Agenda Document Pack - Regulatory Functions Board - 14/11/2024
Renfrewshire Council · 14 November 2024
Back to Regulatory Functions Board — 14 November 2024 and its agenda
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07/11/2024 Notice of Meeting and Agenda Regulatory Functions Board Date Time Venue Thursday, 14 November 2024 10:00 Council Chambers (Renfrewshire), Council Headquarters, Renfrewshire House, Cotton Street, Paisley, PA1 1AN Membership Councillor John McNaughtan (Convener): Councillor Cathy McEwan (Depute Convener): Councillor Audrey Doig: Councillor Neill Graham: Councillor Lisa-Marie Hughes: Councillor Janis McDonald: Councillor Kevin Montgomery: Councillor Sam Mullin: Councillor Emma Rodden: Councillor Andy Steel: Hybrid Meeting Please note that this meeting is scheduled to be held in the Council Chambers. However, it is a hybrid meeting and arrangements have been made for members to join the meeting remotely should they wish. Further Information This is a meeting which is open to members of the public. A copy of the agenda and reports for this meeting will be available for inspection prior to the meeting at the Customer Service Centre, Renfrewshire House, Cotton Street, Paisley and online at http://renfrewshire.cmis.uk.com/renfrewshire/CouncilandBoards.aspx For further information, please email democratic-services@renfrewshire.gov.uk Members of the Press and Public Members of the press and public wishing to attend the meeting should report to the customer service centre where they will be met and directed to the meeting. MARK CONAGHAN Head of Corporate Governance Page 1 of 50
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07/11/2024 Items of business Apologies Apologies from members. Declarations of Interest and Transparency Statements Members are asked to declare an interest or make a transparency statement in any item(s) on the agenda and to provide a brief explanation of the nature of the interest or the transparency statement. 1 Licensing of Short-term Lets: Implementation of Changes to Legislation and Review of Policy Report by Director of Finance & Resources. 7 - 20 2 Civic Government (Scotland) Act 1982: Review of Taxi Fares within Renfrewshire Report by Director of Finance & Resources. 21 - 50 3 Renewal of Late Hours Catering Licences Submit the undernoted applications for renewal of Late Hours Catering Licences:- (a) Applicant: Select Service Partner UK Limited Premises: Starbucks, First Floor Main International Departures Lounge, Glasgow Airport Activity: provision of catering Operating hours: Monday to Sunday – 11.00 pm to 5.00 am Licence No.: LHC041 (b) Applicant: Select Service Partner UK Limited Premises: Starbucks, Arrivals Hall, Glasgow Airport Activity: provision of catering Operating hours: Monday to Sunday – 11.00 pm to 5.00 am Licence No.: LHC042 4 Grant of Second Hand Dealer's Licence - Personal Appearance Submit the undernoted application for grant of a Second Hand Dealer’s Licence. The applicant has been asked to appear personally together with the Civic Licensing Standards Officer who has submitted a representation to the application received outwith the statutory timescale:-. Page 3 of 50
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07/11/2024 Applicant: Jonathan Rooney Premises: 2A High Street, Johnstone Authorised activity: buying and selling of cars Operating hours: 7 days per week – 9.00 am to 5.00 pm 5 Variation of Private Hire Car Operator's Licence - Personal Appearance Submit the undernoted application for variation of a Private Hire Car Operator’s Licence. The applicant has been asked to appear personally:- Applicant: Waseem Sarwar Variation: exception to standard condition 9 Licence No.: PH1531 6 Surrender and Re-issue of Taxi Operator's Licence - Personal Appearances Submit the undernoted application for surrender and re-issue of a Taxi Operator’s Licence. The applicants have been asked to appear personally:- Present operator: Raymond Stanley Proposed operator: Kuldeep Kumar Licence No.: TX034 7 Variation of Taxi Operators' Licences - Personal Appearances Submit the undernoted applications for variation of Taxi Operators’ Licences. The applicants have been asked to appear personally:- (a) Applicant: Renfrewshire Radio Taxis Limited Variation: exception to standard condition 22 and requirement to test vehicle again within 28 days of any variation of licence Licence No.: TX171 Exclusion of Press and Public The Board may by resolution exclude the press and public from the meeting during consideration of the following items of business as it is likely, in view of the nature of the business to be transacted, that if members of the press and public were present there would be disclosure to them of exempt information as defined in paragraph 3 of part I of schedule 7A of the Local Government (Scotland) Act 1973 Page 4 of 50
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07/11/2024 (b) Applicant: Andrew McCallum Variation: exception to policy and standard condition 22 to operate a saloon car Licence No.: TX212c 8 Renewal of Taxi Driver's Licence - Personal Appearance Submit the undernoted application for renewal of a Taxi Driver’s Licence. The applicant has been asked to appear personally together with Police Scotland who has submitted a representation to the application received outwith the statutory timescale:- Applicant: Jason Belk Licence No.: T0181 9 Renewal of Taxi Operators' Licences Submit the undernoted applications for renewal of Taxi Operators’ Licences. Applicant (a) has been asked to appear personally together with Police Scotland who has submitted a representation to the application:- (a) Applicant: Jason Belk Licence No.: TX057 (b) Applicant: Graeme Anderson Licence No.: TX191 10 Grant of Private Hire Car Drivers' Licences Submit the undernoted applications for grant of Private Hire Car Drivers’ Licences. Applicants (a), (g), (h) and (i) have been asked to appear personally together with Police Scotland who has submitted objections to applications (a), (h) and (i) and an objection to application (g) received outwith the statutory timescale together with a further letter:- (a) Richard Sloss (b) Anthony Okolidim (c) Tahir Ashraf (d) Abdihamid Elmi (e) Mohammed Gobara (f) Rega Asan Adjournment The meeting will adjourn following consideration of application 10(f) and reconvene at 1.30 pm. (g) Zabiullah Khan Page 5 of 50
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07/11/2024 (h) Fahad Minir Bhatti (i) Rizwan Javid (j) Abdullah Safdar (k) Mohammad Al Rifai (l) Noman Sahak 11 Grant of Private Hire Car Operator's Licence - Personal Appearance Submit the undernoted application for grant of a Private Hire Car Operator’s Licence. The applicant has been asked to appear personally:- Sayedmansoor Hashimi 12 Hearing into Possible Suspension or Revocation of Private Hire Car Driver's Licence - Personal Appearance Consider the possible suspension or revocation of the undernoted Private Hire Car Driver’s Licence. The licence holder has been asked to appear personally together with Police Scotland:- Licence holder: Mumtaz Malik Licence No.: P0357 13 Request for Exemption from Carrying Guide Dogs, Hearing Dogs and Assistance Dogs - Personal Appearance Submit the undernoted request for exemption from carrying guide dogs, hearing dogs and assistance dogs. The licence holder has been asked to appear personally:- Licence holder: Mark Nugent Licence No.: P0184 Page 6 of 50
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___________________________________________________________________ To: Regulatory Functions Board On: 14th November 2024 ___________________________________________________________________ Report by: Director of Finance and Resources ___________________________________________________________________ Heading: Licensing of Short-Term Lets: Implementation of Changes to Legislation and Review of Policy ___________________________________________________________________ 1. Summary 1.1 The purpose of this report is to advise the Board of recent changes to the short-term lets licensing legislation and the steps the Council as licensing authority is required to take to implement these changes. 1.2 The Board is also asked to agree application fees in respect of new statutory processes introduced by the new legislation and to agree necessary updating of the Board’s current short-term lets licensing policy relating to Temporary Exemptions. 1.3 Finally, the Board is asked to recommend to Council that limited changes be made to the Scheme of Delegated Functions to allow the approval of new types of applications relating to short-term let licences and to reflect the change in legislation regarding Temporary Exemptions (where a delegated power already exists within the Scheme). _____________________________________________________________ 2. Recommendations 2.1 Note the changes introduced by the new legislation; Item 1 Page 7 of 50
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2.2 Agree the new application fees proposed for provisional short-term let licences and confirmation of these licences; and the proposed application fees for transfer of short-term let licences, all as set out at Paragraph 5.8, Paragraph 5.13 and Appendix 2 to this report; and 2.3 Agree that the changes set out at Appendix 1 to the report be made to the Council’s current policy as it relates to Temporary Exemptions; 2.4 Instruct officers to publish on the Council’s website details of (i) such new fees and (ii) changes to the existing policy, as may be agreed by the Board in relation to the recommendations at Paragraphs 2.2 and 2.3 above; 2.5 Instruct officers to develop new application forms and procedures relative to applications for provisional short-term let licences, as also for confirmation and transfer of short-term let licences; 2.6 Recommend to Council that changes be made to the Scheme of Delegated Functions as set out at Paragraph 6.1; and 2.7 Otherwise note the terms of the report. ___________________________________________________ 3. Background 3.1 In June and September 2022, the Board considered reports relative to a new legal requirement for the Council to introduce a regime for the licensing of short-term lets. This new regime required to be in place to allow applications for short-term let licences to be made from the beginning of October 2022. Officers carried out a consultation exercise in the summer of 2022 and, at their meeting in September that year, the Board agreed a policy in relation to the licensing of short-term lets and a fees structure for applications. The Board also agreed to recommend to Council that some necessary changes be made to the Scheme of Delegated Functions as a result of the new short- term lets licensing legislation. 3.2 The legal requirement to set up a licensing scheme was introduced as a result of the Civic Government (Scotland) Act 1982 (Licensing of Short-Term Lets) Order 2022 (“the Licensing Order”), which introduced short-term lets as a new activity to be licensed. This Order modified the terms of existing legislation, the Civic Government (Scotland) Act 1982 (“the 1982 Act”), in relation to short-term lets. In the period since 1st October 2022 to 30th September 2023, being the deadline for existing operators to apply, the Council received approximately 120 applications. The initial applications received have now been decided, either by officers or at meetings of the Board. Page 8 of 50
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3.3 On 29th August 2024, amending legislation, the Civic Government (Scotland) Act 1982 (Licensing of Short-Term Lets) Amendment Order 2024 (“the 2024 Order”), was made, which came into force on 30th August 2024. The 2024 Order makes a number of changes to the above legislation for the licensing of short-term lets, as summarised in section 4 of this report. 4. The 2024 Order 4.1 The 2024 Order makes several changes to the legal position previously set out in the Licensing Order in relation to short-term lets. These can be summarised as: the introduction of provisional licences; a facility to transfer licences; changes to the rules on temporary exemptions; and other ancillary changes. These are further detailed in the following paragraphs. Provisional Short-Term Let Licences 4.2 The 2024 Order introduces a new procedure to allow an application for a short-term let licence to be made in respect of premises prior to them being constructed. This type of application, and resulting licence, are known as a provisional licence application/ provisional licence. A provisional licence will not come into effect immediately, but at a later date, when the premises are fully constructed and the Council is satisfied that the mandatory conditions of licence can be met. This is known as the confirmation process and would require a further licensing application to be made to the Council. While a similar, but not identical, process exists under liquor licensing legislation, this has not until now been available for licences applied for under the terms of the 1982 Act, or under the previous modifications made to that Act for short-term lets. The introduction of the process will avoid applicants for licences having to wait until the completion of construction before commencing the licence application process. The Board may wish to note that the introduction of provisional licences for short-term lets only applies to premises to be newly constructed; the legislation does not, unlike its liquor licensing equivalent, apply to premises to be converted for use as a short-term let. Transfer of Short-Term Let Licences 4.3 Similarly to the position with provisional licences, the 1982 Act, and the Licensing Order, did not until now allow an application to be made for transfer of a licence from a licence holder to another person. The 2024 Order changes this position, for short-term lets only, to allow the existing licence holder to apply for transfer of the licence to another party. Page 9 of 50
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The procedure for transfer of a licence is simpler in comparison to an application for a licence: the suitability of the premises will have been considered when the licence was obtained, so the requirement for a transfer application is to consult Police Scotland who will be able to comment within a period of 28 days from the application being made on the fit and proper status of an applicant. The new transfer provision does, however, allow conditions to be imposed at the time of transfer of a short-term let licence. Temporary Exemptions 4.4 The Licensing Order introduced a temporary exemption from the need for a short-term let licence. This provided a means by which a host/ operator of premises could let their property or properties, without a licence, for up to 6 weeks: for example, for the duration of a festival or sporting event. This temporary exemption provision became the subject of discussion nationally as to whether a temporary exemption required to be for a single continuous period of up to six weeks, or whether it could be cumulative periods of up to six weeks within a calendar year. The 2024 Order now provides some clarity regarding this. It provides that a temporary exemption may only be granted in relation to a specified property or properties if, in one calendar year, there are no more than three separate periods and the total period is 6 weeks or less. In calculating this, the 2024 Order also clarifies that any periods of exemption before it came into force should not be counted. Amendment to Licence Conditions 4.5 The 2024 Order recognises a recommendation made as a result of a Fatal Accident Inquiry regarding the use of mobile gas cabinet heaters in short- term lets. It provides for two additions to one of the mandatory conditions of licence regulating the information to be displayed in premises, including information about the action to be taken when a carbon monoxide alarm sounds and about the operation and movement of these heaters. Miscellaneous 4.6 Otherwise, the 2024 Order makes a few other changes to the Licensing Order. The most significant of these is an exemption for fostering and nursing arrangements and sheltered housing from the requirement to be licensed. 5. Implementation 5.1 While some of the above changes are of a technical nature and will be implemented by officers as required, others will require the authority of the Page 10 of 50
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Board. In particular, this is the case for temporary exemptions, where a change to the Council’s published policy in relation to the licensing of short- term lets requires to be made, and for provisional licence/ confirmation and transfer applications, where, in addition to forms and application processes being developed by officers, reasonable fee levels require to be agreed by the Board. Finally, as a result of the new procedures which the 2024 Order introduces, changes will be required to the Council’s Scheme of Delegated Functions, which is addressed at section 6 of the report. Change of Policy in relation to Temporary Exemptions 5.2 The Council requires under the terms of the Licensing Order to have a policy in relation to the use of temporary exemptions and to keep this policy under review. The Councils’ current published policy in relation to the licensing of short-term lets, which includes its policy on Temporary Exemptions at section 9 of that policy, can be accessed at: https://www.renfrewshire.gov.uk/article/12823/Short-term-let-licence-for- residential-accommodation 5.3 The Council’s current policy in relation to Temporary Exemptions was prepared in 2022 on the basis of the legislation applicable at that time. While no requests for Temporary Exemptions have been received in Renfrewshire to date, the existing policy assumes a temporary exemption being possible in respect of a single period of up to six weeks within a calendar year. In light of the clarification given by the 2024 Order, the Board is now asked to agree to change the section of the Council’s above policy which deals with Temporary Exemptions to the new version set out at Appendix 1 to this report. The requirement to develop and publish a policy statement on temporary exemptions and to keep it under review is a statutory one, in terms of the Licensing Order. In reviewing the statement, which is required every three years, the Licensing Order requires the Council to consult with such persons as the licensing authority considers appropriate. As the changes proposed to the policy on temporary exemptions are of an entirely technical nature, to reflect the clarity now provided by the 2024 Order (which affords more flexibility to operators) and to incorporate an inflationary increase in the fee level previously agreed by the Council in 2023 (the possibility of such increases having been recognised in the existing policy), it is not considered appropriate to consult any persons at this time on these limited changes. While the Licensing Order’s provisions requiring publication of a policy statement relates only to temporary exemptions, it is anticipated that the Board’s published policy covering wider matters regarding short-term lets will be reviewed in 2025 and consideration will be given to what consultation is to be carried out at that time. Officers have noted that some content within Page 11 of 50
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the current policy statement relating to short-term lets generally was developed in advance of the transitional period for applications and as such no longer relevant for current applications. It is also recognised that changes to the legislation and guidance, the development of case law and the potential for further guidance in the foreseeable future may result in changes to the Board’s published policy on the licensing of short-term lets. Fees 5.4 As set out above, the Board requires to agree fees in respect of applications for provisional licences, applications for confirmation of provisional licences and applications for transfer. 5.5 The Board will appreciate that fees for licensing applications made under the terms of the Civic Government (Scotland) Act 1982, including short-term let licensing applications, are based on cost recovery. The Board had regard to this requirement when setting various short-term let licensing fees in 2022. Provisional Licence and Confirmation Application Fees 5.6 In relation to provisional short-term let licence applications, the current fee for licence applications, whether for home sharing or letting (or both) or secondary letting includes the full application process from receipt and verification of an application, to considering any objections or representations received, to the Council being satisfied that the conditions of licence can be met, to the grant and issue of a licence. 5.7 While the detail of the new legislation around provisional licences will raise some complexities in practice, it is clear that obtaining a licence in two stages will involve a cumulative amount of work no less than equivalent to, and likely greater than, an application for a full licence, due to the requirement to verify and process two applications rather than one. In addition, there will need to be additional checks at the first stage, to ensure that applications are related to premises to be constructed rather than converted, as set out above. 5.8 Officers have given consideration to an appropriate level of fee to be payable where an application for provisional licence or confirmation is made. Having done so, it is recommended that the fee should be set broadly based on the equivalent fee for a full short-term let licence of the same type. However, it is proposed that the fee should be split between the provisional and confirmation stages, with 65% attributable to the provisional stage and 35% to the confirmation stage, with an extra £100 added in respect of the confirmation application. A summary of the fees, based on this proposal, is set out at Appendix 2. The Board may wish to note that the agreed fees will be subject to any annual increase to Council charges as part of the budget setting process in advance of April 1st 2025, and then similarly in subsequent years. Otherwise Page 12 of 50
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the fees would immediately fall out of step with those that form the basis of them. 5.9 The Board may wish to note that, while the usual consultation procedure will be followed at the stage of the provisional licence application, detailed checks as to whether the mandatory and additional conditions of licence can be met will require to take place at the stage of confirming a provisional licence. As such, the confirmation process is likely to be less straightforward than under the liquor licensing procedures for confirmation, where the checks carried out are limited to ensuring that full certification exists from Planning, Building Standards and Environmental Health and that there have been no changes to the original layout proposed. Transfer Application Fees 5.10 As indicated above, an application for transfer is likely to be simpler than a full application for a licence. 5.11 Until now, it was not possible to apply for the transfer of a licence relating to a short-term let, or relating to any other premises licensed under the terms of the 1982 Act and the Board will require to determine a reasonable level of fee for this new type of application. 5.12 The Board may wish to note that applications for transfer may currently be made in respect of premises licensed for the sale of alcohol under the Licensing (Scotland) Act 2005 (“the 2005 Act”), albeit the procedure is not identical. The fees for these applications are set by the Licensing Board and are presently £50 (where the transfer is applied for by the existing licence holder, as will be the case for any short-term let transfers applied for as a result of the 2024 Order). 5.13 However, the current transfer application fees under the 2005 Act have not been increased since that Act came fully into force in 2009. Having considered the likely amount of work to transfer a short-term let licence, officers recommend £80 as a proposed fee for an application for transfer of a short-term let licence. 6. Recommended Changes to the Scheme of Delegated Functions 6.1 The changes made by the 2024 Order are likely to necessitate minor changes to the Council’s Scheme of Delegated Functions. While officers recognise that changes to the Scheme can only be made by Council, the Board is asked to recommend the following changes to the Scheme to Council: (i) Revisal of the existing delegated power, numbered 57, in Section E of the Scheme of Delegated Functions to the following- “57. With the Managing Solicitor (Licensing) and the Managing Solicitor (Litigation & Advice), and Senior Solicitor (Litigation and Regulatory Page 13 of 50
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Services), and in consultation with the Convener of the Regulatory Functions Board, to grant an exemption from the requirement to obtain a short-term let licence in relation to a specified property or properties and during no more than three periods within a calendar year not exceeding a total of six weeks, in terms of Paragraph 1A of Schedule 1 to the Civic Government (Scotland) Act 1982, as modified, in exceptional circumstances where an influx of large numbers of visitors is likely to require increasing accommodation capacity within Renfrewshire due to sporting, cultural or other events or festivals of national or international significance, or due to an emergency situation of similar significance.” (ii) Additional delegated powers to the Head of Corporate Governance, Managing Solicitors and Senior Solicitor (Litigation and Regulatory Services), as follows- “To grant applications for a provisional short-term let licence and confirmation of these licences, in terms of Paragraphs 7A and 7B of the Civic Government (Scotland) Act 1982, as modified by the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022 as amended”; “To extend the period of a provisional premises licence where it cannot be confirmed within three years after the date on which it was issued, in terms of Paragraph 7A(7) of the Civic Government (Scotland) Act 1982, as modified by the Civic Government (Scotland) Act 1982 (Licensing of Short- term Lets) Order 2022, as amended”; and “To grant applications for transfer of a short-term let licence made by a short- term let licence holder in terms of Paragraph 9A(7) of Schedule 1 to the Civic Government (Scotland) Act 1982, as modified by the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022, as amended”. 7. Further Steps 7.1 In addition to the matters set out above, officers will arrange for the development of further online application forms for provisional licences, confirmation and transfers, once the fees for these applications have been agreed by the Board. The new online forms will require to be developed with the assistance of the Customer Service and Digital Experience team. Officers will investigate also whether any upgrades are required to the electronic licensing system used for the processing of applications by the licensing team as a result of the changes. 7.2 Separately, officers will write out to licensed hosts/ operators of short-term lets regarding the further conditions of licence which now apply, as set out at Paragraph 4.5, above. They will also arrange for the short-term lets licensing page of the Council’s website to be necessarily updated, in light of the new legislation and such fees/ changes as may be agreed by the Board. Page 14 of 50
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8. Additional Information 8.1 The Board may wish to note that the licensing of short-term lets across Scotland continues to be monitored by Scottish Government. The Council, as with other licensing authorities, provide regular updates to the Scottish Government on various matters, including numbers of applications for short- term let licences received and decisions made on these applications. 8.2 The Scottish Government in August this year published an Implementation Update on short-term let licensing. This is available at: https://www.gov.scot/publications/short-term-licensing-implementation- update-report-2024/documents/ 8.3 They have also published further guidance documents, for both hosts/ operators and licensing authorities, which can be accessed at the below links. https://www.gov.scot/publications/short-term-lets-scotland-licensing-scheme- part-1-guidance-hosts-operators-4/ https://www.gov.scot/publications/short-term-lets-scotland-licensing-scheme- part-2-supplementary-guidance-licensing-authorities-letting-agencies- platforms-4/ It is understood that the guidance will continue to be kept under review with possible updated guidance published in due course. _____________________________________________________________ Implications of the Report 1. Financial – Where applications for provisional licences, confirmation and transfer are received, some income will be received by the Council as licensing authority, but it should be noted that licensing fees are charged on a cost recovery basis. 2. HR & Organisational Development - Nil 3. Community/Council Planning – • Our Renfrewshire is safe – the continued monitoring and improvement of licensing processes to ensure the safety of Renfrewshire residents. 4. Legal – As detailed in the report. The Civic Government (Scotland) Act 1982 (Licensing of Short-Term Lets) Amendment Order 2024 sets out changes to the licensing regime which the Council is required by law to operate. Under the Civic Government (Scotland) Act 1982, the Council charges fees for licence applications on a cost recovery basis. 5. Property/Assets – Nil. 6. Information Technology – There is a requirement for assistance from the Customer Service and Digital Experience team for the development of online application forms to support the new legal processes introduced. Some Page 15 of 50
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upgrades may be required to the electronic licensing system which is provided externally. These will be required as a result of the new legislation, as the Council requires to implement the new provisions. 7. Equality & Human Rights -The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report, as it seeks to advise the Board on the implementation of recent changes to legislation and to obtain authority on the level of fees payable for the statutory licensing process, minor changes to an existing policy and associated matters. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – Nil 9. Procurement – Nil 10. Risk – Nil 11. Privacy Impact – Nil 12. Climate Risk – Nil 13. Children’s Rights – the recommendations in the report are not considered to be incompatible with the UNCRC. 14. Cosla Policy Position - Nil ____________________________________________________________ List of Background Papers Background Paper – None _____________________________________________________________ Author: Douglas J. Campbell, Managing Solicitor (Licensing), 0141-487-1096 douglas.campbell@renfrewshire.gov.uk Page 16 of 50
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APPENDIX 1 Revised Policy on Temporary Exemptions 9. Temporary Exemptions 9.1 The Council requires under the modified provisions of the 1982 Act to publish, and keep under review, a policy statement in relation to its functions relating to Temporary Exemptions. 9.2 The Council, as licensing authority, may, but is not required to, grant a temporary exemption from the requirement to obtain a short-term let licence in relation to a specified property or properties if, in one calendar year, there are no more than three separate periods of temporary exemption for that property or properties and the total period of temporary exemption is six weeks or less. In order to do so, the Council may consult the chief constable and the Scottish Fire and Rescue Service. The Council is also empowered, in granting any temporary exemption, to attach conditions to that exemption. 9.3 The Council requires to publish its first policy statement on temporary exemptions on or before 1st October 2022 and on or before the same date every three years thereafter. The policy statement must be made available on the Council’s website. In preparing/ reviewing their policy statement, the Council must consult with such persons as they consider appropriate. In preparing its policy statement in advance of 1st October 2022, the Board consulted the parties as already set out at Paragraph 1.1 above. The Board agreed a revised policy regarding temporary exemptions with limited changes in November 2024 to reflect legislative amendments made by the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Amendment Order 2024 9.4 Following consultation, the Board has agreed that temporary exemptions will be able to be granted in Renfrewshire in certain circumstances. The Board has agreed that a temporary exemption may be suitable for granting in exceptional circumstances where an influx of large numbers of visitors is likely to require increasing accommodation capacity within Renfrewshire due to sporting, cultural or other events or festivals of national or international significance, or due to an emergency situation of similar significance. 9.5 The fee chargeable for a Temporary Exemption is currently £105 (originally £100). This may change slightly during the period of this policy being in place where fees are reviewed generally by the Council, so those interested in seeking a Temporary Exemption should check the current fee within the Civic Licensing Fees section of the Council’s licensing web pages). The Council will consult Police Scotland and Scottish Fire and Rescue Service in relation to these applications, but considers that, as this is a simpler process than an application for a licence, this lower fee should be charged in comparison to the licensing application fees for short-term lets. Page 17 of 50
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9.6 Applications for temporary exemptions will be determined by Council officers in consultation with the Convener of the Regulatory Functions Board, taking into account whether the application meets the above requirements of this policy at Paragraph 9.4 and any representations received from Police Scotland and/ or Scottish Fire and Rescue Service. 9.7 The Council will seek to make a decision on a temporary exemption application within a period of two months but will seek to prioritise applications received at shorter notice due to unforeseen circumstances. Where the Council grants a Temporary Exemption, it will do so subject to the same conditions of licence applicable to licensed short-term lets, including both the mandatory and additional conditions published on the Council’s licensing web pages. A unique temporary exemption number will also be provided to the applicant. 9.8 Where an application for a Temporary Exemption is refused, the applicant is entitled to seek written reasons and should seek their own independent legal advice if they are considering whether to appeal the decision to the sheriff. Page 18 of 50
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APPENDIX 2 Summary of Proposed Provisional Licence and Confirmation Application Fees Type of Licence Bedrooms Provisional Confirmation Home Sharing 1 £171 £192 Home Sharing 2 £239 £229 Home Sharing 3 £239 £229 Home Sharing 4 or more £239 £229 Home Letting 1 £171 £192 Home Letting 2 £239 £229 Home Letting 3 £239 £229 Home Letting 4 or more £239 £229 Home Sharing/ 1 £171 £192 Letting Home Sharing/ 2 £239 £229 Letting Home Sharing/ 3 £239 £229 Letting Home Sharing/ 4 or more £239 £229 Letting Secondary 1 £546 £394 Letting Secondary 2 £614 £431 Letting Secondary 3 £683 £467 Letting Secondary 4 or more £751 £504 Letting Page 19 of 50
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___________________________________________________________________ To: Regulatory Functions Board On: 14 November 2024 ___________________________________________________________________ Report by: Director of Finance & Resources ___________________________________________________________________ Heading: Civic Government (Scotland) Act 1982: Review of Taxi Fares within Renfrewshire ___________________________________________________________________ 1. Summary 1.1 The Council as Licensing Authority is obliged to fix scales for the fares and other charges in its area in connection with the hire of a taxi. The legislation, the Civic Government (Scotland) Act 1982 (“the 1982 Act”), provides that fares should be fixed within 18 months beginning with the date on which scales last came into effect. 1.2 The last Taxi Fares Review was carried out during 2022 and 2023 with a revised Taxi Fares Scale being fixed by the Deputy Traffic Commissioner following an appeal, who made changes to the scale which had earlier been agreed by the Board. The Deputy Traffic Commissioner determined that the new scale, with these changes, would come into effect as at 1 September 2023. The revised fares scale represented a change to the previous scale fixed by the Council, by: (i) increasing the minimum charge or Flag Fall from £3.45 to £4.05; (ii) increasing the additional charge, by maintaining the unit charge of 30p but reducing the distance to which that charge applies to 267 yards; (iii) increasing the charge for waiting time from 36p to 42p for each period of 2 minutes (or part); (iv) increasing the additional passenger charge (for each passenger in excess of four) from 60p to 70p; (v) allowing an increase in the Glasgow Airport pick up and drop off charge from £4 to £5; (vi) increasing the additional charge between midnight and 5am on Item 2 Page 21 of 50
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Sunday to Thursday evenings from £1.60 to £1.90; (vii) increasing the additional charge between midnight and 5am on Friday and Saturday evenings from £2.00 to £2.30; and (viii) increasing the additional charge for journeys commencing after midnight on 24 December until midnight on 26 December, and from midnight on 31 December until midnight on 2 January, from £1.00 to £1.20. 1.3 On 2nd July 2024, the Council consulted with persons or organisations representative of the operators of taxis within its area on the current taxi fare scale, by email, requesting responses by 30th July 2024. One detailed response was received from Renfrewshire Public Hire Association within the above deadline, with another trade representative, Josephine Gatley, indicating her support for that response on 31st July. The responses are further detailed at Paragraphs 3.4.1 to 3.4.2 of the report. 1.4 The existing scales require to be reviewed and new scales proposed by the Board. Thereafter, formal notification of the proposed new scales will be given via a newspaper advertisement in the local press in order that representations may be made on the agreed proposal by a specified date at least one month from the date of the newspaper advertisement. 1.5 A further report will thereafter be submitted to the Board after the last date for making representations in order that the representations can be considered and the new fare scale can be fixed. The date for the new taxi fares scale to come into effect requires to be decided by the Board. ___________________________________________________________________ 2. Recommendations 2.1 It is recommended that the Board:- (i) review the existing fares scale shown at Appendix 1 and consider the proposal received and decide whether this proposal, or other fares scale, should be proposed as a new taxi fares scale for Renfrewshire and included in the newspaper advertisement as detailed in paragraph 1.4 above; (ii) agree a proposed date of Monday 14th April 2025 for the proposed revised fare scale to come in to effect; (iii) note that, if approved by the Board, the proposals will be advertised in the local press, and thereafter Page 22 of 50
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(iv) agree that the last day for lodging representations following on the proposed fare scale being advertised shall be one calendar month after the date of publication of that advertisement. _________________________________________________________ 3. Background 3.1 Prior to fixing a new Taxi Fares Scale, the Council as Licensing Authority requires to consult with persons or organisations appearing to it to be, or be representative of, the operators of taxis in its area, review the existing fares scales and propose new scales and publish these in a local newspaper. 3.2 Consultation has taken place with organisations appearing to the Licensing Authority to be representative of operators of taxis operating in the area, namely:- • Renfrewshire Public Hire Association • Unite • Alpha Taxis • Glasgow Airport Booking Office • Renfrewshire Cab Company • Johnstone TOA • Paisley Taxis Ltd • Renfrewshire Radio Taxis Ltd • Raymond Stanley • Paisley Independent Operators 3.3 Consultation was by email of 2nd July 2024, requesting responses by 30th July 2024. 3.4 The responses received are summarised in paragraphs 3.4.1 to 3.4.2 of this report. 3.4.1 Proposal 1- Proposal 1 is from Renfrewshire Public Hire Association (“the Association”). They suggest a number of increases and also provide a report in support of their proposal from Vector Transport Consultancy. Specifically, they propose increases in the Flag Fall from £4.05 to £4.35 and an increase in the additional distance charge, by retaining the unit charge of 30p but changing the measure of distance from 267 yards to Page 23 of 50
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252 yards. They also suggest an increase in the waiting time charge from 42 to 45p, based on the existing unit of 2 minutes (or part of that period). Finally, they propose various changes to the additional charges on the existing tariff. They seek to increase the charge for passengers in excess of four passengers from 70p to 75p. They seek increases in the existing late night charges from £1.90 to £2 and from £2.30 to £2.45, respectively. They also seek to increase the additional charges during the festive period from £1.20 to £1.25 and an increase in the soiling charge, which has been static in recent years, from £50 to £100. The Association also ask the Board to allow flexibility with regard to Glasgow Airport pick up and drop off charges, to allow the taxi trade to recover these as and when they are increased by the airport authority, rather than having to await completion of the next statutory fares review process. Officers have previously advised the Board that they are required to fix maximum fares and charges for the operation of taxis in their area. However, officers are aware that some licensing authorities have allowed flexible charges, for example “as per current barrier value according to local signage”, at airports and ferry terminals. The rationale for the Association’s fares scale proposal is set out in a report from Vector Transport Consultancy, attached as Appendix 3. Comments on the report by officers are attached at Appendix 4. 3.4.2 No other detailed proposals have been received. However, as stated above, a response in support of the above proposal was received from Mrs. Gatley of Renfrewshire Radio Taxis Limited, shortly after the consultation deadline. 3.5 The fares as existing and as proposed are summarised at Appendix 1. 3.6 In relation to the current rate of inflation, the Consumer Prices Index (CPI) rose by 1.7% in the 12 months to September 2024, down from 2.2% in August. The largest downward contribution to the monthly change in the CPI annual rates came from transport, with larger negative contributions from air fares and motor fuels. Further information in relation to the CPIH and the CPI is available at: https://www.ons.gov.uk/economy/inflationandpriceindices/bulletins/cons umerpriceinflation/september2024 Additional information regarding inflation in the period since Vector Transport Consultancy’s report in relation to the previous fares review, which was taken into account by the Traffic Commissioner during the Page 24 of 50
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appeal in August 2023, has been included in their report in support of the proposal received at Appendix 4. 3.7 In terms of a Circular, 25/1986, reference is expected to be made by the licensing authority to, inter alia, the capital costs of vehicles, the cost of maintaining and replacing them to the standards required, the costs of employing drivers and the prevailing level of wages and costs in related road transport industries. The Circular also sets out a view that the public interest is better serviced by ensuring the maintenance of an adequate taxi service by giving the trade a fair return than by depressing fares for social reasons, however understandable. It states that, if fares are fixed at a level higher than the market can stand, then the trade is free to reduce them. The full Circular can be accessed at: https://www.gov.scot/publications/circular-25-1986-licensing-taxis- private-hire-cars/documents/ 3.8 Members will wish to consider the terms of the “Taxi and Private Hire Car Licensing - Best Practice for Licensing Authorities and Taxi and Private Hire Car Operators” (3rd Edition), which can be accessed at the following link: https://www.gov.scot/publications/taxi-private-hire-car-licensing-best- practice-licensing-authorities-taxi-private-hire-car-operators-3rd- edition/documents/ In particular, Paragraph 2.3 of this Best Practice Guidance recognises that a balanced approach is beneficial when setting taxi fares between the expectations of taxi drivers/ operators to earn a living, against the backdrop of a cost of living crisis and against the public expectation to be able to hire a taxi of reasonable quality at a reasonable price. Section 6 of the document also contains further guidance in relation to taxi fares. 3.9 Appendix 2 to this report shows fares under the current and proposed fares as they would affect standard journeys of between 1 mile and 5 miles within Renfrewshire. 3.10 The report from Vector Transport Consultancy referred to at Paragraph 3.4.1 is attached as Appendix 3, as stated above. Comments from officers in response are set out at Appendix 4. Page 25 of 50
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___________________________________________________________________ Implications of the Report 1. Financial – there will be costs associated with the production of new fare scales, cards and advertising costs which will require to be met from existing budgets. 2. HR & Organisational Development - Nil 3. Council and Community Planning- • Our Renfrewshire is safe – the continued monitoring of taxi licensing contributes to safer communities. 4. Legal – (i) Section 17 of the Civic Government (Scotland) 1982 as amended provides that the maximum fare for the hire of taxis and other related charges shall not be greater than those fixed under that Section by the Licensing Authority. The amended section states that the Licensing Authority must fix scales for the fares and other charges within 18 months beginning with the date on which scales last came into effect. (ii) The Licensing Authority may in fixing scales alter fares or charges or fix them at the same rate as existing charges. (iii) Before fixing a new taxi fare scale, the Council must consult with persons appearing to be representative of taxi operators, review existing scales and propose new scales and advertise its proposal in a newspaper circulating in its area detailing the proposal the date when it is proposed to come into effect and stating that representations may be made within a specified period (ending at least one month from the date of the advertisement). (iv) if any representations are received, the Council require to consider these before fixing a new fares scale. 5. Property/Assets-Nil 6. Information Technology – Nil 7. Equality & Human Rights – The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations Page 26 of 50
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contained in the report because it seeks a review only of taxi fares, which the Council has a statutory duty to review at regular intervals. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety - Nil 9. Procurement – Nil 10. Risk - Nil 11. Privacy Impact - Nil 12. Climate Risk – Nil, as the report only sets out proposals received for new taxi fares in Renfrewshire for consideration by the Board and that, once a proposed new fares scale is agreed, these will be advertised. 13. Children’s Rights – the recommendations in the report are not considered to be incompatible with the UNCRC. 14. Cosla Policy Position - Nil _______________________________________________________ List of Background Papers (a) Background Paper 1 - None ___________________________________________________________________ Author: Douglas J. Campbell, Managing Solicitor (Licensing), 0141-487-1096 douglas.campbell@renfrewshire.gov.uk Page 27 of 50
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APPENDIX 1 CURRENT AND PROPOSED TAXI FARE SCALES Fares to Places Beyond the Renfrewshire Area Boundary The driver is not obliged to accept the hire. Any hire terminating outwith the Renfrewshire area will be charged at a rate to be agreed at the time of hire. Fares chargeable for journeys where a taxi is hired on an exclusive basis shall be charged in accordance with the normal fares scale determined by the Council, but shall be modified where a taxi is hired on a shared basis according to the number of hirers sharing the vehicle, as follows: 1. One hirer 100% of the fare 2. For two hirers 100% of the first hirer to the point of the second hirer and thereafter both pay 75% of the standard fare each 3. If three hirers As above to the point of the third hirer and thereafter all pay 65% of the standard fare each Current Proposal (1) Fares by Distance Minimum fare for a distance not exceeding ½ mile £4.05 £4.35 For each additional yards or part thereof 267 yards/ 30p 252 yards/30p Fares for waiting time For each period of 2 minutes or part thereof 42p 45p Extras For each passenger in excess of 4, a fifth passenger charge of (applicable to 5, 6, or 7 seater taxis) 70p 75p An additional charge for journeys commencing after midnight and before 5 am Sunday to Thursday £1.90 £2.00 An additional charge for journeys commencing after midnight and before 5.00 am Friday and Saturday £2.30 £2.45 Glasgow Airport Terminal Departure Charge £5 Flexible per barrier An additional charge for journeys commencing after midnight on 24 December until midnight on 26 December and from midnight on 31 December until midnight on 2 January £1.20 £1.25 From midnight on 24 December until midnight on 26 December the fare chargeable shall be Normal Fare plus 1/3 (Tariff 2) no change From midnight on 31 December until midnight on 2 January the fare chargeable shall be Normal Fare plus 1/3 (Tariff 2) no change Soiling Fee Soiling in this context includes any soiling by means of food, drink, vomit, urine or excrement up to a maximum of £50.00 Up to a maximum of £100 Page 29 of 50
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4. If four hirers As above to the point of the third hirer and thereafter all pay 55% of the standard fare each 5. If five hirers As above to the point of the third hirer and thereafter all pay 50% of the standard fare each 6. On departure from the taxi of one or more hirers the fare payable will revert to the rate appropriate to the remaining number of hirers Page 30 of 50
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APPENDIX 2 TAXI FARES REVIEW 2022 Table showing current fares tariff and proposed fares Proposal 1 Mile 2 miles 3 miles 4 miles 5 miles Current 5.25 7.05 9.15 £11.25 13.05 Proposal 1 5.55 7.65 9.75 £11.85 13.95 Page 31 of 50
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APPENDIX 3 Report by Vector Transport Consultancy in support of Proposal received Page 33 of 50
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Review of Taxi Tariff in Renfrewshire July 2024 Page 34 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx Vector Transport Consultancy www.vector-consultancy.co.uk www.taxi-surveys.co.uk CONTENTS 1 BACKGROUND 1 2 COSTS ASSESSED 2 3 CONSIDERATION OF OTHER INFORMATION 8 4 CONCLUSIONS AND RECOMMENDATION 9 Page 35 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 1 Vector Transport Consultancy www.vector-consultancy.co.uk www.taxi-surveys.co.uk 1 BACKGROUND 1.1 Introduction Vector Transport Consultancy have been commissioned by Renfrewshire Public Hire Association to undertake a review of the current taxi tariff, in July 2024, in response to an invitation from Renfrewshire Council to provide proposals for a revised taxi fares scale. Recommendations for adjustments to the taxi fares scale are made, based on cost changes since the last review. 1.2 Previous reviews The taxi tariff was revised in September 2023, based on costs calculated in October 2022, using the latest available data at that time. In order to assess relevant cost changes, we need to compare present day operating costs with those calculated in October 2022 and derive the proportionate change in cost between the two sets of data. The proportion of cost change is then used as the basis for recommending potential changes to the distance and time based fares used in the taxi tariff table. Page 36 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 2 Vector Transport Consultancy www.vector-consultancy.co.uk 2 COSTS ASSESSED 2.1 Overview of methodology A common approach to reviewing fares, is to use a basket of costs as a representative basis for comparing overall costs between dates. The combination of costs that is used to determine changes in cost, varies between licensing authority areas. The method used in this report to calculate the change in costs associated with operating a taxi in Renfrewshire uses several component costs which are associated with operating a taxi. These costs do not necessarily encompass all costs which are incurred by all taxi drivers and owners. The costs are intended to provide a reasonable basis for weighting the relative changes in cost for the main components of cost within the overall basket of costs. Indices of cost changes are available for several elements of motoring costs. The change in cost can vary by the element of cost. For example, the change in fuel cost can be relatively volatile compared with, for example, changes in the cost of tyres or indeed the change in vehicle purchase and depreciation cost. Therefore, it would not be reasonable to choose the variation in a single cost element (such as fuel) as the basis for deciding on changes in taxi fares. The cost indices should be weighted according to what proportion of overall cost each element represents. So, for example, if fuel accounts for say 11% of annual cost, then the fuel price index would be weighted to represent 11% of overall cost change index. The weighting of cost indices is achieved by using current [present day] costs to calculate an aggregate operating cost. The present day costs were then compared with the costs calculated for the last fares review, which used costs for October 2022 [base cost]. The base cost and present day costs were then aggregated and the difference in overall aggregate cost was used as the overall cost change index. In this way, the changes in major cost elements, such as vehicle depreciation and driver labour cost, have a greater influence than relatively minor elements such as Vehicle Excise Duty. The costs used to derive the overall change in cost index are: • Vehicle cost • Servicing • Fuel • Insurance • Vehicle Excise Duty • Licensing cost • Average National Earnings Some of the costs are influenced by the annual mileage driven. Based on feedback from the trade, the average annual mileage is estimated to be approximately 38,200 miles. Page 37 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 3 Vector Transport Consultancy www.vector-consultancy.co.uk 2.2 Vehicle Costs The most common vehicles used in 2022 were Peugeot Rifter, Renault Traffic and Mercedes Vito. The Mercedes Vito present day equivalent is generally not considered as a replacement vehicle. Peugeot produce contemporary equivalent vehicles. However, these are less popular amongst the trade. A popular vehicle as a new vehicle replacement for an existing taxi is a Volkswagen Caddy. Similar vehicles of equivalent size and similar cost, are also purchased or leased as replacement vehicles. Renault Traffic based wheelchair accessible vehicles remain a popular choice for use as larger taxi vehicles. It is estimated that around 75% of the taxi fleet are smaller wheelchair accessible vehicles and the remaining 25% are larger taxis. For the sake of calculating comparisons, a 75% small / 25% large split was assumed as a representative assumption for the fleet. In order to provide a representative basis for costs, the costs associated with Volkswagen Caddy vehicles are assumed to be representative of all replacement small taxi vehicles. Similarly, Renault Traffic taxis are assumed to be representative of large taxi vehicles, for the purpose of calculating representative costs. Whilst not all owners follow the same practice, a common approach is to purchase a vehicle, with finance. Vehicles are commonly kept for 5 years, which coincides with common 60 month financing deals. The cost of financing a vehicle over 60 months has been taken as the representative cost of ownership. The same basis was used to determine the 2022 fares calculations. This figure represents the actual annual cost of keeping a vehicle, and takes into account interest and depreciation. The cost of the two types of vehicle vary significantly. A weighted vehicle cost has been derived, which is weighted by 75% small vehicle costs and 25% large vehicle costs. Present day and base (2022) costs were derived. The present day equivalent new vehicle has been used to derive the cost for each of the two representative vehicle types. The current equivalent to a Peugeot Rifter Horizon RS (used for 2022 prices) is a Volkswagen Caddy with wheelchair access modifications. The Renault Traffic equivalent is still available for comparison purposes. The present day annual weighted cost was calculated as £10,184 The base (2022) cost was calculated for the previous cost review, as £9,868. 2.3 Servicing cost The cost of vehicle servicing, including parts and labour, varies by vehicle. The mean cost of servicing and maintenance was estimated to be £2,687 in 2022. The Office of National Statistics publish a range of inflation indices related to costs incurred by society. One of these indices relates to maintenance and repair of vehicles. The index indicates that the cost of maintenance has increased since September 2022 by 13.98% Therefore, the July 2024 maintenance cost has been assumed to have increased from the 2022 level, to £3,062.64 in 2024. 2.4 Fuel cost Fuel consumption for the two representative vehicles varies. For the calculation of a suitable value for fuel cost, we have obtained the urban fuel consumption for Page 38 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 4 Vector Transport Consultancy www.vector-consultancy.co.uk the most fuel efficient diesel version of each model. The fuel consumption rates obtained were as follows: Volkswagen Caddy, 56.5 mpg Renault Traffic, 44.8 mpg For the purposes of this calculation, we have calculated the cost of fuel for an annual mileage of 38,200 miles, for each vehicle type, for both 2022 and 2024. The average cost of diesel in September 2022 was £1.820 per litre. In July 2024 (the latest report available at the time of writing), the average cost of diesel was £1.506 per litre. Therefore, based on the fuel consumption figures above, the cost of fuel for each type of vehicle is as follows: Page 39 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 5 Vector Transport Consultancy www.vector-consultancy.co.uk Table 1 - Fuel Costs Cost 2022 Cost 2024 Mileage 38,200 Cost per litre £1.820 £1.506 Fuel Consumption (mpg) Annual fuel consumed (gallons) Annual fuel consumed (litres) Annual fuel cost Annual fuel cost VW Caddy 56.5 676.1 3,073.6 £4,628.90 Peugeot Rifter Horizon RS 57.4 665.5 3,028.0 £5,510.96 Renault Traffic 44.8 852.7 3,876.4 £7,055.05 £5,837.79 Mercedes Vito 39.2 974.5 4,430.1 £8,062.78 average 816.4 £6,876.26 £4,931.12 The average cost was derived as the average of the three vehicle types in 2022 and the two vehicle types (75% small and 25% large) in July 2024. 2.5 Insurance The cost of insurance varies by the individual and vehicle insured. The average insurance cost was estimated to be around £1,132 per annum for the previous cost review in 2022. Office of National Statistics publish a range of inflation indices related to costs incurred by society. One of these indices relates to motor vehicle insurance. The index indicates that the cost of insurance has increased since 2022 by 48.2% Therefore, the July 2024 insurance cost has been assumed to have increased from the 2022 level, to £1,677.62. 2.6 Vehicle Excise Duty cost Vehicle excise duty has two stages of charge. For the purchase of a new vehicle, there is a first year Vehicle Excise Duty charge, followed by an annual charge in subsequent years. The duty charges have been assessed over 5 years for each vehicle type and a mean cost calculated, for each assessment year. The costs for 2022 are as follows: Page 40 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 6 Vector Transport Consultancy www.vector-consultancy.co.uk Table 2 - 2022 VED Costs 2022 VED rates First year Subsequent years Average over 5 years Peugeot Rifter Horizon RS £230 £165 £178 Renault Traffic £230 £165 £178 Mercedes Vito £945 £165 £321 Average £225.67 The costs for 2022 are as follows: Table 3 - 2024 VED Costs 2024 VED rates First year Subsequent years Average over 5 years VW Caddy £680 £190 £178 Renault Traffic £680 £190 £178 Average £288 2.7 Licensing costs There are some recurring licensing costs incurred, associated with operating a taxi. The 2022 costs were calculated as follows: In October 2022, licensing charges were: A taxi operators licence was renewed every 2 years at a cost of £331, equating to £165.5 per annum A taxi driver licence was renewed every 2 years at a cost of £109, equating to £54.5 per annum. Annual taxi test fees of £75.45 were required. Therefore total licensing costs per annum in 2022 was £295.45 In July 2024, licensing charges were: A taxi operators licence was renewed every 2 years at a cost of £328, equating to £164 per annum A taxi driver licence was renewed every 2 years at a cost of £120, equating to £60 per annum. Annual taxi test fees of £83.25 were required. Therefore total licensing costs per annum in 2024 was £307.25 Page 41 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 7 Vector Transport Consultancy www.vector-consultancy.co.uk 2.8 Average national earnings The Office of National Statistics collects and publishes earnings data in a variety of formats and from different sources. One of the sources is the Annual Survey of Hours and Earnings. This survey collects data annually and publishes results. The most recent available data is used for this assessment. The data for Scotland was obtained for 2021 for the previous assessment. This data is used as the base data for comparison with the latest available data. The average gross earnings for 2021 were £29,798. The equivalent average gross earnings for 2023 were £33,385. The difference in earnings between 2021 and 2023 was an increase of 12.0%. Total costs calculations The total indicative annual costs have been summarised in the following table: Table 4 - Annual Operating Costs Cost item 2022 Costs 2024 Costs Vehicle cost £9,868 £10,184 Servicing £2,687 £3,062.64 Fuel £6,876.26 £4,931.12 Insurance £1,132 £1,677.62 Vehicle Excise Duty £225.67 £288 Licensing cost £295.45 £307.25 Average National Earnings £29,798 £33,385 Total cost £50,882.38 £53,835.63 The proportionate change in overall costs between 2022 and 2024 was an increase of 5.80%. Page 42 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 8 Vector Transport Consultancy www.vector-consultancy.co.uk 3 CONSIDERATION OF OTHER INFORMATION 3.1 Retail Price Index The office of National Statistics publishes the Retail Price Index on a monthly basis. The index for September 2022 was 347.6. The equivalent index value for June 2024 (the latest data available) was 387.3. To calculate inflation between September 2022 and June 2024, we divide the later index value by the earlier index value, i.e. 387.3 / 347.6 = 1.114 Therefore, inflation between September 2022 and June 2024 was 11.4% 3.2 Consumer price index Another inflation index which has become more popular in recent years and which has generally replaced the RPI index is the Consumer Price Index (CPI). The CPI value for October 2022 was 124.3. The latest value for June 2024 was 133.0. Therefore, inflation between October 2022 and June 2024, based on CPI index values was 133.0/124.3 = 1.0699, which equates to 7.0%. 3.3 Comparison of UK average fares The publication Private Hire and Taxi Monthly maintains a league table of taxi fares around the UK. The table contains an average cost for a 2 mile taxi fare in the UK. In October 2022, the median position 2 mile fare, in PHTM table (rank 174) cost £6.60 In July 2024, the median position 2 mile fare, in PHTM table (Rank 171) cost £7.00. The difference in fares between 2022 and 2024 equates to an increase of 6.1% Page 43 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 9 Vector Transport Consultancy www.vector-consultancy.co.uk 4 CONCLUSIONS AND RECOMMENDATION 4.1 Conclusions There is evidence that operational costs have increased since the last fares increase. The cost increase was less than Retail Price Inflation. However, it is noted that the latest average earnings data relates to 2023 average earnings and are likely to underestimate the equivalent annual earnings for 2024. Consequently, the operational cost increase calculation is likely to be a conservative calculation. The operational cost increase was in line with the increase in the UK average for a 2 mile taxi fare. 4.2 Recommendation It is recommended that a fares increase be considered in line with the proportionate operation costs incurred since the last increase, based on 2022 costs. As such, fares should increase by approximately 5.80%. It is not practical to simply apply this increase to each of the elements in the Taxi Tariff in Renfrewshire. It is generally preferred that some of the elements are rounded to the nearest 5 or 10 pence. Furthermore, some elements of a taxi fare are rounded up within the meter. For example, for journeys longer that the minimum fare distance (currently half a mile), the cost increases by 30 pence for each 267 yards or part thereof, so a journey which is one yard over the half mile would cost the same as a journey which is 266 yards over the half mile. Consequently, when the tariff is changed, the increase in fares charged is not a consistent percentage for all distances travelled. Various adjustment can be made to different elements of the tariff rates to generate a resultant increase of around 5.80% in a typical fare. The fare structure includes an adjustment to Tariff 1 rates of normal fare plus 1/3 to form Tariff 2. Therefore it is prudent to take this adjustment into account when considering fare adjustments. Where possible, it is recommended that fare components are divisible by 3 to facilitate Tariff 2 adjustments and where feasible, divisible by 10 to facilitate rounding of fares. The current Tariff Card for taxi fares indicates that the minimum fare for a distance not exceeding ½ mile is £4.05. Each additional 267 yards, or part thereof is charged at £0.30. If we were to apply an increase to the minimum fare and round this off, the £4.05 increased by 5.80% would be £4.2849 This would naturally be rounded to £4.35, which is divisible by 3 and fits with the Tariff 2 multiplier. The incremental distance on which charges for journeys in excess of ½ mile are currently charged is 267 yards. A charge of £0.30 is added for each additional 267 yards or part thereof. Applying the 5.80% increase to £0.30 would result in £0.317. Even if rounded up to the nearest penny, a charge of £0.35 per 267 yards is not practical. Consequently, one would normally keep the incremental cost the same, but adjust the incremental distance in line with the proposed increase in Page 44 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 10 Vector Transport Consultancy www.vector-consultancy.co.uk cost. The incremental distance would be reduced, so that over longer distances, more increments would be covered and this in turn would lead to a proportionate increase in cost. On this basis, we would consider reducing the 267 yard current increment by 5.80%, to 252.36 yards. In practice, this would be rounded off to 252 yards, which is divisible by 3. If the increase in flag drop fare and reduction in incremental distance are applied, the resultant proportionate increase in cost will vary by distance, owing to the rounding up effects of the charging structure. The differences in distance based fare are illustrated in the following tables over a variety of distances. Figure 1 indicates that over longer distances, the increase tends towards 5.80%, with the increase varying around this proportion for shorter distances. Table 5 – Proposed tariff change Option Existing Proposed Flag drop minimum fare £4.05 £4.35 Cost per additional distance increment £0.30 £0.30 Length of additional distance increment 267 252 The distance based fares comparison for the existing and proposed tariff is illustrated as follows: Page 45 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 11 Vector Transport Consultancy www.vector-consultancy.co.uk Table 6 - Distance based costs associated with tariff options Current fare Proposed fare Resulting % increase in fare (VTC proposal) Flag drop minimum fare £4.05 £4.35 7.4% Cost 1 mile £5.25 £5.55 5.7% Cost 2 miles £7.05 £7.65 8.5% Cost 3 miles £9.15 £9.75 6.6% Cost 4 miles £11.25 £11.85 5.3% Cost 5 mile £13.05 £13.95 6.9% Cost 6 miles £15.15 £16.05 5.9% Cost 7 miles £16.95 £18.15 7.1% Cost 8 miles £19.05 £20.25 6.3% Cost 9 mile £21.15 £22.35 5.7% Cost 10 miles £22.95 £24.45 6.5% Cost 15 miles £32.85 £34.95 6.4% Cost 20 miles £42.75 £45.45 6.3% Cost 50 miles £102.15 £108.15 5.9% Page 46 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 12 Vector Transport Consultancy www.vector-consultancy.co.uk Figure 1 - Resulting percentage increase in fare with the proposed tariff Waiting time is currently 42 pence per 2 minutes or part thereof. If a 5.80% increase were applied to this charge, the cost per 2 minutes could rise to 44.436 pence. This would in practice be rounded to 45 pence per 2 minutes or part thereof. The existing tariff card includes several extra charges. It is proposed that the majority of the extra charges are increased by 5.80% and rounded to the nearest amount which is divisible by 5. Therefore , the additional charge per passenger in excess of 4, would increase from 70 pence to 75 pence. Additional charge for journeys commencing after midnight and before 5.00 am Sunday to Thursday, would increase from £1.90 to £2.00. Additional charge for journeys commencing after midnight and before 5.00 am Friday and Saturday, would increase from £2.30 to £2.45. An additional charge for journeys commencing after midnight on 24 December until midnight on 26 December and from midnight on 31 December until midnight on 2 January, would increase from £1.20 to £1.25. The Glasgow Airport terminal pick up or drop off charge is currently set at £5.00. By its nature, this charge, by being defined as a fixed amount in the tariff table, will lag behind any increases in the pick up charge at the airport, when that charge is increased by the airport operators. Changes to the pick up or drop off charge in future are unlikely to occur at the same time as future tariff tables are updated. Therefore it is proposed that the charge definition is amended in the tariff table. The proposed definition for applying the Glasgow Airport terminal pick up or drop off charge is: “Glasgow airport pick up and drop off charges - The hirer shall be liable for the cost of charges levied by Glasgow Airport for passenger pick up and drop off. Any such applicable charge will be added to the fare” Page 47 of 50
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Review of taxi tariff in Renfrewshire 2024 R1.docx, 13 Vector Transport Consultancy www.vector-consultancy.co.uk Similar additional costs are applied in the taxi tariff tables by some other authorities where external charges are incurred. For example, ferry charges, airport pick up and drop off charges and toll charges. Page 48 of 50
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APPENDIX 4 Officers’ Comments in response to Report from Vector Transport Consultancy The report from Vector Transport Consultancy (“the Consultancy”) was prepared in July 2024. They have made the observation that the current fares scale, which was decided at an appeal before the Traffic Commissioner, was based on data from October 2022 and have made their calculations, as at July 2024, on that basis. Officers have considered the calculations, with regard to the current financial and economic climate. Members may wish to consider whether the basis of annual weighted costs of keeping particular vehicles are clearly explained at Paragraph 2.2 of the Consultancy’s report. The report refers to interest and depreciation, making assumptions regarding the representative costs of ownership, but does not appear to provide a detailed breakdown of the figures. The Board may wish to note that, while some operators may choose to keep their vehicles over a period of five years, others choose to run their vehicles for longer periods (which can often be for between eight and ten years in accordance with the temporary policy agreed by the Board in relation to vehicle age, following the pandemic). Officers are of the view that vehicle costs and servicing costs are the most difficult to assess the reasonableness of because of the level of variables involved. With regard to servicing, while the increase of 14% appears high, it is recognised that in recent years component prices in all sector areas have increased significantly. With regard to fuel costs, while officers appreciate that these are only one element of the basket of costs identified by the Consultancy, Members will be aware that the cost of diesel has continued to fall significantly to date, from the reduction as observed by the Consultancy in their July 2024 report. With regard to licensing costs, it should be noted that the cost of an application for 2 year renewal of a taxi licence in October 2022 was £297, rather than the £331 stated in the report. The cost of a similar renewal application currently (£328) is correctly stated in the report. As such, the cost of renewal has increased, rather than fallen, between these dates. Members will note the Consultancy’s calculations at Table 6 on page 11 of the report. While the intention of the Association/ Consultancy’s proposal is to raise fares by 5.8% overall, Members will note, while recognising that any increase to the overall distance charge will not result in a linear increase (as an additional one yard or 266/251 yards distance will attract the same addition to the fare), that in relation to the thirteen distances set out in that table, all but three of the fares stated equate to a Page 49 of 50
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higher, or significantly higher, increase than 5.8%. It may be that the Consultancy have determined their proposal based on what they consider to be a typical journey. The Board may wish to consider these points further. Page 50 of 50