGENDA 
MEMBERS ARE REMINDED OF THEIR OBLIGATION TO DECLARE ANY
FINANCIAL OR NON-FINANCIAL INTEREST WHICH THEY MAY HAVE IN ANY
ITEM ON THIS AGENDA IN ACCORDANCE WITH THE COUNCILLORS’ CODE
OF CONDUCT. 
1 WELCOME AND APOLOGIES   
2 DECLARATIONS OF INTEREST   
3 REPORT ON UNMET DEMAND SURVEY AND PUBLIC
CONSULTATION
Report by Strategic Lead - Legal and Governance (copy herewith
25/260) 
5 - 156 
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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.
3
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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   
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Perth 
December 2024 
Taxi Unmet Demand Survey
3
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Perth Taxi Unmet Demand Survey 
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Perth Taxi Unmet Demand Survey 
Executive Summary
LVSA were commissioned by Perth & Kinross Council to undertake a taxi
unmet demand survey.  The study is intended to fulfil the requirements set
out in the Civic Government (Scotland) Act 1982 (CGSA) and Best Practice
Guidance (BPG) issued by the Scottish Government and relevant case
history in regard to unmet demand.
Within the Council licensing area, the council maintains a limit regarding
the number of taxis which may be licensed in Perth.  The current limit is set
at 80 taxi vehicles in Perth.  There is no limit to the number of taxis which
may be licensed in other areas around Perth and Kinross.
Data has been collected through consultation with stakeholders, the trade
and members of the public.  In addition, observations of activity at taxi
ranks were undertaken to record volumes of taxis and passengers using
each rank and whether any passengers had to wait for taxis to arrive at the
ranks.
The 2024 survey is the latest in a regular series of surveys commissioned
by the Council.  The last two surveys were conducted in 2021 and 2017.
Taxi demand in 2021 was heavily influenced by the aftermath of the Covid-
19 pandemic.  Since 2021, the level of passenger demand had increased.
The total volume of observed hires of taxis from the ranks in Perth was
lower in 2024 than that observed in 2017.  However, despite the reduced
volume of hires through the ranks, the number of people who had to wait
for a taxi to arrive at the ranks in 2024 was significantly higher in 2024,
than in 2017.
There has also been an increase in the number of taxis in the fleet in Perth
in 2024, compared with 2017. 
Year Total number
of taxi hires
from ranks
Total number
of passengers
waiting at the
ranks.
Average
waiting time
for passengers
who had to
wait for a taxi
Number of
taxis in the
fleet in Perth
2017 1,959 159 2 min 08 sec 75
2024 943 331 5 min 30 sec 80 
The purpose of this survey is to identify whether there is sufficient
availability of taxis at the ranks to meet the level of demand.  
The result of the survey is a clear indication that there is not sufficient
availability of taxis at the taxi ranks, to meet demand.  There is significant
unmet demand for taxis.
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Perth Taxi Unmet Demand Survey 
The number of hires obtained from ranks has fallen dramatically since 2017. 
The hires observed at ranks in 2024 were around 48% of the level observed
in 2017.  The number of taxis in the fleet has increased by 6.7%.  Despite
more taxis and less hires taking place at ranks, the number of people who
had to wait for taxis to arrive at the ranks had increased by 108%.  
Clearly, the way in which taxis operate has changed.  The way in which
people hire licensed vehicles has also changed, with more people pre-
booking hires for immediate travel.
The situation in 2024, compared with 2017, was that use of the ranks has
reduced, passenger waiting has increased and the number of taxis in the
fleet has increased.  However, the increase in the number of taxis has not
addressed the increased passenger waiting and hence the level of unmet
demand is significant.
Options open to the Council to address the shortage of supply are limited. 
A change in fares could be considered, however the level of taxi fares and
structure of the taxi fares table are outside the remit of this survey.
There remains only the option to increase the number of licences, either by
increasing the cap on licences, or by removing the cap altogether.  
If the cap were to be increased, it would require a large increase to result
in the changes needed to address the level of unmet demand observed.
It is recommended that the cap on licence numbers is increased by 24
licences.  The issue of licences should follow current policies for additional
taxi licences. 
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Perth Taxi Unmet Demand Survey 
Contents
Executive Summary ................................ ii
Contents ................................................ iv
1 General introduction and background ...... 1
2 Local background and context ................ 2
3 Patent demand measurement (rank surveys) 8
4 General public views ........................... 15
5 Key stakeholder consultation ............... 35
6 Trade consultation .............................. 39
7 Evaluation of unmet demand and its significance 52
8 Summary and study conclusions .......... 58
9 Recommendations .............................. 66 
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1 Perth Taxi Unmet Demand Survey
1 General introduction and background
Perth & Kinross Council is responsible for the licensing of Taxi and Private
Hire Cars operating within the Council area. It retains a limit on the number
of Taxi vehicles licensed. 
This study is intended to fulfil the requirements set out in the Civic
Government (Scotland) Act 1982 (CGSA) and Best Practice Guidance (BPG)
issued by the Scottish Government.  
Current taxi, private hire and operator licensing is undertaken within the
legal frameworks set by the Civic Government (Scotland) Act 1982 (CGSA). 
Leeds University Institute for Transport Studies developed a tool by which
unmet demand could be evaluated and a determination made if this was
significant or not. The tool was taken forward and developed as more
studies were undertaken. Over time this ‘index of significance of unmet
demand’ (ISUD) has become established as an industry standard tool to be
used for this purpose. 
In general, the determination of conclusions about significance of unmet
demand must take into account the practicability of improving the standard
of service through the increase of supply of vehicles. It is also important to
have consistent treatment of authorities as well as for the same authority
over time.
In conclusion, the present legislation in Scotland sees public fare-paying
passenger carrying vehicles firstly split by passenger capacity. All vehicles
able to carry nine or more passengers are dealt with under national public
service vehicle licensing. Local licensing authorities have jurisdiction over
vehicles carrying eight or fewer passengers. 
These are split between taxis which are alone able to wait at ranks or pick
up people in the streets without a booking, and private hire who can only
be used with a booking made through an operator. If any passenger uses a
private hire car without such a properly made booking, they are generally
not insured for their journey.  
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2 Perth Taxi Unmet Demand Survey
2 Local background and context
The authority has a current population of 153,000, based on Scottish
Government statistics. 
All licensing authorities have full powers over licensing the vehicles, drivers
and operators serving people within their area. Perth & Kinross Council has
chosen to utilize its power to limit Taxi vehicle numbers in Perth. 
Throughout other areas within Perth and Kinross, there is no limit to the
number of taxis.
Perth & Kinross Council undertakes regular review of its policy to limit Taxi
vehicle numbers in line with the BPG.  
Table 1, Table 2 and Figure 1 illustrate the fleet composition for the licensing
authorities in Scotland.  The authorities are arranged in order of increasing
licensed vehicles per 1,000 population and increasing proportion of licensed
vehicle drivers per licensed vehicle.  
Licensed Vehicle numbers and proportions are largely based on 2023 figures
and Mid 2023 population data.
Table 1 - Comparison of Licenced Vehicles per 1,000 population 
Licensing area pop 2021
Taxi
vehicles
Private hire
cars
Total
vehicles
Wheelchair
accessible
taxis
Wheelchair
accessible
private hire
cars
Taxis per
1,000
population
Private Hire
Cars per
1,000
population
Total
licensed
vehicles per
1,000
population
Aberdeen City 227,430 593 225 818 335 0 2.6 1.0 3.6
Aberdeenshire 262,690 335 390 725 28 39 1.3 1.5 2.8
Angus 116,120 86 64 150 5 3 0.7 0.6 1.3
Argyll and Bute 86,220 173 53 226 10 1 2.0 0.6 2.6
Clackmannanshire 51,540 46 42 88 5 1 0.9 0.8 1.7
Dumfries and Galloway 148,790 211 50 261 3 0 1.4 0.3 1.8
Dundee City 147,720 298 169 467 186 0 2.0 1.1 3.2
East Ayrshire 122,020 125 104 229 24 3 1.0 0.9 1.9
East Dunbartonshire 108,900 207 275 482 41 2 1.9 2.5 4.4
East Lothian 109,580 119 112 231 119 [unavailable] 1.1 1.0 2.1
East Renfrewshire 96,580 40 406 446 1 3 0.4 4.2 4.6
City of Edinburgh 526,470 1164 2552 3716 1164 10 2.2 4.8 7.1
Na h-Eileanan Siar 26,640 83 18 101 2 3 3.1 0.7 3.8
Falkirk 160,700 396 92 488 56 5 2.5 0.6 3.0
Fife 374,730 481 320 801 16 50 1.3 0.9 2.1
Glasgow City 635,130 1351 3276 4627 1351 25 2.1 5.2 7.3
Highland 238,060 473 228 701 9 12 2.0 1.0 2.9
Inverclyde 76,700 245 42 287 20 0 3.2 0.5 3.7
Midlothian 94,680 36 124 160 36 0 0.4 1.3 1.7
Moray 96,410 125 17 142 7 16 1.3 0.2 1.5
North Ayrshire 134,220 235 46 281 48 4 1.8 0.3 2.1
North Lanarkshire 341,400 435 1025 1460 167 0 1.3 3.0 4.3
Orkney Islands 22,540 36 17 53 1 2 1.6 0.8 2.4
Perth and Kinross 153,810 103 231 334 24 41 0.7 1.5 2.2
Renfrewshire 179,940 224 686 910 220 21 1.2 3.8 5.1
Scottish Borders 116,020 161 60 221 14 14 1.4 0.5 1.9
Shetland Islands 22,940 61 64 125 3 3 2.7 2.8 5.4
South Ayrshire 112,450 92 161 253 92 0 0.8 1.4 2.2
South Lanarkshire 322,630 355 1585 1940 20 29 1.1 4.9 6.0
Stirling 93,470 180 105 285 15 9 1.9 1.1 3.0
West Dunbartonshire 87,790 326 85 411 161 8 3.7 1.0 4.7
West Lothian 185,580 62 437 499 62 74 0.3 2.4 2.7
Total 5,479,900 8,857 13,061 21,918 4,245 378 1.6 2.4 4.0
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3 Perth Taxi Unmet Demand Survey
Note:  Data for Aberdeen City, Argyll and Bute, Clackmannanshire, East
Lothian, Na h-Eileanan Siar and Inverclyde, for 2023 was not available.  For
these areas, the latest data (2022) was used, except for Clackmannanshire,
which used the latest available data from 2021.  No data for 2024 has yet
been published. 
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4 Perth Taxi Unmet Demand Survey 
Figure 1 - Comparison of Licensed Vehicles per 1,000 population
0.0
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
Angus
Moray
Midlothian
Clackmannanshire
Dumfries and Galloway
East Ayrshire
Scottish Borders
North Ayrshire
East Lothian
Fife
Perth and Kinross
South Ayrshire
Orkney Islands
Argyll and Bute
West Lothian
Aberdeenshire
Highland
Falkirk
Stirling
Dundee City
Aberdeen City
Inverclyde
Na h-Eileanan Siar
Scotland average
North Lanarkshire
East Dunbartonshire
East Renfrewshire
West Dunbartonshire
Renfrewshire
Shetland Islands
South Lanarkshire
City of Edinburgh
Glasgow
City
Licensed vehicles per 1,000 population
Taxis per 1,000 population Private hire cars per 1,000 population
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5 Perth Taxi Unmet Demand Survey  5 
Whilst the comparison of licensed vehicles against population provides a
useful metric, it should be noted that population size is not the only driver
of demand for licensed vehicles.  Other aspects such as visitor numbers,
car ownership/availability, levels of business travel, the presence of large
rail termini and airports can have a significant influence on the demand for
licensed vehicles.  For example, Renfrewshire has a large proportion of
licensed vehicles per head of population.  A significant influence on the
demand for licensed vehicles is the fact that Glasgow Airport lies within the
boundary of Renfrewshire and many of the licensed vehicles servicing the
airport are licensed by Renfrewshire Council.  Glasgow and Edinburgh also
have relatively high levels of licensed vehicle provision per head of
population.  Much of the demand is driven by the level of non resident users
in each city.  Tourist and leisure visitors, business visitors and passengers
in transit from the airports and major rail stations all contribute to demand,
in addition to demand generated by residents in each Council area.
Both taxis and private hire cars are often associated by the public as
vehicles which are commonly hired by any member of the public for
immediate travel, often for relatively short local trips.  However licensed
vehicles also fulfil other functions such as limousine services, airport
transfers, tourism services, contract hires and corporate travel.  As such, in
some licensing areas, such vehicles rarely or never are used for immediate
hires by the general public.  Larger cities tend to have higher levels of
demand for such services and hence a greater number of licensed vehicles
in cities may be used for such non-immediate hire purposes, compared with
smaller and more rural areas.
In addition to licensed vehicle numbers, it is prudent to consider the number
of drivers licensed to drive these vehicles.  In Perth & Kinross, taxi drivers
and private hire car drivers may drive both taxis and private hire cars. 
Some licensing authorities limit private hire car drivers to only driving
private hire cars.
Higher ratios of licensed vehicle drivers to licensed vehicles may imply more
intensive use of each vehicle.  Consequently, the capacity of the fleet is
enhanced with more extensive use of vehicles for multiple shifts.  Fleets
with a higher ratio of drivers to vehicles tend to be more capable of catering
for larger fluctuations in demand, such as increased demand on Friday and
Saturday nights.  Table 2 provides the ratio of licensed vehicle drivers to
licensed vehicles, ranked by the ratio of all drivers to all licensed vehicles,
based on 2020 Scottish Government data.  The ratio of all licensed vehicle
drivers to all licensed vehicles for Perth & Kinross was 1.74.  This is higher
than the Scottish average.
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6 Perth Taxi Unmet Demand Survey
Table 2 - Ratio of licensed drivers to licensed vehicles   
Fares comparison
Private Hire and Taxi Monthly magazine publish monthly league tables of
the metred fares for taxis in Licensing Authorities in the UK.  The Tariff 1
fares for a two mile journey (distance costs only) are compared and ranked. 
The lower the ranking (number), the more expensive the journey,
compared with other authorities.  The December 2024 table indicated that
the fares in Perth & Kinross were ranked 291 out of 362 authorities listed. 
This indicates that taxis in Perth & Kinross are cheaper than for most
authorities. A comparison of the fares ranking of Scottish authorities is
presented in Table 3
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7 Perth Taxi Unmet Demand Survey
Table 3 - Comparison of Taxi fares rankings in Scottish authorities
Local Authority Rank
Aberdeen City 242
Aberdeenshire 180
Angus 236
Argyll & Bute 169
Clackmannan 31
Clydebank 201
Dumbarton & Vale of Leven 212
Dumfries & Galloway 256
Dundee 92
East Ayrshire 105
East Dunbartonshire 239
East Lothian 35
East Renfrew 132
Edinburgh 13
Falkirk 290
Fife 106
Glasgow 16
Highland 174
Inverclyde 191
Mid Lothian 20
Moray 150
North Ayrshire 274
North Lanarkshire 315
Orkney 260
Perth & Kinross 205
Renfrewshire 181
Scottish Borders 301
Shetland 102
South Ayrshire 138
South Lanarkshire (Cambuslang / Rutherglen) 224
South Lanarkshire (Clydesdale) 299
South Lanarkshire (East Kilbride) 250
South Lanarkshire (Hamilton) 293
Stirling 264
West Lothian 229
Western Isles 186 
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8 Perth Taxi Unmet Demand Survey
3 Patent demand measurement (rank surveys)
Perth taxi ranks
Within Perth & Kinross, Perth is defined as a separate taxi licensing zone,
with a limit of 80 taxis licensed within the zone.  
Five taxi rank locations in Perth were surveyed from the morning of
Thursday 20th June 2024 to the morning of Sunday 23rd of June 2024
These locations were:
1 Murray Street
2 Railway Station
3 South Street (outside Tesco)
4 South Street (outside Loft)
5 Pomarium Street, near the bus station
Rank surveys
Surveys were undertaken using video cameras which recorded activity at
the ranks from Thursday to the following Sunday morning.  The video
footage of each rank was processed to assess the level of usage of each
rank and to record any incidences of passenger waiting.  Footage was
recorded from 7:00 on Thursday 20th June 2024 to 7:00 on Sunday 23rd
June 2024.  
Overview of observations
During the course of the survey, some 943 taxis were observed departing
the ranks with passengers.  This total was more than the 774 vehicles
observed departing the ranks with passengers during the 2021 survey,
However, the observed total was less than the 1,959 vehicles which were
observed departing the ranks, with passengers during the 2017 survey.  
The number of hires observed during the 2024 survey equates to
approximately 12 hires per vehicle (with a fleet size of 80) over the three
days of observation.  
The proportion of taxis which left the rank empty was approximately 33%. 
This is higher than the 24% proportion observed during the 2017 survey,
but lower than the 40% observed during the 2021 survey.  
Taxis normally leave ranks empty for a variety of reasons.  These include
moving to another rank, having waited unsuccessfully for a hire, or leaving
the rank to service a booking.  Many of the taxis which departed the railway
station rank empty, departed after a train had arrived and not all waiting
taxis were hired.  Rather than wait for the next train, it was common for
remaining taxis to leave the rank.  
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9 Perth Taxi Unmet Demand Survey
Most of the taxis departing the rank empty, were from the Murray Street
rank.  It is assumed that a significant proportion of those departures were
in response to a booking, rather than moving to another rank. Generally,
these departures occurred when other ranks were not active, so were
unlikely to attract taxis from the Murray Street rank.  This assumption was
corroborated by feedback from the trade.  
During the course of the surveys, no passengers were observed, who used
a wheelchair.
Many incidences of passenger waiting were observed.  Out of 1,451
passengers observed using Taxis, 331 (23%) had to wait for a taxi.  It
should be noted that not all passengers observed waiting for a taxi, actually
boarded a taxi.  40 intending passengers left the ranks in frustration, having
waited at the rank for a taxi to arrive.  For comparison, during the 2021
survey, 159 passengers (6%) of 2,730 passengers were observed waiting
for a taxi to arrive at a rank.
The maximum wait time observed during the 2024 survey was39 minutes
30 seconds.
The average waiting time for all passengers who had to wait for a Taxi,
during the 2024 survey, was 5 minutes and 30 seconds.  This was lower
than the average wait times observed during the 2021 survey, which was
12 minutes 31 seconds.  The average waiting time for all passengers who
had to wait for a taxi during the 2024 survey was significantly longer than
the observed average wait time during the 2017 survey, of 2 minutes and
8 seconds.  
During the 2024 survey, the average waiting time for all passengers,
including those who didn’t have to wait, 1 minute 14 seconds.  This
compares with the 2021 waiting time of 3 minutes 25 seconds.  During the
2017 survey, the average wait time was significantly lower, at 7 seconds. 
Total volumes of passengers and taxis through each of the ranks is
summarised in the following tables. 
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10 Perth Taxi Unmet Demand Survey 
The number of passengers who had to wait at a rank for a taxi, is presented
in Figure 2, aggregated across all ranks. 
Figure 2 - Total wating passengers each hour (Perth)
Waiting passengers in each hour, as a proportion of all passengers during
the same hour, are presented in Figure 3.  
0
5
10
15
20
25
Thursday 07:00
Thursday 10:00
Thursday 13:00
Thursday 16:00
Thursday 19:00
Thursday 22:00
Friday 01:00
Friday 04:00
Friday 07:00
Friday 10:00
Friday 13:00
Friday 16:00
Friday 19:00
Friday 22:00
Saturday 01:00
Saturday 04:00
Saturday 07:00
Saturday 10:00
Saturday 13:00
Saturday 16:00
Saturday 19:00
Saturday 22:00
Sunday 01:00
Sunday 04:00
Total passengers who had to wait at ranks for a taxi to
arrive
(aggregated across all ranks)
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11 Perth Taxi Unmet Demand Survey 
Figure 3 - Proportion of boarding passengers who waited for a taxi
(Perth)
The levels of passenger activity at the ranks were analysed and the graph
presented below summarises the profile of activity at each of the ranks. 
Figure 4 – Observed 2024 volumes of passengers through each rank
The profile of passenger demand is dominated by the Murray Street rank
during the evenings and in particular, Friday and Saturday evenings.  No
activity was observed at South Street – Loft rank location.  Hence, the rank
is not included in tables and figures. 
Pomarium Street
South Street Tesco
Railway Sta4on
Murray Street
0
10
20
30
40
50
60
70
Thursday 07:00
Thursday 09:00
Thursday 11:00
Thursday 13:00
Thursday 15:00
Thursday 17:00
Thursday 19:00
Thursday 21:00
Thursday 23:00
Friday 01:00
Friday 03:00
Friday 05:00
Friday 07:00
Friday 09:00
Friday 11:00
Friday 13:00
Friday 15:00
Friday 17:00
Friday 19:00
Friday 21:00
Friday 23:00
Saturday 01:00
Saturday 03:00
Saturday 05:00
Saturday 07:00
Saturday 09:00
Saturday 11:00
Saturday 13:00
Saturday 15:00
Saturday 17:00
Saturday 19:00
Saturday 21:00
Saturday 23:00
Sunday 01:00
Sunday 03:00
Sunday 05:00
Total Passengers Per Hour
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12 Perth Taxi Unmet Demand Survey
Taxi hire profile
The number of passengers hiring each taxi varies.  Therefore, we also
present a profile of taxi hires from each rank and from all ranks combined,
each hour. 
Figure 5 - Observed 2024 volumes of taxi hires through each rank 
The hourly profile of hires per hour, aggregated across all ranks is also
presented. 
Figure 6 - Observed 2024 volumes of taxi hires aggregated across
all ranks
The profile in Figure 6 indicated a similar level of hourly activity for Friday
and Saturday evenings.  There was a brief peak of hire activity on Saturday
night.  However, this was not a large enough peak, either in magnitude or
Pomarium Street
South Street Tesco
Railway Sta4on
Murray Street
0
5
10
15
20
25
30
35
Thursday 07:00
Thursday 09:00
Thursday 11:00
Thursday 13:00
Thursday 15:00
Thursday 17:00
Thursday 19:00
Thursday 21:00
Thursday 23:00
Friday 01:00
Friday 03:00
Friday 05:00
Friday 07:00
Friday 09:00
Friday 11:00
Friday 13:00
Friday 15:00
Friday 17:00
Friday 19:00
Friday 21:00
Friday 23:00
Saturday 01:00
Saturday 03:00
Saturday 05:00
Saturday 07:00
Saturday 09:00
Saturday 11:00
Saturday 13:00
Saturday 15:00
Saturday 17:00
Saturday 19:00
Saturday 21:00
Saturday 23:00
Sunday 01:00
Sunday 03:00
Sunday 05:00
Total Taxis Depar3ng With Passengers
0
5
10
15
20
25
30
35
40
Thursday 07:00
Thursday 09:00
Thursday 11:00
Thursday 13:00
Thursday 15:00
Thursday 17:00
Thursday 19:00
Thursday 21:00
Thursday 23:00
Friday 01:00
Friday 03:00
Friday 05:00
Friday 07:00
Friday 09:00
Friday 11:00
Friday 13:00
Friday 15:00
Friday 17:00
Friday 19:00
Friday 21:00
Friday 23:00
Saturday 01:00
Saturday 03:00
Saturday 05:00
Saturday 07:00
Saturday 09:00
Saturday 11:00
Saturday 13:00
Saturday 15:00
Saturday 17:00
Saturday 19:00
Saturday 21:00
Saturday 23:00
Sunday 01:00
Sunday 03:00
Sunday 05:00
Total volume of hires across all ranks
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13 Perth Taxi Unmet Demand Survey
duration, for the profile to be considered highly peaked.  This assessment
is used to determine one of the variables in the calculation of the Index of
Significance of Unmet Demand. 
Estimation of the number of taxis working from ranks
The rank observation data was processed to provide an estimate of how
many taxis were working from the ranks during each hour of the survey. 
The nature of work undertaken by most of the taxis in the fleet is a mixture
of rank hires and pre-booked hires.  Therefore, not all working taxis were
working from the ranks at any given time, some were undertaking pre-
booked hires and were not available for hire from ranks.
The estimate derived is the number of full time equivalent taxis working
from the rank, rather than a count of how many distinct taxis were observed
at some point during each hour.   i.e. how many taxis spend each hour
either conveying passengers from the ranks or waiting at the ranks for a
passenger.  Typically, at peak activity levels, taxis, which pick up only from
ranks, may undertake around 3 to 5 hires per hour, if passengers are
queued at the rank.  At other times, the number of hires is lower and taxis
wait at the ranks between hires.  However, in Perth, some taxis undertake
both rank hires and pre-booked hires and some undertake only pre-booked
hires.  A common scenario would be that a taxi may pick up a hire from a
rank, then pick up one or more hires from non-rank locations, through pre-
booked hires.  Under this scenario where taxis may work from a rank for
part of an hour, only that fraction of the hour is counted towards the
aggregate taxi equivalence.  Figure 7 presents the aggregate equivalent
taxis working from ranks and excludes any other taxis either not working
during that hour, or undertaking pre-booked hires.
The following examples illustrate how equivalences are determined, within
a single hour.  
In this example, a taxi waits at a taxi rank for 5 minutes, then picks up a
fare and travels for 10 minutes to the destination.  The wait time at the
rank and the duration of the trip hired at the rank, both count towards rank
based working time.  The taxi then is hired to pick up passengers from non-
rank locations through pre-booked hires.  These hires take up the rest of
the hour.  The taxi spent 25% of the hour on rank based hires, either wating
for a hire or conveying a passenger from the rank.  Therefore, in the taxi
equivalence calculation, the taxi would count as 0.25 of a taxi working solely
from the rank.  
Alternatively, we consider a taxi which waited at a rank for 5 minutes then
picked up a fare, which took 10 minutes to the destination, then returned
to the rank 10 minutes later, waited 15 minutes at the rank, picked up
another fare from the rank and travelled 10 minutes to the destination, then
returned to the rank 10 minutes later.  In this situation, the taxi was
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14 Perth Taxi Unmet Demand Survey
engaged in waiting at the rank, or travelling to or from the rank, for the full
hour.  Hence, under this scenario, the taxi would count as a full equivalent
taxi working solely from the rank.   
Figure 7 - Estimate of taxis working from the ranks (Perth)
The number of taxis working from the ranks peaked mid afternoon each
day.  There were more taxis working from the ranks on Friday and Saturday
nights than on Thursday night.  However, the number working at night from
the ranks was generally lower than in the afternoon, each day.
As discussed earlier in the report, some taxis obtain some of their hires
through pre-booking, either directly with the driver or through a booking
office or web site.  Consequently, if some drivers are undertaking pre-
booked hires, they would not be seen to be working from the ranks at these
time.  Therefore, the number of taxis working from the ranks as indicated
in Figure 7 are unlikely to reflect the true total of all taxis working during
each hour.  
0
5
10
15
20
25
07:00
08:00
09:00
10:00
11:00
12:00
13:00
14:00
15:00
16:00
17:00
18:00
19:00
20:00
21:00
22:00
23:00
00:00
01:00
02:00
03:00
04:00
05:00
06:00
Es#mated number of Taxis working off all ranks in each hour
Thursday to Friday
Friday to Saturday
Saturday to Sunday
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15 Perth Taxi Unmet Demand Survey
4 General public views
It is very important that the views of people within the area are obtained
about the service provided by licensed vehicles. A key element which these
surveys seek to discover is specifically if people have given up waiting for
taxis at ranks (the most readily available measure of latent demand).
However, the opportunity is also taken with these surveys to identify the
overall usage and views of taxis and Private Hire Cars within the study area,
and to provide an opportunity for people to identify current issues and
factors which may encourage them to use licensed vehicles more.
Such surveys can also be key in identifying variation of demand for licensed
vehicles across an area, particularly if there are significant areas of potential
demand without ranks, albeit in the context that many areas do not have
places apart from their central area with sufficient demand to justify taxis
waiting at ranks. 
An online survey was used to gather opinions from members of the public.
The results of the survey are presented in this chapter.  Not all questions
were answered by all respondents.  The total number of answers to each
question have been presented in this chapter along with percentages
relating to the total responses to each question, rather than a percentage
of all people interviewed.
Perth public attitude survey results
A total of 435 survey responses were received.  
In the last three months, have you made one or more trips by Taxi or
Private Hire Car in Perth and, if yes, was this a Taxi or Private Hire car? 
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16 Perth Taxi Unmet Demand Survey
How frequently do you travel by Taxi, as opposed to Private Hire car? 
What was the purpose of your last trip by taxi? 
Regarding your last trip by Taxi or Private Hire Car, how did you obtain your
Taxi or Private Hire Car? 
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17 Perth Taxi Unmet Demand Survey
If hired from a stance or rank – How long did you have to wait for a Taxi at
the stance? (minutes) 
If hired by telephone- Did you require the Taxi or Private Hire car
immediately, or did you pre-book it for another time? 
If you telephoned for an immediate booking, how long did it take for the
Taxi or Private Hire car to arrive? (minutes) 
Up to 5 minutes
9%
6 to 10 minutes
25%
11 to 20 minutes
15%21 to 30 minutes
13%
31 to 40 minutes
7%
41 to 50 minutes
9%
51 to 60 minutes
6%
61 to 90 minutes
9%
91 minutes to 2
hours
1%
Over 2 hours or
no availability
6%
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18 Perth Taxi Unmet Demand Survey
If pre-booked for another time, how close to the booked time did the Taxi
or Private Hire car arrive? 
How did you rate your most recent trip by taxi or private hire car for value
for money with 1 very poor and 5 very good? 
Early -between 6 and 10
minutes
1%
On time (within 5 minutes
of booked time)
59%Late -between 6 and 10
minutes
11%
Late -between 11 and 20
minutes
16%
Late -between 21 and 30
minutes
6%
Late -between 31 and 60
minutes
0%
Up to 1 hour late
1%
Over 1 hour late
6%
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19 Perth Taxi Unmet Demand Survey
With respect to the standard of Taxis, in Perth.  How would you rate the
following aspects: 
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20 Perth Taxi Unmet Demand Survey
With respect to the standard of Private Hire Cars, in Perth.  How would
you rate the following aspects: 
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21 Perth Taxi Unmet Demand Survey
Have you encountered any difficulty in entering or exiting any particular
type of Taxi or Private Hire car? 
If yes, do you recall which type of vehicle this was? 
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22 Perth Taxi Unmet Demand Survey
What is the principal factor which limits your use of Taxis in Perth? 
Have you experienced problems in obtaining a Taxi in Perth in the last three
months?     
If yes, approximately what time and day of week did this occur?
348 responses were received to this question.  Responses included a broad
spectrum of days of the week and times of day.  Many respondents indicated
that at most times of day and days of the week, there were difficulties.  A
slightly more popular response indicated that there was particular difficulty
obtaining taxis during weekday mornings and afternoons, particularly
during ‘school run’ times.  Other popular responses indicated that Friday
and Saturday nights were particularly difficult times to obtain a taxi. 
Poor availability
79%
Cost
9%
Access to the
vehicle
2%
Driver hygiene is
poor
2%
I have my own car
3%
Limited avaialbility of
wheelchair accessible
vehicles
1%
No need
4%
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23 Perth Taxi Unmet Demand Survey
What method do you use most often to obtain a Taxi (NOT PRIVATE
HIRE!)? 
How would you assess the availability of Taxis in Perth? 
If the cost of Taxi fares was to increase by 10%, do you think this would
lead to you using Taxis less frequently?   
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24 Perth Taxi Unmet Demand Survey
If the cost of Taxi fares was to decrease by 10%, do you think this would
lead to you using Taxis more frequently? 
Are there any locations where you would like a new Taxi Rank?   
Respondents were asked to specify locations where they would like to see
new taxi ranks.  Some respondents indicated general locations such as ‘the
City Centre’ or ‘Supermarkets’ or ‘retail parks’.  
Some popular suggestions for specific locations were:
Broxden Park and Ride - Justification was given by some that intercity buses
which call at the park and ride, don’t go to Perth Centre and taxis would
connect to the city centre.
Concert Hall – Close do daytime shopping and evening venues.
High Street – A central location.
George Street – Close to night time venues
Tay Street – Close to night time venues.
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25 Perth Taxi Unmet Demand Survey
Additional suggestions were made for taxi ranks in locations outside Perth,
in other locations in Perth & Kinross. 
Taxi ranks work effectively if drivers have a reasonable expectation of
obtaining a fare from the rank.  Rank locations which generally work best
are located where taxis can reach a rank as part of a route returning to
another rank.  For example, if drivers operate from the Murray Street rank,
they may return to the Murray Street rank after dropping off a fare.  If the
route back to the Murray Street rank involves passing another rank location,
the driver may see if there are any waiting passengers, or indeed if the taxi
queue is short and consequently decide to wait at that rank, rather than
return to the Murray Street rank.  In this way, supply is better balanced
across ranks.  Using an alternative example, if a new rank is placed in a
location which requires a detour of several minutes to visit the rank, drivers
are less inclined to visit the new rank ‘on spec’ and are more likely to invest
the time required for the detour, to return to the established rank at Murray
Street and wait in the taxi queue.
At present, the Murray Street rank is effectively the only rank operating at
night in Perth.  Several of the suggestions made were aimed at establishing
a new night time rank which is closer to some of the night time economy
venues than Murray Street.  The rank outside, on South Street was
identified as one which several respondents would like to see “ reopened”. 
In the past, the rank in this location has been a busy night time rank. 
However, the presence of parked vehicles at night on the rank space has
prevented the use of these spaces as a taxi rank in recent times.   
Are there any existing Taxi ranks that you would use more often if Taxis
were more reliably found there? 
Respondents were asked which ranks they would use.  They indicated all of
the existing ranks which are in common use.
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26 Perth Taxi Unmet Demand Survey
Have you wanted to hire a Taxi in the last three months at a taxi rank or
by hailing and given up or made alternative arrangements for travel
because none were available? 
Whilst 73.8% of respondents indicated that they had given up at a taxi
rank, the respondents were asked a supplementary question to establish
whether the incident occurred at a valid taxi rank location or at another
location.  97.8% of those who indicated that they had given up, stated that
this had occurred at valid rank locations in Perth.  The remainder of
responses suggested that they had given up on pre-booked hires or at
locations which were not valid taxi ranks, including locations outside Perth.  
Consequently, the valid response for those who had given up waiting was
72.2%.  This statistic is used in the calculation of the Index of Significance
of Unmet Demand. 
Have you wanted to book a Taxi specifically, as opposed to a Private Hire
car, by telephone, app or online, for immediate travel, in the last three
months and had to make alternative arrangements because a Taxi was not
available within a reasonable time?   
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27 Perth Taxi Unmet Demand Survey
What features of Taxi services in Perth & Kinross that you feel are
particularly good?  
The most popular response was that the drivers were knowledgeable and
friendly. 
What would encourage you to use Taxis more frequently?
The most popular response was increased availability. 
Do you, or anyone with you on a taxi journey, within the last 3 months,
have a mobility or visual impairment or travel in a wheel chair? 
The most common impairments were mobility impairments, some of the
passengers with mobility impairments were also wheelchair users.  There
were also a range of other mobility impairments identified, including
breathing difficulties and difficulties with joints.
Respondents also identified visual impairments, hearing impairments and
learning disabilities, amongst other impairments. 
Did this cause any difficulties when travelling? If yes, please describe.
Around 8% of those respondents who indicated an impairment, indicated
that the impairment did not cause any difficulties.  The remainder indicated
a range of difficulties, which included the following, which are listed in
reducing order of frequency:
• Difficulty getting in and out of vehicles, including identifying that cars
are too low to get in and out of easily and larger vehicles are too
hight to get in and out of easily.
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28 Perth Taxi Unmet Demand Survey
• Lack of wheelchair accessible vehicles.
• Difficulty with walking the distance to the taxi rank / pick up location
or walking from the taxi drop off location.  This is an issue when
travelling to pedestrianised areas.
• Difficulty with standing for extended period whilst waiting for a taxi
to arrive.
• Difficulty fitting walking frame / wheelchair into the vehicle. 
How would you suggest these difficulties could be reduced for travel by taxi
in Perth? 
Are you a permanent resident in Perth & Kinross Council area? 
More more wheelchair
accessible taxis
A discount scheme for
those on benefits
Accept additional cost
for extra time needed
for mobility impaired
passengers
Vehicles to carry a small
step for passengers to
use to get in and out of
the vehicle
Be able to request
smaller vehicle when
booking
Vehicles which were
easier to get in and out
of
Standardised vehicle
size
Better understanding of
the needs of disabled
users
Larger vehicles
Smaller vehicles
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29 Perth Taxi Unmet Demand Survey
Are you: 
What age range do you fall under? 
Do you have any other comments, suggestions or points to make
which are not covered in the earlier questions?
Responses included the following statements: 
Bring in Uber
Taxis are expensive and unreliable! Uber would help with competition and
is much safer 
Make both the bus and taxi service more accessible at night for times. 
Lack of buses now means people need more taxis and this has not happened
meaning people having to walk home late putting themselves in vulnerable
situations.
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30 Perth Taxi Unmet Demand Survey
Taxi’s are expensive to rural areas, and no buses available either
Rural areas not covered
Tariff prices should also be reviewed, during the cost of living crisis, those
seemed to have risen; this could have a negative impact on companies cash
flow resulting in potential closure. PKC could help these companies out? 
Transport generally in Perth is terrible.  Availability, frequency and high
costs.  It is easier and more convenient to drive these days.  There’s no
encouragement for people to use services.  
The reinstatement of rural bus services would reduce the requirement for
taxi services. Students, elderly and the disabled population have been
particularly affected by these cuts along with opportunities for
socialising/visiting areas in Perth without their own vehicle. A communal /
shared travel taxi service option would be good in rural areas where
bookings can be shared at the discretion of the taxi driver and customer to
improve efficiency, reduce costs, reduce the carbon footprint and, I suspect
also, reducing wasted time for the taxi firm traveling to more rural areas.
Reliable availability of a taxi service to rural communities would be
beneficial.
Look at who holds the plates in Perth. If they are not being used to be of
service to the community then they should be revoked and given to taxi
companies who will be of service. Perth also needs Uber. I've just spent 3
weeks in the U.S.A and the service was brilliant and inexpensive. 
Uber would benefit residents in Perth & Kinross. Taxis between outlying
areas are charged from Perth making this travel almost impossible. The
uber concept provides a more customer focused and cost effective
approach. 
Taxis must improve. It’s 2024!
My daughter and her pals have struggled to get a taxi home at night and
ended up having to walk 3-4 miles home in the early hours of the morning,
this is not a safe thing to do for a young women. 
It's having an impact on people going out socialising when you can't
guarantee getting home at the end of the day 
Footfall in the city centre from surrounding areas of Perth and outskirts of
Perth may be improved if availability and service improved. I now travel via
bus from Broxden to travel outside of Perth for dinner/drinks, or drive out
with Perth, to avoid having issues getting home late at night as I am unable
to get a taxi and buses within the city centre do not run late enough. I
previously lived in Dundee and never had availability issues with Taxi’s,
there were far more ranks and far more taxis around town late at night and
at peak times. 
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Please make sure companies have accessible taxis on in evening and
weekends it would make the world of difference.
There are so few taxis, there is little competition so price wise you are over
a barrel.
Please get more taxis
Just that in the big cities Uber has been extremely useful and affordable
and extremely easy to get a taxi with them
I think our taxi provision is not as bad as some people suggest. I travel and
often find other cities more frustrating than Perth 
It is unsafe for women to be waiting hours for a taxi possibly attempting to
walk home alone after a night out due to no taxis being available leaving
them vulnerable 
With a limited bus service now especially after 8pm Perth needs more taxis
especially later on in the evening
The lack of availability is starting to get dangerous.  People are being forced
to walk distances late at night because of no other option.  As a young
woman, that makes me feel unsafe.  It's not much better being forced to
stand at a rank for at least 30 minutes if you are on your own.  
Our bus service is awful with last bus from city centre to Oakbank at 8pm.
Can’t have a night out without someone driving or trying to find a non
existent taxi
Some taxi drivers shouldn't have their badges. When they jump red lights
all time 
Taxi services refuse to pre book taxis on Friday/Saturday nights when it’s
really busy but this puts hospitality workers in danger having to walk home
alone. Provisions should be put in place to ensure that cars should be
available to book in advance for staff. 
The lack of taxis is stopping us from going out later or staying out - we tend
to leave early due to the lack of taxis to get home 
Would love uber in PKC. Very poor public transport from Luncarty, especially
on Sundays. Also no buses from Broxden park and ride on Sundays so rely
on taxis there. A rank there on Sundays? 
An app for checking the availability of taxis, from all the companies
operating in Perth, at any time day or night
Need more taxis on a sat night put me off going out on sat night as don’t
want to walk home alone.
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In a town that you can walk across in 60 minutes, anything more than a 5
minute wait for a taxi is unacceptable. 
Taxis are unavailable during school pick up and drop of times, as they all
seem to be on contacts.
Demand for taxis wouldn’t be so bad if a late bus was run on Saturday
nights to get people home safely.  We are supposed to be a city.
Taxi drivers in Perth are generally very good and deserve as much support
as possible to maintain this
Due to lack of available taxis at ranks I now phone in advance. It would be
nice to be able to be spontaneous and know if I am out that I have a safe
and reliable way home by taxi
It would have been helpful for you to include the question, where you hail
a taxi as you’ve omitted visiting an office
Think I've said it all. It's a disaster. Get a school bus and make more taxis
available for disabled and just people in general. 
Only issue I have is the lack of taxi coverage. Having to wait up to 30 mins
or even an hour for a taxi 
Improvements to the bus service would reduce demand to a manageable
standard for taxis. Lack of evening buses impacts on the local economy...if
you live out of Perth it's cheaper to stay in a hotel than get a taxi home
I also think there should be more female, taxi drivers.
Safety paramount and taxi ranks could do with a police presence at
weekends especially Mill Street [Murray Street] 
Taxi services in Perth have been the same for 40 year, it’s needs to be
updated to help attract people to Perth 
Please remove some School contracts. Owners make money make enough
money from them leaving no requirement to work evenings or weekends. 
Please bring back the no 8 Hillend bus after 8pm evenings, disgraceful
cutting this.  Used to be bus from town 9.15pm, 10.15pm + 11.15pm now
last one 8pm!!
Some taxi ranks using apps I feel cancel bookings unexpectedly. Please
don’t provide an app if it’s not linked to main booking system 
It’s going to have a knock on effect of other areas of the city such as
nightlife as many people aren’t going out as they know they will have to
wait well over an hour to get home, this is made worse by the change in
bus timetables by stagecoach. Having more taxis for the last train of the
night for similar reasons; people may have been traveling all day and finally
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33 Perth Taxi Unmet Demand Survey
get back to Perth then still have to wait over an hour to get home. I have
had to go to work in Dundee at short notice and tried to call a taxi and been
told no because they can’t spare any cars for that long a journey 
Support and encourage taxis for evening and weekend work 
A notable reduction in bus services and taxi availability has resulted in more
of our social and entertainment expenditure being in Dundee/Broughty
Ferry and Glasgow areas as it is now, remarkably, easier to get a bus home
from these places than it is to get a bus or taxi home from Perth city at the
end of a night.
At times the service in Perth is an absolute disgrace. I have missed
appointments because I couldn't get taxis at the rank. Most of the time it is
completely unreliable 
Perth council need to sort out the available transport into the CITY centre.
It’s a disgrace and I’m surprised businesses can survive when’s it’s so
difficult for people to access them by public transport or taxi service. It’s
embarrassing. 
I feel taxis are very expensive as it is, please don’t look to increase them
again. In comparison to other cities our starting price is quite high.
Yes, People of Perth and surrounding areas do not venture into the city as
they cannot get home after 9pm at the weekend etc by the way buses are
the same.
Maybe a OAP rate for older 
Some taxis and drivers are better than others in keeping their vehicles
clean.
Most drivers are great polite and courteous 
PKC take account of high number of elderly disabled wheelchair users who
need taxis for morning and afternoon appointments. Consult via lunch/tea
clubs, retirement living, etc. Stop issuing WAV licences to those who don't
have WAVs or drivers, get professionals in to train WAV drivers on 2 day
courses, not charity on useless 2 hour course
The safety of people in town centre walking to main rank, especially in
evening needs sorted out.
Bring back late night buses and add Ubers, then there won't be long waits
at the too few taxi ranks.  
Just would be nice for me or my daughter to be able to get home safely
after a night out. 
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34 Perth Taxi Unmet Demand Survey
I have a young daughter and would like taxis to be readily available for her
and her friends when required. I would be more reassured if the taxis were
council licensed and drivers thoroughly checked to maximize safety of
vulnerable people. Clear pricing structure.  
Think drivers should have some kind of uniform to smarten them up and
this would uplift the view of the city to tourists as well 
Certain cars are extremely unclean - high standard of cleanliness should be
ensured. Spot checks to monitor.
The questions about what factors determine taxi use, e.g. price, are often
not relevant. I don't have a car so sometimes need to use a taxi as there
are no other options for some journeys. 
Improve drivers customer communication skills- in general they don’t say
a word to you the whole journey
Fill the gap in unmet demand in taxis by getting the late buses back!
Usually Always friendly taxis drivers 
Twice have had to walk from Tulloch to Scone on a Saturday night as
phoned for a taxi and no taxis available. Even after walking to the rank on
Mill Street [Murray Street] and still no taxis.
Why not have taxis at railway station later at night when it is known trains
are arriving eg after a well publicised sporting event/music event in
Glasgow/Edinburgh and fans arrive back to Perth in dark and there are
never any taxis there
The lack of taxis is proving unsafe for youngsters who are trying to get
home from a night out. Hanging around in the streets at the early hours in
the morning is resulting in people feeling frustrated which is leading to
fighting and it is a huge danger for people who are on their own.
New drivers should be taught personal boundaries and to behave better
with women. 
It's quite worrying when my daughter is on a night out as getting a taxi is
a nightmare.  Also the rank needs to be policed better
Due to the reduced bus service in the evenings to the Oakbank area the
taxi service is invaluable if you want people to support the
theatre/restaurants and local businesses to keep Perth city centre thriving 
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5 Key stakeholder consultation
The following key stakeholders were contacted in line with the
recommendations of the Best Practice Guidance:
• Supermarkets
• Hotels
• Pubwatch / individual pubs / night clubs
• Other entertainment venues
• Restaurants
• Hospitals
• Police
• Disability representatives
• Rail operators
• Other council contacts within all relevant local councils
Comments received have been aggregated below to provide an overall
appreciation of the situation at the time of this survey. In some cases there
are very specific comments from stakeholders. The comments provided in
the remainder of this Chapter are the views of those consulted, and not that
of the authors of this report. 
Our information was obtained by telephone, email, letter or face to face
meeting as appropriate. The list contacted includes those suggested by the
Best Practice Guidance.  Our target stakeholders are as far as possible
drawn from across the two licensing areas.
For the sake of clarity, we cover key stakeholders from the public side
separately to those from the licensed vehicle trade element, whose views
are summarized separately in the following Chapter.
Supermarkets
It is not generally possible to contact individual supermarkets by telephone. 
Therefore, where possible, individual supermarkets were visited and staff
at the customer service desk were asked about taxi services.  Feedback
from supermarkets indicated that mobile phones or dedicated taxi phones
were generally used to book travel by licensed vehicles.  None of the
customer service desk staff were aware of any notable issues with the
availability of licensed vehicles for customers.  However, use of licensed
vehicles was not a matter which they were generally involved with.  It was
rare that customer service desks were involved in helping to book a licensed
vehicle.  Some staff did venture opinions, based on personal experience,
that reliance on taxi availability at the ranks in Perth was likely to result in
a wait for a taxi to be available.  It was better to try booking by phone, half
an hour or so, before you were likely to need a licensed vehicle.
Hotels
None of the hotels contacted indicated that they had a Freephone facility
for any particular private hire company.  Most guests, if they needed a taxi
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36 Perth Taxi Unmet Demand Survey
would call and book one themselves.  There is often information provided
by the hotels, with some local numbers.  If guests made it known that they
were intending to use taxis during their stay, staff would sometimes advise
them that they should book their return trip in advance, in order to
maximise the chance of obtaining a licensed vehicle on time.  
Pubs Clubs and Restaurants
A selection of public houses were contacted to seek their views on the
availability of licensed vehicles.  In some cases, door staff were contacted
for a face to face discussion.  In general, there was an awareness that
obtaining a licensed vehicle by booking with a booking office, or obtaining
one at a rank, would generally involve a wait at busy times.  This was
especially the case late at night.  
Central Perth venues generally felt that if all else fails, waiting at the rank
at Murray Street would guarantee a taxi, although there may be a
significant wait to get to the head of the queue.  
There was some feedback that a combination of fewer venues and lack of
night time transport was attracting fewer people into Perth from outlying
areas.  Fewer venues seemed to result in less ‘critical mass’ of alternative
pubs clubs and restaurants, to tempt people into Perth.  This, coupled with
reduced public transport availability through both buses and taxis had
reduced visitor numbers.  Some felt that Perth residents were going to other
localities which offered greater variety of night life.
It is thought that some people visiting night time economy venues booked
a taxi home, in advance, with an arrangement made directly with the driver.
Hospitals
People normally made their own arrangements for taxis.  Licensed vehicles
frequently set down and pick up from the hospital.  Occasionally, it has been
noticed that some people may have to wait for extended periods for their
transport to arrive.  Generally there are no issues worth noting.
Police
Police Scotland indicated that they were aware that delays can occur at pub
closing times and generally late at night.  There was no indication that this
was creating a particular problem with public order. 
Disability
A sample of care homes were contacted to ask if they use licensed vehicles
and if so, what level of service they received.  Generally there were no
issues identified by care homes.  The majority of care homes use regular
providers and pre book a licensed vehicle if they need a wheelchair
accessible vehicle (WAV).  Some care homes use a regular supplier, even
though they may not have a frequent need for licensed vehicles.  This
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approach seems to accord some degree of priority of service.  Their regular
suppliers normally had a suitable vehicle available.  
Consultation was undertaken with representatives of elderly and disabled
user groups and Council representatives who deal with taxi contracts for
school and other special need transport.
The responses are summarised as follows:
• With regards to availability of WAVs (Wheelchair Accessible Vehicles)
at taxi ranks – members [wheelchair users] have told us that they
do not visit ranks as they do not expect a WAV to be available.  
• If WAV taxis were more regularly available at ranks, the preferred
means of hiring a licensed vehicle (by wheelchair users) would still
be by pre-booking, as most trips are not to or from a location near a
taxi rank. 
• Driver awareness of the needs of disabled passengers is generally ok
to good.  Some drivers forget on occasion that different people have
different needs.  Some awareness training is available to drivers.
• Occasionally taxis don’t turn up, or turn up late and due to this people
are missing NHS appointments.  As a consequence, travel is often
booked for an earlier time to allow more of a margin for late arrivals.
• Availability of taxis, especially WAVs tends to be the biggest issue in
recent times. People report that they are unable to book a WAV and
that they may get one to take them to a venue but cannot guarantee
they will be available to pick them up.  Which they've said can cause
anxiety or cause them not to book events in the first place. 
• Lack of taxi availability around school contract times remains an issue
for pre-booked hires.  This is especially difficult if a WAV vehicle is
required. 
• Often a taxi is the only method of public transport that some people
with mobility impairments can use, due to difficulties with other
methods or modes.  Indeed, in suburban and rural areas, this may
be the only option for people (both with and without disabilities) who
do not have access to a car.  Consequently, some people with
mobility impairments are more likely to require more frequent taxis
and for shorter journeys.  
• It is understood that some taxis and private hire cars which are
engaged on contract work for Perth and Kinross Council, do not also
undertake public facing hire work.  i.e. the drivers of some of the
vehicles which undertake contracts, such as school contracts, only
undertake these contracts and do not undertake any other form or
hire.
• Limited availability of licensed vehicles may be giving rise to lack of
competition for some Perth and Kinross Council contracts and hence
leading to inflationary pressures when pricing such contracts.  The
‘part time’ nature of these contracts suits some drivers and is more
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attractive than undertaking more numerous hires through booking
circuits or from ranks.
• Council transport contracts for locations in Perth and Kinross which
are outside Perth itself, are often fulfilled by Perth based operators
using Perth taxis, rather than taxis licensed to operate in other parts
of Perth & Kinross.
• A lot of users stick to the same company as they have had positive
experience with them 
Rail and other transport operators
In Perth, at the railway station, there were generally a small number of
taxis which arrived at the station in advance of arriving trains.  Rail staff at
the station had no view regarding availability of taxis.  They indicated that
there were generally taxis waiting for trains when they arrived and that
some people had booked a taxi in advance to meet them at the station
when a train arrived.
Stagecoach buses were contacted and indicated that there were no issues
with taxis.    
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6 Trade consultation
The BPG encourages all studies to include ‘all those involved in the trade’.
There are a number of different ways felt to be valid in meeting this
requirement, partly dependent on what the licensing authority feel is
reasonable and possible given the specifics of those involved in the trade in
their area.
A link to an online questionnaire was sent to members of the licensed
vehicle trades.  This included taxi operators and private hire car owners. 
A total of 78 responses to the online questionnaire were received. 
Not all respondents answer honestly.  Some respondents set out to provide
inputs that they believe will help to skew results towards an outcome which
they would prefer.  However, many other respondents to answer honestly. 
The data received was evaluated and those results which were intended to
skew results were identified.  For some of the analysis, these intentionally
erroneous results were excluded.
Of those 78 responses, 70 indicated that they were taxi drivers. 
Subsequent responses indicated that some of those who indicated that they
were taxi drivers, were in fact private hire car drivers and some were taxi
drivers from other areas within Perth & Kinross.  
All of the responses provided information of value.  However, some
responses which relate to Perth only matters were analysed on the basis of
responses from Perth drivers only.
What make and model of vehicle do you drive? e.g. Toyota Prius.
82% of drivers generally drove a saloon or estate car.  The remainder drove
MPV or Van based vehicles.
In terms of typical hours worked, the majority of Perth taxi drivers who
responded worked day time rather than night time hours.  
The maximum working hours per week claimed was 168 hours.  This is 24
hours per day 7 days per week.  Clearly, this level of continuous working is
not feasible.  
Respondents were also asked how many hires they undertook per day from
different sources; rank hires, pre-booked hires, contract hires and hailing. 
As with working hours, some respondents indicated either an excessive
number of hires or no hires.  These outlier results were excluded.
Once outlier data was excluded, the number of hires undertaken was plotted
against the number of hours worked.
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Figure 8 - Plot of hires versus hours worked
The scatter graph of hires versus hours worked resulted in a trend line of
around 1.7 hires per hour.  
The type of work undertaken varied amongst respondents.  Some focussed
on contract work or airport runs.  Such work generally involves a lower
frequency of hires per hour worked.  Other drivers undertook a mix of pre-
booked hires and rank hires which can generate a higher number of hires
per hour.
Drivers were asked which type of hire best described the type of hire that
they most commonly undertook.  Responses indicated a mix of hire types. 
Around 25% primarily undertook contract or airport run type hires.  Around
46% of drivers predominantly undertook hires for immediate travel.  The
remainder of drivers were primarily engaged undertaking pre-booked hires.  
Respondents were asked how many hires each week required the carriage
of a wheelchair.  Around a third of taxi drivers indicated that they typically
carried one or more wheelchair using passenger per week.  Around half of
those who carried wheelchair passengers typically carried one or two
wheelchair passengers per week.  However, the remaining half of
respondents who carried wheelchair passengers indicated that they would
undertake several trips per week, carrying wheelchair users.  Around 7% of
drivers carried 15 or more wheelchair users per week.  The majority of
wheelchair user hires were obtained by pre-booking.
Drivers were asked if they had any regular clients who used a wheelchair
and any who had a mobility impairment.  The majority of Perth drivers, who
did not regularly carry wheelchairs also did not have any regular clients who
R² = 0.834
0
50
100
150
200
250
0 20 40 60 80 100
Hires per week
Hours worked per week
Hires per working week
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41 Perth Taxi Unmet Demand Survey
used wheelchairs.  However, some of these respondents did have regular
clients with mobility impairments.  
Of the Perth drivers who did regularly carry one or more wheelchair using
passengers, most had regular clients who used wheelchairs and regular
clients who had a mobility impairment.  Overall, around 50% of taxi drivers
had regular clients who had a mobility impairment.
Respondents were asked if the vehicle that they normally drove, was
normally driven by more than one driver.  35% of drivers indicated that
the vehicle they normally drove, was also driven by another driver. 
Respondents were asked if any existing ranks needed improvement. 
Responses included the following statements:
The railway station rank has special arrangements but I would like to have
access to it
Re-site the South Street rank opposite side of street, reinstate the other
South Street rank. Do away with the bus station rank. Open up the Scotrail
rank to all taxis and make a deal with Scotrail as it is a private rank and
you have to pay for the privilege to use it.
South street rank, needs to be moved back so the first taxi is facing Tesco
main door
An extra couple of spaces on each
Not enough spaces for taxis , South St rank needs to be moved so front of
rank is at Tesco’s door , to stop customers jumping in back taxi leaving taxi
at front of queue waiting
Needs to be more rank space for a start. 75 cars into 29 spaces does not
go. Drivers do not want to drive rank cars and prefer pre booked hires as
the anti social behaviour around ranks is terrible. Positioning and rank space
is something i was undertaken with licensing as chair of the taxi association.
Whilst they are sympathetic the block seems to be the PKC roads
department. Police and wardens need to manage the anti social behaviour
around the ranks by drug addicts , old people do not feel safe and prefer to
book by phone and be collected at a suitable place.
Murray Street......Improved safety for drivers perhaps stewarding at peak
times. 
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Do any new ranks need to be established?  If so, where should they
be located and why? 
There aren't many suitable places around town but I would assume that a
wee 3 car rank at the back of m&s would be beneficial 
Hospital  so people can come out and get one right away
possibly Bertha Park a small rank
Outside the loft nightclub, broxden park and ride,
Yes. As before, Broxden and scott street/kinoull st. 
By the concert hall 
In my personal opinion. I feel there should perhaps be a rank at
supermarkets, like Asda, Tesco etc. 
A rank beside the new Museum would be good, there are lots of
entertainment venues there
Broxden park n ride. Much more customers use this facility than bus station.
Bertha park. Covers a vast area on the outskirts with massive new housing
developments 
One at the retail park for shopers
The top of the hill at the front door of the PRI can be difficult to access and
there is no parking for taxis
Yes south st between south methven st and scott st
Railway station,  broxden bus station,  hospital
Outside Asda and both main Tesco's should be considered. There is
currently very poor drop off and collect facilities at all these sites
broxden park and ride, and perth royal infirmary
Broxden park and ride. New museum a drop off and pick up point. 
Proper drop off and pick up point Broxden Park and Ride beside the  bus
stops at the low level car park  otherwise cant think of anywhere else
Asda and crieff road tesco need rank 
A rank at George Street/ High Street would be useful as there is no rank in
that area for potential customers. 
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Are you aware of any times or locations where members of the
public may face difficulties hiring a taxi? 
There seems to be a short supply when the school runs are on.
Yes. Late weekends. Dont feel safe driving/on streets after dark anymore.
School contract time. At weekend night’s because the custom is not there
except at peak periods so not worth working
Not seen a lot of queues at mill street compared to years ago. This is
because people are booking their taxi home in advance to avoid walking to
the rank. Being picked up from a bar or restaurant for example
Morning rush hour. Taxis busy on school contracts.
SATURDAY 23.00-O100
not nowadays, Saturday night maybe after rewind festival only
School contract hours
During school times
Murray street rank, south street rank, bus station rank
During school times and night time
school contract times during term
Friday night, Saturday night.
Saturday night between 12.30/1.30am
Between 830-930 am due to contracts . Many private individuals have
contracts now for WAVS etc . On a Friday maybe a Saturday night between
1130 - 1am it can be busy but rest of night is quiet. If we put more cars on
we dilute the income and less drivers will work . It is a vicious circle.
8.30-09.30—14.30-15.30
school contract times
Sometimes around about 9.00 am and at around about 3 pm when taxis
are completing school contracts during term time.
Tesco South Street, undesirable people congregating drinking alcohol and
consuming and dealing illicit substances.
During school time on all ranks
No
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After 18.00 on Thurs, Fri, Sat Sun all day
during council contract times , morning /afternoon
School contract times-offices refuse work as a rule. Evenings and weekends
generally
Between 2200 and 0100 on Saturdays
At school contract time.
Taxi offices refuse to pick up customers during school contract times 
Do you feel that the level of customer care and service quality from
taxi drivers in general in Perth is satisfactory?
81% of respondents said yes. 
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Do you agree or disagree with the following statements?
Statement
Strongly
agree
Som
ewhat agree
No
opinion
/ neutral
Som
ewhat disagree
Strongly
disagree
There are not enough taxis
licensed in Perth to cater for
demand
18.9% 6.8% 16.2% 13.5% 44.6%
There are not enough taxi
drivers working in Perth 35.1% 16.2% 17.6% 17.6% 13.5%
Some taxis rarely work from
the ranks 26.7% 26.7% 26.7% 10.7% 9.3%
It is rare that passengers
have to wait at ranks for taxis
to arrive
24.7% 23.3% 26.0% 9.6% 16.4%
Apart from peak times late at
night, it is rare to see
passenger queues at the
ranks.
46.6% 16.4% 24.7% 2.7% 9.6%
There is not enough demand
to keep all taxis working full
time
42.7% 25.3% 20.0% 4.0% 8.0%
There are too many taxis in
Perth 20.0% 12.0% 42.7% 6.7% 18.7% 
Could you tell us how you feel licensed vehicle demand is likely to
change or develop over the next 12 months?  For example,
increased use of telephone bookings, fewer business trips etc.
Responses included the following representative statements:
More secure payment methods. Coping with roadworks (diversions) and
closures information
All round drop in trade. I cant see myself driving taxis in 12 months time
due to lack of income.
It’s not going to change unless PKC broaden their way of thinking. There is
nothing to entice people into the city centre. Do away with alcohol and unit
pricing and people will go out.
Seems to be much the same over the last few years and don’t see it
changing. If anything it is getting quieter and less busy due to the cost of
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living and the prices that bars and restaurants have to charge to survive.
Don’t see any change in business airport runs. Same people using taxis to
airports etc
Increased use of telephone and on-line bookings. Demand has stabilised
post COVID and expected to continue at the current level for the next 12
months.
Impossible to predict
More bookings
domestic trade within the city will continue to dwindle and long run agency
work will make it viable for drivers
Think younger people use apps for most things so be online bookings
More business runs
increase phone bookings 
the demand is likely to increase as Perth is rapidly growing and is used as
a centre point for business users and tourists alike, google plays a massive
part in this and for me telephone bookings and or internet bookings are
increasing, mainly due to the lack of taxis at key areas such as the railway
station and the park and ride
More telephone bookings
There are more houses being built and therefore more people. However,
there are changing habits in going out etc. We find a lot of people take
personal cars and do not drink. The public have changed a lot of habits due
to the bus services finishing earlier and we can often have a busier night on
a Monday or Tuesday if football is on TV than a weekend . Definite change
in habits of socialising.
More app bookings
More mobile
Wont change
Increased telephone bookings
More online bookings
Increase use of telephone bookings.
Few business trips less busy
More work coming in on telephone calls, the city is expanding but the
increase of taxis is static.
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Fewer business trips.
Mobile apps, increased population, improved road infrastructure
Increase in price and availability of public transport
With the cost of living going up and up, there could be a decrease in people
using taxis.
The trade is still trying to build up to pre covid levels ,customer base is
smaller as part of the covid and cost of living crisis, a few drivers got other
jobs during covid and still haven't been replaced
I will increase on all counts, the town is growing therefore the demand will
grow.
i think people more use telephone booking then rank
Economy & price increases
More people are using apps to book taxis and demand will increase
I personally think demand will continue to decrease across all forms of hire.
Perth town centre is no longer a place to meet or shop. The standard of
hotels does not encourage short breaks or any form of tourism. The general
public do not come in to town anymore due mostly to the lack of any quality
shops and the councils inability to move on beggars , drunks and those
under the influence of drugs
Less people going out into town, pubs quieter especially midweek. 
Is there anything else you would like to tell us about the licensed
vehicle trade?
There is a need for ongoing training for drivers, but achieving that without
disenfranchising drivers is very difficult.
The trade could probably do with a few more drivers, i think there’s plenty
licensed taxis in Perth, just not enough drivers to drive them all.
The issues I keep hearing from customers are cars being late or last minute
cancelled, unavailable for long times when needed asap, sometimes rude
dispatch or driver
The application process for school contracts should also be accessible to
small local businesses. The process itself is unclear, the website looks
outdated and is very unintuitive
Pay drivers a wage not self-employed 
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We need to have more control on the way the cars are displaying private
hire badges on door panels
There only few yellow plates in this area and most of them owned by fewer
people it should be distributed among the driver whose always willing to
work that’s will help customers to get easy access to taxis
It would be nice if the licensing staff were out more at nights to check on
dress codes and conditions of the inside of some cars my daughter jumped
out of one from the rank as the car was stinking of cigarette smoke.  Also,
some private hire drivers doing food deliveries so the cars are stinking of
food.
More support given to drivers when complaints from the public received.
Most complaints are very one sided. 
Not well enough paid. Working for less than minimal wage.
Not enough enforcement. Dundee and Edinburgh cars picking up lots of
trade via uber app, carding while delivering parcels and poaching 
Yes still too many drivers not displaying their badge so passengers can’t
identify them 
There are currently a lot of taxis parked up, with some offices more than
29 taxis parked with no one to drive them. 
Need more hackneys...Private hire is saturated
Maybe open up yellow plates
There are more than enough cars but a lack of drivers. Policing is terrible
and this contributes to less people feeling safe in Perth late at night.
Youngsters seem to roam the town at all hours. More needs to be done to
protect drivers from taxi fraud and runners.  Police do not have the time or
resources and all too often nothing happens so drivers do not report this as
it will cost them more time and money. There is a definite fractured
relationship between licensing and the trade and this needs to be repaired 
All too often we hear about the wheelchair access trade but these customers
are very selective in their comments. They have no longer wait or
discrimination than other users , they simply do not book in advance ,
preferring to call on spec and having to wait 10-20 minutes .  We need more
drivers and we can get more cars driving. 
While not perfect, generally high level of efficiency and quality to meet
current and immediate future demands within Perth city and Perthshire 
As a private hire I am not allowed to take flag downs or sit on a rank.
Frequently I would be able to take fares if allowed.  After all yellow plates
Frequently steal our fares.
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Driver long hours to make a living. Dangerous !!!
Customers are usually supportive
People should stop abusing drivers 
Too many business people, outwith the taxi trade, own or are registered as
taxi plate operators and sub lease to actual drivers. 
Far too many scruffy taxi drivers 
An MOT every 3 months for a 7-10 year old vehicle is excessive 
The new museum has generated some additional fares - £4.20ish from the
station - and a driver would have to do 40 such runs a shift, if it were
possible, to get anywhere near minimum wage; 
It would help IF ALL yellow plated cars were actually out working.
Why are there so many "licensed" public hire vehicles parked up at peak
times. Time to open the trade up to cover demand.
There is a complete lack of wheelchair accessible taxis available , also there
are many taxis that are solely used for contract work or only work Monday
to Friday during the day as the operator is older and does not want to work
at any other time, there is an issue that because taxi licences have a
perceived value that many operators have several taxi licenses but don't
actually have those vehicles doing any rank based work
There’s plenty Hackney plates in use, but the majority are working in the
three main offices and being used as office cars hence the reason they are
not using the ranks
It can be a stressful job at times and to consider some way of increasing
taxis in Perth would put a lot more pressure on present Perth taxi drivers
and taxi businesses. 
Vehicles in poor condition and drivers not dressed appropriately 
As licence driver its very hard to make money now days specially after
covid. Thats why lots of driver left this professional 
And the final question, are there any other comments that you
would like to make?
Scrap the monopolies the major companies have. Create one company with
driver ownership and run it as a fair place to work. Perth is not big enough
to sustain the amount of taxis. Increase Hackney plates numbers and
reduce private hire, transfer contract only from excess private hire
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I personally think the Licensing board should do more spot checks on taxis
day and night cars to make sure cars are always being kept to a high
standard of cleanliness and tidiness.
I started a year ago and when I did the driver examination I thought it was
an unnecessary barrier to entry. Once I’d done it, I thought it was useful
training and I’ve continued to use what I learned.
Just tighten up on some drivers driving too many hours 1 guy I know is out
most mornings and is still out at 2-4 am the next morning it's shocking and
his level of driving is really worrying too.
Make owner operators work the taxi they own either day or night and not
just sit back and benefit by cashing in on having others working hard.  My
2 cars are out 5 days from 8 till 6. I go out from 7 till 10 others don’t even
do 1 hires rank work because of a massive contract.  All wrong and that’s
the issue.  Drivers don't want to work then hand 50% of the earning to
someone else.  I have 70 -30 split so they’re working for themselves.  Given
50% is not what self employed is about
To be paid the minimum hourly wage as basic income.
Plenty of taxis parked up as there are no drivers
The statistical questions in this survey are nonsensical, what were the
cameras for? Would they not provide the information you are looking for?
Until the trade can attract more drivers we will continue to struggle to
provide the service the public deserves, we have 3 taxis, 2 of which are
parked up at night, 7 nights a week. There are plenty of licenced vehicles
available but not enough competent drivers about to drive them.
Make it easier to buy plates
Poor driver standards
The sooner they remove the cap from taxi operator licenses the better as
you will then get owner operators who actually want to provide a service to
the general public, rather than those who pay the required fee and then
rent that license out at £150 per week
The last 5 plates you issued 4 are on minibuses and only do school
contracts, therefore are unavailable for rank work.
More ranks- not nearly enough
More drivers means more cars will be working
Easier application process
Driver Testing Abolished in favour of interview with licensing staff
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More spot checks on driver appearance and cars checked at random
Reintroduce annual testing of cars - new system too cumbersome and
impractical
Licensing department to be easier to contact or speak to
Promote the trade more positively- we have canvassed for a long time for
WAV only ranks and this should be promoted by the city and council as a
benefit to visitors
Need a union
Scrap the knowledge test to attract new driver
Taxis picking fares on rank in any position on the rank rather than FIRST
TAXI , this can cause friction among drivers and effects drivers that may
have been waiting quite a long time for a hire.
Private hire picking up off street
Private hire taxis are picking up from the streets
There has to be better control of the way cars get licences and I think there
should be follow up inspections for all cars
It's not lack of taxis , it's lack of drivers to drive that is the issue. So more
taxis would not solve any issues.
I would like to see more access to P&K team at High Street, very hard to
get a hold of
There should be a limit to hours taxi drivers work as seen some working
double shifts
Edinburgh plated cars are driving about Perth looking for work and the
licensing board don’t seem to stop them and ask why they are in Perth
Support the drivers in your city and encourage new drivers.
I feel that it is a difficult balance between too many taxis at quieter times
and not enough during busy times. I am a private operator and have been
driving on my own since covid and cannot get another driver to share due
to rank cars being available (Thursday, Friday, Saturday nights). 
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7 Evaluation of unmet demand and its significance
It is first important to define our specific view about what constitutes unmet
demand. Our definition is when a person turns up at a Taxi rank and finds
there is no vehicle there available for immediate hire. This can lead to a
queue of people building up, some of whom may walk off, whilst others will
wait until a vehicle collects them. 
There are other instances where a queue of passengers can be observed at
a Taxi rank, whilst a queue of Taxis is present, waiting to pick up
passengers. This can occur when the level of demand is such that it takes
longer for vehicles to move up to waiting passengers than passengers can
board and move away. This often occurs at railway stations, but can also
occur at other ranks where high levels of passenger arrivals occur. We do
not consider this is unmet demand, but geometric delay and although we
note this, it is not counted towards unmet demand being significant.
The industry standard index of the significance of unmet demand (ISUD)
was initiated at the time of the introduction of section 16 of the 1985
Transport Act as a numeric and consistent way of evaluating unmet demand
and its significance. The ISUD methodology was initially developed by a
university and subsequently adopted by consultants undertaking the
surveys made necessary to enable authorities to retain their limit on Taxi
vehicle numbers. The index has been developed over time to take into
account various court challenges. It has now become accepted as the
industry standard test of if identified unmet demand is significant. 
The index is a statistical guide derived to evaluate if observed unmet
demand is in fact significant. However, its basis is that early tests using first
principles identified based on a moderate sample suggested that the level
of index of 80 was the cut-off above which the index was in fact significant,
and that unmet demand therefore was such that action was needed in terms
of additional issue of plates to reduce the demand below this level, or a
complete change of policy if it was felt appropriate. This level has been
accepted as part of the industry standard. However, the index is not a strict
determinant and care is needed in providing the input samples as well as
interpreting the result provided. However, the index has various
components which can also be used to understand what is happening in the
rank-based and overall licensed vehicle market.
ISUD draws from several different parts of the study data. Each separate
component of the index is designed to capture a part of the operation of
the demand for Taxis and reflect this numerically. Whilst the principal inputs
are from the rank surveys, the measure of latent demand comes from the
public on-street surveys, and any final decision about if identified unmet
demand is significant, or in fact about the value of continuing the current
policy of restricting vehicle numbers, must be taken fully in the context of
a careful balance of all the evidence gathered during the survey process. 
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The present ISUD calculation has two components which both could be zero.
In the case that either are zero, the overall index result is zero, which
means they clearly demonstrate there is no unmet demand which is
significant, even if other values are high.
The first component which can be zero is the proportion of daytime hours
where people are observed to have to wait for a Taxi to arrive. The level of
wait used is ANY average wait at all within any hour. The industry definition
of these hours varies, the main index user counts from 10:00 to 18:00 (i.e.
eight hours ending at 17:59). The present index is clear that unmet demand
cannot be significant if there are no such hours. The only rider on this
component is that the sample of hours collected must include a fair element
of such hours, and that if the value is non-zero, review of the potential
effect of a wider sample needs to be considered.
The other component which could be zero is the test identifying the
proportion of passengers which are travelling in any hour when the average
passenger wait in that hour is greater than one minute. 
If both of these components are non-zero, then the remaining components
of the index come into play. These are the peakiness factor, the seasonality
factor, average passenger delay, and the latent demand factor. 
Average passenger delay is the total amount of time waited by all
passengers in the sample, divided by the total number of passengers
observed who entered Taxis. 
The seasonality factor allows for the undertaking of rank survey work in
periods which are not typical, although guidance is that such periods should
normally be avoided if possible particularly as the impact of seasons may
not just be on the level of passenger demand, but may also impact on the
level of supply. This is particularly true in regard to if surveys are
undertaken when schools are active or not. 
Periods when schools are not active can lead to more Taxi vehicles being
available whilst they are not required for school contract work. Such periods
can also reduce Taxi demand with people away on holiday from the area.
Generally, use of Taxis is higher in December in the run-up to Christmas,
but much lower in January, February and the parts of July and August when
more people are likely to be on holiday. The factor tends to range from 0.8
for December to 1.2 for January / February. 
There can be special cases where summer demand needs to be covered,
although high peaks for tourist traffic use of Taxis tend not to be so
dominant at the current time, apart from in a few key tourist authorities.
The peakiness factor is generally either 1 (level demand generally) or 0.5
(demand has a high peak at one point during the week). This is used to
allow for the difficulty of any transport system being able to meet high levels
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of peaking. It is rarely possible or practicable for example for any public
transport system, or any road capacity, to be provided to cover a few peak
hours a week. 
The latent demand factor was added following a court case. It comes from
asking people in the public consultation questionnaires if they have ever
given up waiting for a Taxi at a rank in any part of the area, together with
any observation of passengers who had waited at a rank, then given up
waiting before a taxi arrived.  This factor generally only affects the level of
the index as it only ranges from 1.0 (no-one has given up) to 2.0 (everyone
says they have). It is also important to check that people are quoting
legitimate Taxi rank waits as some, for example, despite careful
questioning, quote giving up waiting at home, which must be for a pre-
booked hire, as there are few private homes with taxi ranks outside.
The ISUD index is the result of multiplying each of the components together
and benchmarking this against the cut-off value of 80. Changes in the
individual components of the index can also be illustrative. For example,
the growth of daytime hour queueing can be an earlier sign of unmet
demand developing than might be apparent from the proportion of people
experiencing a queue particularly as the former element is based on any
wait and not just that averaging over a minute. The change to a peaky
demand profile can tend towards reducing the potential for unmet demand
to be significant. 
Finally, any ISUD value must be interpreted in the light of the sample used
to feed it, as well as completely in the context of all other information
gathered. Generally, the guide of the index will tend not to be overturned
in regard to significant unmet demand being identified, but this cannot be
assumed to be the case – the index is a guide and a part of the evidence. 
ISUD value, Perth
For the 2024 survey, average passenger delay was 1.23 minutes (1 minute
14 seconds), this compares with the 2021 survey, when the average
passenger delay was 2.17 minutes (2 minutes 10 seconds). 
Periods when passengers had to wait for a taxi to arrive at the rank
amounted to 25.3% of weekday off peak hours.  This compares with the
2017 survey result, which was 16.9% of the observed off peaks hours.
40 % of passengers travelled in hours when there was an average wait of
over a minute. 
The demand profile did not exhibit highly peaked demand, resulting in a
factor of 1.0 being used. 
The seasonal factor is 1.0.  
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The latent demand factor was 1.722  
The resultant ISUD value of 2,143.5 is significantly greater than the value
of 80 that would suggest the observed unmet demand might be significant. 
Consequently, this suggests that there is significant unmet demand.  
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 of by hailing.  
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The 2024 survey ISUD components are summarised in the following table.
Table 4 2024 ISUD Components
ISUD component Perth
Average passenger delay 1.23
Off peak hours with observed waiting 25.3
% of passengers travelling in hours with
average queue over a minute
40.0 
Seasonal factor 1.0
Peak factor 1.0
Latent demand factor 1.722
ISUD Calculated Value 2,143.5 
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Railway Statistics 
Some demand for licensed vehicles is related to rail passenger volumes. 
Where rail passenger volume changes, we would expect to observe some
related change in associated use of licensed vehicles by rail passengers. 
Figure 9 - Annual passenger movements at principal Railway
Stations
Data is available for annual passenger numbers each year, from April to
March the following year.  Data is presented for each year, from 2009 to
2024.  
Passenger volumes in 2024 have not recovered to pre-Covid levels.  
0
200
400
600
800
1,000
1,200
1,400
2009 - 10
2010 - 11
2011 - 12
2012 - 13
2013 - 14
2014 - 15
2015 - 16
2016 - 17
2017 - 18
2018 - 19
2019 - 20
2020 - 21
2021 - 22
2022 - 23
2023 - 24
Thousands
Annual rail passenger entries and exits
Perth
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8 Summary and study conclusions
Level of unmet demand 
The ISUD index should not be taken in isolation as definitive evidence of
the level of unmet demand.  
The high index value does indeed suggest that the level of unmet demand
is significant.  This indicator was strongly corroborated by feedback from
the public and from stakeholders.  
If passenger waiting were limited to periods of peak demand, such as on
Friday and Saturday nights, then the coefficient in the ISUD calculation
which related to passenger queuing during off peak weekday periods, would
have been significantly lower.  However, passenger waiting was in evidence
during weekday off peak periods as well as during peak periods.  This
extended profile of passenger waiting also suggests an undersupply of taxis
over extended period, rather than focussed on peak periods.
The profile of rank usage, reflected in the profile of taxis leaving the ranks
with passengers, is relatively flat during Friday and Saturday nights. 
However, passenger waiting increased during the traditional peak periods. 
The passenger waiting peak suggests that there were peaks in demand
during Friday and Saturday nights, however, the level of supply did not rise
to meet that demand.
The evidence from different sources does corroborate the result of the ISUD
calculation, leading to the conclusion that the level of unmet demand for
taxis is significant.
Evaluation of results
The level of provision of taxi services at taxi ranks is dependent on several
key factors.  These are:
• The number of taxis licensed.
• The number of drivers who are driving the taxi vehicles.
• The times that drivers are working
• The type of hires which taxis/drivers are fulfilling
There are scenarios where the level of taxi availability at ranks could
increase, with no increase in the number of taxis which are licensed. 
Similarly, there are scenarios where the level of taxi availability at ranks
may not increase, even with an increase in the number of taxis licensed.
Feedback from public consultation indicated the view from some members
of the public, that the Council have direct input and control over how taxis
are operated.  This is not the case.  Whilst the Council may grant a right for
specific vehicles to operate as taxis and may grant the right for specific
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people to drive taxis, there is no control over when the taxis would be
operated or indeed the type of hires which would be undertaken by taxis.
In most of Perth & Kinross, the number of taxis licensed to operate is not
limited.  The operation of taxis in Perth & Kinross, outside Perth itself, is
subject to market forces and access to the market is unrestricted, subject
to applicants meeting licensing conditions.  
Within Perth itself, there is a cap on the number of taxis which are licensed. 
The implementation of a cap on the number of taxi licences issued, if often
held to be of benefit to the travelling public, as it ensures that the level of
provision is not excessive during off peak period and that driver earnings
would be of a sufficient level to encourage longer service in the trade.  Such
traits are expected, in turn, to lead to greater levels of experience and
professionalism and higher levels of service than may otherwise be
expected.
When we compare the results of the last unmet demand survey, prior to
the Covid-19 epidemic (in 2017), with the latest 2024 survey, we can see
that the volume of taxi hires obtained from the ranks in Perth was lower in
2024 than it was in 2017.  
Passenger waiting observed in 2024 was significantly greater than
passenger waiting observed in 2017.
Despite these contrary indicators, the number of taxis licensed in Perth has
increased since 2017.  
The traditional approach to addressing levels of unmet demand for taxis
which is significant, is to issue more taxi licences.  However, there are more
licences in operation in 2024 than there were in 2017 and despite lower
levels of rank based hires observed in 2024, the level of unmet demand is
higher in 2024.  
There was a high level of suppressed or latent demand indicated in the
feedback from the public.  i.e. if there were more taxis readily available at
the ranks, more people would use the taxis to be found at the ranks.
The majority of licensed vehicle hires undertaken by the public are booked
hires, rather than hires obtained at taxi ranks.  Feedback from the trade
indicates that most taxi hires are obtained through pre-booking rather than
from ranks.  The level of hires obtained from pre-booking appears to have
increased since before the Covid-19 pandemic.  
It seems plausible that changes in operating practices amongst the trade,
coupled with changes in patterns of demand, have both influenced the level
of availability of taxis at ranks.  Whilst taxis are engaged on pre-booked
hires, they are less likely to visit ranks.  This is especially likely during busy
periods when they may be engaged in a sequence of back-to-back pre-
booked hires, without the opportunity to visit the ranks between hires.
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As more taxis engaged in pre-booked hires in recent years, passengers used
this facility more readily.  
Some of the feedback from public consultation included comments from
people stating that they had to book a licensed vehicle by phone or app,
because there were no taxis operating from the ranks, because many of the
taxis were fulfilling these pre-booked hires.  The implication from some of
these comments was that the respondents would prefer to just go to a rank
rather than have to book a taxi.  However, this preference may be related
to an expectation that booking a taxi involves a wait for the taxi to arrive,
whilst if there were taxis waiting at a rank, there would be less waiting time. 
Consequently, if bookings were fulfilled within a short time period (less than
5 minutes) passengers may be less willing to walk to a rank rather than
pre-book a taxi.
The feedback from the public indicated that under supply of licensed
vehicles was an issue with pre-booked hire of licensed vehicles, for
immediate hire, as well as an issue with taxi availability at ranks.  If there
was a significant increase in licensed vehicles available to pre-book, it is
likely that this increase in capacity would fulfil some of the unmet demand
for taxis at the taxi ranks.  
It is tempting to assume that all the taxis in the fleet are primarily engaged
in public facing hire work, either from taxi ranks or through pre-booked
hires.  However, there is some plausible evidence that some taxis are
normally engaged in undertaking contract hires and do not supplement this
work with public facing hire work.  
There is some suggestion from the trade that some taxis are not in regular
operation.  This suggestion is based on a case that these taxis are rented
to drivers and fares are split with the taxi owner and that there are
insufficient drivers available and willing to pay the rent for the taxis.  It was
not possible to verify this situation.  However, if true, this would be a
plausible contribution to the lack of supply at taxi ranks, despite the
increase in licensed taxis in recent years.
The purpose of this survey is to identify whether there is sufficient
availability of taxis at the ranks to meet the level of demand.  
The result of the survey is a clear indication that there is not sufficient
availability of taxis at the taxi ranks, to meet demand.
The number of hires obtained from ranks has fallen dramatically since 2017. 
The hires observed at ranks in 2024 were around 48% of the level observed
in 2017.  The number of taxis in the fleet has increased by 6.7%.  Despite
more taxis and less hires taking place at ranks, the number of people who
had to wait for taxis to arrive at the ranks had increased by 108%.  
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Clearly, the way in which taxis operate has changed.  The way in which
people hire licensed vehicles has also changed, with more people pre-
booking hires for immediate travel.
The situation in 2024, compared with 2017, was that use of the ranks has
reduced, passenger waiting has increased and the number of taxis in the
fleet has increased, but the increase has not addressed the increased
passenger waiting and hence the level of unmet demand is significant.
Consideration of potential measures
Perth & Kinross Council need to consider potential measures to address the
lack of availability of taxis at ranks.  However, the range of potential
measures which could be applied is relatively limited.
Measures could include actions and initiatives to encourage some of the
following outcomes:
• Increase the number of taxis which are licensed
• Increase the number of taxis which operate from the ranks
• Change the mix of pre-booked hires and rank based hires, in favour
of rank operation.
• Increase the number of drivers who drive taxis and attend ranks.
• Increase the number of hours each week when existing taxis are
operating, through measures such as multi-shift usage, or
encouraging part-time drivers to work full time.
If more taxi licences are issued in the future, it would be highly unlikely that
all of these taxis would operate from the ranks.  
If three additional taxis were to work from the ranks on Friday and Saturday
nights and one additional taxi were to operate from the ranks during
weekdays and weekend day times, this would provide sufficient additional
capacity to reduce the level of unmet demand to a level which is not
significant.  However, this assessment assumes that the level of demand
from passengers at the ranks would not increase, as a result of increased
availability.   
It is highly unlikely that if four additional licences were issued, they would
be operated as taxis which worked solely from the ranks.  
It is also unlikely that demand levels would remain static, if provision at the
ranks were to be increased.
In order to provide an equivalent of three additional taxis during night time
peaks, we need to consider how this could be achieved.  As operational
practices vary regarding how taxis obtain hires, we would need to scale
provision to achieve the equivalent of three extra taxis working from the
ranks on Friday and Saturday nights. 
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We need to consider how to scale the fleet size, in order that the observed
equivalent number of taxis operating from the ranks on Friday and Saturday
night, were to increase by 3.
Evaluation of the rank activity indicated that on Friday and Saturday nights,
around 8 taxis on Friday and 10 taxis on Saturday were operating from the
ranks.  These are equivalences calculated from observed data.  In reality,
there were more taxis operating on Friday and Saturday nights during the
rank surveys.  However, some of those taxis which attended the ranks also
undertook pre-booked hires and so were only in attendance at the ranks
part time.  Hence, the level of provision on Friday and Saturday nights was
equivalent to 8 taxis on Friday and 10 taxis on Saturday working solely from
the ranks and not undertaking other types of hires.
An increase of three taxis (equivalent) on Saturday night would require a
30% increase in provision, if it were assumed that taxis (including those
newly licensed) would continue to be operated in the same way as they
were during the rank surveys.  i.e. some taxis focussing on pre-booked
hires, some on a mix of pre-booked and rank based hires and some focusing
on contract hires and perhaps some not working at all but waiting, ready
for new drivers to work the taxis on a rental and shared fares basis. 
Therefore, we would need to increase the size of the taxi fleet by 30% in
order that the mix of operational practices could result in a 30% increase
in provision at the ranks.
If we were to increase the taxi fleet by 30% this would be an increase of 24
licences.  
If 24 licences were to be made available, the take up of some of the licences
would be by existing drivers of private hire cars and existing taxi drivers,
who don’t own their own taxi.  As such, unless more drivers could be
recruited by the owners of the vehicles previously driven by these drivers,
the transfer of existing drivers would reduce the net gain in provision and
hence capacity at ranks.
If 24 licences were issued and taken up, it is likely that some of the licences
would be taken up by people who previously operated private hire cars.  As
such, if private hire cars were re-plated with a taxi plates, there may be no
net gain in capacity with those specific plates, if the taxis then continued to
fulfil the pre-booked hires that the vehicles previously fulfilled as private
hire cars.
If the licence cap were increased by 24 in a single move, it may be that not
all licences are initially taken up.  In such a situation, it may be considered
that the difference between having a cap level above the number of licences
issued is no different to removing the cap altogether.  However, there may
be some practical differences in terms of how people view existing licences
against a potential new licence.  
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Trade feedback indicated that there is a perceived notional value in holding
a taxi licence and a business, including the taxi licence can be sold.  The
value of the business to be transferred would include a ‘plate value’
premium.  If the licence cap were removed and no vehicle conditions applied
to any new licences, the plate value of existing plates would be likely to be
reduced to zero.  This may discourage operators from retaining licenced
taxis which are not in regular use.  
An alternative scenario could be that the cap on licences were removed, but
vehicle conditions applied to any new licences, that they would need to be
for wheelchair accessible taxis.  In such a scenario, existing plates which
retained ‘grandfather rights’ to be operated without the need to be
wheelchair accessible, would retain a value.  However, such a value would
be contingent on whether these grandfather rights could be transferred,
with the sale of the business and transfer of the licence.  
A further alternative scenario could be that the cap on licences were
removed and any new licences or transferred licences would need to be
wheelchair accessible vehicles.  In this scenario, existing licence holders (of
licences which did not require operation of wheelchair accessible vehicles)
could continue to operate as such, so long as the licence holder continued
to operate the licence.  Under this scenario, licences owned by individual
owner / drivers would eventually be transferred once the owner retired from
the trade.  Then the licence would need to operate a wheelchair accessible
vehicle.  However, if a licence were registered with a company, then
potentially, ‘ownership’ of the licence could be transferred with the
company, without the need to transfer to a new licence holder.  Such
licences could potentially continue in perpetuity to exercise grandfather
rights to operate non-wheelchair accessible vehicles.
Wheelchair accessible vehicles are more expensive to own and operate than
saloon cars and hence, operation of a cheaper saloon car taxi is a
preferrable option for some operators, as taxi fares are fixed, irrespective
of the size and cost of the vehicle used.
For various reasons, the level of use of taxi ranks to hire taxis has fallen
since 2017.  If the number of taxis were to be increased by 30% to cater
for this lower level of usage, there would inevitably be an impact on other
aspects of the licensed vehicle trade in Perth.
The type of existing taxi ownership will also influence the effectiveness of
introducing additional taxi licences.  For example, companies which own
multiple vehicles and rent these to drivers, may find some difficulty in
recruiting new drivers, if some of the existing drivers take up a new licence. 
Alternatively, renting a taxi provides a means of access to the trade for
people who do not have the capital to invest in a vehicle, so if some or all
newly introduced licences were taken up by existing fleets, this could
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provide an avenue for more drivers to join the trade with low levels of
investment.
In reality, the introduction of such a large increase in taxi licences would
have an impact on the trade which would be difficult to predict.
If the introduction of a large number of licences is considered, it is also
worth considering whether there is a realistic difference between a large
release of licences or removing the cap altogether.
Disabled users and the need for wheelchair accessible taxis
Whilst the public in general has faced difficulty in reliably obtaining licensed
vehicle services, disabled users and in particular wheelchair users continue
to face increased difficulties, over and above those faced by non-disabled
passengers.  Increased availability of wheelchair accessible taxis and
private hire cars has been called for by the public.  One measure which can
increase wheelchair accessible vehicle provision, is to have a requirement
that any additional licences should be for wheelchair accessible vehicles
only.
The cost of purchasing or leasing and subsequently operating a wheelchair
accessible vehicle can be significantly higher than the equivalent costs for
operating a saloon car as a taxi.  Therefore, a wheelchair accessible vehicle
condition for any new licences may discourage some potential applicants.
Most journeys in a wheelchair accessible licensed vehicle are pre-booked. 
Rank based hires of wheelchair accessible taxis are relatively rare.  A
common issue with obtaining the service of wheelchair accessible taxis, in
some locations, is that few of the taxis are directly contactable by
wheelchair users, in order to book travel.  In Perth, this is likely to be less
of an issue as many of the existing taxis obtain pre-booked hires, through
a booking office, app based system, or directly by telephone or messaging
contact between passengers and drivers. 
Feedback from stakeholders and trade members indicates that some of the
wheelchair accessible taxis most recently licensed in Perth are
predominantly or solely engaged in contract hire work and don’t provide
any service at taxi ranks.  Potentially, some additional licences issued could
be deployed in the same way.
If we consider measures which may:
• Change the mix of pre-booked hires and rank based hires, in favour
of rank operation.
• Increase the number of drivers who drive taxis and attend ranks.
• Increase the number of hours each week when existing taxis are
operating, through measures such as multi-shift usage, or
encouraging part-time drivers to work full time.
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The only realistically feasible measure which may result in the outcomes
above, would be to increase the driver’s income.  In turn, this is likely to be
achievable only by considering changes to the fares tariff.  Taxi fares are
outside the scope of this survey and are not considered further.
In order to increase the number of taxis which attend ranks, if driver
operational patterns are not changed, then more taxi vehicle licences would
need to be issued.  It would be assumed that some of these additional
licences would operate for at least some of the time, from ranks and that
some new licences would attract new drivers into the trade, either directly
or indirectly.
If more licences are to be issued, the question of how many and whether
they should be required to be wheelchair accessible taxis should be
considered.
Some of the most recently issued licences are required to operate
wheelchair accessible taxis.  Therefore, if a significant number of new
licences were issued, which did not have this requirement, then existing
holders of the newest licences may feel aggrieved.  Some holders of
wheelchair accessible vehicle licences could apply for a new un-restricted
licence and hand in an existing licence with a wheelchair accessible vehicle
requirement.  Realistically, any additional licences would probably need to
be issued with a condition that vehicles require to be approved wheelchair
accessible vehicles.
There is an option of making no changes and letting market forces deal with
demand for licensed vehicles.  
In such a scenario, it would be anticipated that, over time, more private
hire cars would be licensed to deal with the excess level of demand for pre-
booked hires.  
If the size of the private hire fleet were to increase, more travellers would
book travel rather than go to taxi ranks.  The resulting increase in private
hire cars may drive more of the taxi fleet back to the ranks, owing to
increased competition for pre-booked hires.
At present, there is no realistically feasible method of predicting how long
it would take for private hire numbers to increase sufficiently.
An alternative to increasing the cap in licence numbers would be to remove
the cap altogether.  The results are likely to be similar to retaining the cap
with a large increase.  However, if the cap is removed, it can be difficult to
re-introduce a cap in the future if it is felt that a new cap is required.  
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9 Recommendations
On the basis of the evidence gathered, our key conclusion is that there was
evidence that there was unmet demand for the services of Taxis, which was
above the level which is significant.  It is prudent to consider measures to
be implemented.  
In order to address unmet demand and increase the level of availability of
taxis, the only measures open to the licensing authority (The Council) are
to consider increasing the number of taxis licensed in Perth.  
In order to comply with existing policy, it is likely that any additional taxis
licensed, would be wheelchair accessible taxis.  
The level of observed passenger waiting was relatively high.  The number
of additional taxis required to address unmet demand would equate to a
significant increase in the fleet size.  
If no changes to operational patterns were made as a result of increasing
the number of licences then 24 additional licences would be required.  
Owing to the uncertainty of how newly licensed taxis would be operated, it
is prudent to consider a range of potential additional licences to be issued. 
This would offer the flexibility to introduce the lower end of the range
initially and, if these additional licences did not lead to a notable reduction
in passenger waiting, then an additional phase of licence release could be
implemented.
It is recommended that the issue of an additional 24 licences, over
and above those already in circulation, is considered at this time,
with the option to release licences in phases. 
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May 2025 
Addendum to the Taxi Unmet Demand Survey – December 2024
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Contents
Contents ............................................... ii
1 Addendum background ......................... 4
2 Error corrections .................................. 5
3 Perth Railway Station ............................ 6 
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1 Addendum background
This document is intended to be read in conjunction with the Perth Taxi
Unmet Demand Survey 2024 report, prepared by LVSA.  This is referred to
as ‘the report’.
The addendum is intended to correct errors in the original report and to
present some additional information which may help to further explain some
of the report contents and recommendations. 
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2 Error corrections
On page 6 of the report, fares are compared with other authority areas in
Scotland.  The report states that “fares in Perth & Kinross were ranked 291
our to 362 authorities listed.”  This should be corrected to ‘fares in Perth &
Kinross were ranked 205 out of 341 authorities’. 
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3 Perth Railway Station
The taxi rank at Perth Railway Station lies within the curtilage of railway
property.  In common with many such railway station ranks around the
country, any taxis which wish to service this rank require an additional
permit to wait on the rank for passengers.  There is an annual cost payable
to hold such a permit.  
It is the view of LVSA that all locations where taxis commonly wait for fares,
including formal ranks, informal ranks and ranks on private grounds, should
be included in an unmet demand the assessment.  Taxis which wait at
informal locations and private ranks are not available at other locations,
including public ranks.  
The assessment in the report did include the private rank at the railway
station.  In order to gauge the degree to which the inlusion of the rank at
the railway station influenced the result, we have undertaken a further
calculation of the Index of Significance of Unmet Demand (ISUD) value.
The ISUD index is a value which increases exponentially with increased
occurrence of passenger waiting.  The index is influenced by when
passenger waiting occurs.  Off peak passenger waiting has greater influence
than peak period passenger waiting.
The ISUD value, including the Railway Station rank was 2,143.5.  When the
observations at the Railway Station were excluded, the value dropped to
1,614.9. 
Both values are well in excess of the threshold value of 80, which suggests
that the level of unmet demand was significant.   
Table 1 - ISUD value including the Railway Station rank
observations
ISUD component Perth
Average passenger delay 1.23
Off peak hours with observed waiting 25.3
% of passengers travelling in hours with
average queue over a minute
40.0 
Seasonal factor 1.0
Peak factor 1.0
Latent demand factor 1.722
ISUD Calculated Value 2,143.5 
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Table 2 - ISUD value excluding the Railway Station rank
observations
ISUD component Perth
Average passenger delay 1.11
Off peak hours with observed waiting 23.6
% of passengers travelling in hours with
average queue over a minute
35.6 
Seasonal factor 1.0
Peak factor 1.0
Latent demand factor 1.722
ISUD Calculated Value 1,605.9 
The comparison confirms that there are not sufficient taxis available at
public ranks to meet the needs of intending passengers and to ensure that
unmet demand is below a level which is significant. 
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QUESTIONS AND ANSWERS
In the Report (Taxi Unmet Demand Survey - December 2024) there is mention of five taxi
ranks in Perth. This includes the Railway Station. Given that this rank is private and taxis
have to pay to present at that rank, have the results been weighted to reflect this fact?
It is important to include all active taxi ranks and even informal rank locations, in order to gather
a true picture of activity. This generally includes private ranks where possible. There is no
weighting of results as such. All activity at all active ranks is considered equally. In some
surveys in the past (not in Perth) there have been incidences where inclusion of data from a
private rank with permits meant that the ISUD index was much higher than the threshold for
significant unmet demand, but if the private rank were excluded from calculations, then the
ISUD value would be within limits. In such occurrences, we have presented parallel
assessments with and without the private rank, to demonstrate that it was the cap on permits
for the rank, rather than the cap on licences, which caused significant unmet demand.
With the Perth data, exclusion of the Railway Station data from analysis would still result in an
extremely high ISUD value. So the results would not be different. The with and without station
analysis was not included in the report, in order to avoid complicating matters.
NOTE FROM PERTH AND KINROSS COUNCIL:
Subsequent to publishing of the December 2024 report, LVSA conducted a comparative
analysis of including v. excluding the Perth Railway Station. Please see Addendum to the Taxi
Unmet Demand Survey report. A summary of the results indicate ‘the ISUD value, including the
Railway Station rank was 2,143.5. When the observations at the Railway Station were excluded,
the value dropped to 1,614.9. Both values are well in excess of the threshold value of 80, which
suggests that the level of unmet demand was significant.’  
In the Report there is mention of the South Street, outside Loft taxi rank. This is a part-time
rank. Have the results been weighted to reflect this?
The rank observations indicated that the rank outside Loft is not in effective operation. On each
night of the survey, the rank space was full of parked vehicles. Pre-booked hires were obtained
from outside the club. Passengers would call to book a licensed vehicle and then be picked up
by a vehicle which pulled up in the roadway, next to the parked vehicles, outside Loft. There
were no rank hires, no waiting taxis and no waiting passengers observed at the South Street,
Loft rank. Where there are part time ranks, which are in operation, the camera footage may in
some incidences be limited to the operational hours. However, some part time ranks (not in
Perth) are used at times, outside the operational hours. As such, it is good practice to observe
all activity at the rank, rather than turning a blind eye to operations outside the posted hours for
the rank. Such rank usage is rare, but not unheard of.
It appears that all comparative data is between 2017 and 2024. Can you confirm why 2021
survey results were not used in any of the comparisons, please?
There are some comparisons in the report with 2021 data. However, that period was affected by
post Covid-19 recovery period. In 2017, the ranks were much busier and the supply of taxis at
ranks was working well. 2017 could be considered to be the last survey of a ‘normal’ situation.
The comparison between 2024 and 2017 relates primarily to the level of passenger waiting and
the level of passenger demand in each year. The comparison was intended to demonstrate that
3
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the level of unmet demand in 2024 was not necessarily just a function of lack of licenced taxis.
There are likely to be numerous factors which influence matters. A key comparison is that
passenger waiting in 2024 was significantly greater than in 2017. Yet, there was less demand in
2024 than in 2017. There are more taxis licensed in 2024 than there were in 2017, but the
smaller fleet in 2017 was able to provide greater capacity to meet demand from the ranks.
In order for the taxi fleet to meet rank-based demand, some behavioural changes would be
required, both within the licensed vehicle trades and by the public. For example, taxis focussing
less on pre-booked hires and more focus on working during peak demand periods off the ranks. 
However, the tools available to the Council to influence such changes are limited. In reality,
measures are limited to raising or removing the limit on taxi licences or changing taxi vehicle
specification requirements, or adjusting the fares table, or a combination of these measures.
Changes to the fares table are not within the remit of this survey, so recommendations are
limited to what would be required with respect to increasing the number of licences.
There are external influences which are thought to affect both passenger demand and taxi
provision. Some of these have been mentioned in the report as feedback from the trade,
stakeholders and members of the public. Most of these external influences cannot be
controlled or modified as a measures to influence provision of taxis at the ranks. The closest
analogy I can think of at the moment is that it is akin to driving a car, when you only have control
of the throttle, but not the steering or the brakes. Difficult to navigate if you can only influence
one controlling factor.
The influences on passenger demand for taxis in Perth have changed the level of demand and
when it occurs. For example, there appear to be fewer nighttime economy venues in Perth than
there were in 2017. The retail offer in Perth appears to have changed in recent years. Both these
changes and potentially other changes will tend to influence demand. If demand has dropped
at the ranks, the trade will tend to look for alternative earning opportunities. Whether this is
undertaking more pre-booked hires, working part time as a driver and part time elsewhere or
undertaking contract work rather than public facing hires.  Public behaviour also changes over
time. The public consultation had calls for Uber to be introduced in Perth. This is not an
uncommon response from the public. As mobile apps are used to control more and more of
daily life, from controlling lighting and entertainment at home and controlling washing
machines and fridges, people are increasingly inclined to use their smartphones to arrange
transport. This includes bus and rail travel, as well as booking licensed vehicles. So, whilst we
have seen a reduction in demand at the ranks, we don’t know how much of this is a reduction in
overall demand and how much is due to changes in behaviour from use of ranks, in favour of
use or pre-booked hire, whether obtained via an app or via telephone booking.
The report is limited to recommendations regarding the licence limit. Unfortunately, there are
no guarantees regarding how any additional licences would be used. There is strong evidence
that some of the most recently released licences are not used for public facing hires and
concentrate on contract work. However, we don’t know if this use of newly licensed taxis has
displaced other licensed vehicles which would otherwise have been used on these contracts.
Was the three-day survey period (June 20-23, 2024) representative of typical demand?
Could local events, school holidays, or seasonal factors have distorted the findings?
The three-day survey period was intended to obtain a snapshot of information regarding the
level of demand for taxis at ranks and supply of taxis available at the ranks. School holidays are
generally avoided when undertaking rank surveys. Seasonal variations are taken into account
when the data is analysed.
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The cost of public consultation has to be balanced against the overall cost of the project and
the role that the public consultation results have within the process.
With only 435 public responses, is the sample size statistically significant? Does it
adequately reflect diverse demographics (e.g., age, mobility needs) and usage patterns
across Perth?
The unmet demand survey related to the level of demand for taxis at taxi ranks and through
hailing passing taxis. The public consultation survey was intended to complement the taxi rank
observations and to provide information regarding the level of demand which could be
suppressed. Other information was also collected and reported. When analysing the data
collected from different sources, the commonality of results was considered. The information
from the public consultation survey generally tended to corroborate information from the rank
survey and stakeholder consultation. As such, the likelihood that a radically increased sample
size would result in radically different result from the public consultation survey seemed
unlikely. Therefore, it would be considered that the survey was indeed statistically significant
and reasonably representative of the population. The level of confidence associated with a
sample of this size would be within the range of plus or minus 10%, for non-extreme results. 
It is acknowledged that the method of survey would have influenced results, with not all of the
population having access to an online survey. All alternative survey methods would be likely to
have an influence on the proportion of the population which could be sampled. The traditional
alternative was to undertake face to face public consultation in public areas, such as shopping
streets in the City centre. This approach also tends to skew the sample towards people who
undertake weekday daytime shopping in the City centre. It was felt that online consultation was
less constrained regarding geography and time or response. i.e. people all over Perth could
respond at any time of day or night.
Why were these five ranks chosen, and were they observed equally? Could focusing on
high-demand ranks like Murray Street overstate unmet demand compared to less-used
ones?
All ranks in Perth were included. All were observed over the same period. There was no focus or
weighting applied to the Murray Street rank. The results were aggregated across all ranks. Data
was collected for the number of passengers, number of taxis departing the ranks and the
number of passengers waiting and the length of time passengers waited. This data was
aggregated for all ranks and analysed. The assessment of unmet demand relates primarily to
the proportion of passengers who had to wait for a taxi.
How many taxis were available via pre-bookings during rank observation periods? Did the
survey account for these in assessing total supply, or does it overemphasize rank-based
demand? 
An unmet demand survey relates to how many taxis are available at ranks and for hailing and
how many passengers hire taxis at ranks and by hailing. The level of passenger waiting at taxi
ranks or for hailing taxis is considered and assessed to determine whether this level of waiting
(termed unmet demand) is significant. If taxis were undertaking pre-booked hires rather than
servicing rank-based demand, this was not taken into account when assessing the level of taxi
availability at ranks to service rank-based passenger demand.  
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If 24 licenses are added, could reduce earnings per driver (due to diluted trade) deter new
entrants or push existing drivers out, negating the intended increase in supply?
There are many influences which influence the level of demand for taxis, the pattern of demand
for taxis (e.g. daytime demand versus nighttime demand), the availability of taxis in different
locations and times and the type of hire work which taxis undertake. The willingness of drivers
to undertake different types of hire work, and the hours that drivers work is influenced by many
factors. It is likely that 24 additional licences would influence both demand for taxis and supply
of taxis. It is unlikely that the introduction of 24 new licences would result in 24 licences leaving
the fleet.
Why weren’t options like optimizing existing taxi schedules (e.g., incentivizing peak-time
work) or improving rank efficiency explored before recommending more licenses?
All taxis are operated within independent commercial businesses. These businesses determine
when and where taxis operate and the type of hires which taxis undertake. Businesses may
operate a single taxi or multiple taxis, and each taxi may be driven by a single driver or multiple
drivers at different times. It is not feasible to implement direct measures to control when the
commercial taxi businesses operate there taxis, where they operate their taxis and whether
they obtain hires from ranks or through pre-booking.
How would 24 new taxi licenses affect private hire cars, which dominate pre-booked
hires? Could this oversaturate the licensed vehicle market, harming both sectors? 
There are many factors which influence private hire cars. The addition of more taxi licences is
likely to influence private hire cars. It is intended that the addition of more taxi licences would
also influence how many taxis service rank-based passenger demand.
The recommendation ties new licenses to wheelchair-accessible vehicles (WAVs). Is there
specific data showing sufficient demand for WAVs at ranks, or could this condition limit
uptake?
Evidence collected over successive taxi unmet demand surveys and from other stakeholder
consultation has indicated that wheelchair users face greater difficulty hiring suitable licensed
vehicles, than other members of the public. Increased availability of wheelchair accessible
licensed vehicles would be anticipated to improve availability of suitable licensed vehicles
available for wheelchair users to hire.
What concrete data supports claims of a driver shortage? If taxis are parked due to no
drivers, how will 24 new licenses be utilized without recruitment strategies?
Stakeholder and trade consultation indicated that some taxis are not utilised to undertake rank
based hires. Feedback also indicated that some drivers don’t work full time. Feedback
indicates that there is a limited level of multi-shift driving of individual taxi vehicles. Some new
licences may be taken up by existing drivers who don’t currently own a taxi. Some may attract
new entrants to the trade.
How does Perth’s ISUD (Index of Significant Unmet Demand) of 2,143.5 compare to other
cities of similar size? Is this value unusually high due to methodological flaws rather than
genuine unmet demand?
The ISUD level in Perth was unusually high. The level of passenger waiting observed at ranks
was extensive. The unmet demand was genuine.
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NOTE FROM PERTH AND KINROSS COUNCIL:
For reference, the ISUD level based on a selection of Surveys of Unmet Demand have been set
out below:
• Stirling in 2022: 271.1
• Aberdeen City in 2024:  55.7
• Edinburgh in 2018: 46
• Argyll and Bute in 2019: 38
• Dundee in 2024: 30
• Perth and Kinross in 2018 (for Perth): 6.7 
• Perth and Kinross in 2018 (for Blairgowrie): 17.3
• Perth and Kinross in 2022 (for Perth): 704.3 
• Perth and Kinross in 2022 (for Blairgowrie): 2,007.7
• Perth and Kinross in 2024 (for Perth): 2,143.5
Did the survey consider shifts toward ride-sharing apps or public transport improvements
that might reduce future taxi demand, making additional licenses unnecessary?
The survey considered a snapshot of observed data over a three-day period. The measures
proposed were intended to address current levels of unmet demand.
How was trade feedback (e.g., insufficient trade, parked taxis) factored into the ISUD or
recommendation? Were specific concerns dismissed, and if so, why?
Trade feedback was considered in conjunction with other information collected. Trade
feedback corroborated information obtained from other sources, including the rank surveys.
Trade feedback covered a range of subject areas. No feedback was dismissed. Trade feedback
was incorporated in the unmet demand survey report. Some feedback was summarised to
represent multiple responses.
2017 figures there are 1959 taxis on the ranks with 159 passengers waiting roughly 2 mins
and 08 seconds. 2021 there were 774 taxis on the ranks and 159 people waiting roughly 12
mins and 31 seconds. In 2024 we have 943 taxis on the ranks 331 fares waiting yet the
waiting time is only 5 mins and 30 seconds. Page 54 of the Survey says the average waiting
time in 2024 is better than in 2021. I thought the Survey indicated it was worse off. This is
confusing. Can you please explain?
The 2017 data referred to of 1959 taxis on the ranks, relates to the total number of taxis
observed departing the ranks, both empty and with passengers. 
The 774 taxis referred to in 2021 relates only to taxis which departed the ranks with passengers.
A further 512 taxis departed the ranks empty, equating to a total of 1286 taxis observed
departing the ranks.
The 943 taxis referred to in the 2024 report relates to taxis which departed the ranks with
passengers. A further 464 taxis departed the ranks empty, equating to a total of 1407 taxis
departing the ranks. 
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The report on page 54 states "For the 2024 survey, average passenger delay was 1.23 minutes (1
minute 14 seconds), this compares with the 2021 survey, when the average passenger delay
was 2.17 minutes (2 minutes 10 seconds)."  The average passenger waiting time was lower in
2024 than in 2021. The difference could be interpreted by some as better. The report did not
state that the waiting time was ‘worse off’. The assessment of unmet demand and whether it is
significant is not solely reliant on comparing the average waiting times for passengers. The
number of passengers who had to wait, the level of waiting at different times of day and the
proportion of all passengers who had to wait, together with the proportion of potential
passengers who don’t use ranks or give up waiting at ranks, because they don’t expect that
there will be taxis available for them to use, all play a part in the assessment.
Page 3 of the Survey refers to a population of 153,810 but that is for the whole of Perth and
Kinross. The City of Perth is just under 50,000. How do you account for this discrepancy?
Table 1 of the report compares the number of licensed vehicles in each local authority area in
Scotland with the population of the relevant authority. This is provided as an illustrative
comparison on a like for like basis. Whilst some local authorities in Scotland have licensing
zones within the authority, it is not practicable to make comparisons on a zone by zone basis,
between different authority areas. The illustration serves to indicate that the relationship
between population and licensed vehicle provision varies. This serves indicate that other
influences can affect the number of licensed vehicles which operate in different areas.
The Survey was completed in June 2024. Is this Survey now not well out of date?
Taxi unmet demand surveys are undertaken periodically every few years. In Perth and Kinross,
this has generally been at intervals of around three years. The results of each survey represent a
snapshot of conditions at the time of the survey. The 2024 survey captured a snapshot of
conditions at that time and remain valid.
According to the National Taxi Groups, the Survey should have been carried out over a
longer period.
The survey was undertaken according to guidance which was in place at the time. The period
over which the survey was conducted was commensurate with the majority of taxi unmet
demand surveys undertaken in the UK.
Page 9 of the Survey indicates 40 passengers ‘left in frustration’ … why is this wording the
same as the last two Survey reports?
The wording ‘left in frustration’ was used in the 2021 and 2024 reports. No use of this wording
was found in the 2017 report. The wording has been found to be representative of the situation
it is intended to depict. The wording in each report related to the number of people who arrived
at taxi ranks where there were no taxis waiting and then waited for taxis to arrive. After having
waited they left the ranks, when no taxis arrived at the ranks. These passengers are held to
represent latent unmet demand for taxis. However, the term ‘left in frustration’ is generally
better understood by readers of the reports and is felt to be a phrase which is generally
representative of the situation it depicts.  
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Page 60 of the Survey the number of hires has dropped by 48%. How will adding more
plates assist?
The survey found that there was a high level of latent demand which was unmet. Increased
availability of taxis at ranks would encourage more of the latent demand to become patent
(actual) demand and use more taxis at the ranks. i.e. if there are more taxis waiting at the ranks,
more passengers would hire them from the ranks. The scope of the survey limits the potential
measures which can be identified to address a significant level of unmet demand. The
measures which may be suggested are limited to variation in the number of taxi licences.
Page 61 of the Survey. If 3 more taxis worked the ranks on Friday and Saturday nights and 1
additional worked during weekdays that would provide sufficient additional capacity. Why
have you recommended 24 plates?
If the number of taxis suggested worked the ranks for the duration of the times indicated (3 on
Friday and Saturday nights and 1 additional worked during weekdays), this would provide a
significant increase in capacity if these taxis worked solely from the ranks. However, there is no
way of ensuring that if, say, four more licences were issued, that they would work from the
ranks at the days and times required and for the duration of operation required. There is strong
evidence to indicate that not all taxis work from the ranks all the time. Consequently, it is
necessary to calculate the ‘equivalent’ number of taxis which work from the ranks at different
times. This ‘equivalent’ is the equivalent number of taxis which would be working full time at the
ranks to provide the equivalent level of capacity provided by the taxis which actually worked
from the ranks. The proportionate increase in ‘equivalent’ number of taxis working from the
ranks, which would be necessary to address the level of unmet demand, was calculated. This
proportion was applied to the full number of taxis, to calculate the number of taxis required to
supply the necessary level of provision at the ranks to cater for unmet demand. When
undertaking the calculation, it is necessary to assume that working practices and operating
hours will be similar to existing practices, for any new licences and that they would be unlikely
to all operate solely from the ranks. 
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PKC - PUBLIC
SUMMARY OF CONSULTATION RESPONSES
This Appendix sets out a summary of the issues raised in the consultation responses. 
1. Economic Impact 
Economic impact was a concern raised by respondents who favoured removing the limit
and those who wanted no change. This indicates that there are divergent views on this
issue, particularly within the taxi trade (drivers and operators). Key Concerns included:
 Many drivers report struggling to earn minimum wage.
 Fear that more licences will dilute income and force drivers out. 
Example Responses:
 “I work 60 hours a week and still struggle to make ends meet.”
 “Wages aren't great that's why we have lack of drivers.”
 “Adding plates will destroy our livelihoods!”
 I personally find that there is more than enough taxis in town to the point all drivers
are struggling to make a living and as you sitting in your office feel that you need
more maybe you should try driving a taxi for a week to find how difficult it is to earn
a decent living without having to do 12/13 hrs a day just to make ends meet. 
2. Value being placed on Licences 
Many comments linked to economic impacts came from a slightly different perspective,
suggesting that having to pay to “rent” a licensed car was unfair and made it difficult to
earn enough to make driving viable. The key concern is described as:
 Criticism of plate/licence leasing and monopoly practices which prevent new
entrants and drivers from obtaining their own licence when there is a limit on
numbers. 
Example Responses:
 … if I was to work independently it would be more worth my while. If only 24 plates
are given they will some how end up with the taxi offices or retirees. I have to work
extra hours to earn minimum amount.
 [Unlimited] (T)his would stop the selling of licences privately for considerable
sums of money. Why don’t the council take the plates back and rent them, thus
making a considerable amount of revenue annually.
 A taxi driver who uses a car from one of the main taxi offices has to hand over 50%
of their taking to the main taxi office - this is not encouraging people to be taxi
drivers - and this is a major issue - there is a shortage of taxi drivers.
 “… there is the issue of the Councils policy of allowing operators to transfer taxi
plates for monetary gain * Also many of these places are leased out (partnerships)
and for example the proceeds contribute to some pensioners income. *YOUR
POLICY WOULD RENDER THE PLATES WORTHLESS.”
3
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 “Drivers pay £150/week to lease plates—this is unsustainable.”
 I answered unlimited as most drivers can’t get rank plate as they are so expensive
to buy so owner driver drivers have to rent taxi firms council would be as well
charging monthly amount it would be fairer 
3. Public Transport & Safety 
The impact of lack of taxis on the public was captured in responses, with respondents
highlighting a number of key concerns:
 Use of taxis for other functions (e.g. school contracts).
 Taxis seen as a lifeline, especially for rural and disabled users.
 Safety concerns for women and vulnerable passengers. 
Example Responses:
 “I had to walk home alone at night because no taxis were available.”
 “Buses stop at 8pm—taxis are essential.”
 “Taxi availability affects nightlife and public safety.”
 The elderly population in particular in Perth is growing.  The elderly give up their
driving licences and vehicle ownership as they age. Travel distances to GPs,
banks, and other vital services are growing. There are often no taxis available at
the Mill Street rank.  It is often empty with no computer rolling public narrative as
to when one can be expected at the rank.  
 It is my understanding that our licensed taxi vehicles (as well as private hires) are
used for school transport and as medical couriers between Perth Royal Infirmary
and Ninewells. If this is correct and the case, the current availability of taxi
provision diminishes even further. 
4. Competition 
Key Concerns:
 Calls for fairer licensing, Uber-style services, and modernization.
 Suggestions for minimum working hours, driver incentives, and app-based
systems. 
Example Responses:
 “Plate barons are killing the trade—open it up!”
 “Let drivers apply directly for plates, not lease them.”
 “Introduce Uber or similar services to improve competition.” 
5. Accessibility & Inclusivity 
As with the unmet demand survey itself, a number of comments were made about
accessibility of tai services. Key Concerns included:
 Strong support for wheelchair-accessible vehicles.
 Frustration from disabled users about lack of reliable transport.
 Calls for inclusive licensing and driver training.
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Some responses which referred to this included:
 “It’s increasingly difficult for wheelchair users to get taxis …”
 “All taxis should be accessible by all of the people all of the time.”
 “Disabled people deserve freedom of movement.”
 “With respect to our disabled community in Perth, I do feel that additional
wheelchair accessible vehicles would be a positive move for the taxi trade in Perth
and existing operators would have no hesitation in adding such appropriate
vehicles to the fleet available for hire to the community.”
 I think everyone should have a choice in how they travel. Whether it be power
wheelchairs or manual wheelchairs, et cetera.
 More taxis are needed never enough in the mornings or at 3 pm in the afternoon
and never any wheelchair accessible taxis available. 
Limited comments were received which expressed the opposite view, such as: 
 This nonsense of a lack of wheelchair accessible taxis is farcical. Never seen
someone in a WC waiting for a taxi on Murray street. 
6. Driver Shortage vs. Vehicle Shortage 
As could be seen from the survey of the trade undertaken as part of the unmet demand
survey, shortage of drivers was raised by a number of respondents, presumably mainly
from the trade.  Key issues raised were
• a shortage of drivers, not vehicles.
• Many taxis are parked due to lack of drivers.
• Calls for driver recruitment, not more plates/licences. 
Example Responses:
• “Perth does not have a taxi vehicle problem, it has a taxi driver problem.”
• “There are plenty of cars sitting unused because there’s no one to drive them.”
• A taxi driver who uses a car from one of the main taxi offices has to hand over 50%
of their taking to the main taxi office - this is not encouraging people to be taxi
drivers - and this is a major issue - there is a shortage of taxi drivers 
7. Environmental Concerns 
Key Concerns:
 Mixed views on electric vehicles.
 Concerns about charging infrastructure and costs.
 Some support for hybrids or net-zero goals, others sceptical. 
Example Responses:
 “Electric vehicles are too expensive and impractical for taxi work.”
 “Encourage hybrid vehicles, not full electric.”
 “Net-zero nonsense—let drivers choose practical cars.”
 “Electric vehicles are the best option for the environment.”
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Page 105

1 
Karen Engelberts
Licensing Manager
Legal & Governance Services
Perth & Kinross Council 
Dear Ms Engelberts 
Unmet Demand Survey
Response on behalf of Perth Taxi AssociaƟon 
1. We write to provide a wriƩen response to the current consultaƟon being conducted by
Perth & Kinross Council (“PKC”) on the subject of unmet demand for taxi services. We
provide this response by way of leƩer rather than using the online consultaƟon portal.
2. We refer to our earlier wriƩen response to the consultaƟon. A number of legal
arguments were set out in our earlier response. For the avoidance of doubt, we stand
by those arguments but, in the interests of brevity, we do not repeat them here.
3. We note (and appreciate) that you have sought to respond to a number of the issues
raised in our earlier response, but the updated report and Q&A document from LVSA
does not deal with all of the issues and certainly does not deal adequately with those it
seeks to address. Indeed, the addendum to the report illustrates that we were correct
to note that the report is (and remains) flawed and is not a proper basis on which to
proceed. 
4. For the reasons set out in this response, it remains our view that the LVSA report
(including the addendum and Q&A) (the “Report”) is fundamentally flawed and
unscienƟfic in nature, meaning it does not provide a proper or raƟonal basis on which
to proceed to determine whether there is unmet demand in Perth. It is therefore our
posiƟon that you should refuse to give any weight to the Report, and you should
determine there not to be any significant demand for the services of taxis in their area
which is unmet for the purpose of secƟon 10(3) of the Civic Government (Scotland) Act
1982. 
3
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5. We invite you, on that basis, to find that there is no need to issue any addiƟonal taxi
licences. 
The Report is flawed
6. It now appears to be accepted by PKC that the Report requires to be properly
considered and not simply accepted at face value. It is essenƟal, therefore, that the
considerable and material deficiencies in the Report are acknowledged by PKC. A failure
to face up to those deficiencies by PKC would render any decision open to legal
challenge. 
7. We begin by making some general comments in relaƟon to the unscienƟfic nature of
the report and then, in the interests of ease of comprehension, the remainder of this
response follows the order of the Q&A document. 
UnscienƟfic CalculaƟon/ Failure to Explain
8. The Report seeks, at its heart, to draw a comparison between the 2024 data and the
data in 2017 or someƟmes (seemingly interchangeably and arbitrarily) with the 2021
data.
9. The ISUD calculaƟon is crude in its nature. Read short, it is a series of numbers which
are then mulƟplied together to give an “ISUD figure”. That figure is then assessed
against a benchmark figure of 80. It is unclear why that figure is chosen.
10. Given that the numbers are mulƟplied together, one or two of the numbers being
arƟficially inflated will, as a maƩer of basic mathemaƟcs, skew the end result. 
11. One of the numbers used is the “Percentage of passengers travelling in hours with
average queue of over one minute”.  It is recognised in the Report that “For the 2024
survey, average passenger delay was 1.23 minutes (1 minute 14 seconds)”. Bearing in
mind that LVSA accepts that the Report was prepared on a very short “snapshot” basis,
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3 
the “Percentage of passengers travelling in hours with average queue of over one
minute” is set at 40 in the ISUG calculaƟon. 
12. Self-evidently, if one of the figures in the calculaƟon is set at 40, it is already rendered
all but impossible for the end ISUG figure to be below 80. Seƫng the figure at 40
because the waiƟng Ɵme was, on average and during the very short snapshot window,
exceeded by 14 seconds (as opposed to the 2021 data where the waiƟng Ɵme was said
to be, on average, over 2 minutes) seems to us to be a material misrepresentaƟon of
what the data really shows. 
13. It is clearly misleading in the extreme to use an arbitrary cut-off of 1 minute when the
average waiƟng Ɵme figure is over that figure by such a small amount. Nowhere in the
Report is it explained properly that, but for the 14 seconds on average, the percentage
figure in that line of the calculaƟon would be zero. Because of how the calculaƟon
works, if that figure had been zero, the end result ISUG figure would have been zero (ie
mulƟplying anything by zero produces a zero). By any reckoning, zero is materially
below the benchmark figure of 80, and the Report would have had no basis on which to
suggest there was any unmet demand at all. 
14. Bearing in mind the other flaws with the data set out below alongside (i) the very limited
window, (ii) the very small amount of data, and (iii) the fact that what data there is
appears to have been gathered by aƩaching a camera to an arbitrary selecƟon of taxi
ranks, and (iv) the general subjecƟvity inherent in the calculaƟon, the ISUG value is
simply not capable of being relied upon as a standalone basis on which to make a
decision such as this. 
15. PKC has been presented with a figure (ie the 40% figure) which would have been the
same for the purposes of the calculaƟon whether the 40% of relevant passengers had
been travelling in an hour with a wait of 90 minutes or with a wait of 90 seconds. Given
the incredibly small margin by which the average exceeds the 1 minute threshold, it was
incumbent on LVSA to have explained that to members and to provide them with other
worked examples so that they are able to make an informed decision on the data. 
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4 
16. The failure to do that is misleading at best and, given the material effect that PKC has
been told this decision will have on the livelihoods of taxi drivers, it is essenƟal that that
factor be given significant weight. 
The Railway StaƟon Rank
17. The above flaw with the Report is exacerbated by the aƩempt by LVSA to explain away
what is, by any reckoning, a material error in having used data from the Railway StaƟon
rank. The Railway StaƟon rank is not a rank that is capable of being used by all taxis.
That has now laƩerly been accepted in the addendum to the report, but it is noted as
follows:
“It is the view of LVSA that all locaƟons where taxis commonly wait for fares, including
formal ranks, informal ranks and ranks on private grounds, should be included in an
unmet demand the assessment.  Taxis which wait at informal locaƟons and private ranks
are not available at other locaƟons, including public ranks.”
18. It is unclear in the extreme what relevance that statement has to the ISUD calculaƟon.
For example, there is no line in the equaƟon which takes into account how many taxis
were waiƟng at the staƟon whilst there were none at another rank where passengers
were waiƟng. It seems to be an aƩempt to explain away a material error in the Report. 
19. The Report sought to use data from a rank at which only selected taxis can collect
passengers to suggest that the whole of Perth requires more taxis. The backtracking
aƩempt to say “it would not have maƩered anyway” belies the wholly subjecƟve and
unscienƟfic nature of the calculaƟon.
20. In effect, the addendum and Q&A indicate that the data is arbitrary. As long as LVSA are
able to demonstrate that they witnessed a percentage of people waiƟng at any
arbitrarily chosen rank for longer than 1 minute (even if, as here, by only a few seconds),
the ISUD calculaƟon will inevitably suggest that there is unmet demand. It is a wholly
unreliable report, made worse because of the selecƟve and subjecƟve manner in which
it has been carried out. 
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5 
21. That PKC has failed to recognise the material deficiencies in the Report is clear by the
parroƟng in the Q&A of the aƩempted explanaƟon by LVSA. That is a material error
which must be recognised and acknowledged because it undermines the credibility of
the Report as a scienƟfic exercise. 
LoŌ Rank, South Street
22. The explanaƟon of the manner in which the data from this rank has been used makes
no sense. It is wholly incredible in our experience to suggest that there were no rank
hires or waiƟng taxis. 
23. This rank is well used, and cars regularly queue there from approximately 11pm when
the rank is open. That suggests to us that one of two things has happened: (i) the data
has not been analysed correctly, or (ii) the data is wholly unrepresentaƟve of the usual
manner in which that rank operates. In either of those cases, the data in the report has
been skewed to a material extent. 
24. Again, there appears to be no explanaƟon in the Report of the manner in which small
changes to the data could have considerable effects on the ISUG calculaƟon. The Report
is misleading in that it gives to PKC members a false impression of the extent to which
the conclusions are (i) supported and (ii) definiƟve. 
WaiƟng Times
25. The Q&A gives a misleading indicaƟon of what the data suggests on waiƟng Ɵmes. 
26. Whilst the Report concludes that “The average waiƟng Ɵme for all passengers who had
to wait for a taxi during the 2024 survey was significantly longer than the observed
average wait Ɵme during the 2017 survey, of 2 minutes and 8 seconds”, the reason for
that is enƟrely clear if one looks back to the preceding paragraph.  That preceding
paragraph notes as follows:
“The maximum wait Ɵme observed during the 2024 survey was 39 minutes 30 seconds.”
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6 
27. It is, again, a basic maƩer of mathemaƟcs that, if an outlier figure of that nature is
included in the average, it will skew the figures. On a proper scienƟfic basis, that clear
outlier figure (assuming it to be accurate) should have been discounted from the
calculaƟon of the average. Otherwise, the snapshot nature of the exercise gives an
enƟrely misleading view of the underlying reality. 
28. We do not have access to the underlying data but it seems to us enƟrely like that, if the
outlier figure had been discounted, the 2024 average would have been significantly
reduced. That would have been a fairer and more balanced comparison figure to use.
29. That this is not explained in the Report is a significant concern to us. It indicates that the
Report sets out to prove a pre-determined conclusion rather than following the data in
a fair and scienƟfic manner. It is essenƟal that PKC recognises this flaw.
30. In any event and by any reckoning, the snapshot data from 2024 is now considerably
out of date. There is a very real limit to which it can possibly be taken to be
representaƟve – if ever it was. It is our posiƟon that a new survey ought to be carried
out, on a more scienƟfic basis, in order to get a set of data that is more accurately
representaƟve of the reality in the city. 
Period of Survey and Sample Size
31. We enƟrely appreciate that proporƟonality must be factored into the carrying out of
these exercises. That being said, the effect of a decision premised on flawed data will
have a disproporƟonate effect on the livelihoods of exisƟng taxi drivers in Perth. It is,
therefore, incumbent on PKC either (i) to ensure that the period is long enough to
provide a representaƟve snapshot, or (ii) to use a shorter period but to adjust the figures
to remove outlier results which skew the data. 
32. It seems to us that neither of those things happened here. Instead, a very short period
of Ɵme was used and a very small data set of consultaƟon responses, which has created
a completely unrepresentaƟve data source, and a wholly unscienƟfic approach has been
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7 
taken whereby the black and white snapshot data is not adjusted to make it more
representaƟve.
33. Simply noƟng that “seasonal variaƟons are taken into account” does not resolve the
issue. If, for example, as noted above, a single passenger has an extremely unusual
waiƟng Ɵme, that will affect the whole of the data set. It is, therefore, important to
prevent that from happening or at least to present the data with a spectrum of
possibiliƟes. Instead, the Report presents the data as black and white. That is a very
serious error which must be taken into account. 
Inconsistent comparisons of populaƟon data
34. There remain issues with the populaƟon data and how it has been used. It is insufficient
to suggest, as is done in the Q&A document, that it is not pracƟcable to make
comparisons on a zone-by-zone basis. 
35. The reality is that we are talking about taxi licences for a specific zone in Perth. We are
not talking about the whole of Perth and Kinross local authority area. We previously
made the point in our earlier response, but we repeat it here as conƟnuing to be a
concern to us.
36. Much is made of the licensed vehicle per 1,000 populaƟon in the Report, but the
populaƟon figure used on page 2 is 153,810. That is the total populaƟon of Perth and
Kinross. The Report does not collect data over the whole local authority area. It focuses
only on Perth City. In the 2022 census, Perth City had a populaƟon of 47,893. This is all
informaƟon readily available on the council’s own website1 so there is no reason why it
would not have been available to LVSA. The reliance on the larger populaƟon figure to
exaggerate the raƟo of vehicles to populaƟon is misleading at best. 
1 hƩps://www.pkc.gov.uk/arƟcle/15093/PopulaƟon-and-the-Census 
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8 
37. Again, this is a flaw that PKC is required to take into account. It makes the Report an
unreliable basis on which to make the decision that PKC is being asked to make.
Effect on exisƟng drivers
38. One very relevant factor to the decision-making process must be the extent to which
the decision will affect exisƟng drivers. The Q&A notes baldly:
“It is likely that 24 addiƟonal licences would influence both demand for taxis and supply
of taxis. It is unlikely that the introducƟon of 24 new licences would result in 24 licences
leaving the fleet.”
39. That statement is not made on the basis of any data as far as we are able to tell. PKC
has shown no interest in the issues that are affecƟng exisƟng taxi drivers without adding
to those concerns by puƫng in doubt whether their business will even remain viable.
We menƟon, in parƟcular, the increasing level of anƟ-social behaviour and violence
faced by drivers in their taxis. AddiƟonally, the increasing level of non-payment and
passengers booking with more than one company and failing to cancel the booking,
resulƟng in wasted journeys for the drivers. PKC may be aware that, for example, Police
Scotland is taking up to four weeks to respond to any reports of non-payment. The
overall working condiƟons for drivers at the moment are very difficult for a number of
reasons.
40. As a result of the new condiƟon that all new licences must be wheelchair accessible
vehicles, PKC is increasing the cost for new intrants whilst diluƟng the revenue stream
into which they are entering. There is no data that suggests that, on a large scale, there
is a demand for wheelchair accessible taxis that is going unmet. It appears to be a
soluƟon in search of a problem. 
41. The taxi industry in Perth does not need diluƟon; it needs help. There has been no
consideraƟon of that at all throughout this process.
Use of earlier consultaƟon responses
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9 
42. We understand it is the intenƟon of PKC to have regard to the previous responses
received in relaƟon to the earlier stage of this consultaƟon. Whilst we take no issue with
that in principle, it is incumbent on PKC to have regard to the iniƟal response having
been made when there was no opƟon to select “no change”. Therefore, given that
anyone who completed the first round of this consultaƟon by way of online response
had to select either 24 new plates or unlimited new plates, the number of people to
made that response will be materially overstated. It is impossible for PKC to know how
many of those people would have selected “no change” if that opƟon had been
available to them.
43. It will, therefore, not raƟonally be open to PKC to rely on those numbers.
44. AddiƟonally, we are aware that a number of people responded to this extended
consultaƟon with a request that their laƩer response supersede what they had said
previously (when certain outcomes were not available opƟons). We are aware that a
number of those people asked for confirmaƟon from PKC that their earlier response
would be disregarded, but no such confirmaƟon has yet been given. Unless a second
response incorporates the earlier response, PKC should not be relying on the earlier
response. 
Conclusion
45. For all of those reasons, it is our view that there is no proper basis on which it can be
said that there is significant unmet demand in Perth City. It would be wholly irraƟonal
of PKC to rely on such a flawed report and such an inadequate consultaƟon process as
providing any lawful basis for an alternaƟve determinaƟon. The Report should be
recognised as being unscienƟfic and misleading, and should be given no weight at all in
the decision-making process.
46. There is no need for the current maximum number of taxi plates to be increased, and
we accordingly invite PKC to refuse to permit any further plates to be issued.
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1 
Karen Engelberts
Licensing Manager
Legal & Governance Services
Perth & Kinross Council
Sent by email to:- civiclicensing@pkc.gov.uk 
Dear Ms Engelberts 
Unmet Demand Survey
Response on behalf of Perth Taxi AssociaƟon 
1. We write to provide a wriƩen response to the current consultaƟon being conducted by
Perth & Kinross Council (“PKC”) on the subject of unmet demand for taxi services. We
provide this response by way of leƩer rather than using the online consultaƟon portal
because, as set out in more detail below, it is our view that the online version of the
consultaƟon is parƟal, unfair, and fails to comply with the requirements of a lawful
consultaƟon. 
2. This response makes the following three broad representaƟons which are expanded
upon below:
a. PKC has misdirected itself as to the nature of the LVSA Report from December
2024 (the “Report”) in that it regards itself to be bound by it. 
b. The Report is flawed and should not be followed. 
c. The consultaƟon has not been conducted lawfully, and the outcome appears to be
pre-determined.
3. In the interests of clarity, those three representaƟons are dealt with separately below. 
MisdirecƟon in relaƟon to the Report
4. We provided to you some comments on 5 May 2025 in relaƟon to the flawed nature of
the consultaƟon. By response on 9 May 2025, you said the following:
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2 
“As the survey indicates that there is a significant demand which is unmet, the Council
now has no legal basis on which to refuse an applicaƟon for a taxi licence in Perth City
on the grounds that it exceeds the exisƟng limit.”
5. That statement is incorrect as a maƩer of law. You will be aware that PKC as the
licensing authority must comply with the provisions of inter alia secƟon 10 of the Civic
Government (Scotland) Act 1982. That includes secƟon 10(3) which requires the
licensing authority to consider whether it is saƟsfied that there is no significant demand
which is unmet. 
6. A statutory power of decision-making must be exercised by the person on whom the
power has been conferred and not deferred to another person: Shahid v Scoƫsh
Ministers 2016 SC (UKSC) 1. PKC is not permiƩed, therefore, to abdicate responsibility
by saying that, because the report reaches a conclusion, PKC is bound by it. That is not
correct. PKC is under a duty to analyse and consider the report, and to quesƟon its
analysis, before ulƟmately coming to a view of its own in relaƟon to significant unmet
demand. 
7. In doing so, it is a requirement that all relevant factors be considered: cf City Cabs
(Edinburgh) Ltd v City of Edinburgh District Council 1988 SLT 184. In these circumstances,
the representaƟons made during this consultaƟon are one such relevant factor in order
to gain an understanding of the actual experience of those who use and operate taxis
in Perth. It is impermissible to restrict the consultaƟon arƟficially as if certain opƟons
are no longer open to PKC when that is not, in fact, the case.
8. We deal in more detail below with the issue of pre-determinaƟon in relaƟon to the
adequacy of the consultaƟon which also touches on this issue but, for the purposes of
this secƟon of this response, it is clear that you are simply incorrect to say that the
Council now has no legal basis on which to refuse an applicaƟon for a taxi licence in
Perth City on the grounds that it exceeds the exisƟng limit. Such a statement is a
feƩering of the PKC’s discreƟon, meaning any decision taken in reliance on that
statement is liable to challenge. 
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3 
9. PKC is not bound to accept the conclusions of the Report.
The Report is flawed and should not be followed
10. Having established below that the Report requires to be properly considered and not
simply accepted at face value, we set out in this secƟon the manner in which the Report
is flawed.
11. The Report is premised on a single 72-hour period between Thursday and Sunday. It
must be seen and understood in that context as a snapshot which cannot possibly be
indicaƟve of the whole experience of taxi users and operators. Similarly, the data
collected come from only five taxi ranks as is made clear at page 8 of the report. Of
those five ranks, one is them is not capable of being used by every taxi, and no account
appears to have been taken of the fact that certain ranks (because of their locaƟon) will
be busy at different Ɵmes. A rank outside a supermarket will not be busy at the same
Ɵme as a rank outside a nightclub. Taxi drivers are well aware of when the train staƟon
is likely to be busy and will plan accordingly. 
12. Separately, despite the Report suggesƟng that the rank at The LoŌ nightclub was
surveyed, that rank was not surveyed at all. That is a major flaw and makes the data
within the Report wholly unreliable.
13. We take issue with the enƟrely unscienƟfic method by which the data has been
recorded. The Report notes that: 
“Surveys were undertaken using video cameras which recorded acƟvity at the ranks
from Thursday to the following Sunday morning. The video footage of each rank was
processed to assess the level of usage of each rank and to record any incidences of
passenger waiƟng. Footage was recorded from 7:00 on Thursday 20th June 2024 to 7:00
on Sunday 23rd June 2024.”
Put another way, LVSA has aƩached a camera to each rank and then observed the
footage later. There was nobody from LVSA at the ranks when the data was being
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4 
collected. This is problemaƟc for a number of reasons. It is impossible to take account
of what may have been happening in the local area at the Ɵme of collecƟng the data if
nobody was there. A road being closed because of an incident off camera would simply
not be capable of being taken into account in the assessment of the data because LVSA
would not know about it. That notwithstanding, the report does go on to make
assumpƟons and to state them as categorical fact on occasion. A parƟcular example at
page 9 is as follows:
“It should be noted that not all passengers observed waiƟng for a taxi, actually boarded
a taxi. 40 intending passengers leŌ the ranks in frustraƟon, having waited at the rank
for a taxi to arrive.”
14. People leave a taxi rank without geƫng into a taxi for all manner of reasons. They may
have arranged a liŌ with a friend, decided not to travel at all, or decided to travel later.
To suggest without any foundaƟon whatsoever that 40 passengers leŌ the rank in
frustraƟon is not possible when LVSA did not have anyone there to speak to the people
and ask them.  That such a comment is made in the report is indicaƟve of the report
seeking to provide a basis for a finding of unmet demand rather than scienƟfically
carrying out a survey in order to see what conclusion is reached. 
15. Separately, the comparisons with 2017 and 2021 are not apt. The habits of the public
have fundamentally changed since the covid-19 pandemic. The Report makes a passing
reference to that changed behaviour in the execuƟve summary, but then goes on to pay
it no aƩenƟon at all when comparing the figures:
“Clearly, the way in which taxis operate has changed. The way in which people hire
licensed vehicles has also changed, with more people prebooking hires for immediate
travel.”
16. Seeking to draw comparisons with the manner in which people used to use taxis is not
comparing like with like. The 2017 data is simply too old to be at all useful, and the use
of the 2021 data also appears to be wholly arbitrary and inconsistent throughout the
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5 
report. For example, if one has regard to the comparison figures used in the ISUD value
on page 54, it is noted that:
“For the 2024 survey, average passenger delay was 1.23 minutes (1 minute 14 seconds),
this compares with the 2021 survey, when the average passenger delay was 2.17
minutes (2 minutes 10 seconds).”
But, when one looks back to page 9 when those averages are being discussed, it is clear
that the 2024 average figure is of that for all passengers, including those who did not
have to wait whereas the 2021 figure is that for only those passengers who had to wait. 
Had the proper comparison figure been used from 2021, it would have been 3 minutes
and 25 seconds, showing a considerably longer wait in 2021 than in 2024. No
explanaƟon is given by LVSA for this arbitrary use of non-comparable figures. 
17. There are real and material issues with the methodology adopted by LVSA. Much is
made of the licensed vehicle per 1,000 populaƟon in the Report, but the populaƟon
figure used on page 2 is 153,810. That is the total populaƟon of Perth and Kinross. The
Report does not collect data over the whole local authority area. It focuses only on Perth
City. In the 2022 census, Perth City had a populaƟon of 47,893. This is all informaƟon
readily available on the council’s own website1 so there is no reason why it would not
have been available to LVSA. The reliance on the larger populaƟon figure to exaggerate
the raƟo of vehicles to populaƟon is misleading at best. 
18. Separately, there is no reference at all in the Report to the difference between a lack of
cars on one hand (which does not exist) and a lack of drivers on the other. This is a
substanƟal oversight within the Report. ConsideraƟon really needs to be given to how
a lack of drivers links to the current or proposed number of plates. Furthermore, there
is a confusion in the Report about the current number of plates. The 80 plates currently
issued include two cars that are necessarily held in reserve. Those two cars are really 
1 hƩps://www.pkc.gov.uk/arƟcle/15093/PopulaƟon-and-the-Census 
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6 
now in abeyance and not on the road. They should not be counted among the cars said
currently to be on the road. 
19. Furthermore, two significant numbers in the ISUD value calculaƟon on page 54 are the
25.3% of weekday off peak hours, and the 40% of passengers with an average wait of
over a minute. In relaƟon to the first of those, because of the snapshot 72-hour period
over which the report data was collected, that can only refer to off peak Ɵmes on the
Thursday and Friday. Fridays are, of course, significantly busier than other weekdays
but, more generally, a two-day snapshot is an unscienƟfically short period of Ɵme over
which to assess data if one is then going to seek to extrapolate a figure like that one.  In
relaƟon to the second figure, the average wait of over 1 minute was 14 seconds. It is
clearly misleading in the extreme to use an arbitrary cut-off of 1 minute when the
average waiƟng Ɵme figure is over that figure by such a small amount. 
20. Both of those figures skew the ISUD calculaƟon on page 56 to such an extent that it is
effecƟvely rendered pointless. In parƟcular, because the figures in that table are
mulƟplied together to give the total, even a relaƟvely modest reducƟon in the 40 figure
(ie the second figure discussed above) would have had a substanƟal and material effect
on the boƩom-line number. The ISUD figure has, unfortunately, been rendered all but
meaningless because of the arbitrary approach that has been taken by LVSA to its
calculaƟon. There is, therefore, no evidence – or certainly no reliable evidence – of any
unmet demand let alone any significant unmet demand. 
21. That must, therefore, lead to the conclusion that there is no need for any addiƟonal
plates to be issued at all. Given that possible opƟon was omiƩed from your online
consultaƟon, we are only able to make that representaƟon in this manner. 
Inadequacy of the consultaƟon process
22. This final secƟon deals with the inadequacy of the consultaƟon process as a maƩer of
law. 
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7 
23. If a public body chooses to consult on a maƩer, it is required to do so lawfully. In R
(Coughlan) v North and East Devon Health Authority [2001] QB 213 at §108, the English
Court of Appeal determined as follows:
“It is common ground that, whether or not consultaƟon of interested parƟes and the
public is a legal requirement, if it is embarked upon it must be carried out properly. To
be proper, consultaƟon must be undertaken at a Ɵme when proposals are sƟll at a
formaƟve stage; it must include sufficient reasons for parƟcular proposals to allow those
consulted to give intelligent consideraƟon and an intelligent response; adequate Ɵme
must be given for this purpose; and the product of consultaƟon must be conscienƟously
taken into account when the ulƟmate decision is taken.”
24. Those principles derive from the decision in R (Gunning) v Brent LBC [1985] 84 LGR 168
and are usually known as the “Gunning principles”. Whilst they derive from an English
court decision, they are regularly referred to and applied in Scoƫsh courts: eg Cains
Trustees (Jersey) Limited and Cains Fiduciaries (Jersey) Limited as Trustees for the
Eastgate Unit Trust [2024] CSOH 80. They are, therefore, a good summary of the broad
principles that will be required in order for any consultaƟon process to be lawful: (i)
consultaƟon must be at a Ɵme when proposals are sƟll at a formaƟve stage, (ii) the
consulƟng authority must give sufficient reasons for any proposal to permit of
intelligent consideraƟon and response, (iii) adequate Ɵme must be given for
consideraƟon and response, and (iv) the product of any consultaƟon must be
conscienƟously taken into account by the decision maker.
25. The adequacy of the consultaƟon process is an inherent element of procedural fairness
and the sufficiency of the legal inquiry that is carried out: R (Help Refugees) v Secretary
of State for the Home Department [2018] 4 WLR 168 at §90.
26. The consultaƟon being undertaken by PKC is in breach of the Gunning principles. It is
clear that PKC has determined that the status quo will not be considered and, instead,
it is simply a maƩer of how many new plates are to be issued. The consultaƟon is
therefore not being conducted when the proposals are at a formaƟve stage. That is
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8 
evident from the first page of the online consultaƟon where one cannot move beyond
the first quesƟon without selecƟng an increase in the number of plates. 
27. Separately, PKC is required to provide details not just of the general proposals but of
what factors are likely to be of substanƟal importance to the decision and the basis
upon which the decision is likely to be taken: R (Eisai) v NaƟonal InsƟtute for Health and
Clinical Excellence [2008] EWCA Civ 438 at §66. No such details have been given to
permit of intelligent consideraƟon and response beyond poinƟng out the flaws in the
Report as set out above. 
28. It is also apparent that PKC has closed its mind to the opƟon of maintaining the status
quo. Again, that is evidenced from the online consultaƟon form. Pre-determinaƟon is a
form of apparent bias: Miller v Health Service Commissioner for England [2018] PTSR
801 at §§57 and 66. 
29. PKC has closed its mind prior to the making of the decision and is unwilling (and indeed
has made the online form such that no aƩempt can even be made) to be swayed no
maƩer what evidence is provided, and any decision that follows is therefore likely to be
unlawful and subject to challenge: R (Lewis) v Redcar and Cleveland Borough Council
[2009] 1 WLR 83 at §96; Electronic Collar Manufacturers AssociaƟon v Environment
Secretary [2019] EWHC 2813 (Admin) at §140.
Conclusion
30. For all of the reasons set out above, it is our view that there is no proper basis on which
it can be said that there is significant unmet demand in Perth City. It would be wholly
irraƟonal of PKC to rely on such a flawed report and such an inadequate consultaƟon
process as providing any lawful basis for an alternaƟve determinaƟon. 
31. There is, therefore, no need for the current maximum number of taxi plates to be
increased, and we accordingly invite PKC to refuse to permit any further plates to be
issued. 
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9 
We would, of course, be willing to discuss any of the issues raised in this response.
AddiƟonally, we look forward to having the opportunity to make oral representaƟons to the
council in due course. 
Yours sincerely 
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LVSA Unmet demand survey methodology clarification. 
1.1 Background
With respect to the taxi unmet demand survey undertaken in Perth during 2024, some
comments made appear to place an interpretation of the methodology used, which
may not be in line with the methodology actually applied.   
This brief paper sets out to define some of the key elements of the Index of Significance
of Unmet Demand calculation. 
1.2 How the passenger delay related elements in the ISUD calculation are
derived.
Passenger waiting at taxi ranks is measured in two principal ways.  This is: 
 Discrete passenger waiting and 
 Continuous passenger waiting. 
Discrete passenger waiting
Discrete passenger waiting occurs when an individual passenger or a group of
passengers arrive at a taxi rank and there are no taxis available for immediate hire.  The
time that the individual or group arrived at the rank is logged.  The time that the
passenger or group leave the rank, either in a taxi or on foot, is logged.  The diƯerence in
times is calculated and recorded as the wait time for the passengers concerned.   
Continuous passenger waiting.
When lengthy passenger queues form, the queuing becomes continuous.  It is often not
feasible to identify each passenger or group of passengers throughout their wait in the
queue.  Therefore an alternative methodology is employed.  The number of passengers
in the queue is measured every 5 minutes.  The number of passengers who departed the
rank in taxis or on foot is logged every five minutes.  This data is then used to calculate
the average wait time for passengers waiting in the queue during each five minute
period.   
Not all waiting passengers are counted as waiting
Occasionally, when passengers are waiting at the taxi ranks, they may not all be waiting
to board a taxi.  For example, it is not uncommon for a group of people to wait at a taxi
rank, for taxis to arrive and not all of the group board a taxi.  Some of the group may
leave the rank on foot, once the rest of the group have boarded a taxi or taxis.  Clearly,
the people who didn’t board the taxi were merely accompanying friends, until the taxi
arrived.  When this occurs, those waiting people who left the rank are not counted as
waiting passengers in the passenger waiting statistics. 
Similarly, it is occasionally observed that people will wait at a taxi rank, when there are
no taxis present.  For example, sitting on a nearby bench.  If a taxi arrived and there were
3
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no other people waiting and the people who were waiting didn’t board the taxi, then they
were assumed not to be waiting for a taxi and were excluded from the passenger waiting
statistics. 
How passenger waiting time is used
Passenger waiting time is used in the calculation of the Index of Significance of Unmet
Demand (ISUD).   
Two of the coeƯicients which are used in the index calculation relate to passenger
waiting times.  These are: 
 The proportion of weekday daytime (off peak) hours where people are observed to
have to wait for a Taxi to arrive.  Also known as the Steady State Performance (SSP)
statistic 
 The proportion of passengers which are travelling in any hour when the average
passenger wait in that hour is greater than one minute. Also known as General
Incidence of Delay (GID) 
SSP Calculation
The proportion of weekday daytime (oƯ peak) hours where people are observed to have
to wait for a taxi to arrive is calculated separately for each taxi rank observed.   
The original definition of the ISUD calculation, developed in the 1980s,  was based on
the assumption that ranks would be sampled for periods of around two hours, during
active periods and the results expanded using standardised profiles of demand
variation throughout the day.   
However, practices have moved on and nowadays, complete observation over 24 hours
each day is commonplace.  As such, the original approach of counting any passenger
waiting (even for a few seconds) as triggering that hour as a passenger wating hour, was
excessively onerous.   
Alongside new, more expansive observation practices, a more conservative approach
has been adopted.  This more conservative approach considers the SSP trigger to occur
if a passenger has been observed to wait for more than a minute at an active taxi rank.  A
rank is considered to be active, for the purposes of calculation of the SSP statistic, if two
or more hires occur during that hour. 
If the level of passenger waiting at an individual rank exceeds the threshold, that rank is
considered to be exhibiting SSD waiting for that hour.  However, if passenger waiting at
other ranks does not exceed the SSD waiting threshold for that hour, then they are not
considered to be exhibiting SSD waiting.   
For example, assuming there are 40 hours per week of oƯ peak hours and four active
ranks, this equates to 160 oƯ peak rank hours.  If passenger waiting at one rank on a
Friday morning exceeds the SSD threshold, this would be one hour out of the 160 rank
hours, i.e. 1/160 = 0.625%
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The data collected on the Thursday surveyed is weighted in order that the Thursday
results are taken to be representative of four weekdays.  The Friday results are used
individually, without weighting. 
GID Calculation
Passenger waiting was observed at each rank from 7:00 am on a Thursday though to
7:00 am the following Sunday.  The total number of passengers boarding taxis during
each hour was recorded.   
Aggregate passenger waiting time was calculated for each hour.  The aggregate
passenger waiting time was divided by the total number of passengers boarding taxis,
during the same hour, to calculate the average waiting time for all passengers during
each hour.   
If the average waiting time for all passengers during any hour exceeded one minute,
then this triggered the threshold to include the total number of passengers during that
hour in the GID calculation. 
Data collected on Thursday was weighted to represent four weekdays. 
1.3 How average passenger delay is calculated.
The total aggregate passenger waiting time observed on Thursday was multiplied by four
to represent four days, Monday to Thursday.  The aggregate passenger waiting time on
Friday and Saturday (including Sunday morning up to 7:00 am) was also added to the
aggregate Monday to Thursday passenger waiting, to calculate a weighted aggregate
passenger waiting time for Monday morning to Sunday morning.  This total represents
aggregate passenger waiting time over six days. 
Similarly, the aggregate number of passengers was calculated for Thursday (multiplied
by four) plus Friday and Saturday.   
The aggregate waiting time was divided by the aggregate passengers to calculate the
average wait time over the six days. 
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Page 126

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Page 127

IMPACT AND VALUE ASSESSMENT
Report Title: Report on Unmet Demand Survey and Public Consultation
Where the Impact & Value Assessment has identified a likely impact in relation to the committee proposal, detailed
evidence is provided below.
STRATEGIC IMPLICATIONS
Corporate Plan
Working in partnership with communities? - NO.
Tackling poverty? - NO.
Tackling climate change and supporting sustainable places? - NO.
Developing as resilient, stronger and greener local economy? - YES.
Enabling our children & young people to achieve their full potential? - NO.
Protecting and caring for our most vulnerable people? - NO.
Supporting and promoting physical and mental wellbeing? - NO.
Legal and Governance
Legal implications identified? - YES.
The Report relates to the legislative framework for regulating taxis and ensures that decisions about placing a limit on
taxi numbers are carried out in line with legal requirements.
Governance implications identified? - NO.
RESOURCE IMPLICATIONS
Finance
Financial implications identified? - NO.
Workforce
Workforce implications identified? - NO.
Asset Management
Asset Management implications identified? - NO.
CONSULTATION AND COMMUNICATION
Consultation
Internal or external consultation? - YES.
3
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External consultation undertaken. Police Scotland, Public Transport Unit and disabled and older persons
representative user-groups, taxi trade, the public and other users of taxi services, such as the hospitality industry. A
public consultation was carried out via the Council's website from 28 April 2025 for seven weeks and then for a
further five weeks from 23 July 2025. Feedback is incorporated in both the Committee Report and in the Unmet
Demand Survey Report which is attached to it.
Communications
Communications plan? - YES.
This will be primarily with the the taxi and private hire trade if a change is agreed to. This will be done through normal
channels of communication which are in place to engage with the taxi trade.
POLICY CHECKLIST
This report represents a new policy or a change to an existing policy document.
Corporate Risk Assessment
Corporate risk implications identified? - NO.
Equality & Fairness Impact Assessment (EFIA)
Protected equality characteristics impact? - YES.
Ensuring an adequate supply of taxis may have a positive impact on older and younger people and those with
disabilities. These people are likely to be more reliant on taxis as they are less likely to have a car. The options being
presented may have a potential negative impact if an increase in numbers of taxis results in a reduction in taxi
services, because there is insufficient income available to make it a sustainable business.
A full EFIA has been undertaken (based on likely impacts to protected equality characteristics) and is available
from https://www.pkc.gov.uk/eqia
Human Rights impact? - NO IMPACT.
Inequalities of outcome caused by socio-economic disadvantage impact? - NO IMPACT.
Inequalities of outcome in relation to Communities of Place or Communities of Interest impact? - POSITIVE IMPACT.
Ensuring an adequate supply of taxis may have a positive impact on older and younger people and those with
disabilities. These people are likely to be more reliant on taxis as they are less likely to have a car.
A full EFIA has been undertaken (including details of likely impacts from inequalities of outcome in relation to
Communities of Place or Communities of Interest) and is available from https://www.pkc.gov.uk/eqia
Strategic Environmental Assessment (SEA)
This proposal does not qualify for SEA.
Climate Change Impact Assessment
Business, Industry & Supply Chain impact? - NO.
Energy, Buildings & Infrastructure impact? - NO.
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Land Use & Land-Use Change impact? - NO.
Transport & Connectivity impact? - YES.
Positive: If a change is agreed to, this would mean adding capacity to existing taxi availability, which may reduce
reliance on private car use. Negative: Increasing the number of licensed taxis may produce greater emissions. The
question of vehicle type will be considered at a later stage, which may help to mitigate any potential impact. If an
increase in taxi numbers is approved, this may contribute towards improving access to local taxis for those of all ages
and those with disabilities, but this issue will be further considered separately in a future Report.
Waste & the Circular Economy impact? - NO.
Climate Resilience & Engagement impact? - NO.
Child Rights & Wellbeing Impact Assessment
Impact based on the GIRFEC wellbeing indicators? - NO.
Sustainable Procurement & Supply Impact Assessment
Resource use and consumption impact? - NO.
Social wellbeing impact? - NO.
Environmental wellbeing impact? - NO.
Economic wellbeing impact? - NO.
Data Protection Impact Assessment (DPIA)
Impact related to personal data/information? - NO.
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Page 130

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Page 131

PKC - PUBLIC
Equality and
Fairness Impact
Assessment (EFIA)
Form 
If the ‘policy or practice’ (see definition below) you are developing or
going to develop is assessed as relevant after undertaking the online
screening process (the Impact and Value Assessment (IVA)) - that is, it
will have either a positive or negative impact on people - you should
complete an Equality and Fairness Impact Assessment (EFIA) using
this form.
This form should only be completed if you have undertaken an Impact and Value Assessment
(IVA) to screen whether a full Equality and Fairness Impact Assessment is required.
Complete this for all relevant policies or practices:
● ‘relevant’ means it will have an impact on people
● ‘policy or practice’ - see definition below
Definition of policy or practice for the purposes of EFIA:
● The term ‘policy or practice’ covers Service delivery and Employment. This can include a
policy, a plan, a strategy, a project, a service review, a function, practice or service activity
or a budget option. 
3
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2
Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Name of policy or practice
Survey of Unmet Demand for Taxis in Perth 
Service and Division/Team
Legal and Governance Services - Licensing 
Owner/Person responsible (include your name and position)
Karen Engelberts, Licensing Manager
Sarah Rodger, Legal Manager 
Impact Assessment Team (include your names and positions). This team can consist of two
people or more as appropriate.
As above 
Is the policy or practice being impact assessed new or existing? 
The Council is responsible for regulating taxis and taxi drivers. The Council ensures that those
who operate and drive taxis are suitable to carry out that activity, from a public safety point of
view. The Council can also refuse new vehicle licences if there is considered to be no unmet
demand for taxis in Perth. There is an existing policy of having a limit on the number of taxis for
Perth City. This is periodically reviewed, approximately every three years, to assess whether
there is a significant demand for taxis which is unmet. This is done through a Survey of Unmet
Demand which is commissioned from an external contractor. The Council then has to decide
whether to accept those findings and if so, decide what action to take if there is a significant
demand which is unmet. This assessment is being undertaken as part of the decision-making
process following the most recent survey, undertaken in December 2024. 
That survey indicates that there is a significant unmet demand for taxis in Perth 
There are two main options which may be considered by Licensing Committee – increasing the
current limit of 80 by 24 more licences or removing the limit completely. Leaving the limit
unchanged would mean that applications for new licences can still be made and would need to
be considered on a case by case basis. Officers are recommending that 24 new licences are
added, although this assessment will also consider the impact of removing the limit where that
may differ from the impact of adding licences. 
Section 1: Policy details (see definition of ‘policy or practice’ above)
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3
Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
What are the main aims of the policy or practice?
Under the legislation that governs taxi licensing, the Council can place a limit on taxi numbers if
it is satisfied that this is needed to ensure the sufficiency of taxis for the public. The Council has
always had a limit in place which has been adjusted upwards when needed to ensure that there
are enough taxis to meet public demand. 
Who are the main target groups/beneficiaries?
The general public who use taxis. Taxi operators and drivers also receive services from
licensing in terms of the regulation of their activity as an operator or driver, but they are not
users of taxi services unless as a member of the public. 
What are the intended outcomes of the policy or practice?
To ensure that there is an adequate supply of taxis for the public. 
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4
Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Key questions to address in the EFIA
● Does the policy or practice evidence that it has eliminated discrimination?
● Does the policy or practice evidence that it has advanced equality of opportunity?
● Does the policy or practice evidence that it will foster good relations between groups? 
The Assessment should highlight areas of interest covering the following:
● positive and negative impacts across all protected characteristics
● scale of the impact: an indication of the degree of potential impact, and whether this is
judged to have a High, Medium or Low impact potential
● anticipated duration of the impact if relevant
● whether there is a specific differential impact to a particular protected characteristic or
characteristics
● if the impact is more wide-ranging and general in its effect
● whether any impacts identified would/could be mitigated by an amendment to the policy,
practice budget decision or service reform proposal 
Equality protected characteristic: Age
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Older people (65
years and over)
Ensuring an adequate supply
of taxis may have a positive
impact on older people who
may be less likely to have a
car. 
The survey indicates that the
impact on taxi services
cannot be predicted if the
number of licences is
Removing the limit outright
might positively impact on
access to taxis, but this is
unknown. It is also possible
that removing the limit may
reduce availability if there is
insufficient work to sustain
services. Once a limit is
removed, it would make it
more difficult to reintroduce a 
Section 2: Detail the positive and/or negative impacts, or tick to indicate no
impact identified
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
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Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
increased, although it is the
only real option the Council
has to address demand. 
Adding 24 licences is
preferred as a first step to
allow assessment of the
impact and would allow steps
to be taken to mitigate any
adverse impact. 
Adding licences is therefore
likely to better mitigate any
adverse impact on public
access to taxis. 
limit later, if it is found that
there is a negative impact on
availability. 
That may make it harder to
mitigate any negative impact
on older people. 
Equality protected characteristic: Disability
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Physical disability Ensuring an adequate supply
of taxis should have a
positive impact on disabled
people who may be more
reliant on taxi services to
meet their transport needs. 
The survey indicates that the
impact on taxi services
Removing the limit outright
might positively impact on
access to taxis, but this is
unknown. It is also possible
that removing the limit may
reduce availability if there is
insufficient work to sustain
services. Once a limit is
removed, it would make it 
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
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Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
cannot be predicted if the
number of licences is
increased, although it is the
only real option the Council
has to address demand. 
Adding 24 licences is
preferred as a first step to
allow assessment of the
impact and would allow steps
to be taken to mitigate any
adverse impact. 
Adding licences is therefore
likely to better mitigate any
adverse impact on public
access to taxis. 
Should the Licensing
Committee decide to issue
further licences, further
equality impact assessment
will be undertaken to inform
decision making about
vehicle type, such as
wheelchair accessible
vehicles. 
more difficult to reintroduce a
limit later, if it is found that
there is a negative impact on
availability. 
That may make it harder to
mitigate any negative impact
on disabled people. 
Sensory
impairment
As above  As above 
Mental health As above  As above 
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact 
Learning disability As above  As above 
Neurodivergent
conditions
As above  As above 
Equality protected characteristic: Gender reassignment
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Male transitioning
to female  
x
Female
transitioning to
Male  
x
Equality protected characteristic: Marriage/Civil partnership
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Women   x
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact 
Men   x
Same sex couple 
(male)  
x
Same sex couple 
(female)  
x
Equality protected characteristic: Pregnancy/Maternity/Paternity
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Women   x
Men (paternity)   x
Equality protected characteristic: Race
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
View the list of
categories used in  
x
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Scotland's Census 
Equality protected characteristic: Religion/Belief
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
View the list of
categories used in
Scotland's Census  
x
Equality protected characteristic: Sex
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Female During the consultation it was
raised that lack of availability
of taxis had meant that
women had to walk home
alone at night. This is
anecdotal information but
indicates that improving the
availability of taxis would
have a positive impact for the
public as a whole. 
x
Male   x
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact 
Equality protected characteristic: Sexual orientation
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
Lesbian   x
Gay   x
Bisexual   x
Other sexual
orientation  
x
Equality protected characteristic: Socio-economic (fairness) Please refer to Appendix 2
of accompanying guidance
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact 
Expanding access to the taxi
trade may offer additional
forms of employment and
allow access to opportunities  
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Positive impact (it could
benefit the group
concerned)
Negative impact (it could
disadvantage the group
concerned) and any
mitigation
No
impact
for those who would welcome
flexible hours. 
For any policies or practice specific to young people under the age of 16 years, a separate
Children’s Rights and Wellbeing Impact Assessment should be undertaken – view the National
Guidance.  
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
As a result of this equality impact assessment, please clearly describe practical actions you
plan to take to:
● reduce or remove any identified negative impact
● promote any positive impact or
● gather further information/evidence 
Equality protected characteristic: Age
Specific
characteristics
Action Who is responsible Date for
completion
Older people (65
years and over)
Licensing Committee
recommendation to
address unmet demand
by increasing licence
numbers by 24. 
Sarah Rodger/Karen
Engelberts
6 October
2025 
Equality protected characteristic: Disability
Specific
characteristics
Action Who is responsible Date for
completion
Physical disability As above 
Further consideration to
be given to availability of
wheelchair accessible
vehicles and whether this
should be considered as
a requirements for new
licences. 
Karen Engelberts 30 November
2025
Section 3: Recommendations and actions
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Action Who is responsible Date for
completion
Sensory impairment 
As above 
Mental health As above 
Learning disability As above 
Neurodivergent
conditions
As above 
Equality protected characteristic: Gender reassignment
Specific
characteristics
Action Who is responsible Date for
completion
Male transitioning to
female   
Female transitioning
to male   
Equality protected characteristic: Marriage/Civil partnership
Specific
characteristics
Action Who is responsible Date for
completion
Women   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Action Who is responsible Date for
completion
Men   
Same sex couple
(male)   
Same sex couple
(female)   
Equality protected characteristic: Pregnancy/Maternity/Paternity
Specific
characteristics
Action Who is responsible Date for
completion
Women   
Men (paternity)   
Equality protected characteristic: Race
Specific
characteristics
Action Who is responsible Date for
completion
View the list of
categories used in
Scotland's Census   
Equality protected characteristic: Religion/Belief
Specific
characteristics
Action Who is responsible Date for
completion
View the list of   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Action Who is responsible Date for
completion
categories used in
Scotland's Census 
Equality protected characteristic: Sex
Specific
characteristics
Action Who is responsible Date for
completion
Female   
Male   
Equality protected characteristic: Sexual orientation
Specific
characteristics
Action Who is responsible Date for
completion
Lesbian   
Gay   
Bisexual   
Other sexual
orientation   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Equality protected characteristic: Socio-economic (fairness) Please refer to Appendix 2
of accompanying guidance
Specific
characteristics
Action Who is responsible Date for
completion   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
You should list here the sources of information used to assess the impact of the relevant policy
or practice. This can include local sources such as reports, information and data, relevant
partners’ information, data and reports, other Council’s relevant information, data and reports,
national information, research outcomes, data profiles and any other evidence which has led to
the development of this policy. 
Information/evidence gained and used
to shape this policy or practice
List details, source and date
(continue on a separate sheet if necessary –
please advise if this has been done)
Community consultation/engagement
outcomes from individuals and
organisations - this usually includes
formally arranged contact with
individuals, community groups, third
sector and other relevant interest groups
As part of the unmet demand survey, a range of
consultation and engagement takes place through
surveys:
 public attitude survey
 taxi trade survey
 stakeholder engagement eg police,
hospitality, 
 representatives of elderly and disabled user
groups 
Further consultation was undertaken with the
public (including the taxi trade) in relation to
options to address unmet demand in particular an
increase in 24 licences or to remove the limit
completely. 
Employee involvement/consultation
feedback (for example survey, focus
groups) 
Section 4: Evidence 
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Information/evidence gained and used
to shape this policy or practice
List details, source and date
(continue on a separate sheet if necessary –
please advise if this has been done)
Research and information list main
sources 
Officer knowledge and experience 
Equality monitoring data   
Service user feedback (including
customer contact, services and
complaints) 
See above – the survey of unmet demand
included a public attitude survey. 
Partner feedback 
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Information/evidence gained and used
to shape this policy or practice
List details, source and date
(continue on a separate sheet if necessary –
please advise if this has been done)
Other - this may be information gathered
in another Council area, nationally or in
partner organisations which is
considered to have relevance 
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Consultation with key stakeholders must be undertaken throughout the EFIA process. This
activity can also help to reach people not previously involved with these processes, but who
will be affected by this policy or practice when it is implemented. You may wish to refer to the
Council’s Consultation Guidance.
The Consultation/Engagement process can also help identify or agree changes that need to
be made to ensure the policy or practice will be inclusive on implementation and future practice.
The Equalities Team Leader (email Equalities@pkc.gov.uk) may be able to provide advice
relating to potential contact with consultees from equality protected characteristic groups via
existing mechanisms such as the Community Equalities Advisory Group (CEAG) or Equalities
Strategic Forum.
A summary of the replies received from individuals and stakeholders consulted/involved. Include
any previous feedback or complaints relating to equality and diversity issues and the policy or
practice currently being assessed.
Continue on a separate sheet(s) if necessary – please advise if this has been done.
Equality protected characteristic: Age
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Older people (65
years and over) 
This is set out in the Unmet Demand Survey. 
Equality protected characteristic: Disability
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Physical disability  This is set out in the Unmet Demand Survey. This
feedback will also be considered if there is an increase
in licence numbers, and will inform decision making
about requirements which will be placed on new
licences, such as wheelchair accessible vehicles. 
Section 5: Consultation/Engagement
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done) 
Sensory impairment  
As above 
Mental health  As above 
Learning disability  As above 
Neurodivergent
conditions   As above 
Equality protected characteristic: Gender reassignment
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Male transitioning to
female   
Female transitioning
to male   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done) 
Equality protected characteristic: Marriage/Civil partnership
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Women   
Men   
Same sex couple
(male)   
Same sex couple
(female)   
Equality protected characteristic: Pregnancy/Maternity/Paternity
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Women   
Men (paternity)   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Equality protected characteristic: Race
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
View the list of
categories used in
Scotland's Census   
Equality protected characteristic: Religion/Belief
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
View the list of
categories used in
Scotland's Census   
Equality protected characteristic: Sex
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Female   
Male   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
Equality protected characteristic: Sexual orientation
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Lesbian   
Gay   
Bisexual   
Other sexual
orientation   
Equality protected characteristic: Socio-economic (fairness) Please refer to Appendix 2
of accompanying guidance
Specific
characteristics
Date Outcome of consultation/engagement
(continue on a separate sheet if necessary – please
advise if this has been done)
Socio-economic
(fairness)   
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
When the evidence has been considered in relation to the proposed policy, practice, project,
service reform or budget option, it will be apparent what the likely impacts are. The type, scale,
duration, and specificity of the likely impacts will inform the direction of the outcome of the EFIA.
There are four potential outcomes as follows (highlight the one you are recommending as a
result of your Impact Assessment):
1. No major change required the policy, practice, project, service reform or budget option is
robust and can continue without amendment.
2. Continue the policy, practice, project, service reform or budget option. A justification is
required for continuing despite the potential for adverse impact.
3. Adjust or amend the policy, practice, project, service reform or budget option. Remove
barriers, make changes to better advance equality or remove or mitigate negative impact.
4. Stop, or remove the policy, practice project, service reform or budget option if adverse
effects cannot be justified and cannot be mitigated. 
The following signatures are required:
Lead Officer Responsible
Signed Sarah Rodger
Name Sarah Rodger
Date 22/9/25
Quality Assured by Perth and Kinross Council Equality and Fairness Impact Assessment
trained officer (within service)
Signed S. Rodger
Name Sarah Rodger
Date 22/9/25 
Section 6: Outcomes 
Section 7: Authorising the assessment
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Equality and Fairness Impact Assessment (EFIA) Form – 2024 
PKC - PUBLIC
The completed and authorised EFIA should be added to the relevant section on the Council
website.
Date action completed: 
Ensure your committee report to accompany this policy includes information about any actions
taken to reduce or remove negative impacts identified, or include any positive impacts expected
when the policy is implemented.
Section 8: Publishing the assessment
Section 9: Committee reporting
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