Have your say on reducing the maximum age limits for taxis

Closed 26 Apr 2019

Opened 15 Feb 2019

Results Updated 10 Jul 2019

We recently consulted on proposals to reduce emissions from taxis. Proposals consulted on were:

a) The mandating of the maximum operating age of taxis from 1 November 2019  

b) Subject to (c) below, the phased reduction in taxi vehicle maximum age limit for Euro 3, 4 and 5 diesel taxis, from 15 years in 2019 to 14 years in 2020, 13 years in 2021 and 12 years in 2022, also effective from 1 November of those years   

c) The retention of the 15 year age limit for:

  • Euro 6 taxis
  • Taxis which have been converted to run on Liquid Petroleum Gas (LPG) after 31 October 2019 and which meet the Euro 6 standard for emissions; and
  • Taxis which meet existing zero emission capable (ZEC) taxi requirements (as defined)

d) The removal of the age limit exemptions, which currently exist for alternative fuel conversions, historic and classic/niche vehicles and for hardship/personal circumstances, noting that TfL retains the ability to consider individual applications and to grant exemptions to the age limit in exceptional circumstances where we consider it justified to do so

Following the consultation and the analysis of the comments received, we can confirm that we are going ahead with our proposals as they were consulted on.

The Licensed Taxi Drivers Association (LTDA) is investigating potential technological solutions to retrofit Euro 5 diesel taxis to meet Euro 6 standards. TfL will keep this under review and if a Euro 6 retrofit is approved in future TfL will consider ways to incorporate retrofitted Euro 5 taxis in the new Conditions of Fitness and age limits. If such vehicles can be shown to meet the required Euro 6 emissions standards in real world driving conditions they could be eligible for the 15-year age limits in the same way as factory standard Euro 6 taxis. TfL will work with the LTDA to look at how any such retrofit solution that may come forward could be applied in practice.
 
We received 5,125 responses to the online consultation questionnaire. Forty-nine stakeholders also responded to the consultation.
 
You can view our consultation report below. In the report we have also responded to the common issued raised by respondents. 

Taxi age limits consultation report (PDF 3.72MB) 

Taxi age limits decision paper (PDF 10.32MB)

Overview

The Mayor’s Transport Strategy is clear that air pollution caused by diesel emissions, high levels of nitrogen dioxide (NO2) and particulate matter (PM) exacerbate poor health conditions and shorten the lives of Londoners. The communities suffering the most from poor air quality are often the most vulnerable in society.

London’s transport network must contribute to meeting legal air quality levels as soon as possible and the achievement of a zero carbon city by 2050, thereby protecting the health of Londoners and demonstrating a commitment to tackling climate change.

The London taxi is rightly recognised as an icon. Taxis are an integral part of our transport network, providing quick, accessible, safe and knowledgeable travel across London. However, road traffic, including taxis, is often the greatest contributor to poor air quality in places where people live and work. Diesel is the most significant source of nitrogen oxides (NOx) emissions, which contribute to illegal levels of NO2.

Historically, taxi drivers have had a limited choice of heavy diesel vehicles to use and this has led to the taxi fleet becoming a significant contributor to poor air quality, particularly in central London. We have encouraged the design and development of new technology for taxis and in 2017 the first zero emissions capable taxi model was introduced into London. Since 1 January 2018, we no longer license new diesel taxis in London and all vehicles presented for inspection for the first time must be zero emission capable. Despite this vital step, we estimate taxis currently contribute to a quarter of all harmful NOx emissions emitted by road transport in central London and, this year, they will be the largest road transport source of NOx emissions from road transport in central London.

There is currently a maximum 15 year vehicle age limit for taxis and we are rolling out electric vehicle charging infrastructure across London, with many charging points dedicated to the taxi trade to help support the take-up of new vehicles. We also have a taxi delicensing scheme to provide financial incentive and help remove Euro 3, 4 and 5 taxis from the fleet. We have recently revised this scheme to enhance the payments offered to taxi vehicle owners with up to £10,000 available to the first 1,250 drivers. But the urgent need to improve London’s air and protect Londoner’s health requires that we go further. 

We are looking across all modes of transport to address London’s air quality challenges and the taxi trade must do its part too. 

About our consultation

This consultation contains proposals to:

  • Mandate the maximum taxi operating age from 1 November 2019 Currently, taxis are allowed to be relicensed for 12 months up until the day before the taxi reaches 15 years old. In practice, this means that taxis can operate beyond the actual maximum age limit, often for a full 12 months (for vehicles being relicensed the day before its age limit is due to expire). We propose to make the maximum operating age the same as the relevant age limit for all licensed taxis in 2019. This would ensure that no taxi is licenced to operate over its relevant maximum age limit (e.g. into its 16th year under the current 15 year age limit).
  • Introduce a new age limit for taxis over a phased period of time from 1 November 2020 We propose that the maximum taxi age limit be reduced to 12 years by 2022 for Euro 3, 4 and 5 taxis. We plan to reduce the age limit in phases, to give taxi owners/operators time to plan ahead and propose reducing the maximum age limit by one year, each year, until 2022. The maximum age limit for Euro 6 and ZEC taxis, as well as those newly converted to LPG would remain at 15 years. 
  • Remove taxi age limit exemptions from 1 November 2019 We also propose removing the age limit exemptions for alternative fuel conversions, historic and classic/niche vehicles and for hardship/personal circumstances.

We explain more about our proposals below, including the benefits they would have in reducing harmful NOx emissions in London. Further details about our proposals, expected emissions savings and an explanation of the likely significant impacts our proposals could have on the taxi trade and its users, as well as on pedestrians and other road users are contained in the ‘Consultation Proposals for reducing emissions from London’s taxis: Information and Integrated Impact Assessment’.

We would like to know if you have alternative suggestions regarding how we could reduce harmful NOx emissions from taxis, either to the same extent or better, in place of these proposals. We would also like to know if you think our proposals might have additional impacts or affect other groups we have not identified through our Integrated Impact Assessment. We are interested in any other thoughts or concerns you might have about our proposals.
 
You can submit your thoughts to us by:  

The closing date for comments is Friday 26 April 2019.
 
What else is TfL doing to improve London’s air quality?
 
Given the seriousness of the issue and the complexity of its causes, a range of solutions are necessary to address London’s very poor air quality. We have described below some of the initiatives we have developed to improve London’s air quality. This isn’t an exhaustive list, and we will need to continue to develop new proposals to further improve London’s environment.
 
The Ultra Low Emission Zone (ULEZ) will be introduced in April 2019.  All vehicles which do not meet strict emissions standards will need to pay a charge: £12.50 a day for cars, vans and motorbikes and £100 a day for lorries, buses and coaches. It will initially cover the same area as the Congestion Charging Zone, but it will be expanded to cover inner London, up to the north and south circular roads, in October 2021. The ULEZ will operate 24 hours a day, 365 days a year. In October 2020, the London-wide LEZ standard for heavy vehicles will also be tightened.
 
There is already a 10 year age limit for PHVs and from 1 January 2020 all new PHVs licensed for the first time must be ZEC. All PHVs must pay the daily ULEZ charge if they do not meet the required emissions standards; although designated wheelchair-accessible PHVs will be exempt from the charge until October 2025. In late 2018 the Mayor announced that PHVs which are not designated wheelchair accessible, or which do not qualify for the new Cleaner Vehicle Discount, will need to pay the daily Congestion Charge from April 2019. 
 
Taxis remain exempt from both the Congestion Charge and the ULEZ. This is due to the way they are regulated and the unique role they play in providing accessible trips in the capital. No changes to these arrangements are proposed in this consultation.
 
We are also taking a number of steps to reduce emissions from the London bus fleet. These include introducing new Low Emission Bus Zones, as well as continuing the roll-out of 3,000 Ultra Low Emission Double Deck buses to central London by 2019.
 
The Mayor's Transport Strategy, which was published in March 2018, includes proposals for a range of further environmental improvement initiatives. These include expanding the electric vehicle charging network and introducing new Town Centre Zero Emission Zones. It also sets a target that 80 per cent of all trips in London should be made on foot, by bike or on public transport by 2041, which would help to reduce harmful emissions. In the longer term, it aims for London’s entire transport network to be zero-emission by 2050.
 
London’s transport networks, including the bus, taxi and private hire fleets, must all do their part so that we can protect London’s must vulnerable people from the harmful effects of pollution.
 
Reducing taxi emissions in London
 
We estimate that taxis currently contribute a quarter of all harmful road transport NOx emissions in central London. This is expected to increase further, and by 2020 taxis are likely to be the biggest source of road transport NOx emissions if we do not take additional action to clean the fleet. Taxis also currently produce 33 kilotonnes of Carbon Dioxide and 2.8 tonnes of harmful PM10 emissions (this information was taken from the London Atmospheric Emissions Inventory (LAEI) and TfL Taxi fleet data.
 
NOx is produced when fossil fuels, particularly diesel, are burnt. It is harmful to human health and contributes to climate change. By law, the UK must reduce NOx and other harmful emissions as quickly as we can. In order to achieve air quality compliance by 2025, London must reduce taxi emissions by 65 per cent (on 2013 levels). This target is included in the Government’s air quality plan for tackling roadside NOx emissions (see paragraph 139(e)), which states that no new diesel taxis will be licensed from 1 January 2018, with an expectation of 9,000 zero emission capable taxis by 2020.

The previous approach, developed with the taxi trade, was to encourage taxi owners to delicense older and dirtier taxis, with age-based payments of up to £5,000, and provide grants to support drivers with purchasing a new ZEC model. The previous Mayor set a target that there should be 9,000 ZEC taxis operating in London by 2020. The current Mayor adopted this target which is the equivalent of reducing NOx emissions from the fleet by 45 per cent (based on 2013 emissions).

Unless we take further action now, we currently expect to reduce taxi NOx emissions by less than 10 per cent by 2020. At the time of starting this consultation, there are a little over 1,100 ZEC taxis operating in London. The original delicensing scheme, which was launched in 2017 has had limited impact with around 200 payments requested by taxi owners/operators. To encourage use of the delicensing scheme we have recently significantly enhanced it to make it more attractive to taxi owners, with top payments of £10,000 – double the previous scheme – available to the first 1,250 owners. The enhanced delicensing scheme was launched on 14 January 2019, and has been expanded and restructured in response to high levels of uptake and stakeholder engagement in developing these proposals. There is more information on the scheme in the following section. We believe however that we need to do more to remove the oldest taxis from the fleet.

Mandating maximum operating age limits

By law, taxi vehicle licences may only be granted for a period of 12 months and we cannot grant a vehicle licence for a shorter duration (e.g. 8 months).  At present, a taxi has been allowed to be licensed for 12 months at any point before it reaches 15 years of age, effectively providing a 16th year of operation.

We propose that from 1 November 2019, the maximum operating age limit would be strictly mandated so that taxis would not remain licensed and in operation beyond their respective age limit. This will mean changing the way we enforce maximum age limits. This proposed change will apply to all licensed taxis, including those whose age limit reduces and to any taxis with an age limit exemption. To be clear, under the current 15 year age limit a taxi will need to get a new licence before its 14th birthday in order to operate into its 15th year. In this example, a vehicle owner may choose to surrender their taxi vehicle licence early and have the vehicle inspected before its 14th birthday in order to obtain a new 12 month licence taking the vehicle up to its 15th birthday.   

Taxis that are currently 14 years old, or that will turn 14 years old before 1 November 2019, when we propose this change is made, would be affected by this change. After this point, they would no longer be able to relicense their vehicle. Until then current arrangements apply and so it is open to operators before 31 October 2019 to either (a) surrender and relicense their vehicle for a full 12 months, allowing it to operate into its 15th year, or (b) to apply for a de-licensing payment of £1,000. 

We estimate that implementing this proposal in 2019 would reduce taxi NOx emissions in central London by up to 14 per cent. Further information is provided in the Integrated Impact Assessment.

If confirmed, our Conditions of Fitness will be clarified to reflect this tighter approach and guidance will be published to taxi owners to assist them in understanding how this would work. 

Reducing taxi age limits

Taxi vehicle age limits are calculated from the date of the vehicle’s first registration with the DVLA under the Vehicle and Excise Registration Act 1994. The maximum age limits for vehicle licencing purposes are set out in section 5A of TfL’s Conditions of Fitness (http://content.tfl.gov.uk/taxi-conditions-of-fitness-update.pdf). 

In 2015, we consulted on proposals to reduce taxi age limits, including options to reduce the age limit to 10 or 12 years. Following the consultation we decided to retain a 15 year age limit for taxis, but also to introduce a delicensing scheme available for taxis over 10 years old. At the time, we explained that:  

  • Progress on the delicensing and ZEC uptake would be monitored annually and reviewed in early 2020, or sooner if necessary
  • If it was apparent there has been insufficient progress, and that further urgent measures from the taxi fleet would be required to address air quality in London, then a reduction in the mandatory age limit (for example to 10 years) could be necessary, subject to further consultation.   

It is clear now that the target of 9,000 ZEC taxis or a 45 per cent reduction in harmful taxi NOx emissions will not be reached. In fact, we are on track to reduce taxi NOx emissions by less than 10 per cent by 2025, in breach of our legal obligations.
 
In developing our proposals, we considered a range of options to reduce taxi NOx emissions, including introducing a blanket 12 year age limit in 2020. On balance, we consider that reducing the age limit for certain taxis is the right approach. It would provide the air quality improvements that London needs by removing the oldest vehicles from the fleet as well as providing the taxi trade with time to prepare for the changes and make vehicle purchasing and delicensing choices in the knowledge of future changes.
 
Our core proposal is to reduce the maximum allowable age limit for Euro 3, 4 and 5 taxis to 12 years by 2022. We would reduce the maximum age limit by one year, in November of each year until 2022, as shown below:

We propose retaining a 15 year maximum age limit for taxis which:  

  • Meet the Euro 6 standard for emissions (same as the ULEZ), or
  • Which have been newly converted to run on Liquid Petroleum Gas (LPG), or
  • Meet the ZEC taxi requirements. 

In addition, taxis which were granted a five year extension to their age limit under the previous LPG conversion age limit exemption would not be affected.  This five year extension will not apply to any newly converted taxis to LPG, however it is proposed that they be subject to a 15 year maximum age limit and not affected by the phased reduction in age limits.

If confirmed, our Conditions of Fitness will be changed to reflect the above changes. 

In developing this proposal we have tried to find a balance between achieving the reductions in taxi NOx emissions we need to deliver, and reducing as much as possible the impacts on taxi owners and drivers by allowing them to plan ahead. We believe that by reducing the age limit gradually and offering an enhanced delicensing package, we have achieved that balance. We would like to know your thoughts on this proposal.
 
We calculate that this proposal, together with the new delicensing scheme, would enable us to deliver the 65 per cent reduction in harmful taxi NOx emissions we must deliver by 2025. Most owners of diesel taxis would be affected by our proposals. 
 
Removing the alternative fuel, historic and classic/niche and hardship age limit exemptions
 
Although the maximum taxi age limit is 15 years, a limited number of exemptions to this have been available. The Conditions of Fitness allow for exemptions and extensions to the maximum age limit where we consider it is reasonable following a request by an applicant. 
 
We have reviewed three of the existing exemptions:   

  • Alternative fuel conversions – this is available for taxis which have been converted to LPG, compressed natural gas (CNG) or biomethane;
  • Historic and classic/niche – this was available for Asquith taxis;
  • ‘Hardship’ exemption – this was available in certain limited circumstances and to taxi drivers who could demonstrate that that they should be allowed to extend the length of time their taxi was licensed for.

We propose to end the alternative fuel exemption to the taxi age limit. To date no taxis have been converted to CNG or biomethane and only 69 taxis have been converted to LPG. Taxi owners who have already converted their vehicle to LPG at their own expense will retain their current exemption and will not be affected by this proposal. A new LPG conversion grant will be available for a limited number of younger, Euro 5 taxis which emit high levels of NOx. This will help reduce emissions from these younger taxis and is described more in the following section. Newly converted LPG taxis will have a 15 year age limit.
 
We propose to remove the exemption for historic and classic/niche taxis. This exemption was introduced to allow Asquith taxis to operate for an additional five years. However, there are no longer any licensed taxis which are eligible for this exemption.
 
We also propose to remove the hardship exemption. This exemption was introduced in 2012 to allow for consideration, on a case by case basis, for an exemption to the age limit to allow an additional 12 month license. This was for taxi vehicle owners in cases of exceptional hardship e.g. medical.

The impacts of our proposals

We have published within this consultation a supporting factsheet: ‘Consultation Proposals for reducing emissions from London’s taxis: Information and Integrated Impact Assessment’. This explains all the above proposals in more detail, including their impacts. In summary, by 2025 we expect our proposals to contribute to a reduction in central London taxi tail-pipe:  

  • NOx emissions by at least 65 per cent
  • CO2 emissions by 60 per cent
  • PM10 emissions by 95 per cent 

These figures compare taxi emissions in 2025 against taxi emissions in 2013, assuming that we implement all of the proposals we have described in this consultation.
 
Taxi drivers, who often spend significant amounts of time in central London and along major road corridors, would also be significant beneficiaries of improved health due to decreased emissions in these areas.
 
Help and assistance for taxi drivers

In January 2019 we launched a significantly improved delicensing scheme for taxis.  The new scheme works on a first come, first served basis and provides up to £10,000 to drivers to delicense their Euro 3, 4 and 5 vehicles early and so contribute to the reduction in taxi NOx emissions we must achieve. Initially, 250 payments of £10,000 were available. However, in response to high levels of uptake and stakeholder engagement in developing these proposals, the scheme has been expanded and restructured, with 1,250 payments of £10,000 now available with more than 2,000 additional payments available at other levels. Details of the expanded scheme can be found below:

We have also doubled the initially proposed £2.5 million fund to help owners of Euro 5 taxis to convert their taxis to LPG, which is a much cleaner fuel system. 1,000 owners of Euro 5 vehicles can now apply for a LPG conversion grant.   

Independent testing shows that an average TX4 taxi emits over 70 per cent less NOx after being converted to run on LPG.  Trials also show that drivers of LPG-converted taxis can save around £200 a month in fuel costs.  We propose that a 15 year maximum age limit would apply to newly converted LPG taxis, so the fuel savings would enable taxi drivers to recoup the conversion costs while also reducing their contribution to damaging NOx emissions in London.

The Government also offers a Plug-in grant which reduces the cost of purchasing a ZEC taxi by £7,500.
 
There is infrastructure in place to support those driving ZEC or LPG taxis.  There are around 50 LPG refuelling stations in the London area, for example. There are also around 2,800 public electric-vehicle charge point units. We have delivered more than 150 rapid charge points, many of which are dedicated solely for use by taxis, and plan to have installed 300 by the end of 2020.
 
In May 2018 the Mayor launched the Electric Vehicle Infrastructure Taskforce to consider the delivery plan for electric vehicle infrastructure in London over the next six years to 2025. The taxi trade have contributed to the work of the Taskforce, and their charging requirements have been considered when determining the type, quantity and location of charging provision needed in London.

Next steps

Once our consultation closes on 26 April 2019 we will collate all of the issues raised and consider them in full. Once we have done so we will publish a Consultation Report, which will include a list of the issues raised and our response to them and make clear whether or not TfL will introduce the proposals as we have described them in this consultation, or with modifications. We expect to publish this report later in 2019.

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 Friday 26 April 2019.

Alternatively, you can:

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

Areas

  • All Areas

Audiences

  • Anyone from any background

Interests

  • Taxis
  • Private hire
  • Air Quality