The operators in the room were split between the ones who abide strictly by the rules, and the
others who choose to disregard the law and carry 10, 12, 14 and even 22 passengers.
Unfortunately, when the inevitable happens and a limousine carrying more than eight passengers
is involved in a fatal accident, there will be screams from everyone. Starting with the Insurance
companies, who whilst being very quick to take your money will be very slow to pay out on an
unlicensed and therefore illegal vehicle. Next to scream will be the Vehicle Inspectorate who,
whilst acknowledging the rules, are not policing them adequately. Then the Police, then finally the
licensing authorities. God help the operator who is involved in the first test case.

Unfortunately a document had been produced some time ago from New Scotland Yard by
an official representative of the Police stating erroneously that it was "Alright to carry ten
passengers". This was an embarrassing and rather maverick statement which has sent a number
of operators down the route of both buying and operating ten passenger limousines. The police
should ultimately accept responsibility for this blunder. Although the person responsible has now
retired from the force the letter was officially produced by their representative, and as such there
is a liability for the issue of the letter.

Traffic police in London were represented on the panel but, by their own admission, the copper
on the street knows very little about the rules regarding limousines. Regrettably, I have found
that the traffic cop who stops you next is likely to know less about the rules than you do. They
appeared to be more concerned about the use of drugs within the limousine, and the statement
that they would be "stopping limousines in the West End and putting sniffer dogs into them" did
absolutely nothing to endear them to the operators in the room. Definitely an own goal!

Where do you go from here if you operate in an area that is still wearing blinkers? Do you
simply go out of business, or operate without a licence? We are still working under legislation
that was drawn up over a quarter of a century ago. The minister at the time was famed for his
statement that "Chauffeurs only drive wedding cars and hearses, so we do not need to consider
them under the act" How those words have come back to haunt the trade.

During the opening statements from the top guns, no less that three of the speakers referred to
a "level playing field". Whilst these sentiments are admirable, there is nowhere less on the level
than Britain for licensing rules for limousine and chauffeured car operators. At my last count
there were 387 local authorities with the power to grant licenses (according to one of the local
authority members at the meeting , this has now risen to over 400). This is where the problem
starts. Under the "Local Government, Miscellaneous Provisions Act (1976)", each Local
Authority has the legal power to interpret the act as they see fit. There are therefore 400
interpretations of the Act. The fact is that, as we speak, over 55% of the local Authorities will
not licence American stretch limousines and/or left hand drive cars.

If you operate in an area where there are pro-active private hire licensing departments then
by all means talk to them and licence your cars if you wish. The only alternative is to register
as a PSV operator and work under the coaching rules with the attendant problems of the
minimum 15 mile rule and the individual fares. This works well for a lot of our members in rural
areas but would present problems for London and major city operators. This is an area where
all the departments concerned must address the problem It will be difficult for prosecutions to
be made against unlicensed operators where the Authorities have not provided a system under
which they can be licensed. I sincerely hope that Don Webster and his colleagues report back
their findings and ask for help for the people involved on both sides of the fence. We
desperately need a proper framework aimed at both American stretched limousines and
chauffeur driven cars generally. It is worth noting that, nationally, the average taxi and private
hire bill is £3.73 and the journey lasts around seven minutes And this is the same framework
that they want to license limousines and chauffeur driven cars under? The time has come for
government to acknowledge that we are in a rapidly growing industry and not to ignore us or
try to hedge us in with inadequate, antiquated and inappropriate rules Limousine Sales.

A lot of the operators present were pushing for licenses generally to cover ten passengers.
Again, all that we can do is see what changes can and will be made in the future; subject to
a willingness for change from Government. It is worth a note of caution on "ten seater
limousines". We all see adverts for ten seater limousines, and the American definition of a ten
seater is NOT ten passengers, it is eight passengers in the rear plus one in front and the driver.
This is the general arrangement on a 120" limousine. Also we have had reports of cars being
over the maximum design weight for the vehicle. This usually happens when someone is going
to the airport with eight passengers plus luggage. You can very easily be way over the design
weight, axle weight, and most importantly, over the tyre rating.

SVA tests were the subject of much discussion, starting with the fact that some importers
along with A1 Limousines are registering their cars without getting an SVA test done. There
appears to be a gaping hole in the net, and whilst the majority of people work extremely hard
to obtain an SVA test, it seems that when you license your car, the SVA certificate disappears
with the paperwork and is never referred to again. How is the buyer of a second hand limousine
registered in Britain to know whether an SVA ever existed for their vehicle? When you possess
a V5 document you appear to be home free! Input is definitely needed from Don Webster
and Ian Corfield on this matter.

There was a lot of debate as to what constituted a seat in a limousine. References kept being
made to the 400 mm (16") minimum rule being the guideline. However, the point was made that
this is only a minimum standard. If you can demonstrate that you only carry eight passengers
then the size of the seat is largely irrelevant.

There is also the requirement for a 300 mm X 300 mm (12" X 12") level platform in front of
each seat for your feet. This effectively precludes the J seat, as there is no foot space. You
can also discount the central rear seat because of the transmission tunnel (you can take the lap
belt out for good measure) and in many cases the seat nearest the bar which does not have the
required foot space. Many times this has demonstrated that ten seats in the rear can be reduced
to seven by correct use of the tape measure.

In summary the meeting served to restate the rules that we were already aware of, and did not
offer any light on future changes. It did however put a shot across the bows of the London and
Home counties operators that the authorities will stop and prosecute anyone carrying over 8
passengers. Forewarned is forearmed, and anyone who ignores this warning does so at their
peril.

At least this is a starting point, and hopefully a system of national licensing will eventually emerge
from the gloom. As they say "watch this space".

The notes contained above are only the author's own view of the proceedings and are not
intended to be taken as a legal document. Operators are required to satisfy themselves as to
their own legal position.

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