Coventry Taxi Study 2012 / 13
Final Report
October 2013
Document Control Sheet BPP 04 F8 Version 14 July 2012
Project: Coventry Taxi Study 2013 Project No: B1294316 Client: Coventry City Council Document Title: Final Report Ref. No:
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Coventry Taxi Study Final Report 2013.doc
Executive Summary
This study was commissioned to provide evidence for Coventry City Council (CCC) to review their taxi licensing policy on vehicle types and on a number of other taxi and private hire vehicle (PHV) licensing issues through consultation with wheelchair users and the taxi trade. CCC currently restricts taxi types to those complying with the London Conditions of Fitness (LCoF), in particular, the ability to U-turn within a 25ft radius. 94.5% of the fleet are the standard ‘black cab’ LTC/LTI TX taxis. 4% are Metrocabs and 1% of the fleet are Mercedes Vito One80 taxis with rear wheel steer to comply with the LCoF requirement for a 25ft turning circle.
Comparison of the reference wheelchair standards with the existing and alternative taxi vehicles reveals that, all existing taxis have doorways equal to or greater than the 700mm specified width standard and the Mercedes Vito One80 has the widest doorway. The LTC/LTI TX4 has the highest doorway and the alternative taxis all have doorway heights below the reference wheelchair standard (55mm - 70mm below the specification). Most existing and alternative taxis have internal heights that meet the reference wheelchair standard, with the LTC/LTI TX4 the highest. The Mercedes Vito One80 and Renault Voyager have variable internal heights with at least part below the reference standard specification.
Consultation with other taxi licensing authorities revealed some, which did not previously apply the LCoF, already applied a more general requirement that taxis must be wheelchair accessible. Several authorities have relaxed their previous LCoF requirements by licensing additional vehicle types. There has been a significant response to the recent Lunt Case in this respect.
The majority of wheelchair users in Coventry have the standard manual chair and are likely to have few difficulties accessing taxis, unless they are particularly tall and have difficulty lowering their head. This was a key accessibility issue identified at the taxi testing event carried out within the study. From the responses to our survey of wheelchair users, we estimate that 20% of users may need to lower their head to enter existing vehicles. However, the doorway headroom of alternative vehicles is not higher than in the existing fleet.
It is estimated that around 16% of wheelchair users have a long wheelchair which may not be able to be turned within taxis. They are more likely to be users of powered wheelchairs.
Market research was undertaken with both taxi drivers and wheelchair users revealing consistency in the reporting of the occurrences when drivers refused to carry wheelchair users by taxi. 6% of drivers often refuse wheelchairs and 38% of drivers sometimes refuse wheelchairs compares with users reporting that 8% of taxis frequently fail to stop and 22% occasionally fail to stop. Also, the users reported that 7% of taxis often refuse to take them and that 27% occasionally refuse to take them.
Analysis of the reasons stated by drivers for refusing wheelchairs suggests that wheelchair types and sizes are key issues. They noted a particular issue with powered wheelchairs. Analysis of the dimensions of wheelchairs in use in Coventry revealed that powered chairs were most likely to have problems due to their height and length. Increasing the fleet range to include larger vehicles might help to increase wheelchair access, however, the alternative taxis are not higher than the
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existing vehicles, therefore it cannot be concluded that increasing the fleet will resolve the problem of users being refused to be carried.
Wheelchair users reported that driver behaviour was the main reason for being refused carriage, where 13% stated that the refusal was due to the wheelchair size. They also reported that inability to access the vehicle was due to the wrong vehicle being sent or driver behaviour / vehicle maintenance issues (eg: lack of ramps). Increasing the range and numbers of taxi types, in particular the proportion of Mercedes Vito One80’s, would increase the likelihood that a user could secure their preferred vehicle.
There was also consistency between drivers and users in the reporting of problems related to the position of wheelchairs and securing them within the taxi. Drivers reported that 25% of passengers often or sometimes complain about the positioning of the wheelchair in the taxi, which compares with 28% of users stating that they were never or frequently not positioned correctly and 33% stating that they were never or frequently not secured properly.
42% of users were not positioned correctly due to insufficient space, though the majority of reasons relate to driver behaviour and vehicle maintenance issues (such as missing ramps and belts). In addition, 10% of users also stated insufficient space as the reason for not being secured properly. The Mercedes Vito One80 has a larger internal space than the LTC/LTI TX4. Increasing the proportion of Mercedes Vito one80 vehicles in the taxi fleet would improve the likelihood that users get a taxi in which they can be positioned and secured appropriately. Increasing the range of vehicles in the fleet would improve opportunities for wheelchair users to travel facing forward.
The taxi testing event held in May 2013 involved four taxis and six wheelchair users. The traditional LTC/LTI TX4 taxi fails to satisfy users only with respect to the ability to position and secure large wheelchairs within the vehicle. Two users that failed to get into the LTC/LTI TX4 and Mercedes Vito one80 taxis also failed to get into the alternative taxis tested. The higher headroom of the LTC/LTI TX4 and lower ramp angle are particular advantages of that vehicle and the traditional ‘black cab’ is very well liked by wheelchair users, most users concluding that they preferred it overall or equally as good as the alternative vehicle-types.
Van-based vehicles have the advantage of greater interior space within which to turn wheelchairs and the option of facing forwards as well as backwards in some models. However, users were generally concerned about poor headroom, steeper ramps and the time taken to set up ramps and to secure wheelchairs. There were concerns that belts and fixing equipment may be lost / disgarded and drivers may not be willing to spend time securing them.
The Mercedes Vito One80 provides an option for larger wheelchairs / users to specify a vehicle type that they are more likely to be able to turn within and be properly secured. However, they comprise only 1% of the Coventry taxi fleet at present.
Assessment of the requirement for a ‘25ft’ turning circle identified a small number of taxi ranks where relaxation of the policy could have potentially adverse safety impacts on sections of key radial streets and/or commercial zones within Coventry. Two City Centre ranks are particularly affected by removal of the 25ft standard and may need to be relocated (Rover Road) or removed (Spon Street West) with consequent reduction in accessibility. Reasonable mitigation measures were
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considered possible to manage these safety implications, including enforcement and partnerships to share best practise and encourage good behaviour.
In terms of the other taxi and PHV policy changes consulted on through this study;
- There was substantial support (84% in favour) for change of the conditions attached to a private hire operator’s licence to require provision of disability awareness training for booking office staff and the cost of training met by the operator.
- The taxi trade were split on the policy for the frequency of medical examinations with most concerned that the suggested policy was too onerous. There was support to bring the policy in line with other similar trades.
- Whilst the taxi trade supported no change to the policy on stretched limousines, in the light of the traffic commissioners comments, it is suggested that there is a need to introduce licencing and slightly revised conditions are suggested (subject to an assessment of adaptation costs as highlighted by the Traffic Commissioner).
- In terms of the policy on tinted windows in private hire vehicles the trade tended to support the application the legal standard but, as that could lead to use of vehicles with limited side and rear visibility as PHV vehicles, it was recommended to retain the current standard which had support from around one third of the trade.
- A range of comments on the Coventry Vehicle Inspection Manual were received including the complexity of the inspection and severity of the test and costs. Three commented that the manual helps maintain safety standards. One suggested driver review prior to publication and three considered the inspections a waste of time.
- There was strong support (82% in favour) for amending the policy to allow an exemption for displaying the plate and stickers on PHVs used exclusively for executive work.
- There was very strong support (94% in favour) for retention of the topographical tests for contract drivers / chauffeurs (Road Knowledge Test).
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Contents
1 Introduction 1 1.1 Background 1 1.1.1 Existing Council Policy on HCV (Taxi) Licences 2 1.2 Study Methodology 3 1.3 Report Structure 5
2 Vehicle Accessibility Assessment 7 2.1 Introduction and Objectives 7 2.2 Vehicle Dimensions for Wheelchair Access 7 2.3 Wheelchair Dimensions 7 2.4 Analysis and Conclusions 9
3 Comparator Authorities Research 11 3.1 Introduction and Objectives 11 3.2 Research Findings 11 3.3 Conclusions 13
4 Research into Coventry Taxi Wheelchair Access Issues 15 4.1 Introduction and Objectives 15 4.2 Stakeholder Research 15 4.3 Market Research 15 4.4 Taxi Drivers Survey Findings 16 4.5 Wheelchair Users Findings 19 4.5.1 Use of Taxis 19 4.5.2 Difficulties Experienced 20 4.6 Analysis of Users Wheelchair Sizes 26 4.6.1 Survey Respondents 26 4.6.2 Analysis of Coventry Wheelchair Service Database 28 4.7 Conclusions 32
5 Vehicle Testing Research 33 5.1 Introduction and Objectives 33 5.2 Approach 33 5.3 Findings 34 5.4 Conclusions 35
6 Turning Circle Research 37 6.1 Introduction and Objectives 37 6.2 Approach 37 6.3 Research Findings 37 6.3.1 Taxi ranks 37 6.3.2 Coventry Streets Analysis 44 6.4 Conclusions 45
7 Consultation on Other Licensing Policy Issues 47
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7.1 Introduction and Objectives 47 7.2 Approach 47 7.3 Results and Conclusions 47 7.3.1 Staff Training in PHV Booking Offices 47 7.3.2 Frequency of Medical Examinations 48 7.3.3 Stretched Limousines Policy 49 7.3.4 Tinted windows in private hire vehicles 52 7.3.5 Criteria for Vehicle Inspections 53 7.3.6 Exemption for the displaying of licence plate and stickers on executive vehicles 54 7.3.7 Topographical Tests for Contract Drivers (Road Knowledge Test) 55 7.3.8 Other responses 55
Table 1-A Current Taxi Fleet 2 Table 2-A Taxi Wheelchair Access Dimensions 7 Table 2-B Wheelchair Dimensions – Summary Statistics 8 Table 4-A Wheelchairs in Use; Source - Coventry Wheelchair Service 29 Table 4-B Analysis of Dimensions of Coventry Manual Wheelchairs (from Coventry Wheelchair Service Database) 31 Table 4-C Analysis of Dimensions of Coventry Powered Wheelchairs (from Coventry Wheelchair Service Database) 31 Table 5-A Space for Passengers as well as Wheelchair by Vehicle 33 Table 5-B Vehicles Tested by Wheelchair Users 34 Table 5-C Summary of Wheelchair Users Comments 34 Table 6-A Taxi Rank Location Analysis. 38
Appendix A Coventry Hackney Carriage Vehicle Requirements Appendix B Manufacturers / Models and Sizes, Sample of Wheelchairs Appendix C Wheelchair Groups / Stakeholders Research Findings Appendix D Consultation Questionnaires Appendix E Additional Stakeholders Consulted Appendix F Vehicle Testing Day Wheelchair Users Comments Appendix G Example Taxi Turning Circle Analysis Appendix H Proposed Policy Conditions: Stretched Limousines Appendix I Other Comments Received in Response to the Criteria for Vehicle Inspections
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1 Introduction
1.1 Background
Jacobs was appointed by Coventry City Council through their framework contract to undertake a review of Taxi (Hackney Carriage) and Private Hire Vehicle (PHV) licensing policy in the City. The need for the review at this time was as a result of the publication of the Equalities Act, the result of the Lunt versus Liverpool Council case1, the lack of guidance on vehicle standards from the Department of Transport (DfT) and resultant requirements for local authorities to make decisions locally.
Jacobs were required to undertake further research and consultation and to provide advice for the City Council to take into account in reviewing the licensing policy. The research needed to cover two specified areas; (A) the type of vehicles suited to being licensed taxis and; (B) consultation on a number of other aspects of Coventry licensing policies. The team selected included accredited road safety auditors (in accordance with Highways Agency Standard HD19/03 Road Safety Audit) for the assessment of the safety implications of a potential change to the vehicle type policy.
The research on vehicle-types was designed to answer a number of specific questions, as follows;
- What size / type of wheelchairs are currently in use? - Which wheelchairs fit / don't fit into the current Coventry City Council fleet? - Which wheelchairs fit / don't fit in any other type of vehicle that could be licensed? - Survey of those with an interest in the issue (e.g. vehicle manufacturers / converters, licenced trade, disability groups, disabled taxi users, Centro, train operators)? - Numbers and nature of disabled users using current fleet? - Whether there is a class of disabled users who cannot use current fleet? - How many of that class would be assisted by any other vehicles on the market? - Is there a road safety justification for retaining a 25' turning circle?
The other issues that required further research and consultation on were;
- The training for Private Hire Operators' (booking office) staff; research into the implications of the Equality Act on Operators on the introduction by Operators of training for their staff;
- Medical Examinations; further research to refresh the data informing the policy options and consultation with stakeholders;
1 The judge found that Liverpool City Council's decision to refuse to license the Peugeot E7 vehicle was flawed because they had based that decision on the erroneous belief that their existing fleet was accessible to all wheelchair users and that difficulties in accommodating wheelchairs were due to driver error rather than lack of space. The Council's decision was quashed on that basis and the Council was required to reconsider its decision in the light of all relevant factors including its duties under the Disability Discrimination Act 1995 (now the Equality Act 2010) and including EU laws governing restraint of trade.
.
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- Stretched Limousines; further research to establish whether the use of cameras and monitors complies with the Construction and Use Regulations and consultation with stakeholders;
- Consultation with stakeholders on; Policy for tinted windows; Criteria for vehicle inspections; Repeal of the PHV Contract Exemption, and; Topographical Tests for Contract Drivers (Road knowledge test).
1.1.1 Existing Council Policy on HCV (Taxi) Licences
In September 2011 Coventry City Council limited Hackney Carriage Vehicle (HCV) (Taxi) Licences to a maximum of 859. In the Vehicle Proprietors Information Document (054) the Council states that “The chart below lists the make and model of vehicles that meet the Council's policies for licensing as hackney carriages in Coventry.”
The Coventry Hackney Carriage Vehicle requirements and standards are set out in Appendix A and include a requirement that the vehicle must meet the London Public Carriage Office ‘Conditions of Fitness’2 which limits the vehicle types.
On 3rd December 2012 the Coventry taxi fleet comprised 830 vehicles, as shown in the Table 1-A. The majority of taxis are LTC/LTI TX2 and TX4 vehicles.
Type Number % LTC/LTI – TX1 141 17.0% LTC/LTI – TX2 349 42.0% LTC/LTI – TX4 294 35.4% LTC/LTI – Fairway 1 0.1% Metrocab 33 4.0% Mercedes – Vito One80 taxi 12 1.5% Total 830 Table 1-A Current Taxi Fleet
The Mercedes Vito Taxi is a variant of the ‘Traveliner’ model and is allowed for operation with the ‘One80’ rear wheel steer system which can be activated to enable the rear wheels to turn in the opposite direction to the front wheels. This allows the taxi to perform the 25’ turning circle required to conform to the London Conditions of Fitness.
2 Transport for London Public Carriage Office, Construction and Licensing of Motor Taxis for Use in London, Conditions of Fitness, 1 January 2007, issue v4.0 April 27 2009.
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1.2 Study Methodology
The study follows on from work undertaken between 2008 and 2010 which examined a wide range of issues raised by Coventry City Councils review of taxi licensing policies on the back of DfT guidance. This study focuses on the remaining issues which were delayed pending further advice from the DfT. Publication of that advice is not now expected. Therefore, Coventry City Council, like other licensing authorities, must formulate policy based on local research.
There were three key aspects to the study;
1. Taxi Vehicle Type Specification
For the council to demonstrate that it is meeting its obligations under the Equality Act, it must assess the requirements of existing and prospective taxi passengers who rely on use of a wheelchair. The Council needs to adopt criteria on the vehicles it licenses which are a reasonable response to the requirements of users, when weighed against the cost and availability of conforming vehicles.
Jacobs approach was based on research of available evidence plus targeted primary research providing a cost-effective and robust methodology. The study required a full breadth of research to be undertaken including seeking evidence from Coventry wheelchair users on the dimensions of their wheelchairs, the experience of Coventry Wheelchair Users in using taxis, the experience of taxi drivers and view of the taxi trade on carrying wheelchair passengers and practical testing of available taxi vehicles by Coventry wheelchair users.
The practical testing of access to specific types of vehicle was undertaken with standard and large wheelchairs in common use, focussing on those vehicles currently licensed by Coventry CC (eg: LTC/LTI TX4 and Mercedes Veto One80 taxi) and alternative taxi vehicles that could potentially be licensed in the short term. The research was not intended as ‘product proofing’, but was intended to test and verify manufacturer’s assessments in a real world situation.
The study tasks were;
- Securing relevant documents that define Coventry City Councils vision, objectives and policies on taxis, especially criteria on acceptable types of vehicle.
- Contacting a range of other cities & towns to compare how they have responded to the Equality Act through their specification of the type of vehicles that are acceptable as licenced hackney carriages. Including places operating the ‘London Conditions of Fitness’ policy, plus a number of comparable size towns and cities that are not applying that policy.
- From manufacturer’s sales information, researching the dimensions of a range of wheelchairs commonly used in the UK and reviewing the capability of different types of taxi to carry wheelchairs through research and dialogue with manufacturers and vehicle-adapters.
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- Contacting relevant industry groups in the region including West Midlands Special Needs Transport, Coventry Wheelchair Users Group, Coventry’s Physical Impairment Partnership and other representatives of people with reduced mobility to obtain information on the common types of wheelchair that are used and the key issues relating to taxi access locally.
- Market research to establish the views of wheelchair users on a range of Taxi issues and identification of a group of users with large wheelchairs / access requirements for inviting to test available vehicles.
- Organisation of the vehicle access testing with the help of the taxi trade organisations and manufacturers/converters providing the specific vehicles for testing with a range of wheelchair types. Establishing the accessibility of the vehicles to accommodate the wheelchairs, the position of the wheelchairs in the vehicle and the users comments.
- Use of the computer mapping programmes to test the 25ft turning circle at taxi ranks and a range of key streets where taxis are likely to be hailed. Safety assessment and risk assessment of relaxing the policy at key locations, noting that the Equality Act has lowered the threshold for changing ‘discriminatory’ policies to ‘substantial disadvantage’.
2. Other Aspects of Licensing Policy
This required completing further research and review of the draft policies / criteria for the following;
- Updating training for staff in PHV booking offices in line with the Equality Act and reviewing CCC draft policy.
- Updating the evidence supporting the draft options for consultation on the frequency of medical examinations.
- Reviewing the Construction and Use Regulations as they relate to stretched limousines and CCC’s draft licensing policy on these vehicles.
3. Consultation
The two previous tasks were completed in parallel and a single consultation exercise was undertaken for efficiency and to minimise demands on consultees. Questionnaires were developed and distributed to understand the views of the taxi trade and other stakeholder’s views on wheelchair access issues and a range of licensing changes. The main issues for the trade consultation were;
- Refusal of wheelchairs and difficulties of access and positioning of wheelchairs. - Training of PHV Booking Office Staff. - Medical Examinations and frequency of examinations. - Tinted Windows in PVH’s. - Criteria for Vehicle Inspections. - Policy on Stretched Limousines. - Exemption for displaying of licence plate and stickers on Executive vehicles. - Topographical Tests for Contract Drivers.
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1.3 Report Structure
Following this introduction the report presents the approach and findings of the study. Section 2 presents the results of research into vehicle accessibility against standards. Section 3 presents the results of research with other Licensing Authorities on changes as a result of the Equality Act. Section 4 presents the results of research with Wheelchair User Groups and Stakeholders on wheelchair access issues, including the market research undertaken with taxi drivers and wheelchair users in taxi access issues. Section 5 presents the findings of the vehicle testing research. Section 6 presents the analysis of the ‘25ft’ turning circle policy3. Section 7 presents the results of consultation on other licensing policy issues.
3 The ‘25ft turning circle’ is 28ft allowing for overhang beyond the front and back wheels and is a specified criteria within the London ‘Conditions of Fitness‘ for Hackney Carriages.
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2 Vehicle Accessibility Assessment
2.1 Introduction and Objectives
Assessment of the dimensions of taxis in Coventry’s existing fleet against wheelchair access standards and typical wheelchairs was undertaken to establish the accessibility of vehicles currently available to Coventry wheelchair users.
2.2 Vehicle Dimensions for Wheelchair Access
Table 2-A shows the dimensions of existing taxi’s and alternative vehicles for wheelchair access derived from manufacturer’s published data.
Doorway Dimensions Internal Dimensions Ramp Angle Vehicle Minimum Widest Height Length Height Width Width (mm) (mm) (mm) (mm) (mm) Ground Ground Pavement
Currently Licensed Taxis LTC/LTI – TX2 740 820 1,315 1,020 – 1,390 19o 14o 1,355 LTC/LTI – TX4 700 788 1,346 1,400 16o 10o Metrocab 730 840 1,260 745 – 1,280 960 Mercedes – Vito One80 985 1,050 1,335 770 - 1,295 – 14o 11o 1360 1,325 Alternative Taxis Peugeot E7 740 925 1,295 1,290 1,350 23o 18.5o Renault Voyager NX8 800 1,290 1,330 – 20o 10.7o 1,390 Citroen Voyager LC7 830 1,280 1,350 19.3o 14.3o Nissan NV200# 693 693 1,171 1,220 – 2,040 Table 2-A Taxi Wheelchair Access Dimensions Footnote: # draft – to be confirmed, vehicle not currently in production. Other vehicles information not readily available.
The LTC/LTI Fairway and Metrocab are relatively old vehicles and there are few remaining in the Coventry fleet. They are likely to be phased out in the future as they are no longer in manufacture so will be replaced by alternatives as the current fleet ages. Through application of the taxi policy, they would be replaced with vehicles less than 5 years old, meeting the latest access standards.
2.3 Wheelchair Dimensions
Research was undertaken to determine the dimensions of the range of wheelchairs. There is a large range of wheelchair manufacturers and different types of wheelchair available. The aim of the research was to establish a representative sample, including those models used by those Coventry residents that responded to the research undertaken in 2010.
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Table 2-B shows the key wheelchair dimensions from 19 self-propelled and 20 powered wheelchairs. The actual models examined are listed in Appendix B.
Length Width Height#
Min Max Min Max Min Max (mm) (mm) (mm) (mm) (mm) (mm) Non- Powered Average (mean) 989 999 617 694 926 939 Maximum 1,140 1,140 730 825 950 1,020 Median 1,000 1,040 630 660 940 940
Powered Average (mean) 1,092 1,113 608 632 935 1,065 Maximum 1,390 1,390 740 740 1,000 1,455 Median 1,090 1,100 610 640 960 975
Reference Chair 1,200 700 1,350 Dimensions (See below) Table 2-B Wheelchair Dimensions – Summary Statistics4 Footnote: # actual height depends on the user.
Requirements in the transport regulations introduced under the Disability Discrimination Act 1995 specify an occupied wheelchair equal to 1,200mm long by 700mm wide. The DfT Inclusive Mobility document5 (2002) specifies an overall clear allowance including a height standard of 1,374mm. In that document the width and length standards are slightly greater at 900mm wide and 1,500mm long.
In the 2008 Lowland Market Research Wheelchair User Experience Taxi Survey report6 the reference wheelchair dimensions are defined as;
- Total Length 1,200mm (including extra long footplates); - Total width 700mm, and; - Sitting height (from ground to top of head) 1,350mm.
The reference wheelchair length is greater than the average (mean), median or maximum of the non-powered chairs. The reference wheelchair length is greater than the average (mean) and median observed for the powered chairs but less than the maximum.
The reference wheelchair width is the average (mean) and median of both powered and non-powered wheelchairs observed but below the maximums.
It is not clear that the heights quoted by manufacturers for the chairs researched for this report make allowance for an average occupant. The reference wheelchair height is at the high end of the range for powered / non-powered observed chairs.
4 Mean = Average, Median = middle of range. 5 Inclusive Mobility, a guide to best practice on access to pedestrian and transport infrastructure, Department for Transport, December 2005 6 Wheelchair User Experience Taxi Survey, Lowland Market Research, March 2008, for Time of Choice Campaign.
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Overall the reference wheelchair dimensions are considered appropriate for application to taxi vehicle standards in Coventry. They would cover the majority of wheelchair types available to users in the city.
2.4 Analysis and Conclusions
Comparison of the reference wheelchair standards with the existing and alternative taxi vehicles reveals that:
- All existing and most alternative taxis have doorways equal to or greater than the 700mm specified width standard, as shown in Figure 1 below. The Mercedes Vito One80 has the widest doorway.
- The LTC/LTI TX4 has the highest doorway and is just 4mm below the reference wheelchair. The Mercedes Vito One80 doorway is 11mm lower than the LTC/LTI TX4 but higher than the older TX2 and Metrocab taxis.
- The alternative taxis all have doorway heights below the reference wheelchair standard, between 55mm and 70mm below the specification for the vehicles currently available, as shown in Figure 2.
- The Metrocab is the only taxi with an internal floor length less than the 1,200mm reference wheelchair standard, as shown in Figure 3.
- The LTC/LTI TX2/4, Peugeot E7 and Citroen Voyager LC7 have internal heights that meet the reference wheelchair standard, with the LTC/LTI TX4 highest at 1,400mm, 50mm above the specification. The Mercedes Vito One80 and Renault Voyager have variable internal heights with at least part below the specification, as shown in Figure 4. .
1000 950 900 850 800 750 Min Width 700
650 Reference Wheelchair Width
Figure 1 Taxi Doorway Widths Compared to Reference Wheelchair Width
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Figure 2 Taxi Doorway Heights Compared to Reference Wheelchair
Figure 3 Taxi Internal Length Compared to Reference Wheelchair
Figure 4 Taxi Internal Height Compared to Reference Wheelchair
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3 Comparator Authorities Research
3.1 Introduction and Objectives
A sample of other taxi licensing authorities was contacted to establish what their responses had been to the Equality Act and the Lunt Case and whether their experience or research could usefully inform Coventry’s policies. The aim was to contact at least 5 comparison authorities in the categories of currently or previously applying the London Conditions of Fitness (LCoF), or not. The comparator authorities were drawn from a list of authorities still applying the LCoF policy and other authorities of a similar size to Coventry.
The telephone research used a standard set of questions covering;
- Whether the Authority operates the London Conditions of Fitness policy. - Whether the Authority's Taxi Licence Policy has changed in the light of the Equality Act and 2009 Lunt versus Liverpool case. - In what way the Authority's policy has changed and when. - What research was undertaken to support the current policy. - What other changes or actions have been taken as a result of the equality act.
3.2 Research Findings
Five licensing authorities that currently, or in the recent past, operate the London Conditions of Fitness for taxi vehicle types were contacted.
Transport for London (TfL) has not changed its policy. In 2002/03 there was a major review of the ‘Conditions of Fitness’ and there is an ongoing process of engagement with taxi licensees and vehicle manufacturers to consider changes and improvements to it. The London Taxi Accessibility Wheelchair User Research report was published on 28 May 20107 and highlighted issues with taxi drivers rather than shortcomings of London taxi vehicles or accessibility equipment contained within London taxis.
In response to the Equality Act, TfL provided information for drivers about their responsibilities under the Act and provided face-to-face engagement with drivers at taxi ranks to talk about assisting disabled passengers. Checks were also made on the accessibility features of licensed taxis. Drivers were advised of the steps to take if they wanted to apply for an exemption prior to the Act coming into effect.
The specific provisions that TfL makes for wheelchair users are that; all newly licensed taxi drivers must pass the DSA taxi driving test and the wheelchair test Information must be provided inside the taxi advising wheelchair users on the correct position to travel in.
No research was undertaken to support the provisions but TfL undertakes regular mystery traveller surveys conducted by disabled passengers.
7 London Taxi Accessibility Wheelchair User Research, Transport for London, May 2010.
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TfL were able to provide the results of several research studies – of particular interest to this project was the “Transport for London (TfL) Conditions of Fitness Independent Review: Study D8” which reviewed the LTC/LTI TXII, Metrocab and Mercedes Vito vehicles alongside the Peugeot E7 and VW Shuttle Unique in terms of accessibility. It concluded that;
“The results of the usability trial demonstrate that there is no single vehicle that provides a best practice design for all criteria for all user groups. This is due in part to disparate needs between types of user. Each of the vehicles would benefit from design changes, which in many cases could be relatively require relatively [sic] minimal effort to implement (e.g. extra grab handles, ramp fixings). The current London taxis can be considered to offer the best all-round performance when considering all dimensions (with equal weightings). The LTC/LTI TX2 performed reasonably well across most criteria including accessibility, comfort and safety. Despite these advantages, the current London taxis can be improved, specifically in terms of wheelchair access (including space available for a wheelchair) driver comfort and safety features.”
“The Peugeot E7 was a close competitor to the LTC/LTI TX2, offering flexibility and provision for mobility and visually impaired users. However, the visibility out of the windows was considered a distinct problem with this model. This factor considerably reduced the ride experience and comfort for both passengers and drivers. Both the Peugeot E7 and the Mercedes Benz Vito passenger doors were viewed as being difficult to operate, particularly from inside the vehicle. Users, particularly able-bodied passengers, were generally very satisfied with the overall performance of the Volkswagen Shuttle Unique.”
“The alternative vehicles offer distinct advantages regarding disabled access, particularly by wheelchair users. The Peugeot E7 can be particularly commended for a highly usable and intuitive step and ramp device, as well as a high level of provision for visually impaired users. The two Bernard Mansell9 vehicles significantly excelled in terms of compartment space allowing flexibility in positioning passengers using a wheelchair. However, this relatively large compartment space could only be achieved by the re-positioning of the forward facing passenger seats. A task that may prove impractical for the driver to complete between hires. The large compartment space also brings with it disadvantages for visually impaired and ambulant passengers when getting in and out of the vehicle. It also creates more issues when interacting with the driver and reaching the door handle to open and close the doors.
Telford and Wrekin Council changed their policy in 2012 as a direct result of the Equality Act and Lunt case. They changed the policy to;
8 Conditions of Fitness Independent Review: Study D Usability Trial, Human Engineering, December 2004 for Public Carriage Office, a division of Transport for London. 9 Volkswagen Shuttle Unique and Mercedes Benz Vito Unique.
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“The proprietor shall ensure that the Hackney Carriage vehicle shall only be of the type approved for Hackney Carriage use by the Council, namely a purpose built vehicle to carry up to eight passengers with factory fitted seatbelts and an engine capacity not less than 1600cc. subject to the following: Hackney Carriage Vehicles are approved by way of a list that will specify as many different types of vehicles as possible. The vehicle must have provision for a minimum of at least one wheelchair"
All taxis are wheelchair accessible, all newly licensed taxi drivers must pass the DSA taxi driving test and the wheelchair test and information is required to be provided inside the taxi advising wheelchair users on the correct position to travel in.
Wirral Borough Council changed their policy in 2002 prior to the Equality Act and has implemented no specific actions in response to the Equality Act. From 1st January 2000 the policy required for all HCVs to be wheelchair accessible.
Blackburn with Darwen Borough Council changed their policy in 2011 as a result of the Lunt case. Following the high court ruling they undertook a disability impact assessment on the alternative vehicles. Alternative purpose-built Hackney Carriage vehicles have been added to the fleet.
Chichester District Council operated the London Conditions of Fitness for 25 years and changed the policy in December 2012 in response to the Lunt Case. The Council has ensured that disabled access levels are still high within their fleet and only purpose built HCVs may be used.
Manchester City Council and Norwich City Council are currently reviewing their policies and were unable to provide detailed responses.
Seven authorities that did not apply the London Conditions of fitness responded. They generally have not altered their policy as a result of the Equality Act though Birmingham City pointed out that "Our fleet is made up of wheelchair accessible vehicles and has been for many years. Any purpose-built hackney carriage with wheelchair accessibility and which meets the minimum specified standard can be licensed."
3.3 Conclusions
There is evidence that some authorities that did not previously apply the London Conditions of Fitness already applied a more general requirement that taxis must be wheelchair accessible (to the DfT Accessibility Standard). Several authorities have relaxed their previous London Conditions of Fitness by licensing additional vehicle types. There has been a significant response to the recent Lunt Case in this respect. The consultation revealed a general lack of research into wheelchair access issues except in London and Coventry, though several other authorities were undertaking further research in parallel to this study.
The London research offers valuable wider assessment of taxi accessibility by a range of disabled groups including wheelchair users. However, it does not establish what proportion of wheelchair users have difficulty accessing licensed vehicles and, having been undertaken 3 years ago, did not cover all vehicles currently available.
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4 Research into Coventry Taxi Wheelchair Access Issues
4.1 Introduction and Objectives
Four areas of research were undertaken to establish the scale and nature of actual wheelchair accessibility problems in Coventry. Initially, telephone research of stakeholder groups was undertaken to establish issues to include in user consultation and to establish access to a large user database for the research. Market research was then undertaken with Coventry taxi drivers and Coventry wheelchair users. Finally comparison of user wheelchair dimensions was made with the existing fleet and potential alternative vehicles.
4.2 Stakeholder Research
Organisations with an involvement with people with mobility impairments were contacted by telephone using a standard set of questions to establish;
• Their role and groups they represent; • Their members experience regarding wheelchair accessibility of taxis; • Issues or concerns about using taxis in Coventry, and; • The types of wheelchair in common use.
The detailed responses are included in Appendix C and were wide ranging. The most relevant observations came from the Coventry Wheelchair Users Group / Coventry Wheelchair Service and Scope. In terms of the core interests of the study the groups stated that, whilst wheelchair users can access taxi’s generally well, there were specific concerns relating to;
- Lack of suitable vehicles in the Taxi / PHV fleet with tail lift facilities; - The height of doorways into the vehicles, and; - The position / proper fixing of the wheelchair within the vehicle.
4.3 Market Research
Two market research exercises were undertaken to investigate issues related to wheelchair access for taxi’s; (1) a survey of taxi drivers / taxi trade operators, and; (2) a survey of wheelchair users.
The taxi trade survey also consulted on other aspects of taxi policy in Coventry the results of which are presented in Section 8.
A two page questionnaire (enclosed in Appendix D) was sent out to all contacts on Coventry City Council’s taxi trade database. It was also sent to additional stakeholders in the region, listed in Appendix E. The first page of the questionnaire dealt with drivers experience in carrying passengers in wheelchairs. The survey was anonymous to encourage drivers to be honest about the issues. 1,270 questionnaires were sent out by post and a reply-paid envelope provided for the responses. A target minimum representative sample of 5%10 of licensed HCV drivers in Coventry was set. This was exceeded as there were 150 responses – almost 12%.
10 For statistical reliability of the results a minimum sample of 35 was required assuming the ‘population’ of 1,200 licensees.
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A two page questionnaire (also enclosed in Appendix D) was sent to over 4,357 wheelchair users registered with the Coventry and Warwickshire Partnership NHS Trust Wheelchair Service. The survey was anonymous to encourage honest responses and contact details only requested for individuals volunteering to assist in the vehicle testing event (see Section 5).
For data protection reasons the database was retained by the Wheelchair Service who printed the address labels for the envelopes. The questionnaire was sent with a reply-paid envelope to encourage responses. A small number of envelopes were unable to be delivered and were forwarded back to the NHS Trust to update their database. The response rate was 344 completed interviews, around 8% sample rate.
4.4 Taxi Drivers Survey Findings
Of the 150 responses to the survey 130 were from taxi drivers / owners. The majority of them (95%) drive / own a LTC/LTI TX vehicle; 3% a Mercedes Vito One80, and; 2% a Metrocab. The responses broadly reflect the make-up of the taxi fleet in Coventry suggesting that the sample is representative.
Figure 5 shows the reported frequency of carrying wheelchair passengers. Very few drivers never carry a wheelchair passenger and few carry wheelchair passengers daily. Most drivers carry wheelchair passenger several times a week, several times a month or less often.
Frequency of Carrying Wheelchair Passengers
Several Times a Day Never 8% 2% Less Often Several Times a 33% Week 27%
Several Times a Month 30%
Figure 5 Frequency of Carrying Wheelchair Passengers (N = 142)
Figure 6 shows the reported rate of refusal to carry a wheelchair passenger. The majority of drivers state that they have never refused a wheelchair passenger. However, a third have sometimes refused to carry a wheelchair passenger and 6% often refuse to carry them.
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Refusal to Carry a Wheelchair Pasenger
70%
60%
50% 40%
30% 20%
10% 0% Often Sometimes Never
Figure 6 Refusal to Carry a Wheelchair Passenger (N =140)
Of the 50 respondents who sometimes refused to take a wheelchair passenger;
• 19 stated that the passenger / chair was too heavy; • 11 stated that the chair would not fit through door; • 12 stated that the chair would not turn; • 7 gave all of the above reasons, and; • 1 stated that electric chairs were the problem.
All of those were drivers of LTC/LTILTI TX vehicles.
Of the 8 drivers who often refused wheelchairs;
• 2 stated that the passenger / chair was too heavy; • 3 stated that the chair would not fit through door; • 1 stated that the chair would not turn; • 1 stated that electric chairs were the problem; and • 1 stated that he had an exemption certificate.
Figure 7 shows the drivers response regarding the number of passengers that complain about the position of the wheelchair in the vehicle.
Three quarters of drivers who responded stated passengers have not complained about the positioning of their wheelchair inside the vehicle. However, one quarter of drivers responded that passengers sometimes (18%) or often (7%) complain about the position of the wheelchair.
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Frequency of Passengers Complaints about Position of Wheelchair in Taxi
80% 70%
60% 50% 40% 30% 20%
10%
0% Often Sometimes Never
Figure 7 Frequency of Complaints about Wheelchair Position (N = 138)
Figure 8 shows the drivers stated use of a swivel seat in the vehicle. Broadly, half stated that it was used often or occasionally and half stated that it was never used or not applicable (assumed as not available in their vehicle).
Use of Swivel Seat
Not applicable Often Used 5% 9%
Occasionally Never used 44% 42%
Figure 8 Use of the Swivel Seat (N = 141)
Figure 9 shows the drivers stated use of the step for access to their vehicle. Over half stated that passengers often or occasionally use the step, less than half stated that the step is never used or not applicable (assumed as not available in their vehicle).
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Use of Step
Not applicable Often Used 8% 8%
Never Used 40% Occasionally 44%
Figure 9 Use of the Step (N = 141)
4.5 Wheelchair Users Findings
4.5.1 Use of Taxis
Figure 10 shows the frequency of taxi use by respondents. 121 (35%) never use taxi’s. Only 4% use taxis daily, and 11% weekly and 50% are occasional users.
Figure 10 Wheelchair Users Frequency of Taxi Use (N = 341)
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4.5.2 Difficulties Experienced
Wheelchair users were asked about various difficulties with taxi use. Figure 11 shows the wheelchair users experience of drivers failing to stop for them. Very few are always ignored, but almost a third of wheelchair users reported drivers frequently or occasionally failing to stop.
Figure 12 shows the users experience of drivers refusing to take them. Again very few are always refused but a third of users frequently or occasionally are refused.
Driver Failed to Stop
Always 0%
Frequently 8%
occasionally 22%
never 70%
Figure 11 Frequency of Drivers Failing to Stop (N = 207)
Driver Refused to Take Me
Always Frequently 2% 7%
occasionally 27%
never 64%
Figure 12 Frequency of Drivers Refusing to Take a Wheelchair (N = 205)
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Figure 13 shows the reasons stated for drivers refusing to take the wheelchair users. Almost half reported that the drivers gave no reason / ignored them. Other common reasons were that they; refused to get the ramp out; stated that they didn’t have the ramp; stated that they don’t take wheelchairs, and; stated that it was too much trouble / time involved.
Breakdown of Driver Refusals
Driver refused to get ramp out 13% Driver Attitude - No Reason Given "too much trouble" 27% 9%
"because of the wheel chair" 13% Driver Refusal 16% Driver Drove off / time User Ignored 6% 16%
Figure 13 Wheelchair Users Reasons for Drivers Refusals (N = 74)
Figure 14 shows the breakdown of wheelchair users’ responses regarding frequency at which they are unable to get into a taxi. Over half of respondents have never been unable to get into the taxi. Very few respondents always have difficulties getting to the taxi. But almost half of respondents frequently or occasionally are unable to get into the vehicle.
Unable to Get Into Vehicle
Always 2% Frequently 20%
never 53%
occasionally 25%
Figure 14 Frequency of Users Being Unable to Access Taxi (N = 183)
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Figure 15 presents the reasons stated for not being able to get into the taxi. One third stated that the vehicle provided was inappropriate (eg: not the vehicle type requested) and one third that the problems related to the ramp. Lack of assistance and the driver not physically able to assist were also significant issues.
Reasons Users were unable to get into Vehicles
Other Health Reasons 6% 7% Ramp Issues 34%
Driver failings 21%
Inappropriate Vehicle 32%
Figure 15 Breakdown of Reasons for Users Unable to Access Taxi (N = 68)
Figure 16 shows users experiences of their wheelchair not being positioned correctly within the taxi. Although over half are always turned within the taxi, almost half have experienced not being turned. A significant proportion of wheelchair users are always and frequently positioned incorrectly.
Wheelchair Not Positioned Correctly
Always 14%
Frequently 14%
never 53%
occasionally 19%
Figure 16 Frequency of Not Being Positioned Correctly (N = 170)
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Figure 17 shows the reasons stated by wheelchair users for their wheelchair not being positioned correctly. A significant 42% of respondents stated that they could not be turned due to lack of space in the vehicle. However, the majority stated that they are not positioned correctly due to driver behaviour and vehicle condition issues (eg: missing ramps and restraint belts).
Figure 17 Reasons for Not Being Positioned Correctly (N = 50)
Figure 18 shows the users responses regarding incidences of their wheelchair not being secured properly within the taxi. A third of users are always or frequently secured. However, two thirds are never or frequently not secured properly.
Wheelchair Not Secured
Always 15%
never Frequently 49% 18%
occasionally 18%
Figure 18 Frequency of Wheelchairs Not Being Secured (N = 175)
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Figure 19 shows the stated reasons for the wheelchair not being secured properly. Ten percent of responses stated “insufficient space”. The majority of responses related to driver attitude including that restraints are not required or that they do not know how to use them. A significant number also stated problems with the wheelchair restraints. Mostly that the equipment is missing.
Reason Not Secured Properly
Unclear response Restraint 10% issues 22% Insufficient Space 10%
Driver attitude 58%
Figure 19 Reasons for Wheelchairs Not Being Secured (N = 69)
Wheelchair Users were requested to state which taxi types they could access. The responses were; • 129 stated only the LTC/LTI TX taxis; • 8 stated only the Mercedes Vito One80 taxi; • 3 stated only the Metrocab; • 8 stated only other taxi; • 4 stated no taxis; • 12 stated the LTC/LTI TX and Mercedes Vito One80 taxis; • 23 stated the LTC/LTI TX and Metrocab taxis; • 3 stated the LTC/LTI TX and other taxis; • 14 stated the LTC/LTI TX, Mercedes Vito One80 and Metrocab; • 1 stated the LTC/LTI TX, Metrocab and other taxis, and; • 4 stated all types and other.
Conclusions are that the majority can access the LTC/LTI TX (traditional ‘black cab’), Only 24 out of the 214 respondents to this question stated that they could not access that vehicle (11%). Only eight stated that they can only access another type (not licensed) and a further four stated none. Users were then asked which taxis they found easiest to access. The responses were; • 120 stated the LTC/LTI TX taxis only; • 17 stated the Mercedes Vito One80 only; • 4 stated the Metrocab only; • 8 stated other taxi only; • 7 stated no taxis;
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• 6 stated the LTC/LTI TX and Mercedes Vito One80 taxis; • 13 stated the LTC/LTI TX and Metrocab taxis; • 1 stated the LTC/LTI TX and Other taxis; • 1 stated the Mercedes Vito One80 and other taxis; • 3 stated the LTC/LTI TX, Mercedes Vito One80 and Metrocab; • 1 stated the LTC/LTI TX, Metrocab and other taxis, and; • 1 stated all types and other taxis.
The majority find the LTC/LTI TX vehicles the easiest to access or the LTC/LTI TX plus another vehicle currently licensed. Only eight stated only another vehicle (not currently licensed) and only seven stated no vehicles are easy to access. The other taxis that were easier to access identified by the users were;
• 5 stated Black Cab (LTC/LTI TX2 and TX4); • 3 stated Mercedes Vito One80; • 3 stated Saloon car; • 4 stated Peugeot (inc E7); • 2 stated Citroen Dispatch; • 2 stated Fiat (Scudo and Doblo); • 1 stated Renault; • 1 stated Ring and Ride; • 1 stated taxis that take scooters.
The first three stated vehicle types (LTC/LTI TX2 and TX4, Mercedes Vito One80 and saloon cars) plus Ring and Ride are already available in Coventry, by pre- booking in the case of the saloon car and Ring and Ride. Only nine people stated vehicles not currently licensed in Coventry.
The reasons for the other vehicles being easier to access were;
• 5 stated easier access, ramp, wider doors; • 3 stated better interior space; • 1 stated better headroom; • 1 stated better secured; • 1 stated lift access11.
Respondents were asked to suggest improvements to taxis in Coventry. The suggestions were mainly related to driver attitude / assistance and vehicle and equipment maintenance. Significant numbers also requested more and larger vehicles and better ramps / easier access;
• 36 stated improved driver attitude / training; • 12 stated better driver assistance; • 20 insisted on being restrained; • 13 suggested better checks on drivers and vehicles and fines / licence removal; • 6 complained about long routes being taken and time keeping; • 2 suggested lower fares; • 4 praised specific companies; • 3 praised / requested retaining black cabs; • 1 praised the Mercedes Vito One80;
11 Not relevant to taxi use.
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• 26 requested more, larger, vehicles; • 6 requested better ramps and easier access.
Other suggestions fell into two categories;
• Improvements to the existing system, such as; • better information; • more access points (ranks) around the City Centre, and; • more Ring and Ride.
• Vehicle improvements, such as; • more / better grips; • taller windows; • higher roof; • ground support for the rear wheel of the chair; • anti-slip ramps; • automated ramp systems; • hydraulic lowering system, and; • taxis with rear access.
4.6 Analysis of Users Wheelchair Sizes
An analysis of Coventry wheelchair users’ actual wheelchair sizes compared to taxi dimensions was undertaken in two parts (a) analysis of survey respondents’ wheelchair dimensions and (b) analysis of the Coventry Wheelchair Service database of wheelchair types.
4.6.1 Survey Respondents
Within the market research wheelchair users were asked to provide dimensions of their wheelchairs. In total 88 respondents responded with data which has been analysed in relation to the reference wheelchair specification and existing vehicle dimensions.
Figure 20 shows the widths of users’ wheelchairs against the standard width and LTC/LTI TX4 and Mercedes Vito One80 doorway widths. Whilst a few wheelchairs are wider than the specified standard, they are all narrower than the existing taxi doorway widths for both the LTC/LTI TX4 and Mercedes Vito One80 vehicles.
Figure 21 shows the height of the wheelchair users in relation to the height of the doorways of the LTC/LTI TX4 (and Standard Height) and Mercedes Vito One80 vehicles. The height of the majority of users (80%) is within the doorway height of the LTC/ LTI TX4. However, 20% of users need to lower their heads to enter the vehicles. This may be difficult for some people. However, it should also be noted that the alternative vehicles have less doorway headroom and headroom within the taxi as they have higher floor levels (see Table 2-A).
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110 Users Chair Width
Width Standard
100 LTC TX4 Width Mercedes Vito Width
90
80
70
60 (cm) Width
50
40
30 1 7 13 19 25 31 37 43 49 55 61 67 73 79 85
Figure 20 Width of Users Wheelchairs vs Standard/Existing Door Widths
180 Wheelchair Users Height Standard / LTC TX4 Height 160 Mercedes Vito Height
140
120
100
(cm) Height
80
60
40 1 7 13 19 25 31 37 43 49 55 61 67 73 79
Figure 21 Height of Users Wheelchairs vs Standard/Existing Door Heights
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Figure 22 shows the length of the users wheelchairs against the specified standard. 84% of users are within the standard and therefore would be expected to be able to be turned within the existing taxis. 16% of wheelchair users may not be able to be turned and secured properly.
180 Users length Standard Length 160
140
120
100
Length (cm) 80
60
40
20 1 6 11 16 21 26 31 36 41 46 51 56 61 66 71 76 81
Figure 22 Length of Users Wheelchairs vs Length Standard
The internal dimensions the existing and alternative taxis was shown in Table 2-A. The Mercedes Vito One80 is slightly larger than the LTC/LTI TX 4 and has a relatively large internal area compared with other existing and alternative taxis, especially the Peugeot E7. Of the 88 responses six wheelchair users may have wheelchairs too long for the existing fleet and reliant on other options, such as Ring and Ride.
4.6.2 Analysis of Coventry Wheelchair Service Database
Coventry Wheelchair Service provided the numbers of each type of wheelchair in their database. This was analysed using the users’ responses on actual sizes of occupied wheelchairs, where available, supported by published dimensions. Table 4-A shows the numbers of each type of wheelchair for manual and powered chairs.
92% of people have manual wheelchairs and 78% of all users have standard manual wheelchairs. There are over 50 different types of manual wheelchairs but the majority are a standard type provided by Remploy, Invacare and Lomax12. The top 5 types cover 95% of manual wheelchairs. In terms of powered chairs there are around 28 types but there is a wider spread of ownership. A quarter of users have the most popular model.
12 Types 8L, 8BL, 8BLRWSB, 8LHD, 8LQRW, 8LRWSB, 8LC, 8LJ, 8LJQRW, 8LJRWSB, 9L, 9LHD, 9LJ, 9LRWSB
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Wheelchair Type Number % Wheelchair Type Number % Manual Wheelchairs Powered Wheelchairs Standard 3,408 85% Apollo EPIC 82 25% Action 176 4% Harrier EPIOC 65 19% Blade 124 3% Pheonix 45 13% Rea 74 2% Spectra EPIOC 42 13% Zipper 41 1% Salsa MWD 19 6% Other 39 1% Spectra XTR 15 4% Quickie 35 1% Badger Highway EPIOC 8 2% Barrett 33 1% Sunrise Medical 8 2% Neo TIS 24 1% Salsa - EPIOC 7 2% Karma 11 1% Lomax Powermax EPIOC 6 2% Fortuna Extra Heavy 8 - Apollo Jnr EPIC 5 1% Shadow TIS 7 - Mid Wheel Badger 5 1% Greencare DB1 6 - Invacare Mirage EPIOC 4 1% Lomax Active 6 - Badger EPIC 3 1% Meteor 5 - Travvla EPIOC 3 1% Lomax Buddy 4 - Other 2 1% Lomax SA8 4 - Newton Royale EPIOC 2 1% Discovery Ottoboc 3 - Samba Sunrise Medical 2 1% Mojo TIS 3 - TDX Invacare 2 1% Hanivip Tilt 2 - Vitesse 2 1% Imperial 2 - Barrett Jewel EPIC 1 - Karma Recliner 2 - Ottoboc B400 1 - Remploy Aurora 2 - Days Medical MWD 1 - Remploy Roller 2 - Kidpower Jnr 1 - Gillingham Tilt 1 - Pronto MWD EPIC 1 - Sunrise Zippiets TIS 1 - Sunrise Tango 1 - Viper days 1 - Total 4023 Total 334
Table 4-A Wheelchairs in Use; Source - Coventry Wheelchair Service
Tables 4-B and 4-C show analysis of the sizes of the occupied wheelchairs for the main types of manual and powered wheelchairs, using the measures from the wheelchair users survey where available. In some cases there was a lack of user data – particularly important for interpretation of height issues. The seat height of the wheelchairs was secured from published data and a range of seat heights shown based on a typical average and top 5% sitting height. The analysis shows that;
• All wheelchairs assessed are narrower than the doors of the taxi fleet;
• Manual wheelchairs tend to have a lower seat height and therefore it is more likely that they can enter vehicles relatively easily;
• The ability for tall wheelchair users to enter taxis easily depends on the individuals’ ability to lower their head. Some users may have difficulties accessing taxis due to restricted door heights;
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• It is more likely that wheelchairs users with powered chairs will have difficulties with the door height including several survey respondents;
• Powered wheelchairs are more likely to require longer spaces for users to turn and position themselves. The range of powered wheelchair lengths tends to be higher than for manual chairs and more likely to be at, or above, the reference wheelchair standard, and;
• The majority of manual wheelchair users would be expected to be able to be turned relatively easily inside all taxis.
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Wheelchair Type % Length Range Width Range Height Range Seat Height Seat Height + Seat Height + (cm) (cm) (cm) (cm) 85cm* 95cm*
Standard Type 85% 92 – 110 60 – 66 94 – 140 Action 4% 107 – 113 70 – 70 97 – 127 46 131 141 Blade 3% 89 – 105 38 – 66 94 – 137 46 – 52 137 147 Rea 2% 90 60 135 Zipper 1% 104 – 133 48 – 60 45 130 140 Quickie 1% 80 – 107 70 - 76 97 - 145 52 137 147 Barrett 1% 109 59 - 64 88 46 131 141 Neo TIS 1% 76 - 174 61 - 64 145 Karma 1% 93 56 - 61 46 131 141 Total 99%
Table 4-B Analysis of Dimensions of Coventry Manual Wheelchairs (from Coventry Wheelchair Service Database)
Wheelchair Type % Length Range Width Range Height Range Seat Height Seat Height + Seat Height + (cm) (cm) (cm) (cm) 85cm* 95cm*
Apollo 25% 102 – 120# 58 – 72 43 128 138 Harrier 19% 106 55 – 63 92 – 105 50 135 145 Pheonix 13% 104 – 114 41 – 64 127 – 127 Spectra 13% 100 – 120 51 – 60 89 – 135 57 142 152 Salsa MWD 8% 105 – 125 60 – 64 135 – 145 47 132 142 Spectra XTR 4% 110 – 121 51 – 62 117 - 145 58 143 153 Sunrise 2% 107 59 - 65 49 134 144 Salsa 2% 114 59 - 65 49 134 144 Sum 86%
Table 4-C Analysis of Dimensions of Coventry Powered Wheelchairs (from Coventry Wheelchair Service Database) # from recommended space requirements for Standard (8L) wheelchair specified in Department of Health, Health Building Note 00-04, Circulation and Communication Spaces. *seat height + 85cm represents user around 5’8” and Seat height + 95cm represents user around 6’.
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4.7 Conclusions
Conclusions have been drawn in relation to two key issues; access to taxis, and; positioning of wheelchairs within taxis.
There was consistency in the reporting of refusal of wheelchair users by taxis from the taxi drivers and passengers. 6% of drivers often refuse wheelchairs and 38% of drivers sometimes refuse wheelchairs. This compares with users reporting that 8% of taxis frequently fail to stop and 22% occasionally fail to stop, also, the users reporting that 7% of taxis often refuse to take them and that 27% occasionally refuse to take them.
Analysis of the reasons stated by drivers for refusing wheelchairs suggests that the wheelchair types and sizes are the key issues. Drivers noted a particular issue with powered wheelchairs and the analysis of the dimensions of the wheelchairs in use in Coventry revealed that powered chairs were most likely to have problems due to height and length. This suggests that increasing the fleet range to include larger vehicles might help to increase wheelchair access, however, the alternative taxis are not higher than the existing vehicles, therefore it cannot be concluded that increasing the fleet will resolve the problem of users being refused to be carried.
Wheelchair users reported that driver behaviour was the main reason for being refused to be carried, 13% stated that the refusal was due to the wheelchair size. They also reported that inability to access the vehicle was due to the wrong vehicle being sent or driver behaviour / vehicle maintenance issues (eg: lack of ramps). Increasing the proportion of Mercedes Vito One80 vehicles within the existing fleet would increase the likelihood that a user could access their preferred vehicle.
There was also consistency in the reporting of problems related to the position of wheelchairs and securing them within the taxi. Drivers reported that 25% of passengers often / sometimes complain about the position of their wheelchair in the taxi, which compares with 28% of users stating that they were never or frequently not positioned correctly and 33% stating that they were never or frequently not secured properly. 42% of users were not positioned correctly due to insufficient space (though the majority of reasons relate to driver behaviour and vehicle maintenance issues). In addition, 10% of users also stated insufficient space as the reason for not being secured properly. The Mercedes Vito One80 has a larger internal space than the LTC/LTI TX4 so increasing the proportion of Mercedes Vito One80 vehicles in the existing fleet would improve the ability for users to secure a taxi in which they can be positioned and secured appropriately. Increasing the range of vehicles in the fleet would introduce the option of travelling facing forward.
The majority of wheelchair users in Coventry have the standard manual chair and are likely to have few difficulties accessing taxis, unless they are particularly tall and have difficulty lowering their head. From the user results it is estimated that 20% of users may need to lower their head to enter vehicles. However, the doorway headroom of alternative vehicles is not higher than the existing fleet.
It is estimated that around 16% of wheelchair users have a long wheelchair which may not be able to be turned within the taxi. They are more likely to be users of powered wheelchairs.
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5 Vehicle Testing Research
5.1 Introduction and Objectives
The DfT previously advised that they would undertake research into wheelchair accessible vehicles. However, they have since requested local authorities to determine the specification of acceptable taxis locally. The objective was to physically test a range of taxis to establish the differences for a range of Coventry wheelchair users.
5.2 Approach
A vehicle testing day was organised to invite Coventry wheelchair users to test accessing a range of taxis, both currently licensed and others. The event was undertaken on 22nd May 2013 and six wheelchair users tested the following vehicle types:
- LTC/LTI TX4. - Mercedes M813. - Peugeot E7. - Renault Voyager NX8.
It had been hoped to also test a Citroen Voyager LC7 and a Nissan NV200. The supplier of the Citroen had a problem with the vehicle on the day. The Nissan is still under development and was not available.
Table 5-A shows the number of passengers that can be carried in each vehicle with a wheelchair passenger,
Vehicle Wheelchair Position and Number of Additional Passengers LTC/LTI TX4 Wheelchair faces back, seats for 1 forward and 1 back alongside = 2 other passengers. Mercedes M8 Front or Rear facing wheelchair (optional) if small chair can have 4 seats in back, Large chair restricts to 1 forward a 1 back alongside = 2 to 4 other passengers. Peugeot E7 Wheelchair faces forward, seats for 1 forward and 1 back alongside = 2 other passengers. Renault Voyager NX8 Wheelchair faces forward, seats for 1 forward and 1 back alongside = 2 other passengers. Table 5-A Space for Passengers as well as Wheelchair by Vehicle
Within the wheelchair users survey sent out to over 4,300 people respondents were asked to volunteer for the wheelchair testing event and supply dimensions of their wheelchairs. Thirty three responded with dimensions and the top 12 largest (tallest, widest, longest) wheelchairs were selected. Of those six users were able to attend the event.
13 The same vehicle as the Mercedes Vito One80 but without the rear wheel steer.
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5.3 Findings
Table 5-B summarises the vehicles accessed by each user, their wheelchair type and dimensions of the chair / user. Three users with manual wheelchairs were able to access all vehicles. Two users with electric chairs were unable to access any vehicles. For one the problems related to the ramp angles and the centre drive wheels. The ramp angles of the LTC/LTI TX4 and Mercedes Vito One80 are lower than for alternative models (see Table 2-A). For the other the problems related to the height of the recliner chair and inability of the user to duck his head. User F arrived towards the end of the event and only tested one vehicle.
User A User B User C User D User E User F Enigma Quickie Manual Shoprider Spectra Invacare Manual XTR Chair Powered XTR2 Recliner Chair Manual Powered Manual Wheelchair Length 81 80 95 107 110 127 (cm) Wheelchair Width (cm) 73 70 56 71 62 70 Occupied Wheelchair 110 145 135 142 145 135 Height (cm) Vehicle LTC/LTI TX4 3 3 3 2 2 - Mercedes M8 3 3 3 2 2 - Peugeot E7 3 3 3 2 2 - Renault Voyager NX8 3 3 3 2 2 3
Table 5-B Vehicles Tested by Wheelchair Users Detailed user comments on each of the vehicles are provided in Appendix F. Table 5-C summarises the observed good and bad points associated with each vehicle.
Vehicle Positive Aspects Negative Aspects LTC/LTI TX4 Headroom Difficult to turn within vehicle Quick / easy access Good use of compact space Short / two part ramp / low floor Low ramp angle Grab handle on open door to aid entry
Mercedes M8 Ramp ‘lips’ Poor Headroom Sufficient space to turn within vehicle Ramp too narrow Ramp too steep Lack of grab handle to aid access (Sliding door) Seat belt strap not ratcheted
Peugeot E7 Integral Ramp – quick assembly Poor Headroom Wide access Ramp too steep Ability to facing forward inside vehicle Lack of grab handle to aid access (Sliding door) Complex restraint system
Renault Wide door Poor Headroom Voyager NX8 Good Headroom Ramp too steep Forward facing Lack of grab handle to aid access Space to turn within vehicle (Sliding door) Well secured Time taken to arrange seats and secure wheelchair Table 5-C Summary of Wheelchair Users Comments
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5.4 Conclusions
The traditional LTC/LTI TX4 taxi fails to satisfy users only on the ability to turn within the vehicle. There was no observed ‘access’ issue between the vehicles, specifically no conclusion could be drawn that more wheelchairs could get into the alternative vehicles. The higher headroom of the LTC TX and lower ramp angle are particular advantages. The ramp angles of the vehicles are shown in the photographs below.
LTC/LTI TX4 with step/ramp extension attached, angle = 19o
Peugeot E7, angle = 23o
Mercedes M8, angle with extension = 14 o
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Renault NX8, angle 20o
However, for users who are relatively large and / or have large wheelchairs, the inability to turn the chair within the LTC/LTI TX4 vehicle prevents the wheelchair being secured properly.
It is also noted that the traditional ‘black cab’ is very well liked with wheelchair users, most users concluding that they preferred it overall or equally as good as the newer models.
The van based models have the advantage of greater space within the vehicle to turn the wheelchairs and the options of facing forwards as well as backwards in some models. However, the users were generally concerned about poor headroom and steep ramps and the time taken to set up the ramps and to secure the wheelchairs. They were concerned that drivers would lose the belts and fixing equipment and might not be bothered to secure them.
The presence of the Mercedes Vito One80 option within the fleet provides an option for large wheelchairs / users to specify a vehicle type that they are more likely to be able to turn within and be properly secured.
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6 Turning Circle Research
6.1 Introduction and Objectives
The London Conditions of Fitness include a requirement for taxis to have a turning circle of 25ft to maximise efficiency for the taxis and passengers by being able to make smooth u - turns off ranks and in the street, rather than extending journeys or undertaking three point turns. The importance of this aspect of taxi policy was investigated through the assessment of Coventry’s ranks and streets.
6.2 Approach
AutoCAD mapping techniques with ordnance survey data were used to test the turning circle issue. The ‘25ft’ rule was interpreted as an allowance of 28ft to provide a clear full unobstructed turning circle for existing taxis, and the Peugeot E7 used as an example of a taxi which does not comply with the ‘25ft’ rule.
The assessment covered all of the taxi ranks and a selection of other key locations in Coventry where people are more likely to hail a taxi including near shops, commercial, educational & industrial premises. The analysis included Coventry City Centre streets and radial routes into the City where people would expect to have a good chance of hailing a taxi returning to the City Centre. The analysis was undertaken in February 2013.
6.3 Research Findings
6.3.1 Taxi ranks
Each rank was examined and tested to establish whether it was practical to turn the vehicles round and access / exit the rank without the need for a three point turn. In some locations the rank is in a one-way street or street with a central reservation making turns impractical. As a result there was no identified issue at; Trinity Street; Lamb Street; Upper Well Street; Queen Victoria Road; Greyfriars Road; Croft Road; Jubilee Crescent; Walsgrave Hospital; Burges East; Bus Station; Greyfriars Lane, and; Hales Street.
At other rank locations the area for turning was sufficient for both types of vehicle or too narrow for either vehicle to turn. These locations are; New Union Street; Earl Street / Jordan Well; Upper Well Street; Earlsdon Street NW and SW; Jardine Crescent; Tesco Arena; Warwick University; Hay Lane; IKEA; Silver Street, and; West Orchards Access Road ranks.
At Coventry Station rank the taxis movement from the feeder ranks to the double rank between the concourse building and short stay car park involves relatively tight turns. However, Autotrack analysis revealed that it is currently not practical for two taxis to make the move onto the double rank at the same time. Also, that there is no significant advantage of having the ‘25ft’ turning capability. Relatively simple redesign of the kerbs would enable non ‘25ft’ turning capability taxis to utilise the rank, which would constitute reasonable adjustment.
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The capacity of the station rank could be impacted by the length of the vehicles and have an impact on passenger waiting times. The LTC/ LTI TX2 and TX4 taxis are 4,575mm and 4,580mm long respectively. The Peugeot E7 is 4,806mm long but the Mercedes Benz Vito One80 (which is already licenced) is 4,763mm long. The rank can hold five LTC/LTI TX2/4 taxis but would be unlikely to be able to accommodate five of the longer vehicles. The difference between 8 and 10 taxis available for boarding at the same time is not considered a significant issue as there is nearly always a large number of taxis immediately available to replenish the rank.
Table 6-A presents ten rank locations there was a significant issue for taxis without the ‘25ft’ turning capability. At these locations assessment was undertaken of the implications of the difference in terms of;
(a) Safety Impact - such as reversing in a busy pedestrian environment;
(b) Traffic Impact - where there are significant volumes of traffic which might be delayed by taxi manoeuvres, and;
(c) Passenger Impact where taxis might make a significantly long detour adding distance, time and cost to the passenger journey.
Account was taken of the likelihood that passengers might require the taxis to turn for their journey. This involved assessment of the transport network and the journey / route opportunities from each location. For each location a summary of the issue is noted and conclusions regarding the impact of non ‘25ft’ turning capability taxis are presented as Red, Amber and Green, where; red indicates a substantial concern; amber indicates a significant concern, and; green indicates no-significant concern.
Location Issue / Comments Impact if Larger Wheel Base Taxi Rank Safety Transport Passenger Locations Bishop Street Existing taxis can make a u-turn by using the taxi rank lay-by. A A A Fairfax Street Existing taxis can make a u-turn by A A G using the taxi rank lay-by. Hales Street Existing taxis can make a u-turn by (opp. Fire using the Coach lay-by (when empty). A A G Station) Riley Square In the vicinity of the rank only the LTC G A A vehicles could make a u-turn Cox Street In the vicinity of the rank and between A G G Lower Ford St & Fairfax St Ford Street Dead end road also providing access to G G G a car park. Lower Dead end with turning head for u-turn G G G Holyhead Road from rank to junction with Spon Street Spon Street Pedestrianised street also providing West access to service road. Only ‘25ft’ taxi R G G can turn at the head of the road. Spon St East / Narrow street but taxis can turn in G G G Fleet St bellmouth of Lower Holyhead Road. Rover Road Taxi’s need to undertake tight u-turn to access the rank or turn in yard behind R G G the market with pedestrian route. Warwick Row Taxis can turn around in between (opposite the parking bays after the central A A A Church) reservation Table 6-A Taxi Rank Location Analysis.
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Within the City Centre (the area enclosed by the Ring Road) existing taxis can easily undertake a full U-turn within one manoeuvre out of the ranks at Bishop Street, Fairfax Street, Hale St (opposite the old Fire Station), Warwick Row and Cox Street. These areas have commercial and night-life activities and are within the new 20mph & restricted parking zone. Taxis without the ‘25ft’ turn capability would have to make a multi-point turn which will have greater safety concerns and an impact on traffic flows including access to commercial premises.
More detailed assessment of the issues and options at Rover Road and Spon Street, where the substantial safety concerns arise, has been undertaken.
(a) Rover Road
At Rover Road the rank is marked for two taxis but can accommodate three taxis. Taxis with ‘25ft’ turning capability can turn in the road space east of the rank to access the rank. However, there are usually more than three taxis on the rank and parked cars on the road opposite the rank (as shown in Figure 23), preventing the taxi’s from turning in Rover Road.
Figure 23 Rover Road Rank
Instead the taxis continue past the rank into the service yard behind the market and turn and queue in the service yard. Through this service yard there are high volume pedestrian movements between Shelton Square and the indoor market and also to Rover Road. There are often other vehicles in the yard including occupied disabled parking spaces. As a result there is limited space for taxis to turn. This rank is also already over ranked due to the demands created by commercial premises including IKEA and Iceland as well as Shelton Square and the market. Taxis without ‘25ft’ turning capability are likely to experience greater difficulty turning without the need for reversing, which is expected to heighten road safety risks. Reversing movements could greatly increase the risk of pedestrian casualties.
Figure 24 Rover Road Turning Area to Access Taxi Rank
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The Coventry Taxi Rank Review and Survey Study (Nov 2011) provides details of taxi rank use. Rank surveys were undertaken between 14th September and 7th October 2011 and recorded the number of vehicles parked and passengers waiting in five minute intervals during the time periods 0700 – 1000, 1000 – 1300, 1300 – 1600, 1600 – 1900, 1900 – 2300. Data from CCTV cameras was used for counts at midnight and 0130 – 0300, including Spon Street. Rover Road (near Iceland) was surveyed in the Unmet Demand Study in May 2011. That data was collected in 5 minute intervals and was converted to the spot survey methodology used for the other locations.
At Rover Road the taxi rank is operational between 10am and 7pm. Rank observations on a Tuesday were:
- 10:00 – 13:00 = 8 taxis; - 13:00 – 16:00 = 8 taxis, and; - 16:00 – 19:00 = 8 taxis.
These figures are considered to be an underestimate due to the observed queues of taxis feeding the rank from the service yard. Rover road is too narrow for taxis without the ‘25ft’ turning capability to feed the rank and there is significant pedestrian traffic, making narrowing the footpath impractical. Pedestrians were observed walking down the roadway, so reversing movements are considered to increase the risk of pedestrian casualties. It would be impractical to redesign / reorganise the yard behind the markets due to physical constraints and other activities undertaken in the service area, including loading/unloading to shops. Severing the pedestrian link between the Shelton Square and market would adversely impact on pedestrian connectivity in the central area of Coventry.
Rover Road Rank
Yard where
taxis turn and
feed the rank
I
The over-ranking issue could be mitigated through monitoring and enforcement to allow taxis without the ‘25ft’ turning capability to access the feeder rank by turning in the corner of the service yard (see Figure 25). That would ensure taxis turn outside the marked pedestrian route. However, this would have significant staffing and financial implications.
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Figure 25 Rover Road Taxi Turning Analysis
It might also be possible to relocate the rank onto Corporation Street outside Iceland on the southbound carriageway. This was suggested in the 2011 Coventry Taxi Rank Review Study in consultation with the Parking Services manager. However, the issue would be controlling over-ranking back in Rover Road or Croft Road (opposite) where there is a layby for electric vehicle charging. Measures would need to be put in place to deter over-ranking, ie: additional traffic regulation orders (TROs) and/or on-street parking provision in Rover Road with appropriate enforcement. Any remediation would require further detailed consultation with the taxi trade.
Figure 26 Victoria Street Possible Rank and Croft Road
(b) Spon Street (West)
Spon Street has a shared surface environment where the road is indicated by block pavers and the path area demarcated with slabs. Kerbs are flush with the carriageway. The taxi rank is on the eastbound side halfway down the street. The street is narrow with a turning facility at the western end, as indicated in Figure 27. There is also a pedestrian corridor linking the ring road underpass and leisure area across the west end of the street, where the taxis have to turn. Taxis must have ‘25ft’ turn capability to avoid reversing. Taxis without the ‘25ft’ turn capability would have to undertake a multi-point turn to access the rank. Reversing movements in a pedestrian area like Spon Street, with significant evening and night-time activity, represent a substantial road safety concern.
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Figure 27 Assessment of Spon Street Taxi Turning Areas
The main demand for taxis in this area is during late evenings / night time. The rank is operational between 10pm and 5am and has six spaces. The overnight CCTV camera data recorded taxi activity levels as;
- Midnight = 7 taxis; - 01:30 = 9 taxis, and; - 03:00 = 6 taxis.
In the 2011 Taxi Rank Review Study unofficial ranking was observed outside Ignite (now Puregym) where a parking bay exists. This may be because the demand at night is from the commercial premises to the south and taxis gravitate towards the main sources of patronage.
Figure 28 Spon Street West Rank and Spon Street East / Fleet Street Rank
Figure 29 Spon Street Turning Area and Access to Ring Road Underpass
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Spon Street is narrow, with buildings fronting the pavement on either side, preventing reasonable adjustment at the rank location itself. Other roads in the vicinity of the rank are also narrow culs-de-sac and the ring road forms a physical barrier to the west. There are other taxi ranks operational in the evenings and overnight at Lower Holyhead Road to the east and Spon Street East / Fleet Street close to the junction with Victoria Street.
Spon Street
Taxis without the ‘25ft’ turning capability could use the one way system in Rudge Street / Croft Street (opposite the back of IKEA) a short walk from Spon Street and to the south of the entertainment area. The 2011 Taxi Rank Review Study identified that this area was already being used unofficially. The 2011 report also identified, alternatively, the taxi rank in the IKEA car park (between Croft Road and Spon Street) might be used. This approach was the preferred option of the Police due to some social disorder problems at night time in the area. Consideration was given to installing temporary barriers at weekends, closing the outside lane of Rudge Street / Croft Street, which would prevent its use as a taxi rank.
All taxis could use the Spon Street East / Fleet Street rank near to the junction with Queen Victoria Road. Taxis without the ‘25ft’ turning capability could turn in the bellmouth of Lower Holyhead Road to access that rank. This could be promoted as the alternative to Spon Street West (which could be closed) and requires an additional walk of 120 metres for passengers. This would encourage greater use of the Fleet Street rank and also the Lower Holyhead Road rank, which have otherwise been suggested for removal due to limited use in recent years. A key issues would be control of unofficial ranking at the west end of Spon Street which would require marshalling / enforcement activity should there be a lack of voluntary compliance.
Figure 30 Croft Road (possible rank location) and IKEA Existing Rank
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6.3.2 Coventry Streets Analysis
Table 6-B presents the results from analysis of available locations for a U-turn manoeuvres on the lengths of the road or, where indicated #, the sections of commercial / industrial frontage on key highways. Only those locations where there are significant issues related to taxis with and without the ‘25ft’ turn capability are presented.
The percentages of available street lengths where taxis with ‘25ft’ turn capability can turn in a smooth movement are shown against the percentage of the street length where non-‘25ft’ turn capability taxis could turn smoothly. The analysis was based on the kerb to kerb width of the streets and excluded signalised junctions where no taxis would be permitted to U-turn. An example section of street analysis is included in Appendix G. The table includes the conclusions of the impact of introducing taxis without the ‘25ft’ turning capability, which are presented as Red, Amber and Green, where; red indicates a substantial concern; amber indicates a significant concern, and; green indicates no-significant concern.
Roads / Streets Issue / Comments Impact of non ‘25ft’ turning capability taxis Safety Transport Passenger Earl St outside Between High Street and St Mary Council House Street only ‘25ft’ turning taxi can A A G turn Gosford Street Outside University, with the layby, outside Coventry only ‘25ft’ turning taxi can turn. A A G University Little Park Street Between New Union Street and Salt lane, only ‘25ft’ turning taxi can U- A A G turn without impact on buses. Foleshill Road ‘25ft’ turning taxis can U-turn along 75% of the street compared to 15% A A A of the street for non ‘25ft’ turn taxis. Stoney Stanton ‘25ft’ turning taxis can U-turn along Road 90% of the street using vacant A A A laybys. Non ‘25ft’ turning taxis can turn on 30% of the street. Radford Road ‘25ft’ turning taxis can U-turn along 33% of the street compared to 5% G A A of the street for non ‘25ft’ turn taxis. Holyhead Road ‘25ft’ turning taxis can U-turn along 75% of the street compared to 20% G A A of the street for non ‘25ft’ turn taxis. Earlsdon Avenue ‘25ft’ turning taxis can U-turn along South 100% of the street compared to G G A 35% of the street for non ‘25ft’ turn taxis. Walsgrave Rd/Ball ‘25ft’ turning taxis can U-turn at 90% Hill # of the commercial / industrial area A A A compared to 10% of the street for non ‘25ft’ turn taxis. Binley Road # ‘25ft’ turning taxis can U-turn at 80% of the commercial / industrial area A A A compared to 50% of the street for non ‘25ft’ turn taxis. Table 6-B Assessment of Non-Rank Locations and impact of Non ‘25ft’ Turn Taxi’s.
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Outside the City Centre there are two key areas which have a large commercial shopping community; Foleshill Road and Stoney Stanton Road. In these locations taxis with ‘25ft’ turn capability can undertake a full U-turn within one manoeuvre along 75% of Foleshill road and 90% of Stoney Stanton. Taxis without the ‘25ft’ turn capability can only perform a single U-turn on 20% of the Foleshill Road and 30% of Stoney Stanton Road.
In these streets and in short sections of Walsgrave Road at Ball Hill and on Binley Road, there is high pedestrian footfall. Taxis that don’t have the ‘25ft’ turn capability that need to U-turn must make a multi-point turn. This would significantly increase the likelihood of conflict / collision with pedestrians with potentially adverse consequences for road safety.
In addition, non ‘25ft’ turning taxis would be more likely to over-ride the footway to complete a quick U-turn. This increases the risks to pedestrians further and it has longer-term highway maintenance implications.
Ultimately, it will be the taxi drivers’ decision where it is safest to turn around and how best to achieve the manoeuvre, either a multi-point turn or driving to a location where a U-turn can be completed safely. A requirement to seek out U-turning opportunities can translate into additional time and money costs on passengers and inconvenience for other road traffic.
Reasonable mitigation for the safety risks could include working in partnership with the taxi association to reinforce ‘best practice’ to avoid reversing movements in areas of high pedestrian activity and overriding the kerb. If necessary the CCC could also ban U-turns on certain sections of the highway network. Other potential safety mitigations may include a requirement to fit audible reversing alarms to taxis and / or to marshal busy ranks, especially at evenings and night time.
6.4 Conclusions
Assessment of the requirement for a ‘25ft’ turning circle has identified a small number of taxi ranks where relaxation of the policy could have potentially adverse safety impacts on sections of key radial streets and/or commercial zones within Coventry. Two City Centre ranks are particularly affected by removal of the 25ft standard and may need to be relocated (Rover Road) or removed (Spon Street West) with consequent reduction in accessibility. Reasonable mitigation measures were considered possible to manage these safety implications, including enforcement and partnerships to share best practise and encourage good behaviour.
In particular, to relax the turning circle policy Coventry City Council would need to investigate changing two rank locations in the City Centre (Rover Road and Spon Street) to enable taxis without the ‘25ft’ turning capability to access the ranks and serve the demand areas.
The relaxation of the turning circle policy could have the following additional impacts;
- Increase the likelihood of taxis over-riding the footway to undertake a quick U-turn, with pedestrian safety risk and long term maintenance implications.
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- Impact on the free flow of traffic on key radial highways and City Centre streets which will delay other vehicles, particularly Foleshill Rd & Stoney Stanton Rd.
- Taxi passenger journeys may be lengthened and therefore cost more as a result of taxi’s travelling further to find locations to turn round.
It is recommended that, if the ‘25ft’ turning circle policy is relaxed, the Council seeks a partnership with the taxi trade to encourage best practise and work with traffic management and the Police to manage the changes required at Rover Road and Spon Street and other locations throughout the City.
It has been possible to identify a number of location-specific or fleet-wide management measures that can assist in adapting Coventry’s taxi provision to operate without the requirement for a ‘25ft’ turning circle. The costs of realising these – both capital and operational costs – would need to be considered alongside the other advantages of widening the choice of licensed taxis in Coventry – both for operators and the taxi users. Overall, it is probable that the costs of reasonable adaptations identified here are offset by wider advantages from relaxing the requirement for the ‘25ft’ turning circle.
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7 Consultation on Other Licensing Policy Issues
7.1 Introduction and Objectives
The City Council identified a number of other taxi and private hire policy areas for further research, stakeholder consultation and reporting. This involved updating research in some areas and preparing a document to accompany the trade questionnaire and analysing the responses to inform the direction the trade would prefer the policy to change.
7.2 Approach
Within the Taxi Trade survey the respondents were requested to comment on each of the policy issues. The summary of the policy issues is presented with the consultation results.
7.3 Results and Conclusions
7.3.1 Staff Training in PHV Booking Offices
Drivers first licensed from February 2003 should be knowledgeable in disability awareness by their attendance on the City Council's Driver Training Course. It is also important that staff working for operators taking bookings also understand the needs of disabled persons so that they can arrange an appropriate vehicle for those with a particular disability.
The Equality Act 2010 places a requirement on Operators as service providers to make reasonable adjustments in favour of disabled customers and the Council would like to strengthen this by requiring Operators to provide disability awareness training to booking office staff.
It is proposed that the conditions attached to a Private Hire Operator's licence be changed to require operators to provide disability awareness training for booking office staff.
84% of respondents agreed that the cost of disability training should be met by the operator.
Of the 22 respondents who disagreed, 19 gave the following reasons:
• 2 stated that they had already completed the course; • 5 stated that it was not relevant or not applicable; • 2 stated that they thought it should be funded by the Local Authority; • 1 stated that they though it should be free or low cost to the taxi drivers, and; • 2 stated that the problem is insufficient numbers of taxis.
There is substantial support for the proposed policy change.
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7.3.2 Frequency of Medical Examinations
The City Council’s current policy only requires a medical examination when a licence is first obtained and an annual examination for drivers over 60 years of age. Given that drivers in Coventry renew their licences annually, it is not considered that a medical is needed at each renewal, as suggested by the DfT. However, it is not considered appropriate for drivers to have no medical examination between obtaining a licence, potentially as young as 18, and reaching 60 years of age. Bus drivers are required to have a medical before obtaining a licence, then every five years after age 45 and every year from age 65.
A study of demographic data provided by the Office of National Statistics was undertaken to reveal evidence of death rates by age in England and Wales. The Table below shows that there is a significantly higher death rate for people aged 55 and over.
Death Rates in England and Wales in 2011 (Office of National Statistics) Age 35-44 45-54 55-64 65-74 Males (deaths per thousand) 1.5 3.1 7.9 19.8 Females (deaths per thousand) 0.9 2.1 5.2 12.9
Figure 31 shows the deaths by age group for the most common causes of sudden deaths - heart attacks and strokes. Those deaths begin to increase from about 45 years of age with a significantly higher likelihood occurring amongst those over 65 years of age.
20000 Ischaemic Heart Disease
15000 Cerebrovascular diseases
10000
Deaths 5000
0
1–4 5–9
10–14 15–19 20–24 25–29 30–34 35–39 40–44 45–49 50–54 55–59 60–64 65–69 70–74 75–79 80–84 85–89 90–94 95 and 95 Under 1 Age Group
Figure 31 Sudden Deaths by Age Group, 2011 (Source ONS)
Although there is a sharp increase in the risk of sudden deaths around 65 there are still some risks at lower age levels. It is therefore not considered appropriate for drivers to have no medical examination between obtaining a licence and 44 years of age as significant medical issues can still arise between age 18 and 44.
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In light of the above research it is not considered appropriate to retain the current policy where drivers have no medical examination between obtaining a licence and reaching 60 years of age. The demographic data, the DfT's recommendation and concern over driver's making declarations on medical conditions suggests a change to the current policy and the introduction of more frequent medicals is needed. In addition, to passenger safety, there will be benefits to drivers in having regular health checks which could provide early warnings of illnesses such as heart disease, aortic aneurysms and diabetes.
It should also be noted that the Group 2 examination now includes the C1 standard for insulin treated diabetes meaning that drivers with such a condition can continue to be licensed.
Stakeholders' views were requested on the following proposed policy changes: a) The retention of the current system where medicals are carried out by doctors on an approved list. This ensures that the doctors are experienced in such work, are kept up to date with changes/issues and are less likely to be influenced as may be the case if the medical is conducted by the person's own doctor. b) Requiring drivers to have a medical before the licence is first granted, then every 5 years until 45 years, and then every 3 years until 65 years, with an annual check required thereafter.
Respondents were evenly split in terms of support for this policy (49% yes and 51% no).
Of those that were against the reasons given were;
• 16 complained about the costs of the medicals; • 2 stated that death rates for under 45’s was low; • 3 considered the critical age was 55; • 7 considered the critical age was 60; • 7 considered the critical age was 65; • A question was asked as to how many passengers had been killed or injured by taxi drivers being ill at the wheel; • 12 considered that your own GP should assess your health, and; • It was suggested that the testing regime should be the same as for other driving jobs, such as PHV and bus drivers.
The taxi trade were split in terms of supporting this policy with most reasons relating to the suggested policy being too onerous and that there would be support to bring in line with the policy for bus drivers.
7.3.3 Stretched Limousines Policy
The DfT Best Practice Guidance recommends that licensing authorities do not refuse such vehicles as part of a blanket policy but that they be considered as PHVs provided they have Individual Vehicle Assessment (formerly Single Vehicle Approval) and that they do not have more than 8 passenger seats. The City Council have not licensed any in the past as they have not met their standards, particularly those prohibiting left hand drive vehicles, those requiring sufficient emergency exits in order to ensure safety and the requirement for vehicles to be as manufactured and not modified.
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Safety concerns could be addressed by the use of state of the art camera technology to improve forward visibility in left hand drive limousines, and by the installation of emergency exit windows in the rear of the vehicles where doors are not available. The fitting of forward facing cameras in the offside wing mirror and a monitor by the driver should make forward visibility when pulling out from on street parking spaces and overtaking comparable to that in a right hand drive vehicle. Research has indicated that the proposed use of cameras and monitors complies with the Construction and Use Regulations.
Having examined some of the standards set by licensing authorities that do accept stretched limousines, a set of special conditions has been drafted that could apply to these vehicles, details of which are shown in Appendix H.
Also, in light of a comment by the National Limousine and Chauffeur Association and the Vehicle and Operator Services Agency who recommend frequent testing of stretched limousines the requirement for them to be inspected before licensing and at four monthly intervals has been included in the draft conditions in Appendix H. Any costs for the testing and licensing of stretched limousines would need to be recovered via fees paid by the vehicle proprietor.
Stakeholders were requested to comment on the following options: a) Retain the existing City Council policy and not licensing stretched limousines unless they have right hand drive, meet the emergency exit requirements and have not been modified (in practice, as all stretched limousines are modified, this would mean not licensing them). b) License any stretched limousine provided it does not have more than 8 passenger seats (the legal maximum is 8 passengers for PHV licensing). c) License only those stretched limousines that have been fitted with a forward facing camera in the offside wing mirror plus monitor and emergency exit windows in the rear of the vehicle where doors are not available (i.e. meets the draft conditions in Appendix A).
The consultation responses were;
• 66% support for a) • 19% support for b) • 14% support for c)
The National Limousine and Chauffeur Association in general accepted the proposals in the consultation “as being good solid common sense” and “applaud the additional inspections on stretched limousines. Specific comments were;
- “Front facing cameras, we have looked at these in the past and find that they are not really helpful, and are more of a distraction. With the number of one way streets and multi lane roads, there is very little disadvantage (if any) in left hand drive vehicles. We generally suggest a spotter mirror on the offside of the vehicle as the problems come mainly from behind when changing lanes, and not from in front. Also, with a high limousine, such as a Ford Excursion or a Hummer, we recommend the use of a “Fresnel” lens on the offside front window.”
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- “Seat belts, when applying the Construction and Use Regulations there are no requirements for seat belts on side facing seats, indeed the jury is still out on whether the body should be restrained in a sideways motion as more injuries can be inflicted than prevented. PSV rules do not require side facing seat belts, only forward and rear facing seats. We would suggest that this should be considered.”
The Traffic Commissioner for Wales and for the West Midlands of England responded as follows;
- “It appears that the City Council has not licensed any stretched limousines in the past because the vehicles have not met its standards. This is part of the reason why the Law Commission is looking at reforming the law to take discretion away from local authorities and impose national standards in relation to specific vehicles.”
The Traffic Commissioner also provided comments on each of the options as follows;
- “Option A – Retain existing council policy… I recommend that the existing policy be amended as it is one that… means that no vehicles are licensed. It is impractical and unrealistic and has not prevented limousines operating in Coventry. The outcome has seen an illegal unlicensed limousine trade flourish and the failure of the City Council to introduce a proper policy has contributed to this state of affairs. I strongly urge that the existing policy be changed.”
- Option B – License … provided it does not have more than 8 passenger seats… The wording of this option implies that there are no standards imposed. It is arguable that the wording provides that if prohibitions would not be issued by VOSA or other regulatory authorities then it is acceptable for use as a private hire vehicle.”
- Option C – License … limousines that have been fitted with a forward facing camera… This is an option that is preferable to Option A. Ultimately, it is a matter for the City Council to consider whether option B or option C is to be preferred.”
- “A decision on whether to adopt option B or option C should include knowledge of the likely cost of adaptation. When introducing and regulation there should be knowledge as to the impact on those who are regulated. It is also accepted that road safety considerations must be taken into account and it is difficult to criticise any decision made that left hand drive vehicles have suitable equipment to ensure that the driver is not significantly disadvantaged by virtue of the placement of the steering wheel.”
- “Finally, I ask that whatever decision you adopt, option B or option C that you ensure that the new licensing regime is enforced. Failure to enforce would impact on creditability. It would also place compliant operators at a significant disadvantage. The fact that proper consideration is now being given to a sensible and logical limousine licensing policy is very much welcomed.”
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Whilst the taxi trade supported no change to the policy, it is suggested that, in the light of the traffic commissioners comments, that there is a need to introduce licencing of stretched limousines. It is suggested that the revised conditions in Appendix H (subject to an assessment of adaptation costs as highlighted by the Traffic Commissioner) could be imposed.
7.3.4 Tinted windows in private hire vehicles
For motor vehicles first used on or after 1 April 1985 the light transmitted through the windscreen must be at least 75% and the front side windows to either side of the driver's head must allow at least 70% of light to be transmitted through them.
Taxis licensed in Coventry are currently required to meet the Public Carriage Office London conditions of fitness for hackney carriage vehicles and this requires all windows to allow at least 75% of light to be transmitted through them. Applying this specification to PHVs creates problems as PHVs are standard production vehicles and many are manufactured with tinted windows as standard.
With regard to the effect on road safety of excessively tinted glass, the Vehicle and Operator Services Agency (VOSA), an executive agency of the Department for Transport, says 'It restricts the driver’s vision, especially in dark conditions. This may prevent drivers from seeing other road users or pedestrians. It also prevents other road users and pedestrians from confirming through eye contact that they have been seen'. Although VOSA was referring to the windscreen and the front side windows, it could be said that good all-round visibility is appropriate for all passenger carrying vehicles.
The Council is considering three alternative options for PHVs; a) Only apply the legal standard i.e. light transmitted through the windscreen must be at least 75% and light transmitted through the front side windows must be at least 70%. This appears to be that recommended by the DfT although the DfT's advice is imprecise. b) Apply the same standard as applied to taxis i.e. light transmitted through all windows must be at least 75%. c) Keep the currently applied compromise i.e. light transmitted through the windscreen must be at least 75% and light transmitted through the front side windows must be at least 70% (as required by law). With the addition that light transmitted through the main rear side windows must be at least 70%, light transmitted through the rear window/screen and any other windows (e.g. small quarter lights) must be at least 40%.
Stakeholders were requested to respond on the following options: a) Apply the legal standard of 75% light through the windscreen and 70% through the front side windows. b) Apply the same standard as taxis – 75% through all windows. c) Retain the current compromise of 75% through the windscreen, 70% through the front and rear side windows, and 40% through the rear and any other windows.
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The consultation responses were;
• 41% in favour of a)
• 32% in favour of b)
• 28% in favour of c)
The National Limousine and Chauffeur Association commented;
- “Front windscreen and driver’s compartment side windows, we suggest that they are left clear as they leave the factory as the driver needs every bit of visibility he or she can get. In the rear you may be limited to the degree of tinting that is applied at the factory, as it would be virtually impossible and prohibitively expensive to change.”
There is overall more support for Option A. However, this could result in the use of vehicles with limited side and rear visibility as private hire vehicles. Option B might be difficult to achieve in practice as many cars cannot meet this standard. It is therefore recommended to adopt policy Option C, retaining the current policy14. This was supported by around one third of the trade.
7.3.5 Criteria for Vehicle Inspections
The DfT recommend that licensing authorities apply the standard MOT test plus a check on the internal condition of the vehicle. The Coventry inspection includes an MOT test plus higher standards for vehicle safety together with an inspection of vehicle reliability, alterations, equipment, signs and internal and external condition.
The Public Authority Transport Network in conjunction with the Freight Transport Association has produced a recommended set of National Inspection Standards for taxis and PHVs. This has been examined by the City Council’s inspection staff and licensing & enforcement officers and modifications have been made in order to maintain Coventry's high standards including external condition. These standards have been set out in a Coventry Vehicle Inspection Manual which was launched in April 2012.
Stakeholders were requested for views on the Coventry Vehicle Inspection Manual. The following comments were made in relation to the Inspection Manual. Wider comments are summarised in Appendix I.
• 7 comments were made about the complexity of the inspection, and that it changes on a frequent basis;
• 23 comments were made relating to the severity of the test, and how a vehicle can be failed for minor faults (e.g. stone chips or minor dents in body work);
• 9 comments were made relating to the cost of the tests;
14 “Tinted windows. The windscreen must permit 75% light transmittance. The main front and rear side windows must permit at least 70% light transmittance. The rear window/screen, and any other window (e.g. small quarterlights) must permit at least 40% light transmittance.”
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• 3 comments agreed that the Vehicle Inspection Manual helps maintain safety standards;
• 1 driver suggested that a driver review of the manual would be useful prior to publication, and;
• 3 drivers thought the inspections are a waste of time.
7.3.6 Exemption for the displaying of licence plate and stickers on executive vehicles
Following the repeal of the contract exemption, vehicles and drivers who were not required to be licensed, if they had contracts lasting not less than seven days, are required to be licensed as private hire; this includes businesses that provide chauffeur services. Chauffeur businesses prefer not to display the licence plate and stickers on their vehicles and the City Council has a policy that allows an exemption for displaying the plate and stickers for executive work which is based on the vehicle type i.e. a recognised prestige/executive model or specification of model or a recognised vintage or classic model (e.g. Rolls Royce, Bentley, Jaguar, Daimler, Cadillac and certain models of BMW/Mercedes).
The City Council has been asked to exempt vehicles from displaying the plate and stickers which do not fall under the above specification (e.g. people carriers) but will be used exclusively for chauffeur/executive work. One option is to amend the current policy to allow an exception based on type of work undertaken as well as allowing an exception based on vehicle type. To ensure compliance the vehicle proprietor would need to satisfy officers that the policy is being adhered to by regularly submitting proof of the work undertaken.
Stakeholders were requested to respond on the proposed policy change to amend the current policy to allow an exception for displaying the plate and stickers on PHVs used exclusively for executive work based on type of work undertaken as well as allowing an exception based on vehicle type.
There was strong support for the change to the policy (82% yes and 18% no).
Those that disagreed provide the following comments;
• 6 drivers raised concerns about the risk of unlicensed vehicles posing as PHV. 2 of these drivers highlighted the increased risk to passengers from bogus/rogue drivers;
• 6 comments highlighted the fact that PHV should be identifiable to the public to show it was licensed, and;
• One largely illegible statement suggested limited use of stickers / plates (i.e. none on doors).
Regency Cars strongly support this policy as their “customers refused to use vehicles which display stickers. They require an executive chauffeur service, not a private hire service.” They and a number of other private hire operators requested relaxation of the restricted vehicle types.
There was strong support to change the policy as consulted on.
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7.3.7 Topographical Tests for Contract Drivers (Road Knowledge Test)
With the repeal of the contract exemption under the auspices of the Road Safety Act 2006, some contract drivers (e.g. chauffeurs) had to apply for PHV drivers’ licences. The DfT is concerned that overly burdensome topographical tests make it difficult for these drivers to obtain licences.
The Coventry Knowledge test is easier than the London test but more difficult than neighbouring authorities' tests. Few driver applicants fail to pass the Coventry Knowledge test although several attempts may be required.
If an exception is allowed for drivers working for contract driver/chauffeur companies (some of whom state that their drivers do not carry out work in Coventry) there would be nothing to stop that driver undertaking ordinary private hire work in Coventry if they leave the company or work part-time for themselves.
Stakeholders were requested to comment on the proposal to retain the requirement for all drivers including contract drivers/chauffeurs to pass the Coventry Knowledge test.
There was very strong support for retaining the policy (94% yes and 6% no).
Those that disagreed provide the following comments;
• 2 commented that sat.nav. / GPS and maps should suffice, and;
• One commented that most of his jobs were out of the city, so it wasn’t necessary.
Regency Cars responded that the “road knowledge test of Coventry is totally irrelevant…” for their type of work… and that “use of satellite navigation is almost universal...”. Also, they pointed out recruitment difficulties for chauffeurs due to the requirement for Coventry Private Hire licenses and indicated that this has contributed to shrinkage of their business (and loss of jobs) due to competition with surrounding areas not applying the policy and resulting in a lack of chauffeur companies in the City.
There was very strong support from the Trade to retain the Coventry Knowledge Test.
7.3.8 Other responses
One taxi driver responded in detail requesting relaxation of the tight vehicle specifications for both hackney and private hire vehicles.
West Midlands Special Needs Transport had no specific comments.
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Coventry Taxi Study Final Report 2013.doc 56
Appendix A Coventry Hackney Carriage Vehicle Requirements
Hackney Carriage Vehicle Requirements & Standards15
“1. To be licensed for the first time the vehicle must be in excellent condition and normally be no older than 5 years from the date of first registration. Please also read the section on the vehicle age policy.
2. The vehicle must meet the London Public Carriage Office 'Conditions of Fitness' adopted by Coventry City Council, unless varied by other requirements set out in this document.
3. The vehicle must be maintained to the same specification as when manufactured and meet other requirements set out in this document. No modification or additions are allowed unless the Taxi Licensing Office has given prior written approval. (Approval has been given by the Taxi Licensing office for the fitting of standard communication and satellite navigation equipment. This is on the understanding that the equipment is fitted by a competent person, and is located and secured so as not to be a hazard to passengers or other road users when the vehicle is in use, or if involved in an accident. Also, the equipment must not obstruct the driver's view of the road). Also see 'Vehicle standards/requirements/condition' under 'Inspections'.
4. Tinted windows. All windows must permit at least 75% light transmittance.
5. No unauthorised signs or advertisements are allowed in or on the vehicle.
6. The taximeter must be of an approved type and be fitted correctly, working and programmed to the Council's current fare structure. A 'Meter Programming Certificate' or Meter Test Certificate', dated on or after the introduction of the current fare structure, must be displayed in the vehicle
7. The plate must be secured to the rear of the vehicle using mechanical fixings. Magnetic/Velcro fixings are not acceptable.
8. The plate must not be obscured and must be clean and in good condition.”
15 Vehicle Proprietors Information Document 054 (Hackney Carriage & Private Hire), Coventry City Council,
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Appendix B Manufacturers / Models and Sizes, Sample of Wheelchairs Opened Chair Opened Chair mm mm mm Min (mm) Max (mm) Min (mm) Max (mm) Min (mm) Max (mm) Max 1390 740 1000 1390 1390 740 740 1000 1455 Average 1098.4 615 948.75 1092.421 1112.684 607.8947 631.8421 935.3571 1065.357 AverageMaxMedian 989.333333 655.8333 932.6471 988.9474 999.4737 616.5789 693.6842 1030 1140 925.7895 939.2105 647.5 730 940 950 1000 1140 1040 1140 630 730 660 825 940 950 940 1020 Median 1090 620 960 1090 1100 610 640 960 975 EtacEtac Balder Finesse Balder Liberty Powered 1130 640 820-1440? 1100 1130 1130 650 835-1455? 640 1100 1100 640 650 820 650 1440 835 1455 InvacareInvacareInvacare Lite Alu Action 3 NG Action 2 NG OccupantInvacare Attendant OccupantInvacareInvacare 1000 1030-1080Invacare Spectra Plus 1030 580-680Invacare Harrier Plus 580-605 920-970Invacare 520-570 815-1020Invacare 1030 Mirage plus Phoenix 1000 945Invacare 2 Typhoon 1080 4 Max Storm 1000 1030 2 HD Spectra XTR TDX-SP 580 580 Powered 1030 Powered 680 605 520 1000-1100 Powered Powered 510 920 815 570 1060 Powered Powered Powered 1060 890 550-625 945 1070 Powered 970 1020 1160 920 1390 1210 1000 570 530-680 650-720 940-970 1060 945 970-1230 1100 960-1240 980 620 1070 1060 1160 1060 510 980-990 1070 1060 1160 640 1210 550 510 530 570 650 1210 980 625 890 1390 680 570 620 720 980 920 1390 940 970 620 960 890 980 920 970 1240 980 640 1230 640 990 980 980 HandicareHandicareHandicare 40 Puma 20 Puma Pacific Powered Powered 1115-1190 Powered 610-655 1095-1160 610-655 1105 1115 740 1095 1190 1160 610 610 1105 655 655 1105 740 740 R HealthcareR HealthcareR HealthcareR HealthcareR Access HealthcareR Access HealthcareR Access Junior/Adult HealthcareR Access Junior/Adult HealthcareR Accent Duty Adult Heavy HealthcareR Occupant Occupant Accent Duty Adult Heavy HealthcareR Attendant Attendant Accent Adult HealthcareR Accent 990-1040 Adult 1040 Avanti Duty 550-700 Adult Heavy 940-990 Occupant 995 Duty Adult Heavy 8TRL 510-660 675-825 Attendant 940 SP100 Junior/Adult Occupant 675-825 940 940 Junior/Adult Attendant 1040 990 Adult 940 Attendant 995 1040 940 650-825 1040 Occupant 1040 995 990 675-825 940 1040 650-700 990 790 550 990-1040 Occupant 940 610-660 995 940 675 1040 535-660 510 700 940 630 995 940 1040 1040 675 825 1040 660 940 990 890 995 1040 990 650 825 940 635 940 990 790 650 1040 675 825 940 940 940 940 610 535 790 700 825 940 940 1040 940 660 660 630 940 940 1040 940 940 940 630 635 940 940 890 635 940 940 940 890 940 Manufacturer Model Variant Propulsion Length Width Height Length Medical LengthRoma MedicalRoma Width MedicalRoma Width MedicalRoma 1000 Height 1419 Height 1472 1485X Occupant Attendant Occupant Attendant 1070 900 1140 660 710 620 730 910 660 890 930 MedicalRoma 1070 940 MedicalRoma 900 Medical 1070Roma 1140 Sirocco P110 P200 Marbella 710 900 1140 660 Vienna SUL-7 710 730 620 660 660 730 620 910 Powered Powered 660 930 890 Powered 910 940 1090 1066 930 890 915 610 940 660 560 920 960 1090 960 1066 1090 915 1066 610 660 915 610 660 560 920 960 560 960 920 960 960 Sunrise Medical Breezy Basix Occupant 1060 570-710 950 1060Sunrise Medical 1060Sunrise Medical QuickieSunrise S525 Medical 570Sunrise Medical Quickie Jive Quickie 2 Samba Quickie M Salsa 710 950 Powered Powered Powered 950 Powered 1070-1215 1040 620-660 1100 1000 620 600-630 560 1070 960 1215 1040 620 1100 1040 1100 660 620 600 1000 620 630 1000 960 560 560 960 Manufacturers / models and sizes of a sample of wheelchairs available for Britain. use in Manufacturers available of wheelchairs of sizes and a sample / models
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Appendix C Wheelchair Groups / Stakeholders Research Findings
The following organisations did not respond in detail;
- Mothers Union. - Council of Disabled People. - West Midlands Special Needs Transport. - Royal Association For Disability Rights (Radar). - Coventry Young Persons Special Needs Group. - CT Community Transport. - One Voice Parents Group/Parent Partnership Service. - Disabled Go.
The reasons stated were:
- Funding being withdrawn. - No Coventry based office / experience. - Their wheelchair users have their own adapted transport and therefore do not use taxis. - Their wheelchair users are mainly using minibuses and therefore not using taxis (3 responses).
Coventry Wheelchair Users Group (CWUG) provides a voice for users working with the Coventry Wheelchair Service (part of the NHS). Their aims are to improve access to services, the design and range of wheelchairs and monitoring of wheelchair access issues. Transport is a key topic for the group. Their concerns include, the following;
• there are lots of ‘black cabs’ but not enough tail lift taxis for larger chairs and powered chairs.
• clients should travel in a taxi either in a front-facing position or rear-facing. Taxi drivers often leave client's in a sideways position which is not the correct position while travelling in a taxi. If there was a crash while the client was in the sideway's position the client would flop side to side instead of moving forward or back.
CWUG users have all types of wheelchair, electrically powered, manual self propelled and attendant propelled. They had no view on any particular advantage in the taxi being able to turn in the street in one smooth movement.
They also stated that all wheelchair users have a manual for their chair that gives clear instructions on how to safely secure a chair in a vehicle. All chairs are crash tested with a 4 points tie down (NHS) system and on modern chairs it is clearly indicated where the tie downs should go.
The Coventry Physical Impairment Team is a service provided by Coventry City Council to Coventry residents with limited mobility to develop skills and provide equipment to enhance independent living. Their service covers a wide range of people, mobility issues and ages. Whilst some people have wheelchairs the team does not cover their transport outside the home and they could not therefore comment on taxi issues. They referred to the Coventry Wheelchair Service for access to wheelchair users.
Coventry Taxi Study Final Report 2013.doc
The team works with the Coventry Physical and Sensory Impairment Partnership – a reference group for consultation, policy changes and addressing key issues such as barriers to services. It was identified that they could provide access to a wider group of independent wheelchair users.
The Coventry Vision Group covers visually impaired people including blind people. They were concerned that visually impaired people cannot read the meter therefore they are at the mercy of the driver. A recent experience was that the driver was unwilling to provide an estimate of the cost of the journey. They stated that drivers should be required to provide a 'quote' for the journey within £1 of the actual cost. They also asked why drivers are not required to give receipts printed from the meter, so that they can be challenged if necessary.
Scope – provides support to people with cerebral palsy, their families and carers. The experience of the respondent was “pretty good really over 25 years”. However, they reported sometimes having to pay an additional charge for the wheelchair. A specific concern related to problems accessing Broadgate. The respondent raised no particular issues with taxi turning circles or having to travel further to turn round.
Individual members concerns related to the following;
- “Well I have to put my speed dial up on my wheelchair to get up the ramp adequately. This can take several efforts.”
- “I have had a huge problem (in the past) having to duck my head when using the ramp as I enter up the ramp into the taxi and often bang my head on the rim of the taxi roof.”
- “Because I’m in an electric wheelchair I’m seated rather high up, taxi roofs tend to be somewhat low.”
- “I think a mini bus style taxi would probably be better in my particular case (not that I’ve ever used one from a taxi firm).”
Organisations contacted that did not reply were;
- Physical & Sensory Impairment Partnership - Age UK/Age Concern/Older Persons Partnership - Coventry Resource Centre For The Blind - Learning Disabilities Partnership - Assist UK - Grapevine Coventry - Mencap - Independent Advocacy - Shine Charity
Coventry Taxi Study Final Report 2013.doc
Appendix D Consultation Questionnaires
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc Coventry Taxi Study, Taxi Trade / Stakeholders / Interest Groups Survey Jacobs is currently carrying out work on behalf of Coventry City Council related to taxi licensing and changes required to the policy because of the equalities law. The survey is to provide information to help the Council review its policies. We would be grateful if you could spend a few minutes answering these questions and return it to: [email protected], by fax to 02476 253501 or by post to: Geoff Smith, Jacobs, 1st Floor, Friars House, Coventry, CV1 2TE.
Part A (Questions 1 to 6) are about wheelchair accessibility. Part B (Questions 7 to 13) are about other policy issues. Please answer questions relevant to you as a driver, owner, operator or stakeholder.
PART A: 2013 Consultation on Proposed Changes to Council Taxi Licensing Policies (Research informing vehicle type policy) Drivers / owners 1. What type of vehicle(s) do you own / drive? LTI / LTC TX 1/2/4 LTC Fairway Mercedes Vito Metrocab (tick all that apply) Drivers 2. How often do you carry a passenger in a wheelchair? Several times Several times Several times (tick one box only) a day a week a month Less often Never
3. Have you ever had to refuse to carry a passenger in a wheelchair? Never Sometimes Often a. How often?
b. If so, was this because: (tick all that apply) Passenger / wheelchair too heavy?
Would not fit through door?
Wheelchair would not turn?
Other, please specify: ………………………………………………………………………………………
4. Do passengers complain about the position of their wheelchair in the taxi? yes no Never Sometimes Often If yes, how often?
5. How often do people make use of the swivel seat? Never Occasionally Often Not relevant
6. How often do people make use of the step? Never Occasionally Often Not relevant PART B: 2013 Consultation on Proposed Changes to Council Taxi Licensing Policies (Other Policy Areas) PHV / taxi operators / Stakeholders 7. The proposed policy is that operators provide disability awareness training for staff in booking offices with costs met by the operator.
Do you Agree? yes no If no, why not? …………………………………….……………………………………………………… Taxi / PHV Drivers / Stakeholders 8. The proposed policy is that the frequency of medical examinations will be every 5 years to age 45, every 3 years to age 65 then every year using doctors on an approved list.
Do you Agree? yes no If no, why not? …………………………………….……………………………………………………… ALL 9. Which of the policy options for licensing Stretched Limousines do you agree with?Tick for option a, b or c below. Other Comments? (a) Retain the existing City Council policy licensing non-modified, right hand drive vehicle meeting emergency exit requirements (b) License any stretched limousine with 8 seats or less. (c) License only those stretched limousines that meet the draft conditions in Appendix A. ALL 10. Which of the policy options in relation to Tinted Windows do you agree with? Tick for option a, b or c below. a) Apply the legal standard of 75% light through the windscreen and 70% through the front side windows. b) Apply the same standard as taxis – 75% through all windows. c) Retain the current compromise of 75% through the windscreen, 70% through the front and rear side windows, and 40% through the rear and any other windows. Drivers / owners 11. Which of the policy options related to the Criteria for Vehicle Inspections do you prefer? Tick for option a, or b below. a) Only apply MOT test standards plus a check on internal condition. b) Apply the standards as set out in the Coventry Vehicle Inspection Manual (i.e. National Inspection Standards modified to maintain Coventry's high standards) and the updating of that manual by Council officers. ALL 12. The proposed policy is to allow an exception for displaying the plate and stickers on PHVs used exclusively for executive work. Do you Agree? yes no If no, why not? …………………………………….………………………………………………… ALL 13. The proposed policy is to retain the Topographical Tests for drivers of executive private hire vehicles (Road Knowledge Test)
Do you Agree? yes no If no, why not? …………………………………….………………………………………………… Coventry Taxi Study, Wheelchair Users Survey Jacobs, on behalf of Coventry City Council, is currently carrying out a review of the licensing of taxis. This survey seeks to gauge wheelchair / disabled people's views on how accessible Coventry's current taxi fleet is . We would very much appreciate it if you would spend a few minutes to complete our survey and return it to: [email protected], by fax to 02476 253501 or by post to: Geoff Smith, Jacobs, 1st Floor, Friars House, Coventry, CV1 2TE.
Please answer all questions which you feel able to, based on your experience.
1. How often do you use taxis in Coventry? (tick one only) Never Occasionally Weekly Daily
2. Have you experienced the following difficulties when using taxis in Coventry? (tick one box in each row) Occasionally Frequently Always Never a. Taxi driver failed to stop?
b. Taxi driver refused to take you?
If so for what reason? …………………………………….…………………………………….……………………………………. c. Unable to get into the vehicle?
If so for what reason? …………………………………….…………………………………….……………………………………. d. Wheelchair not facing in the right direction?
If so why? …………………………………….…………………………………….……………………………………. e. Wheelchair not secured properly in the vehicle?
If so why? …………………………………….…………………………………….…………………………………….
3. Which type of taxi can you access?
LTC TX Mercedes Vito Metrocab Other None (see question 5) PTO 4. Which taxi do you find easiest to access? LTC TX Mercedes Vito Metrocab Other None (see question 5)
5. If you find other taxis easier to access: a. What was the make and model? …………………………………….…………………………………….…………………… b. What was better about that model? …………………………………….…………………………………….…………………… 6. Are there any improvements you would like to see to taxis in Coventry. If so what are they?
..………………………………………………………………………………………………………………………………………………………
..………………………………………………………………………………………………………………………………………………………
7. We are organising a taxi testing day at the Barracks Car Park in Coventry City Centre. The aim is to trial different types of taxis to assess their suitability for people using wheelchairs. Would you be interested in attending this event? yes no If yes, please provide us with your contact details below: Name ……………………………….………………………………. Telephone ………………………………..………………………………. Email ………………………………..………………………………. Please note, you only need to supply your name and contact details if you wish to be considered for inclusion in the taxi testing day. We will contact people to take part in the testing event within the next 4 weeks.
8. We would like to know a few details about the wheelchair you use;
a. What make and model is your wheelchair?
b. Is your chair? A self-propelled manual chair Pushed by another person Electric-powered
c. How long is it (including footrests)? cm or inches
d. How wide is it? cm or inches e. How high is it (from floor to top of your head)? cm or inches
Thank you for completing this questionnaire.
Appendix E Additional Stakeholders Consulted
LTI Vehicles, Coventry, Mercedes Benz UK Ltd., Milton Keynes Citroen UK Ltd., Slough, Jubilee Automotive Group, Wednesbury. Co Trim, Salisbury. Voyager MPV, Crewe. Bernard Mansell, Northampton. Council of Disabled People, Coventry. Nissan, Rickmansworth. Volkswagen, Milton Keynes. Specialist Vehicle Assemblies Ltd., Coventry. National Limousine & Chauffeur Association, Wakefield. Cab Direct, Glasgow. Coventry Wheelchair User Group. NHS Coventry. Traffic Commissioner for The West Midlands. Supreme Stretch Limousine, Coventry. Starlight Stretch Limos Ltd.,, Coventry. A Stretch Limo, Coventry. American Limousine Company, Coventry. Krystal Limousines, Coventry. Snobs Limousines, Coventry. Coventry Society for the Blind. Routeforward, Coventry. Warwickshire & Coventry Federation of Small Businesses. CVOne Ltd., Coventry. Coventry and Warwickshire Chamber of Commerce. University of Warwick. Coventry University. Learning Disabilities Partnership, Coventry. Older Person’s Partnership, Coventry. Physical & Sensory Impairment Partnership, Coventry. West Midlands Special Needs Transport, Aston, Birmingham. Centro, Birmingham. Virgin Trains. London Midland Trains. Arriva Trains Cross Country. Coventry Taxi Association.
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Appendix F Vehicle Testing Day Wheelchair Users Comments
Comments recorded from wheelchair users at the Taxi Testing event, 22 May 2013. The 6 wheelchair users have been recorded as Users A to F. The wheelchair type for each user was;
• User A - has an Enigma manual chair. This is a standard width lightweight chair. (Wheelchair dimensions: Length 81cm, Width 73cm, Height 110cm).
• User B – has a Quickie XTR. This is a sports / all terrain wheelchair with no handles on the back. The occupant was particularly tall (Wheelchair dimensions: Length 80cm, Width 70cm, Height 145cm).
• User C – has a manual wheelchair. (Wheelchair dimensions: Length 95cm, Width 56cm, Height 135cm).
• User D – has a Shoprider Powerchair, which a mid-wheel drive system with front and rear castors. This is shown below for information, due to the particular issues related to this wheelchair. (Wheelchair dimensions: Length 107cm, Width 71cm, Height 142cm).
• User E – has a Spectra XTR2 electric wheelchair in which he sits in a reclined position. (Wheelchair dimensions: Length 110cm, Width 62cm, Height 145cm).
• User F – has an Invacare Recliner Wheelchair, which is particularly large as the user sits in a more reclined position. (Wheelchair dimensions: Length 127cm, Width 70cm, Height 135cm).
Coventry Taxi Study Final Report 2013.doc
There were four taxi’s available to test on the day:
• LTC/LTI TX4. • Mercedes M8. • Peugeot E7. • Renault NX8.
(a) LTC / LTI TX4 Vehicle
User A (Enigma manual chair) found it quick and easy to enter the taxi and thought this was the best vehicle for headroom. He noted that the two part partly integrated ramp was very useful for limiting the ramp angle from floor or pavement level (though he had never seen drivers getting the second part out). He rated this as a ‘preferred’ vehicle alongside the Renault.
User B (Quickie XTR) thought headroom was good as his head was not touching the roof. He liked the gab handle on the open door to help him get into the vehicle unaided. He prefers to face forwards in the vehicle so would normally transfer himself to the back seat. Strapping in was a bit tricky and he felt this might have been due to his sports chair. He prefers to exit taxi forwards but there was insufficient space to turn around inside. The supplier pointed out that he would always help wheelchair users out backwards otherwise there was a danger of them tipping forwards. Overall he thought this vehicle made the best use of a compact space and he preferred this vehicle and rated the Renault as the ‘best of the rest’.
User C (Manual wheelchair and carers spoke on his behalf) thought that seatbelt system was secure but it was a problem that straps etc. were not already in place in the vehicle and needed to be attached. It was felt that for many taxi drivers this might be a barrier to using and therefore carrying wheelchair users. They also felt that shorter ramp was a benefit in tighter spaces, such as the doctors’ surgery that their uncle visits and therefore preferred this vehicle type overall. However, this user also has an electric wheelchair and would prefer more van type vehicles with rear lift access.
User D (Shoprider Powerchair). The ramp angle resulted in middle (drive) wheels being lifted off ground so it couldn’t enter the taxi. He noted that previously, loading from the pavement, he has been able to get into this type of taxi but is tall and has problem with headroom. He had recently cut his head badly getting into a van type taxi (assumed to be the Mercedes Vito One80).
User E (Spectra XTR2) was unable to duck his head. The ramp was OK to use, however, in two attempts he couldn’t move his head down sufficiently to enter vehicle.
User F (Invacare Recliner Wheelchair) had previously used this type of vehicle and commented that the wheelchair is too long - so didn’t attempt to enter the taxi.
Coventry Taxi Study Final Report 2013.doc
(b) Mercedes Benz M8
User A (Enigma manual chair) liked having lips on either side of the ramp as allayed concerns about slipping off. Headroom was not good: his head was touching the roof. He thought the restraints to secure the wheelchair were neat.
User B (Sports wheelchair) felt that the ramp was too narrow and made it more difficult to manoeuvre. He noted the lack of grab handle due to the sliding door. He found the headroom insufficient: his head was touching the roof. He felt comfortable strapped in. He finds sitting sideways in the vehicle most comfortable for him, but supplier said that this is illegal. There was sufficient space to turn inside the vehicle.
User C (Manual Wheelchair) footrests caught on the ramp, meaning the carers had to tip wheelchair up onto the rear wheel to use the ramp and enter vehicle. This took some effort. Mr. Clarke lives in sheltered accommodation where there is no kerb so always has problems using ramps. The carers felt that the seatbelt strap was not suitable as it didn’t ratchet.
User D (Shoprider Powerchair) ramp angle resulted in middle (drive) wheels being lifted off ground so he couldn’t enter the taxi.
User E (Spectra XTR2). Based on his experience with the headroom of the other vehicles he did not attempt to enter this vehicle.
User F arrived late and departed early so did not test this vehicle.
(c) Peugeot E7
User A (Enigma manual chair) found Headroom was limited and had to duck his head on entering the taxi, and commented that he would not need to do this in a traditional cab. He found the ramp to be quite scary, but noted it would not be so steep when there was a kerb. He liked the fact it was built-in. He thought the restraint system was slick, although more involved than in a traditional cab. He liked the karabiners. He also liked the wide access.
User B (Quickie XTR) found the ramp too steep, but would be OK if on a kerb. He was able to manoeuvre up the ramp himself, but it should be noted that he is fit and strong and had to use the hand grips to enter the taxi, He noted the lack of grab handle alongside the ramp due to the sliding door. He is tall and found Headroom was limited, his head was touching the ceiling inside the taxi. He struggled to exit the taxi. He would normally come out forward facing, however there was insufficient headroom. He was concerned that the straps would get tangled up. He normally transfers to the seats in a taxi and his wheel chair is not secured. He liked the fact that you can face either way in this taxi. He would prefer lower grab handles. Overall he thought this was a “nice cab”.
Coventry Taxi Study Final Report 2013.doc
User C (Manual wheelchair) On trying to enter the taxi, his foot rest caught on the ramp. His wheelchair had to be tipped backwards by the carer/driver to enable him to access. The carers commented on the additional risk that he might tip over as a result. The carer required help from the driver to get him and his wheelchair into the taxi. However, they thought that the integrated ramp design was “brilliant” as no parts could be lost and it was simple to put in place. He commented there was insufficient headroom as he nearly bumped his head. The carers also commented that the seatbelts should be retractable, “idiot proof”, with no additional parts, so that the carer could put them in place if the driver didn’t. This would also reduce the chance of parts being lost. They “loved” the karabiners used to restrain the wheelchair as they were retractable and very secure.
User D (Shoprider Powerchair) was unable to enter the taxi as, once the front castor ascended the ramp, the drive wheels lifted off the floor and the wheelchair could no longer be propelled forward. He tried to reverse into the vehicle, but encountered the same problem.
User E (Spectra XTR2) was unable to enter the taxi as there was insufficient headroom (by a couple of inches). This was a similar problem with traditional taxis, and he could only use taxis with rear access.
User F arrived late and departed early so did not test this vehicle.
(d) Renault NX8
User A (Enigma manual chair) found the ramp to be very steep and described it as “scary”. It was noted that a 7 foot telescopic ramp is available for this vehicle (but was not brought on the day). He commented that the door was “nice and wide” but he thought that headroom was limited, however it should be noted that he is tall. He liked the fact that there was lots of space available in this vehicle, “more than the others”. He liked the fact that the default position for the wheelchair is forward facing. He liked the “comprehensive strap arrangements”, however noted that it took a bit longer to strap him in. Overall he said “this one’s great” and rated it alongside the TX4 and ‘preferred’.
User B (Sports wheelchair) found the ramp too steep and he was afraid that he would tip over backwards. Due to the lack of handles on his chair, it was not possible for the driver to help. He opted to climb into the taxi, and his chair was passed up to him. It was noted that longer telescopic ramps are usually specified for this vehicle. He also noted that the ramp could be fitted to both sides of the cab, making it more flexible. He noted there was plenty of space within the taxi to manoeuvre his wheelchair and there was also sufficient headroom for a tall person. He liked the forward facing position. The seatbelt is usually tucked behind the handle on the back of the wheelchair to keep it in place. As this was not possible on the sports wheelchair, it would need to be threaded under the back brace to make it secure. He was impressed with how secure the chair was when correctly strapped in place, however he noted that it might take the driver longer to arrange the seats and restraints. Despite the difficulty in getting into/out of the taxi due to the short ramp, he liked this one, rating it as ‘best of the rest behind the TX4’.
Coventry Taxi Study Final Report 2013.doc
User C (Manual Wheelchair). On trying to enter the taxi, his foot rest caught on the ramp. His wheelchair had to be tipped backwards by the carer/driver to enable him access. The carers commented on the additional risk that he might tip over as a result. The carer required help from the driver to get him and his wheelchair into the taxi. The carers commented that the ramp was too steep and very high. It was noted that the 7 foot ramp would be preferable. On descent, the ramp was found to be slippery (it should be noted that this was a brand new vehicle). The straps and restraints were found to be ‘fiddly’. The carers want an “idiot proof” system that does not require additional loose parts which can be lost. The seatbelt was found to be secure, but took too long to put in place. The carers though that drivers would not be bothered to use them. He liked the forward facing position of the wheelchair.
User D (Shoprider Powerchair) was unable to enter the taxi as, once the front castor ascended the ramp, the drive wheels lifted off the floor and the wheelchair could no longer be propelled forward.
User E (Spectra XTR2) was unable to enter the taxi as there was insufficient headroom (by a couple of inches). He said that this was a similar problem with traditional taxis, and he could only use taxis with rear access. Additionally, the ramp was too steep, and this caused difficulties for the carer when it came to managing the decent.
User F (Invacare Recliner Wheelchair) found the ramp was too steep; the carer was unable to manoeuvre the chair into the taxi without help. Headroom was limited on entry. The wheelchair was very large, however there was space to manoeuvre the chair into the forward facing position. She liked the forward facing position. Usually she has to ride facing sideways. The straps to secure the front of the wheelchair were too short. Longer straps or ratchet straps would need to be specified. The seatbelt was found to be secure.
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Appendix G Example Taxi Turning Circle Analysis
Coventry Taxi Study Final Report 2013.doc
Coventry Taxi Study Final Report 2013.doc
Appendix H Proposed Policy Conditions: Stretched Limousines
Draft Conditions Consulted On;
PROPOSED LICENCE CONDITIONS APPLICABLE TO STRETCHED LIMOUSINES LICENSED AS PHVs IN COVENTRY
1.1 All bookings for a licensed limousine must be taken by a licensed Private Hire Operator.
1.2 Each vehicle will only be licensed by the Council if it is: - Suitable in type, size and design; - Not of a design and appearance whereby it could be confused with a hackney carriage; - In a suitable mechanical condition; - Safe and comfortable; - Insured for private hire use not just for weddings and funerals.
1.3 A stretched limousine for the purpose of licensing in Coventry shall be a vehicle modified as a stretched vehicle, such as a Ford Lincoln, Ford Excursion, Cadillac, Volvo or Mercedes, by a converter approved by the manufacturer.
1.4 The criteria for these vehicles will be the same as for private hire vehicles subject to the following amended conditions - The vehicle will be licensed for a maximum of eight passengers; - Tinted windows must comply with the Road Vehicles (Construction & Use ) Regulations 1986 in so far as the windscreen and front side windows are concerned; - The vehicle may be left hand drive provided it is fitted with a forward-facing camera on the offside of the vehicle (such as in the wing mirror) and a monitor displaying video from the camera and visible to the driver; - A seat belt must be fitted for each seat in accordance with the Construction and Use Regulations and must be used by passengers; - Each passenger must be able to exit the vehicle on both sides of the vehicle by either a door or an emergency window exit. Childproof locks which prevent egress from the rear of the vehicle shall not be fitted; - The vehicle will be required to pass a vehicle inspection, before licensing and at four monthly intervals, to a standard set by the City Council at a City Council nominated garage/MOT testing station; - Where alcohol is supplied it must be authorised under the Licensing Act 2003 and no alcohol shall be supplied to any person below the age of 18.
1.5 As with Executive Hire Private Hire Vehicles, the plate identifying the vehicle as a Private Hire Vehicle, in accordance with section 48 of the Local Government (Miscellaneous Provisions) Act 1976, will not have to be displayed on the rear but may alternatively be fitted in a conspicuous position on the inside of the vehicle.
1.6 The vehicle will also not be required to display door or window stickers.
1.7 The correct type of tyres of both the appropriate size and the correct weight loading must be fitted.
Coventry Taxi Study Final Report 2013.doc
Adjusted Conditions – to reflect the comments made (Highlighted).
PROPOSED LICENCE CONDITIONS APPLICABLE TO STRETCHED LIMOUSINES LICENSED AS PHVs IN COVENTRY
1.1 All bookings for a licensed limousine must be taken by a licensed Private Hire Operator.
1.2 Each vehicle will only be licensed by the Council if it is: - Suitable in type, size and design; - Not of a design and appearance whereby it could be confused with a hackney carriage; - In a suitable mechanical condition; - Safe and comfortable; - Insured for private hire use not just for weddings and funerals.
1.3 A stretched limousine for the purpose of licensing in Coventry shall be a vehicle modified as a stretched vehicle, such as a Ford Lincoln, Ford Excursion, Cadillac, Volvo or Mercedes, by a converter approved by the manufacturer.
1.4 The criteria for these vehicles will be the same as for private hire vehicles subject to the following amended conditions; - The vehicle will be licensed for a maximum of eight passengers; - Tinted windows must comply with the Road Vehicles (Construction & Use ) Regulations 1986 in so far as the windscreen and front side windows are concerned; - The vehicle may be left hand drive provided it is fitted with a spotter mirror on the offside of the vehicle or, with a high limousine, such as a Ford Excursion or a Hummer, a “Fresnel” lens on the offside front window; - A seat belt must be fitted for each seat in accordance with the Construction and Use Regulations and must be used by passengers; - Each passenger must be able to exit the vehicle on both sides of the vehicle by either a door or an emergency window exit. Childproof locks which prevent egress from the rear of the vehicle shall not be fitted; - The vehicle will be required to pass a vehicle inspection, before licensing and at four monthly intervals, to a standard set by the City Council at a City Council nominated garage / MOT testing station; - Where alcohol is supplied it must be authorised under the Licensing Act 2003 and no alcohol shall be supplied to any person below the age of 18.
1.5 As with Executive Hire Private Hire Vehicles, the plate identifying the vehicle as a Private Hire Vehicle, in accordance with section 48 of the Local Government (Miscellaneous Provisions) Act 1976, will not have to be displayed on the rear but may alternatively be fitted in a conspicuous position on the inside of the vehicle.
1.6 The vehicle will also not be required to display door or window stickers.
1.7 The correct type of tyres of both the appropriate size and the correct weight loading must be fitted.
Coventry Taxi Study Final Report 2013.doc
Appendix I Other Comments Received in Response to the Criteria for Vehicle Inspections
The following comments were received from the Trade in response to the Criteria for Vehicle Inspections – but were related to wider issues;
• 23 comments were made about the frequency of the test, of which 20 said the test should be held annually. The remaining three did not specify a frequency, but indicated that twice a year was too often;
• 4 suggested Badge renewal should be every three years;
• 15 comments were made regarding the need for additional MOT test centres;
• 3 comments were made regarding the amount of time it takes to get a test or re-test;
• Increase in vehicle age limits to 14 or 15 years were suggested by 2 drivers;
• 1 comment was made noting that drivers are not trained in how to use the fire extinguishers;
• 2 comments were made relating to the integrity of inspectors;
• 2 comments were made about staff rudeness
• 1 comment was made suggesting the council should fund CCTV;
• 1 comment was made suggesting there needs to be greater awareness of changes to vehicle drivers and owners.
Coventry Taxi Study Final Report 2013.doc