22 Sep 2014

Air Weapons and Licensing (Scotland) Bill 2014 Financial Memorandum.

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Finance Committee Questionnaire.

Consultation Part 3-Civic Licensing.

Dear Sirs,

  1. The Scottish Taxi Federation confirms it took part in the consultation exercise preceding the above Bill. It further confirms that at no stage of the consultation did the question of financial assumptions arise and therefore we were not required to make any comment.
  2. Since we were not asked for and therefore made no comment the answer is NO.
  3. Yes.
  4. The Bill does not directly affect the Scottish Taxi Federation as an organisation. However, in light of the Government’s comments that additional costs should be charged to licence fees, it is clear that our members will be directly affected.
  5. As stated in (4) above, the additional costs referred to may not affect our organisation directly, but it is clearly the case that individual members will be affected. We therefore, do not accept that the anticipated cost of court challenges to the question of over provision, which in our view are more likely as a result of the weakness in the legislation, should simply be passed back to licence fees.
  6. Licence holders are in effect are being punished for a system that the Scottish Government acknowledge in advance, is more likely to be challenged.
  7. This is difficult to answer since the assumptions are just that and not based on factual evidence.
  8. In terms of the Civic Licensing Section, the FM does not capture factual costs mainly by its admission that these are based purely on assumptions
  9. Yes, but these can not be quantified in advance.
  10. The FM suggests that the likely cost to a Local Authority of undertaking an assessment of private hire car services, might be in the region of £15 to £20 k every three years. How is it possible to arrive at such a conclusion?
  11. There currently exists no methodology or measurement tool by which a Local Authority can measure that the numbers of private hire cars operating within its Licensing area is sufficient or otherwise. This of course means that one will have to be devised and with respect,such a measurement tool, because of the nature of the private hire operation, will be difficult if not impossible to achieve. It will therefore be equally difficult to quantify the cost of such a measurement tool assuming it is possible.
  12. The courts have long accepted the SUD measurement used to determine demand for taxis, is in fact a legitimate methodology and have also decreed that 3 years between such surveys may be considered too long.It is also a fact that SUD surveys can and do cost more than the £15 to £20 k suggested. For example, it is our belief that in the case of Edinburgh City, the last SUD report may well have exceed these figures by some distance.

In Summary;

The Scottish Taxi Federation is of the view that the FM has got things badly wrong in terms of its cost assumptions. It may be that it has been assumed that the cost of administering the over provision section and the possible court challenges, will only be charged back to the Licence fees for private hire car operators. If this is the case, then the legislation needs to make this clear otherwise Local Authorities will be free to make their own interpretations and as has been proven all too often in the past, these do not always work out as anticipated.

Yours Faithfully
Bill McIntosh
General Secretary
Scottish Taxi Federation

Note: Our email address is now enquiries@scottaxifed.org

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