Proposed updates to London Service Permit guidance

Closed 26 Oct 2018

Opened 14 Sep 2018


Update 6 March 2020

This consultation has closed. Thank you to those who took part. We expect to be able to publish the outcome of the consultation in the early summer.

- Update ends -

Through his Transport Strategy (MTS) the Mayor has committed to improving life in London, by promoting a good public transport experience, tackling air quality, introducing the Healthy Streets Approach and encouraging growth in cycling and walking. The Mayor’s aim is to reduce Londoners’ dependency on cars with the target for 80 per cent of all trips in London to be made on foot, by cycle or using public transport by 2041.

Transport for London (TfL) provides the core London bus network, but we recognise that scheduled bus and coach services that are not part of  our bus network provide an important part of the public transport mix. They help to encourage a move away from car usage, encouraging active travel and in some cases supporting the tourist economy of the Capital. These services that provide local journeys within and to/from London can only operate under London Service Permits (LSPs) granted by TfL. Click here to find out more about these types of services.

Under sections 185 and 191 of the Greater London Authority Act 1999 (“the Act”) the Mayor is required to produce a guidance document containing the criteria by which TfL will consider applications for LSPs and consult on any revisions to it. The Mayor is proposing to revise the existing guidance to take into account the new versions of the Mayor’s Transport Strategy and London Environment Strategy and the emergence of Demand Responsive Transport (DRT) services. TfL is undertaking the consultation on behalf of the Mayor.

We would like to understand through this consultation how these proposed changes may impact on the provision of existing or future LSP operated services.

What changes are proposed to the LSP guidance?

The current guidance document was last updated in 2014. We are proposing to revise the document to reflect the recently published strategies and new or updated road transport schemes, including the Low Emission Zone and Ultra Low Emission Zone, and the emergence of new types of bus services which have DRT features such as flexible pick-up and drop-off based on passenger demand and use of app-based technology for pre-booking.

In updating the guidance, care has been taken to ensure all services operating under an LSP are fully aligned with the aims of the Mayor’s Transport Strategy by contributing to a safer, more reliable, accessible and environmentally friendly transport network. We have also considered the interests of everyone who live, works or visits London including communities in outer London which may be served by long running cross-boundary bus services which provide important links locally and to the wider transport network.

The revisions are detailed in full here and are summarised below:


The Mayor has committed through the Mayor’s Transport Strategy to improving the Capital’s air quality and environment.

  • Revised criteria will allow TfL to have regard to operators’ compliance with policies and proposals contained in the new Mayor’s Transport Strategy and the London Environment Strategy
  • For vehicles in scope, compliance with the Low Emission Zone Scheme is compulsory under the current guidance – payment of the daily charge is not permitted. We are proposing to require compulsory compliance with the Ultra Low Emission Zone Scheme from its date of introduction in central London on 8 April 2019 and with the progressive expansion of the zone and any proposed future updates. In line with the scheme orders, the small number of vintage vehicles which may operate under LSPs will remain out of scope.

Accessibility and inclusion

The Mayor’s Transport Strategy outlines the Mayor’s aim to improve public transport accessibility so that disabled and older people can travel spontaneously and independently.

  • United Kingdom legislation requires that buses and coaches used on scheduled services (including LSPs) must incorporate features that assist elderly and disabled passengers, such as wheelchair access (the Public Service Vehicle Accessibility Regulations 2000). However, some vehicles are exempt. Such exemptions include minibuses with less than 23 seats, where it can be difficult to incorporate the full range of features in such small vehicles, and also heritage vehicles such as Routemasters provided they have been issued with a Special Authorisation Order by the Department for Transport (DfT). In these cases we are proposing to take account of any provisions the applicant intends to make to improve access to such services, such as a stand-by accessible vehicle or additional passenger assistance so that elderly and disabled passengers are not excluded from the service.
  • Where pre-booking of a service is primarily online through a web page or app, we will expect applicants to demonstrate what methods they have to assist booking for elderly and disabled users, such as booking by phone and/or disability-friendly features on the app.

Health and Safety

The Mayor, through his  Transport Strategy, has made the  commitment to adopt a Vision Zero for road danger in London. Vision Zero aims to improve safety so that people do not feel worried about road danger or experience threats to their personal safety.

While operator safety is the responsibility of the traffic commissioners and Driver and Vehicle Services Agency, mandated by national legislation, any service which operates under a LSP should be safe. We conduct audits of LSP applicants’ health & safety policies and procedures to ensure that operators meet the minimum national standards, and through the guidance we propose that these audits additionally take account of:

  • Whether there is evidence of systems in place to monitor and enhance driver and vehicle standards, demonstrating a commitment to the Mayor’s Vision Zero for London. This may include manual monitoring or automated telematics systems.
  • Whether the operator has in place a system that allows confidential incident reporting (“whistleblowing”) of safety concerns by staff. Operators will be expected to provide details of the system in place and how it works.
  • Where proposed services such as DRT do not use fixed stops or have advertised stopping places that are not TfL stops, whether the operator is competent in being able to risk-assess such locations and the drivers' capability of using them. This may include a review of a detailed route risk assessment submitted to us by the operator.

Information and provision

In order to support the Healthy Streets Approach, one of the principles adopted by the Mayor is ensuring improved monitoring and planning of the transport network by encouraging data and knowledge sharing between new transport services and TfL and the GLA.

It is therefore proposed that we have the right to access anonymised data to verify that a service is operating in compliance with the conditions of their LSPs particularly in respect of adherence to routeings and timetables. We expect to use this right to investigate stakeholder and public complaints and, potentially, to gather evidence where regulatory action may be necessary.

General updates

The primary criterion for LSPs remains that the service must not be against the interests of the London public and that TfL must be satisfied that the operator and service comply with the law. This criterion has been re-worded to make it clearer.

The Mayor’s guidance will be accompanied by an explanatory note which provides more detail about each criteria as well as describing the application process, the LSP itself and various procedures. We will update the current explanatory note to align with any revisions to the guidance which are adopted by the Mayor following this consultation.

Using the links below you can see the proposed changes in detail:

Draft updated guidance with track changes (PDF 139 KB)

Draft updated guidance untracked (PDF 131 KB)

Current guidance (PDF 25 KB)

The following documents are included here as reference:

Draft EQIA

London Environment Strategy

Accessibility Implementation Plan

Vision Zero

CIRAS confidential incident reporting as an example used by TfL

Next steps

We will review all consultation responses and use these to make a recommendation to the Mayor to either amend the changes or to adopt them as proposed.

We are also currently reviewing the LSP explanatory note, the application and assessment process, and permit conditions. The proposed updated guidance and any changes we make to it as a result of consultation will influence our review. We currently expect to introduce all changes to these documents and processes at the same time or shortly after the Mayor has formally adopted the updated guidance.

This chart summarises the processes under review:

Your browser does not support inline PDF viewing.Please download the PDF. 

Click here to view a larger version of the above process flowchart (PDF 15 KB)

We are also separately reviewing the LSP application fee (currently £150 per new application) and plan to issue an update shortly. 

When would the revised guidance come into force?

If adopted by the Mayor, the revised guidance would come into force on the day after the Mayor formally adopts it. The Mayor is expected to make a decision in early 2019. The updated guidance would apply to all new and renewed applications received from this date. 

Have your say

We would like to know what you think about our proposals.

Please give us your views by completing the online survey below by 26 October 2018.

Alternatively, you can:

You can also request paper copies of all the consultation materials and a response form by emailing, or writing to FREEPOST TFL CONSULTATIONS.


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