Tag Archives: UberPool

My personal submission to TfL private hire consultation

Everyone has at least one if not numerous opinions about how TfL should develop the private hire regulatory problems. Actually it doesn’t take a rocket scientist to figure out the answer to the problem is to impose a cap to stop the city congesting itself to a coronary and to protect worker rights so private hire drivers don’t end up suffering the same.

Here is what I will be submitting personally to TfL before consultation closes tomorrow. UPHD will be sending in its own submission also on behalf of the member base. Register for free membership at UPHD to see a copy of its submission.

Do you agree with my answers? Feel free to use an adapt it at will to submit your own feedback to TfL.  You can find the consultation document including the questions asked which I respond to below at this link.

Question 1
Do you agree with the above proposal? If you don’t agree, please explain why.

Answer:
No I do not agree to this. I already wear a TfL picture ID which is sufficient and already a much higher standard than the taxi trade. I am not convinced that my personal details will not be misused or leaked on to the internet

Question 2
Do you agree with our proposal for a time delay between journey booking and commencement? If you don’t agree, please explain why.

No I do not agree. An imposed waiting time will only lead to more congestion and income loss for drivers and pose a safety threat for passengers.

Question 3
Do you think that a different time interval to five minutes is appropriate? If you do, please say what you consider an appropriate time interval to be, and why.

There should be no time delay imposed.

Question 4
Do you agree with our proposal? If you don’t agree, please explain why.

Yes, I agree with this proposal.

Question 5
What are your views on ensuring that app based platforms are secure and do not allow passenger or driver fraud?

I don’t have a view on how operators manage passenger fraud. I believe drivers wearing a picture ID at all times provides sufficient security. I don’t believe the problem is app specific. For example a taxi driver can easily pass his badge and cab to an unlicensed driver.

Question 6
Do you believe that there is sufficient technology available to achieve this and if so what technology do you believe we should consider?

I don’t believe the technology exists to properly secure driver details. At the moment driver details are being cut and pasted from the app to social media channels. The best security is not to collect data that is not needed.

Question 7
Do you agree with our proposal? If you don’t agree, please say why.

Yes.

Question 8
Do you consider a period other than seven days to be appropriate? If you do, please say why.

The same advance booking period as airlines allow.

Question 9
Do you agree with our proposal? If you don’t agree, please say why.

No. Large trade events and concerts cannot be serviced adequately and safely without on site service. If TfL bans this it will only encourage touting.

Question 10
How would you propose that venues and temporary events ensure safe and adequate transportation options for those attending such events?

On site operator could be asked to register and submit driver and phv details in advance.

Question 11
Do you agree with our proposal? If you don’t agree, please say why.

Yes but there must also be a manned support line for operators to support drivers 24×7.

Question 12
Do you agree with our proposal? If you don’t agree, please say why.

Yes I agree.

Question 13
Do you agree with our proposal? If you don’t agree, please say why not.

No I don’t agree. I have no objection with the operator supplying my details to TfL but I do object to your monitoring of ‘behavioural indiscretions’. TfL must stick to writing and enforcing regulations only. I would like TfL to get professional, independent advice on equalities.

Question 14
Do you agree with our proposal? If you don’t agree, please say why.

I do not agree. It’s impossible to fix a time and distance fare in advance. To mandate this will result in either the passenger being overcharged or the driver being underpaid.

Question 15
Do you agree with our proposal? If you don’t agree, please say why.

Yes I agree. I also believe I must be told of the destination at the time of booking confirmation so that I can prepare for the journey and also have the option to decline or discuss with the operator if I feel I am unable to complete the journey.

Question 16
Do you agree with our proposal? If you don’t agree, please say why.

Yes, I agree to this proposal.

Question 17
Do you agree with our proposal? If you don’t agree, please say why.

No I don’t agree. I don’t see why an operator cannot organise and market their business anyway they chose.

Question 18
Do you agree with our proposal? If you don’t agree, please say why.

I don’t agree.

Question 19
What standard do you think it would be appropriate for applicants to demonstrate?

I suggest TfL gets professional, external equalities advice on this question.

Question 20
Do you agree with our proposal? If you don’t agree, please say why.

I completely disagree with this proposal. It would directly reduce and harm my employment prospects. I should be allowed to work for as many operators as I chose. Not all operators can offer me enough work to provide a full time income.

Question 21
Do you agree with our proposal? If you don’t agree, please say why.

I completely disagree with this proposal and I resent the implication that I or my colleagues are benefit cheats. TfL should stick to regulating the taxi and private hire trade where it already has more than enough to do.

Question 22
Do you agree with our proposal? If you don’t agree, please say why.

Yes I agree.

Question 23
Do you agree with our proposal? If you don’t agree, please say why.

Yes I agree.

Question 24
Do you agree with this proposal? If you don’t agree, please say why.

I disagree.

Question 25
Do you agree with our proposal? If not, please say why.

Yes I agree

Question 26
Do you agree with our proposal? If you don’t agree, please say why.

Yes, I agree to this proposal.

Question 27
If you agree, should the driver be required to display the insurance in the vehicle?
If you don’t agree, please say why.

Yes but only via a windscreen sticker but not inside the car.

Question 28
Do you agree that Hire and Reward fleet insurance put in place by operators is necessary in addition to, or instead of, individual driver insurance cover? If you don’t agree, please say why.

Yes I agree that operators should carry fleet insurance in addition to but not instead of driver HR insurance.

Question 29
Do you agree with our proposal? If you don’t agree, please say why.

Yes but TfL should bring detailed proposals back for further consultation.

Question 30
Do you support the above proposal? If not, why not?

Yes I support the proposal. Ride sharing should not be allowed. Based on my experience I believe it is unsafe for me as a driver and for the passenger.

Question 31
Do you agree with our proposal? If you don’t agree, please say why.

No I do not agree. I see no reason for any further restrictions.

Additional measures:

I agree with the additional you propose and in addition I think the following are essential also:
• Safety and security training for drivers to be provided by operators.
• TfL should provide whistle blower protection and an anonymous complaints lines for drivers and operators to report concerns to TfL.
• Driver deposits need to be protected by a TfL approved scheme to stop operator abuse.
• TfL should carry out credit checks on operators to ensure they are fir for business.
• TfL should ensure that operators provide suitable rest, kitchen and toilet facilities 24×7.
• TfL must provide suitable rest areas throughout London.
• All operators must provide a 24 hour, live, manned support line for driver operations.

UberPool – TfL has failed us all again

Last Friday, Uber launched UberPool to the utter dismay of every private hire driver on the platform. We were given no notice, allowed no opportunity for advance consultation and no choice to opt out. Even at launch, while Uber was providing extensive details to the public on fare structures, we drivers were left in the dark. Some of us were offered in person training via an SMS message but when I went to book there were no slots available at all.

As drivers, completed the basic on boarding training details started to trickle out and it was worse than feared, First, Uber have opted to grab 35% commission share – much higher than most markets in the US. Drivers are paid on a flat fare based on historical data but you can bet that the fare is constructed to benefit Uber and not the driver. We saw some fares netting as low as £3.50 for 2 miles over twenty minutes. This is simply uneconomic and it is unreasonable for Uber to force drivers to accept these fares if we are notionally independent business people.

Uber has proven itself to be an unrepentant profit seeking machine without regard for drivers but we are entitled to expect more from our regulator who we pay to order our trade through our taxes and license fees. So why are they asleep at the wheel when it comes to UberPool?

Let’s consider the reason why private hire regulations are under review at the moment. This from the introduction to the PH regulatory review on TfL’s website:

Because of a number of developments within the private hire industry including advancements in new technology and an increase in the different ways people engage and share taxi and private hire services, we are undertaking a review of the current policies and processes that govern the licensing of private hire drivers, vehicles and operators.

With new regulations not due until June 2016 why has TfL then jumped the gun to allow UberPool before the consultation has even finished? In the first stage of consultation there was universal concern over safety of ride share concepts such as UberPool:

Many stakeholders expressed concern about this proposal, with particular anxiety about sharing at night and ensuring that customers can make an informed choice on whether to share…….The GMB trade union argued that all sharing should be prohibited because of the risks to drivers and passengers; the taxi trade associations felt that sharing should not be allowed in private hire vehicles

So there you have it, consensus agreement that there are very serious issues in operating ride sharing. As a result TfL pledged:

….the regulatory framework must properly any safety concerns and the safety of passengers and drivers must not be put at risk. We will continue to take action in relation to the use of any vehicle undertaking journeys for commercial reward which circumvents the licensing system.

And yet last week Garrett Emmerson, Chief Operating Officer for Surface Transport said publicly that TfL had sought and received assurances from Uber on the safety of UberPool. Funny that, because Uber says its not the transportation provider – we are. So what assurances did TfL get exactly and why didn’t TfL ask us as the relevant transportation provider?

Clearly, TfL has rode rough shod over the consultation process and pre empted our collective participation by giving UberPool an immediate go ahead.

We’ll be looking for answers at our demo outside TfL on December 17. Join us there.