Hackney Carriage and Private Hire Licensing
With effect from [insert date]
1.0 Approved by the Executive of North Yorkshire County Council on [insert date] with effect from [insert date]
Contents
·
Disability in the UK and in North Yorkshire
Hackney carriage and private hire drivers
Complaints to private hire operators
Hackney carriage and private hire vehicles
Wheelchair accessible vehicles
Overcoming the barriers to providing wheelchair accessible services
List of designated wheelchair accessible vehicles
Proposed measures to satisfy the ISP objectives
According to the Department for Transport’s Taxi and Private Hire Vehicle Statistics, England (2023)[1], 2% of all trips for those with mobility difficulties involve the use of hackney carriage or private hire services, compared to just 1% for those without mobility difficulties.
Licensed vehicles are among the most popular modes of transport for disabled people as they provide a door-to-door service with scope for individual assistance with the particular needs of a disabled passenger.
Many disabled people are particularly reliant on hackney carriage and private hire services and therefore the Council is committed to ensuring the availability of an accessible, affordable service.
In formulating the Plan, we have considered the needs of people whose access requirements are apparent when using public transport, such as wheelchair users and assistance dog owners. We have also considered the needs of people with less-visible disabilities, including autistic people or those with mental illness.
Disability in the UK and in North Yorkshire
According to the Office of National Statistics’ Census 2021 results, 17.7% of the population of England were disabled.
The proportion of disabled people varied across North Yorkshire as follows:
Craven 15.2%
Hambleton 15.4%
Harrogate 14.9%
Richmondshire 15.5%
Ryedale 15.6%
Selby 16.1%
Scarborough 20%
Source: Office for National Statistics – Census 2021[2]
According to more recent estimates, around 20% of the UK population is disabled and the proportion is expected to rise as the average age of the population increases[3].
As the licensing authority with responsibility for hackney carriage and private hire licensing functions, North Yorkshire Council has a duty to ensure that the public is adequately protected from any risks associated with hackney carriage and private hire services.
In accordance with section 149 of the Equality Act 2010, North Yorkshire Council must also have due regard to the need to:
· eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by the Act;
· advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; and
· foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
Licensing authorities are required under section 22(2) of the Legislative and Regulatory Reform Act 2006 to have regard to the Regulators’ Code. In accordance with the Regulators’ Code, the Council must seek to reduce regulatory burdens and support compliant business growth by ensuring that each requirement is properly justified by the risk it seeks to address, balancing the cost of the requirement against the benefit to the public.
The Council must therefore balance its responsibilities and deliver licensing services in a fair, safe and legal way.
In accordance with the Council Plan (2023-2027), to demonstrate commitment to equality, diversity and inclusion as an organisation, show leadership across the county and work in partnership to improve equality, diversity and inclusion, the Council will:
· demonstrate political and officer leadership;
· work in partnership to achieve shared priorities;
· use equality impact assessment as part of the decision-making process; and
· monitor, review and scrutinise performance against our objectives
One of the key commitments in North Yorkshire Council’s Local Transport Plan is to “consider our duties under transport and equalities legislation to decide whether the commercial network caters sufficiently for the needs of the community having regard to the transport needs of members of the public who are elderly or disabled. We will consider whether there is a need to procure additional services and what funding is available to deliver these”.
In implementing this Inclusive Service Plan, the licensing authority’s objectives are:
· To improve the access and availability of licensed vehicles sufficiently to satisfy the demand for accessible services from wheelchair users and non-wheelchair users.
· To promote passenger rights by providing information in formats that all passengers can access in relation to the service that can be expected when travelling in hackney carriage and private hire vehicles.
· To deliver effective enforcement to ensure that users of licensed vehicles can be confident that any reports of non-compliance will be appropriately addressed.
· To enhance the understanding of all licensed drivers, proprietors and operators in relation to the needs and legal rights of disabled people.
In preparing this Inclusive Service Plan, the Council has consulted with the following stakeholders:
· Licence holders
· Passenger Transport
· North Yorkshire Police
· Disability action groups
· Other Council departments
· Service users
Hackney carriage and private hire drivers
The licensing authority must be satisfied that every licensed driver of a hackney carriage or private hire vehicle is a fit and proper person to hold a licence.
In accordance with the Council’s Hackney Carriage and Private Hire Licensing Policy, where an applicant has a conviction involving or connected with discrimination in any form, a licence will not be granted until at least seven years have elapsed since the completion of any sentence imposed.
The Equality Act 2010 places the following duties on licensed drivers to protect the rights of disabled people to access hackney carriage and private hire services:
· The driver of a non-wheelchair accessible hackney carriage or private hire vehicle must accept the carriage of any disabled person and must not charge extra for doing so[4]. This applies to any disabled passenger, including wheelchair users (with the assumption that the wheelchair user transfers to a passenger seat to travel).
· The driver of any hackney carriage or private hire vehicle must provide reasonable assistance to any disabled passenger[5]. This requirement does not apply to any driver who has been granted an exemption from the mobility assistance duties on medical grounds.
· The driver of any pre-booked hackney carriage or private hire vehicle must assist any disabled person to identify and find the vehicle and to refrain from charging them extra for doing so, provided the driver is made aware that the passenger requires such assistance[6].
· The driver of any hackney carriage or private hire vehicle must accept the carriage of an assistance dog and must not charge extra for doing so[7]. This requirement does not apply to any driver who has been granted an exemption on medical grounds.
· The driver of a designated wheelchair accessible hackney carriage or private hire vehicle must, when requested to do so, carry a wheelchair user whilst seated in their wheelchair without charging extra. If the passenger chooses to sit in a passenger seat, the driver must carry the passenger and the wheelchair in safety and in reasonable comfort. The driver must also provide reasonable assistance to any wheelchair user unless they have been granted an exemption from the mobility assistance duties on medical grounds[8].
According to the Department for Transport’s Taxi and Private Hire Vehicle Statistics, England (2023)[9], 62% of all licensing authorities require taxi drivers to undergo disability awareness training.
The Council acknowledges the need to ensure that licensed drivers have a reasonable understanding of the barriers that disabled people may face when using licensed vehicles, and that they know how to assist people with a range of visible and less visible impairments. Accordingly, every applicant for a hackney carriage and private hire driver licence must undergo suitable disability awareness training prior to being granted a licence by North Yorkshire Council. Appropriate training must be repeated by all licensed drivers every three years.
In accordance
with the Council’s Hackney Carriage and Private Hire
Licensing Policy, licensed drivers are not authorised to drive a
wheelchair accessible vehicle unless the driver understands how to
operate the vehicle and any equipment fitted to make the vehicle
accessible by disabled persons. Furthermore, the driver must pass
an appropriate practical assessment before driving a wheelchair
accessible vehicle.
The licensing authority must be satisfied that every licensed private hire operator is a fit and proper person to hold a licence. In instances where the private hire operator is a company or partnership, the licensing authority applies the ‘fit and proper’ test to each of the directors or partners in that company or partnership.
In accordance with the Council’s Hackney Carriage and Private Hire Licensing Policy, where an applicant has a conviction involving or connected with discrimination in any form, a licence will not be granted until at least seven years have elapsed since the completion of any sentence imposed.
The Equality Act 2010 places the following duties on licensed private hire operators to protect the rights of disabled people to access private hire services:
· Service providers must make reasonable adjustments to enable disabled passengers to access their services[10].
· A private hire operator cannot refuse or fail to provide a booking for a disabled person if the reason for the refusal or failure is that the person is disabled[11].
· A private hire operator cannot refuse or fail to provide a booking if the reason for the refusal or failure is that the passenger will be accompanied by an assistance dog[12].
· A private hire operator cannot make any additional charge for the carrying out of any duty imposed on the driver of the private hire vehicle[13].
Complaints to private hire operators
In accordance with the conditions attached to a private hire operator’s licence, the operator must notify the licensing authority in writing of any complaints concerning a driver’s conduct or about a vehicle’s suitability. This includes complaints of any failure to comply with the above duties.
Individuals responsible for taking bookings and dispatching vehicles on behalf of a private hire operator do not require a licence. However, in accordance with the Council’s Hackney Carriage and Private Hire Licensing Policy, all private hire operators are required to formulate a policy on assessing the suitability of any person taking bookings and dispatching vehicles on their behalf prior to undertaking any such role.
The licensing authority has produced a template policy for these purposes, which includes guidelines for assessing staff. The template policy recommends that private hire operators do not employ any individual with a conviction relating to discrimination in any form until at least seven years have elapsed since the completion of any sentence imposed.
If a private hire operator fails to adopt an
appropriate policy for the assessment of staff, it may raise
serious doubts about their own suitability to hold a
licence.
Hackney carriage and private hire vehicles
A hackney carriage vehicle can be hailed by passengers on the roadside, it can stand on a rank to await the approach of passengers and it can be pre-booked by telephone. In contrast, private hire vehicles are licensed to perform pre-booked work only, which must be obtained through a private hire operator.
In accordance with the Council’s Hackney Carriage and Private Hire Licensing Policy, all licensed hackney carriage vehicles must have means for carrying a “reference wheelchair” and luggage sufficient for the number of passengers for which the vehicle is licensed to carry. This requirement ensures that drivers of hackney carriage vehicles licensed by North Yorkshire Council cannot, in most cases, refuse fares on the grounds that it would not have been possible for the wheelchair or mobility aids to be carried safely in the vehicle. The “reference wheelchair” is defined as 700mm in width, 1200mm in length, and 1350mm in height. Private hire vehicles, on the other hand, are not available for public hire and therefore any luggage or accessibility needs can be discussed at the time of booking.
In accordance with the Council’s current Hackney Carriage and Private Hire Licensing Policy, licensed vehicles are generally required to be no more than 10 years old at the time of a grant or renewal application. However, in order to ensure that this requirement does not have an adverse effect on the number of wheelchair accessible licensed in North Yorkshire, the age limits do not apply to designated wheelchair accessible hackney carriage vehicles.
The vehicle specification is subject to review as a proposed outcome of this Inclusive Service Plan.
The provision of a clear, simple and well-publicised process for the public to make comments and complaints about drivers, vehicles and operators will enable officers to target compliance and enforcement activity. Complaints provide a further source of intelligence when considering applications and identifying any additional training that may be required.
Accordingly, all hackney carriage and private hire vehicles licensed by North Yorkshire Council are required to display at least two adhesive signs advising passengers how to complain to the licensing authority about any licensed driver, vehicle or operator in a position that can be easily read by passengers from the front and rear of the vehicle.
Further information about how to complain is published on the Council’s website.
Wheelchair accessible vehicles
According to the Department for Transport’s Taxi and Private Hire Vehicle Statistics, England (2023)[14], 39% of all licensed hackney carriage vehicles outside London are wheelchair accessible.
According to the DfT Statistics report, metropolitan areas tended to have higher proportions of wheelchair accessible hackney carriage vehicles.
At the time of drafting this Plan, just 9% of all licensed hackney carriage vehicles in North Yorkshire were wheelchair accessible.
65% of local authorities require all or part of the hackney carriage fleet to be wheelchair accessible. Just over 20% of local authorities (59 out of 287 data sets submitted in 2023) maintain a 100% wheelchair accessible hackney carriage fleet. It is, however, of note that 54 of the 59 authorities with a 100% wheelchair accessible hackney carriage fleet are in urban areas while the other five are largely rural[15].
The proportion of wheelchair accessible private hire vehicles remains very low, at about 3% nationally.
The Council recognises that a reduction in the number of non-WAVs would raise the proportion of WAVs despite not having any positive impact on availability. On that basis, measuring the number of WAVs as a percentage of the total fleet is not considered the most effective method of assessing availability. The ratio of WAVs:population is believed to be a more meaningful metric.
At the time of drafting this Plan, North Yorkshire Council licensed 70 wheelchair accessible hackney carriage vehicles, which represents one WAV for every 8,880 people. For context, some licensing authorities have excellent provision of wheelchair accessible hackney carriage vehicles (15 urban local authority areas have at least one WAV for every 1,000 people. In rural areas, the best WAVs:population ratios are approximately one WAV for every 2,000 to 3,000 people. In order to achieve a similar ratio for its population of 615,400, North Yorkshire would need between 200 and 300 WAVs (roughly three to four times the current number).
The Council acknowledges that, as is the case in many parts of the country, the demand for wheelchair accessible hackney carriage vehicles is not currently being met by the trade in North Yorkshire.
According to the Department for Transport’s Taxi and Private Hire Vehicle Licensing Best Practice Guidance[16], licensing authorities should incentivise the uptake of wheelchair accessible vehicles where mandating them would be inappropriate. The Council has previously introduced incentives by waiving the licence fee and by relaxing the age limits in respect of WAVs. However, despite a slight increase in recent months, the number of hackney carriage WAVs in North Yorkshire remains low.
The Council is therefore satisfied that it must take further action to significantly improve the access and availability of licensed WAVs to satisfy the demand from wheelchair users.
The Council acknowledges the view of the Department for Transport that the licensing authority should understand the demand for mixed fleets in its area and ensure that, when issuing licences, it has the right mix of vehicles. Furthermore, some designs of wheelchair accessible vehicles may not be suitable for some ambulant disabled passengers[17].
Many journeys in North Yorkshire are in rural areas involving longer journeys over local roads and the Council recognises that saloon cars tend to give a smoother and more economical ride. However, WAVs are essential for wheelchair users who are unable to transfer from their wheelchair to the vehicle and for those who prefer to travel in their wheelchair.
The Council has a wide discretion over the types of vehicle that it may license. Without limiting the hackney carriage vehicle specification further, the demand for wheelchair accessible vehicles is unlikely to be met by the hackney carriage trade.
The costs associated with purchasing and maintaining a WAV are often higher than for saloon vehicles. Furthermore, the time taken to fulfil a WAV booking can often take longer than it would for a non-WAV to find a safe place to park, load and secure the wheelchair, offer reasonable assistance etc. With no scope to be able to make an additional charge for the service, the provision of a WAV is not perceived as economically viable for many licensed drivers and proprietors.
However, recent research has revealed that service providers may not appreciate the scale of the demand for accessible transport across North Yorkshire. On that basis, the provision of a WAV (even at greater cost) may be beneficial to service providers and service users alike.
Overcoming the barriers to providing wheelchair accessible services
The Council is satisfied that there is a demand for WAV services not being fulfilled, particularly in the more rural parts of North Yorkshire. The anecdotal evidence obtained from disability action groups and wheelchair users is supported by data, which indicates that the availability of WAVs in North Yorkshire is low. It is therefore crucial to understand the barriers faced by the hackney carriage and private hire trade when considering the provision of wheelchair accessible services.
The Council is aware of a pervading misconception among operators that there are few wheelchair users in need of accessible transport across North Yorkshire. The Council will therefore endeavour to communicate with the trade in relation to the business opportunities associated with operating WAV services.
It is widely understood that the purchase and running costs of a WAV are often higher than that of a non-WAV. However, recent research has revealed that some WAV operators have purchased and maintained WAVs at low cost with good fuel economy and with no problems or significant time or effort required to deliver the service, particularly as many of their passengers use powered wheelchairs and therefore boarding and alighting is far quicker than some may expect.
Some operators have also indicated that they have secured a good level of WAV-related business and established a clientele that would not otherwise have been available to them.
With comparably fewer competitors, there are clear business benefits to offering WAV services. The costs involved in delivering such a service can be outweighed by the additional income from fares that cannot be secured by non-WAV service providers. Drivers and operators currently providing WAV services have reported that the work is both rewarding and enjoyable.
The Council is confident that there is a general willingness among operators to provide a service for wheelchair users if a critical level of such work can be achieved. The Council therefore acknowledges the need to match the supply with the demand and this may be achieved to some extent by facilitating dialogue between the licensed trade and the end-users.
It is widely understood that vehicle manufacturers have faced a number of challenges in recent years and this has led to delays in the supply chain. While the licensing authority cannot have any influence on the availability of new and used WAVs, it may be able to provide some useful information to drivers and operators who are interested in purchasing a WAV or converting a vehicle for wheelchair accessible purposes.
List of designated wheelchair accessible vehicles
In accordance with section 167 of the Equality Act 2010, the licensing authority maintains and publishes a list of designated wheelchair accessible hackney carriage and private hire vehicles. For these purposes, wheelchair accessible means that it would be possible for the user of a “reference wheelchair” to enter, leave and travel in the passenger compartment in safety and reasonable comfort whilst seated in their wheelchair.
In accordance with statutory guidance issued under section 167(6) of the Equality Act 2010, the list of designated wheelchair accessible vehicles should provide the following information:
· the make and model of the vehicle
· the licence number of the vehicle
· whether the vehicle is a taxi or private hire vehicle
· where it is easily accessible for the licensing authority to gather and the operator has given consent, the name of the vehicle’s operator(s)
· their contact telephone number and email and/or website address
· information about the size and weight of wheelchairs that can be accommodated, including whether the vehicle can accommodate wheelchairs which are larger than the “reference wheelchair” standard
· the number of passengers that can be carried whilst seated in their wheelchairs
The licensing authority maintains and publishes its list of designated wheelchair accessible vehicle on the Council website. In the event of any requests for the information in other formats, officers will communicate with the requestor to understand their specific needs and to identify how the information could be tailored where applicable.
Where any of the above information can be published but has not yet been included on the list of designated wheelchair accessible vehicles, officers will endeavour to obtain further details and amend the list accordingly.
In accordance with the Department for Transport’s statutory guidance on access to taxis and private hire vehicles for disabled users[18], the government expects licensing authorities to take tough action where drivers or operators breach their duties under the Equality Act 2010.
The Council has committed to using its available powers to ensure that drivers or operators who discriminate against disabled passengers are held accountable.
According to the Council’s Hackney Carriage and Private Hire Licensing Policy, the licensing authority will consider the suitability of any driver or operator who receives a conviction for breaching their duties under the Equality Act 2010
The licensing authority may also consider the suspension, revocation or refusal of a licence where no prosecution proceeds, but the authority is satisfied that the driver or operator has treated a disabled passenger unreasonably. A driver or operator who wilfully fails to comply with their duties in this regard would be unlikely to remain a fit and proper person to hold a licence.
The Council is committed to ensuring that any companies and individuals delivering hackney carriage and private hire services not only satisfy all legal requirements but also raise standards to meet the needs of passengers more consistently.
The Council acknowledges its responsibility to make reasonable adjustments to remove barriers preventing disabled people from accessing hackney carriage and private hire vehicle services.
Ultimately, the Council acknowledges the need to enable disabled people to travel easily, confidently and at a fair and reasonable cost. The Council recognises the importance of all transport services playing their part in making this a reality.
Proposed measures to satisfy the ISP objectives
The Council proposes to revise its Hackney Carriage and Private Hire Licensing Policy to specify that any new hackney carriage vehicle licence must be in respect of a wheelchair accessible vehicle (WAV) or a zero-emission vehicle (ZEV).
The Council must have regard to DEFRA’s Air Quality Strategy when exercising functions of a public nature that could affect the quality of air. The proposed hackney carriage vehicle specification is intended to enhance the number of WAVs available in North Yorkshire whilst mitigating any potential adverse effects on climate change and air quality. The proposal facilitates compliance with the Council’s equality duty and its air quality obligations, giving vehicle proprietors multiple options with wider social benefits.
The Council proposes to allow any existing licensed hackney carriage vehicles to retain ‘grandfather rights’ until 31st December 2029, after which, only WAVs and ZEVs may be licensed as hackney carriages.
The Council recognises that ZEVs will not be appropriate for all drivers and proprietors (depending on the nature of their business) due to varying factors including range, cost, typical journey length and electric charging capabilities. Although ZEVs would represent the only alternative option to a WAV, the Council is satisfied that the proposal is reasonable and proportionate with a view to achieving legitimate aims.
A hackney carriage vehicle can be hailed by passengers on the roadside, it can stand on a rank to await the approach of passengers and it can be pre-booked by telephone. In contrast, private hire vehicles are licensed to perform pre-booked work only, which must be obtained through a licensed private hire operator. On that basis, any accessibility needs can be discussed at the time of booking a private hire vehicle, which will not necessarily be the case for hackney carriage vehicles.
It is therefore not considered necessary to also apply the WAV/ZEV requirement to private hire vehicles at present. However, it is proposed to introduce new obligations on all private hire operators to identify a passenger’s accessibility needs prior to taking a booking, to ensure that an appropriate vehicle is provided.
Hackney carriage vehicle proprietors unwilling or unable to acquire a suitable WAV or ZEV may consider adapting their service to a private hire operation with no such WAV or ZEV restriction. It is anticipated that this approach will support the delivery of a mixed WAV and non-WAV fleet across hackney carriage and private hire services in accordance with Best Practice Guidance.
Any opportunities to attract external funding to subsidise the provision of WAV services will continue to be explored, although the Council recognises the need to be realistic about any expectations of large-scale public funding being made available.
The licensing authority will consult with disabled passengers regularly on their experience of using hackney carriage and private hire vehicle services. The licensing authority will also continue to consult representatives of the hackney carriage and private hire trade in this regard.
All members of the licensing team will continue to complete regular disability awareness training to ensure that decisions are informed by the lived experiences of disabled people. The Council acknowledges the value in licensing staff possessing a reasonable understanding of the barriers that disabled people may face when using licensed vehicles.
Disability awareness training will remain a mandatory requirement for all hackney carriage and private hire drivers and the training must be repeated every three years. The Council recognises the need to ensure that licensed drivers have a reasonable understanding of the barriers that disabled people may face when using licensed vehicles, and that they know how to provide reasonable assistance when called upon to do so.
A practical assessment will remain a mandatory requirement for all hackney carriage and private hire drivers using WAVs. The Council recognises the need to ensure that WAV drivers understand how to operate the vehicle and any equipment fitted to make the vehicle accessible by disabled persons.
The Council will retain the policy requirement for all non-WAV hackney carriage vehicles to have means for carrying a “reference wheelchair” and luggage sufficient for the number of passengers for which the vehicle is licensed to carry. The Council acknowledges that the Equality Act 2010 provides a defence for licensed drivers who refuse to carry a disabled passenger and their mobility aids in instances where it would not have been possible to do so safely. The policy requirements ensure that the carriage of any mobility aids will be possible in the vast majority of instances.
The licensing authority will review the information contained on its list of designated WAVs (as required by section 167 of the Equality Act 2010) in accordance with the statutory guidance. Further information will be published where it can be obtained. The licensing authority will also review the relevant web pages to establish whether or not the list of designated WAVs should be accompanied by any further information that may be of benefit to visitors.
The Council will review the information displayed in licensed vehicles and provide further information via social media, at hackney carriage ranks wherever possible and on the Council’s website. The Council recognises the need for stronger signposting not only for complaints and suggestions to be made in relation to hackney carriage and private hire services but also to raise awareness of passenger rights.
Information relating to passenger rights will therefore be made more readily accessible via social media, the Council’s website and any other appropriate means. The Council acknowledges that many disabled people may have had negative experiences in the past that might affect their confidence to use hackney carriage and private hire services. The duties placed on drivers and operators of all licensed vehicles by the Taxis and Private Hire Vehicles (Disabled Persons) Act 2022 remain relatively new and the Council recognises that some members of the public may be unaware of these new requirements.
The Council is committed to addressing complaints in a robust and efficient manner to ensure that disabled people can have confidence that they will be able to travel by hackney carriage or private hire vehicle free from the fear of discrimination and that appropriate action will be taken against licensed drivers and operators in the event of any non-compliance.
The Council will work with station operators and other location managers where large numbers of passengers use hackney carriage and private hire vehicle services to ensure disabled passengers can always access and exit vehicles safely and easily.
The licensing authority will maintain engagement with disability action groups by attending regular meetings. Any feedback relating to the provision of hackney carriage and private hire services will be given appropriate attention
The Council will take active steps to facilitate dialogue between the licensed trade and end-users with a view to matching the supply of wheelchair accessible vehicles with the demand. The Council will also make arrangements for the business benefits of a wheelchair accessible service to be communicated to drivers and operators of hackney carriage and private hire services with specific focus on refuting the misconception that there are few wheelchair users in need of accessible transport across North Yorkshire.
The licensing authority will implement new arrangements to convey consistent messages to all licensed drivers, proprietors and operators via a regular newsletter. The newsletter will update drivers and proprietors on relevant licensing matters and will also include a dedicated space for equality provisions, feedback from disabled passengers and any business opportunities or promotions on new WAVs and/or vehicle conversions. Disability Action Groups and other interested parties will be invited to submit ideas for newsletter content.
Adequate resources from Licensing and any other services (including those with responsibility for business engagement and community engagement) will be allocated to ensure that the objectives of this Inclusive Service Plan can be met. The Council recognises that it will be necessary to deploy officers appropriately to deliver on the proposed measures.
The Council is committed to monitoring the delivery of this Inclusive Service Plan and evaluating its impact.
Within 12 months of publishing this Inclusive Service Plan, the licensing authority will evaluate the impact of any proposed action through consultation with the licensed trade, disability action groups and end-users.
A full review of the Inclusive Service Plan will be undertaken where appropriate (and, in any case, at least once every five years) to assess whether any amendments are required taking into account changing circumstances affecting the area, or any relevant changes in national policy.
Minor and inconsequential amendments may be made to the Inclusive Service Plan from time-to-time by a senior officer to reflect legislative changes or to correct any inaccuracies. In all other cases, the licensing authority will consult with stakeholders prior to implementation to ensure that the Inclusive Service Plan continues to meet its objectives.
