Dear Residents of Conwy,

We need your help to bring fairness and balance to our local taxi / hackney carriage licensing system. While we fully support ensuring accessibility for wheelchair users, the current regulations are causing serious problems for drivers, businesses, and passengers alike. These rules mandate extremely expensive seven-seater wheelchair-accessible vehicles (WAVs) with side wheelchair access.

This solution, while intended to help wheelchair users, is counterproductive as it limits the number of WAV taxis available on the roads. The high cost and restrictive requirements discourage drivers from entering or staying in the trade, ultimately reducing accessibility for wheelchair users and creating significant challenges, including:

Drivers are struggling financially, often unable to replace their vehicles, leading to an increase in older, less safe cars on the roads.

Passengers are being underserved. Elderly and less mobile residents often struggle to use large vehicles, preferring smaller, safer cars.

The environment is suffering. Larger vehicles consume more fuel, release more emissions, and current regulations make it impossible to license eco-friendly electric taxis due to the side-access requirement.

Our petition outlines how these regulations are creating barriers and proposes solutions to create a fairer, more inclusive system. These include allowing rear-access WAVs, permitting smaller vehicles, and ensuring all businesses meet proportional WAV requirements.

We believe in a system that benefits everyone—wheelchair users, elderly passengers, drivers, and the environment.

Please read the petition below and sign to show your support. Your voice matters in helping us advocate for a safer, greener, and more equitable taxi system in Conwy. Together, we can make a difference!

 

To:
Conwy Borough Council

Council Offices
Coed Pella
Conwy Road
Colwyn Bay
LL29 7AZ

We, the undersigned, request Conwy Borough Council to review and amend its current taxi (hackney carriage) licensing regulations. While we fully support ensuring accessibility for wheelchair users, the existing requirements—particularly mandating costly seven-seater wheelchair-accessible vehicles (WAVs) with side wheelchair access—are causing significant challenges for drivers, businesses, and passengers.

These regulations not only limit the availability of WAV taxis on the roads but also place a disproportionate financial burden on small businesses and independent drivers. They fail to balance the needs of all passengers, harm the environment, and lead to an inequitable and unsustainable taxi industry in Conwy.

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Key Issues with Current Regulations

1. Limited Support for Wheelchair Users - While the intent of requiring WAVs is commendable, the specific requirement for side wheelchair access is overly restrictive. Most electric vehicles (EVs) have batteries installed under the floor, making side access ramps impossible to install. As a result, electric WAVs cannot currently be manufactured to meet the Council's licensing requirements, eliminating eco-friendly options from the market.

Rear-access WAVs, which are widely available, more cost-effective, and equally functional for wheelchair users, are excluded under current regulations. This unnecessarily limits the number of WAVs on the roads, reducing availability for wheelchair users.

2. Accessibility for Non-Wheelchair Users

Many elderly passengers or those with mobility challenges find it difficult to board large WAVs, which are higher off the ground than standard cars. These individuals prefer smaller vehicles that are easier to enter and exit, safer, and more comfortable.

By mandating large WAVs, the Council unintentionally excludes a significant portion of the population who rely on taxis for safe and convenient transportation.

3. Financial Burden on Drivers and Businesses

The cost of purchasing a WAV with side wheelchair access starts at £52,000, with some models exceeding £60,000. Financing options require hefty deposits and monthly payments over £1,800.

For independent drivers or small businesses operating in areas like North Wales, where taxi rates are low, these costs are unsustainable. Many drivers are forced to leave the trade, reducing taxi availability overall.

4. Safety Concerns

Many of the Council-approved WAVs, such as the Renault Trafic, have low safety ratings (e.g., two out of five stars in crash tests), especially when older models with high mileage are used. In contrast, high-quality, smaller vehicles like the Mercedes S-Class or Audi A6 consistently achieve five-star safety ratings but are disallowed under current regulations.

This situation results in an ironic outcome: older, less safe vehicles with hundreds of thousands of miles on the odometer can be licensed, but brand-new, top-rated cars cannot.

5. Environmental Impact

Larger WAVs have higher fuel consumption and emit more greenhouse gases compared to smaller vehicles. For example, a seven-seater WAV may consume up to 50% more fuel than a smaller, efficient car.

Current regulations make it impossible to license electric WAVs because the batteries in EVs are installed under the floor, where side wheelchair access ramps must be fitted. This design limitation prevents manufacturers from meeting the Council's requirements, effectively excluding EVs from the WAV market.

By revising the side-access requirement and encouraging rear-access WAVs, the Council could enable the licensing of electric taxis, significantly reducing the environmental footprint of the taxi fleet.

6. Discrimination Against New Drivers

Drivers with existing licenses for small cars are allowed to replace their vehicles with similar ones, avoiding the WAV requirement. New drivers, however, must comply with the expensive WAV regulations.

This unequal treatment creates a two-tier system that unfairly penalizes new drivers, discouraging them from entering the trade and limiting competition.

7. Illegal Taxi Plate Trade

The disparity in regulations has led to a black market for taxi plates. Drivers with old small-car licenses can sell their plates to others, often for significant sums, without paying taxes. This practice undermines the integrity of the licensing system and deprives the Council of potential revenue.

8. Increased Costs Without Fair Pricing
Drivers of larger, more expensive WAVs currently earn the same fare as those operating smaller, cheaper cars. This unfair pricing system discourages investment in WAVs and other large vehicles, exacerbating accessibility challenges.

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Our Proposed Solutions :

1) Allow "Small" Cars to Be Licensed -  Permit small, non-WAV vehicles to be licensed as Hackney carriages for independent drivers or single-vehicle operators. This would support small businesses, provide affordable options for drivers, and cater to the preferences of elderly and non-wheelchair users.

2. Implement Proportional WAV Requirements

Require businesses operating multiple vehicles to ensure a proportion of their fleet is WAVs, starting with their second vehicle. Large businesses should transition over five years to replace all non-WAV vehicles with WAVs.

3. Eliminate the Side Wheelchair Access Mandate

Allow rear-access WAVs to be licensed. These vehicles are cost-effective, functional, and compatible with electric vehicles. This change would promote sustainability and increase the availability of WAV taxis.

4. Promote Competition and Fairness

Ensure all drivers, new and existing, are subject to the same licensing standards. Removing the preferential treatment for existing small car license holders would create a level playing field.

5. Encourage Sustainability

Support the adoption of electric vehicles by revising licensing requirements and providing incentives such as reduced fees or grants. This would align Conwy’s taxi fleet with modern environmental standards.

6. Introduce a Two-Tier Charging System

Implement a pricing structure that reflects the type of vehicle and passenger capacity. 

This system would allow drivers of larger WAVs to charge appropriately for their higher operating costs, promoting investment in accessible and versatile vehicles. 

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Conclusion

The current regulations are inequitable, unsustainable, and fail to meet the diverse needs of Conwy's residents. By adopting these proposed changes, the Council can foster a fair, inclusive, and environmentally conscious taxi system that benefits all stakeholders.

We urge Conwy Borough Council to act now and modernize taxi / hackney carriage licensing regulations for a more accessible and equitable future.