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 Page 1 of 156
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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 Page 3 of 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 Page 5 of 156
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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 Page 6 of 156
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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. Page 7 of 156
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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. Page 8 of 156
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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 Page 9 of 156
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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. Page 10 of 156
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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 Page 11 of 156
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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 Page 12 of 156
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Perth December 2024 Taxi Unmet Demand Survey 3 Page 13 of 156
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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. Page 15 of 156
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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. Page 16 of 156
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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 Page 17 of 156
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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. Page 19 of 156
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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 Page 20 of 156
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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. Page 21 of 156
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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 Page 22 of 156
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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. Page 23 of 156
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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 Page 24 of 156
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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 Page 25 of 156
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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. Page 26 of 156
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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. Page 27 of 156
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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) Page 28 of 156
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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 Page 29 of 156
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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 Page 30 of 156
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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 Page 31 of 156
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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 Page 32 of 156
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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? Page 33 of 156
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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? Page 34 of 156
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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% Page 35 of 156
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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% Page 36 of 156
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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: Page 37 of 156
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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: Page 38 of 156
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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? Page 39 of 156
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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% Page 40 of 156
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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? Page 41 of 156
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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. Page 42 of 156
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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. Page 43 of 156
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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? Page 44 of 156
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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. Page 45 of 156
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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 Page 46 of 156
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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. Page 47 of 156
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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. Page 48 of 156
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31 Perth Taxi Unmet Demand Survey 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. Page 49 of 156
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32 Perth Taxi Unmet Demand Survey 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 Page 50 of 156
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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. Page 51 of 156
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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 Page 52 of 156
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35 Perth Taxi Unmet Demand Survey 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 Page 53 of 156
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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 Page 54 of 156
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37 Perth Taxi Unmet Demand Survey 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 Page 55 of 156
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38 Perth Taxi Unmet Demand Survey 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. Page 56 of 156
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39 Perth Taxi Unmet Demand Survey 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. Page 57 of 156
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40 Perth Taxi Unmet Demand Survey 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 Page 58 of 156
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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. Page 59 of 156
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42 Perth Taxi Unmet Demand Survey 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. Page 60 of 156
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43 Perth Taxi Unmet Demand Survey 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 Page 61 of 156
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44 Perth Taxi Unmet Demand Survey 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. Page 62 of 156
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45 Perth Taxi Unmet Demand Survey 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 Page 63 of 156
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46 Perth Taxi Unmet Demand Survey 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. Page 64 of 156
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47 Perth Taxi Unmet Demand Survey 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 Page 65 of 156
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48 Perth Taxi Unmet Demand Survey 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. Page 66 of 156
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49 Perth Taxi Unmet Demand Survey 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 Page 67 of 156
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50 Perth Taxi Unmet Demand Survey 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 Page 68 of 156
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51 Perth Taxi Unmet Demand Survey 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). Page 69 of 156
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52 Perth Taxi Unmet Demand Survey 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. Page 70 of 156
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53 Perth Taxi Unmet Demand Survey 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 Page 71 of 156
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54 Perth Taxi Unmet Demand Survey 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. Page 72 of 156
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55 Perth Taxi Unmet Demand Survey 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. Page 73 of 156
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56 Perth Taxi Unmet Demand Survey 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 Page 74 of 156
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57 Perth Taxi Unmet Demand Survey 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 Page 75 of 156
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58 Perth Taxi Unmet Demand Survey 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 Page 76 of 156
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59 Perth Taxi Unmet Demand Survey 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. Page 77 of 156
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60 Perth Taxi Unmet Demand Survey 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%. Page 78 of 156
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61 Perth Taxi Unmet Demand Survey 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. Page 79 of 156
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62 Perth Taxi Unmet Demand Survey 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. Page 80 of 156
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63 Perth Taxi Unmet Demand Survey 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 Page 81 of 156
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64 Perth Taxi Unmet Demand Survey 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. Page 82 of 156
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65 Perth Taxi Unmet Demand Survey 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. Page 83 of 156
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66 Perth Taxi Unmet Demand Survey 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. Page 84 of 156
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Perth May 2025 Addendum to the Taxi Unmet Demand Survey – December 2024 Page 85 of 156
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Perth Taxi Unmet Demand Survey Contents Contents ............................................... ii 1 Addendum background ......................... 4 2 Error corrections .................................. 5 3 Perth Railway Station ............................ 6 Page 87 of 156
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Perth Taxi Unmet Demand Survey 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. Page 89 of 156
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Perth Taxi Unmet Demand Survey 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’. Page 90 of 156
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Perth Taxi Unmet Demand Survey 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 Page 91 of 156
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Perth Taxi Unmet Demand Survey 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. Page 92 of 156
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PKC - PUBLIC 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 Page 93 of 156
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PKC - PUBLIC 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. Page 94 of 156
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PKC - PUBLIC 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. Page 95 of 156
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PKC - PUBLIC 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. Page 96 of 156
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PKC - PUBLIC 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. Page 97 of 156
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PKC - PUBLIC 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. Page 98 of 156
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PKC - PUBLIC 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. Page 99 of 156
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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 Page 101 of 156
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PKC - PUBLIC “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. Page 102 of 156
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PKC - PUBLIC 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.” Page 103 of 156
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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 Page 105 of 156
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2 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, Page 106 of 156
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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. Page 107 of 156
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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. Page 108 of 156
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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.” Page 109 of 156
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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 Page 110 of 156
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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 Page 111 of 156
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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 Page 112 of 156
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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. Page 113 of 156
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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: Page 114 of 156
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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. Page 115 of 156
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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 Page 116 of 156
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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 Page 117 of 156
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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 Page 118 of 156
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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. Page 119 of 156
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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 Page 120 of 156
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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. Page 121 of 156
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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 Page 122 of 156
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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 Page 123 of 156
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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% Page 124 of 156
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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. Page 125 of 156
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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 Page 127 of 156
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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. Page 128 of 156
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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. Page 129 of 156
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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 Page 131 of 156
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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) Page 132 of 156
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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. Page 133 of 156
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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 Page 134 of 156
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5 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 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 Page 135 of 156
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6 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 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 Page 136 of 156
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7 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 Page 137 of 156
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8 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 Page 138 of 156
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9 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 Page 139 of 156
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10 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 Page 140 of 156
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11 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. Page 141 of 156
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12 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 Page 142 of 156
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13 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 Page 143 of 156
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14 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 Page 144 of 156
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15 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 Page 145 of 156
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16 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 Page 146 of 156
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17 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 Page 147 of 156
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18 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 Page 148 of 156
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19 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 Page 149 of 156
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20 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 Page 150 of 156
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21 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 Page 151 of 156
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22 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) Page 152 of 156
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23 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 Page 153 of 156
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24 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) Page 154 of 156
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25 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 Page 155 of 156
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26 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 Page 156 of 156