Our Ref:         FOI-3855-1920
 
Thank you for your request received by Transport for London (TfL) on 11 March 2020 asking for information about licensing for Private Hire Vehicles (PHVs). I apologise for the delay in our response.
 
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our Information Access Policy. You asked:
 
We are keen to understand why TFL (and/or a company named NSL acting on behalf of TFL) appear to have adopted a policy of refusing to approve PHV Licence applications in respect of vehicles imported from Japan. To that end, please provide all information held by or on behalf of TFL that concerns any consideration, discussion, policy or decision on the part of TFL and/or NSL (between 1 January 2020 and today’s date) to reject PHV Licence applications for vehicles imported from Japan (including but not limited to any direction by TFL to NSL in respect of the same).
 
We also understand that TFL is refusing to book PHV Licence assessments in respect of vehicles imported from Japan. To that end, please provide all information held by or on behalf of TFL that concerns any consideration, discussion, policy or decision on the part of TFL (between 1 January 2020 and today’s date) to refuse to book assessments in respect of vehicles imported from Japan.  
 
Following an extensive consultation process, to help reduce emissions in London and improve air quality for everyone, we made changes to the licensing requirements for private hire vehicles (PHVs). As a result, from 1 January 2020 all new PHVs (under 18 months old) that are presented for licensing must be zero emission capable (ZEC) and meet Euro 6 emission standards when licensed for the first time. In addition, all PHVs over 18 months old must have a Euro 6 (petrol or diesel) engine when licensed for the first time.
 
We have identified a potential issue with vehicles that are imported from Japan relating to the emissions standards of these vehicles, which are subject to different testing regimes and may not meet the Euro 6 standard that is required for PHV licensing.
 
As a result and until we are satisfied a vehicle meets the appropriate emission standards, we are not be licensing vehicles that have been imported from Japan. We are currently working with DVSA to establish whether the vehicles you have written to us about meet our new emission standards for PHVs.
 
More information on our ZEC requirement and the reasons behind its introduction can be found here:www.tfl.gov.uk/green-PHVs.
 
Unfortunately to provide the information you have requested would exceed the ‘appropriate limit’ of £450 set by the Freedom of Information (Appropriate Limit and Fees) Regulations 2004.
 
Under section 12 of the FOI Act, we are not obliged to comply with a request if we estimate that the cost of determining whether we hold the information, locating and retrieving it and extracting it from other information would exceed the appropriate limit. This is calculated at £25 per hour for every hour spent on the activities described.
 
We have estimated that it would take over 18 working hours to retrieve and compile the information you have requested. This is because your request is very broad and correspondence is likely to be held across a large number of individuals and require searches against multiple identifying keywords to attempt to locate all emails that fit within the scope of your request. A search on such broad terms would generate a significant volume of material requiring manual review. For example, a preliminary search using the keyword “NSL” produced in excess of 4,000 hits, the vast majority of which are likely to be not relevant. However we would need to review each of them to determine whether the email relates in any way to the subject matter you are interested in and then extract and collate the results. There are likely to be additional searches required using alternative keywords that would exacerbate the burden further.
 
We hope that the explanation above provides sufficient background information to this subject matter. But, as explained, we are unable to provide the specific information sought within the cost limit.

Please note, the Government has announced a series of measures to tackle the coronavirus. It is essential for London, that we continue to provide a safe transport network for essential journeys.
 
In current circumstances, we are not able to answer FOI requests readily and we ask that you please do not make a request to us at present.
 
Answering FOI requests will require the use of limited resources and the attention of staff who could be supporting other essential activity. In any event, please note that our response time will be affected by the current situation.
 
Please see the attached information sheet for details of your right to appeal.

Yours sincerely

Gemma Jacob
Senior FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London

[email protected]