Corporate report

Annual Report to the Secretary of State 2019-20

Updated 13 November 2020

Annual report presented to the Secretary of State pursuant to Section 55 of the Public Passenger Vehicles Act 1981

1. Foreword by the Senior Traffic Commissioner

Last year we explained how this jurisdiction is uniquely equipped to respond to change. That ability was most definitely tested in the period up to and including the lock down restrictions. We have demonstrated a flexibility to meet the requirements of industry. That response is a credit to the individual commissioners, the strength of our team, and to the individuals supporting us.

That pales compared to the efforts of individuals on the front-line. The mental health impact from the pandemic has yet to be fully felt but those of us stuck at home will have a new-found respect for the isolation of long-distance drivers. The country has relied on the regulated industries to deliver key personnel and goods in support of the national effort and our economy. I heard from one of our road transport solicitors who returned to driving in support of our communities. He reported on the efforts to put as many vehicles as possible on essential supply chain work. In his case any reliance on the exemption from EU Drivers Hours rules had to be authorised by the Transport Manager. He told me about the reduction in driver facilities but also the efforts of operators to protect their drivers in increasingly difficult conditions.

Traffic commissioners require a firm foundation to support the regulated industries. There are two areas which are key to delivering traffic commissioner functions:

1. the provision of admissible evidence following properly conducted investigations, and
2. the administrative and operational support for licensing and the tribunal. The response to coronavirus across public service has relied on the ability to cut across organisational boundaries and traditional hierarchies.

It is already fashionable to start talking about the ‘new normal’ but the clear synergies between licensing and tribunal functions (which DfT confirmed during the last triennial review) should not be lost. The existing structure has not proved sufficiently responsive to the traffic commissioners’ desire for modernisation. The current model attracts inherent risks and repeated confusion as to what is legally permissible in support of traffic commissioners.

In the Office of the Traffic Commissioner (OTC) some lessons are already emerging - managers will need to operate differently and have the right skills and approach to ensure that performance is effectively monitored. Resources will need to be deployed to deliver the 7-week average application time set by the Department. Great Britain will need to be ready for the changes which the Mobility Package will bring in 2023. Traffic commissioners can draw on our experiences of implementing Regulation 1071/ 2009.

The oversight of the licensing and tribunal functions will require specialist and legal knowledge so OTC needs to be free to recruit the right people. It has been 10 years since I completed the first draft of the Statutory Documents. Traffic commissioners are ready for the next big step change in our jurisdiction. We therefore welcome the announcement of an independent review of the traffic commissioners’ functions and DVSA support. The review will find a strong team of commissioners who have shown that they are best placed to deliver the needs of this regulatory jurisdiction, and to support the restart of our economy.

2. Our purpose

The Traffic Commissioners for Great Britain (TCs) are independent regulators for the heavy goods vehicle (HGV) and public service vehicle (PSV) industries and their professional drivers.

Collectively, we are a non-departmental tribunal and licensing authority, sponsored by the Department for Transport (DfT). Our mission is to promote safe, fair, efficient and reliable passenger and goods transport through effective licensing and regulation of the commercial vehicle industries.

Our shared vision is for traffic commissioners to be recognised by our stakeholders as providing a proportionate, accountable, consistent and transparent decision-making - a model of independent regulation.

2.1 What we do

We work to keep Great Britain’s roads safe by licensing and regulating the commercial vehicle industries. With DfT, its agencies, the police and industry stakeholders we support the compliant, licensed operation of HGVs and PSVs. We do this by:

• providing statutory guidance and statutory directions to commissioners and industry regarding the operator licensing regime and tribunal activities
• holding regulatory hearings to examine evidence and take proportionate action to maintain safety standards and promote fair competition in the industry
• holding conduct hearings to examine evidence and take proportionate action to ensure professional driving standards are upheld
• targeting limited tribunal time so that the most serious cases are dealt with quickly and fairly
• delivering efficient, digital licensing services to responsible new applicants and compliant operators
• liaising with other regulatory bodies to identify and share knowledge around non- compliance
• educating and communicating with industry about the value of compliance and the licensing regime

Traffic commissioners seek to reduce regulatory burdens and support compliant businesses. However, statistics are unable to record the instances where the advice or assistance provided by individual traffic commissioners has resulted in improved compliance and road safety.

2.2 Overview: regulation & industry

Domestic freight (UK registered vehicles)

• 79% of goods moved by road
• 152 billion tonnes kilometres moved

International freight (UK registered vehicles)

• 5.6 billion tonne kilometres moved
• Freight industry contributed £12bn to UK economy

Local bus services

• 4.8 billion local bus service passenger journeys
• 58% of all public transport journeys
• 99% of local buses are disability accessible

Employment

• 1.56 million people employed in Transport and Storage

Our licensing work

• 68,983 goods vehicle operator licences
• 601,468 goods vehicles authorised
• 6,852 PSV operator licences
• 95,601 passenger vehicles authorised
• 11,803 operator licence applications and variations processed
• 15,640 local bus registrations processed

Our regulatory work

• 1,541 public inquiries
• 318 preliminary hearings
• 140 Senior Team Leader (STL) interviews
• 17,937 driver conduct cases closed

3. Response to the coronavirus (COVID-19) pandemic of 2020

As the reporting year was ending the country was starting to feel the full effects of the coronavirus (COVID-19) pandemic. At the time of writing this report the full impact has yet to be determined. It remains to be seen exactly how events will unfold in the longer-term. Even before the lock-down we sought to anticipate some of significant challenges which would face the road transport industries. The Senior Traffic Commissioner (STC) published a statutory document for Contingency and Emergency Planning ahead of the restrictions and in the early stages of the pandemic.

We followed this up with further guidance providing practical advice and clarification for operators. The first iteration of ‘Coronavirus (COVID-19): Advice for Heavy Goods (HGV) and Public Service Vehicle (PSV) Operators’ was published on GOV.UK on 18 March 2020; the intention being to provide ongoing guidance aimed at operators.

That early, proactive work illustrates the flexibility in the regulatory regime and our willingness to explore new ways of working. We also worked in partnership with various individuals and organisations to understand how we might best respond to the crisis, whilst maintaining a heavy emphasis on road safety. Where access to testing and inspection services has been reduced, we have encouraged operators to take a risk-based approach to managing their operations.

3.1 A proportionate approach

Balancing the needs of operators and society is at the legal heart of the traffic commissioner system. It allows traffic commissioners to take account of surrounding circumstances.

The measures set out in the new statutory document were intended to inform the decision-making process for traffic commissioners during the pandemic. The STC’s approach acknowledges the national effort to address the impact of the virus and seeks to assist operators during this difficult period. For example, instead of requiring financial documents, which might be hard to obtain during the early days of the lock down, traffic commissioners were able to rely on a previous, satisfactory financial check. The senior traffic commissioner also set a starting point to allow for a four-month period of grace, where the operator met the qualifying circumstances. Similarly, flexible provisions were made for granting interim licences and temporary exemptions to hauliers.

The general approach takes account of the extraordinary operating conditions during this period.

3.2 Guidance for operators

The practical advice has been regularly updated in response to queries from operators and the trade bodies to give clear, easy to understand advice on a range of issues, including:

• being unable to meet the requirements of financial standing
• losing access to an operating centre
• being unable to comply with notified maintenance intervals
• the challenges in effective management of operations
• being unable to attend training
• being unable to run a registered bus service
• needing to register or vary local bus service at short notice

In providing early, clear guidance for the industry, the commissioners sought to provide clarity and certainty in the most challenging of circumstances.

3.3 Maintaining vehicle safety

Concerns for logistical supply chains were widely reported on. In the early days of the outbreak, DVSA and OTC staff received enquiries from operators unable to gain access to maintenance facilities. Working closely with the trade associations and DVSA policy teams, traffic commissioners produced guidance around a series of risk-based scenarios for operators who are unable to maintain their stated maintenance programs. Initial guidance on maintenance concentrated on essential services.

Traffic Commissioner Kevin Rooney led on this work, liaising with DVSA policy expert, Dave Wood, to formulate guidance on maintenance during the pandemic. It quickly became apparent that hauliers needed to deploy vehicles across various sectors. The risk-based approach was extended to include guidance which recognise the additional assurance available where a qualified transport manager is exercising effective management. Traffic Commissioner Sarah Bell also liaised with HSE in support of the need for similar practical advice for operators around compliance with The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and The Pressure Systems Safety Regulations 2000 (PSSR).

We have continued to adapt the guidance to the changing circumstances. Kevin, supported by the TC Corporate Office, engaged with DVSA and trade representatives to produce further risk-based guidance to address long gaps in the maintenance of vehicles required to support the national effort. Latterly, commissioners have considered how operators would reintroduce fleets of vehicles after periods of inactivity.

3.4 Maintaining standards

Another challenge presented by the coronavirus pandemic was finding a way of carrying out compliance checks during the lockdown. Traffic commissioners had the benefit of access to DVSA’s Remote Enforcement Office (REO). Through the efforts of Caroline Hicks from DVSA’s enforcement directorate, a system was put in place to ensure the availability of Examiners to support traffic commissioners in their compliance functions. This relied upon tools such as a Desk Based Assessment (DBA) to obtain an up to date picture of an operator’s performance and any risk posed.

All responsible operators and transport managers engage in checks of their own compliance. Many employ a fresh pair of eyes to scrutinise their performance and therefore do not attract the attention of traffic commissioners. Compliance checks are important for road safety and, even in challenging circumstances audits can be a valuable tool for operators who want to make sure their systems are good enough. Where the operator has been encountered by DVSA an audit can offer reassurance that any identified shortcomings have now been addressed. Audits usually require a physical visit to the operator’s premises so that the auditor can check records and interview key staff. We recognised the challenges presented by the lock-down restrictions and, drawing on some of the experiences of the Earned Recognition Scheme, we adapted existing guidance so that operators might continue to benefit from these checks.

We accept that a remote audit may not offer the same opportunities as face-to-face engagement and that remote audits may require more effort on behalf of the operator and possibly also the auditor. We published a framework for audits to be conducted remotely so that operators could continue to benefit from compliance checks during the pandemic and support road safety.

3.5 Maintaining skills

The challenging circumstances have only highlighted the skills and knowledge required to run a safe transport operation. Attendance at training allows responsible operators to remain on top of compliance, but the lock-down restrictions clearly prevented physical attendance at training.

Traffic commissioner, Nick Denton, holds his own transport manager Certificate of Professional Competence and has observed numerous training courses in the past. He leads for us on external training standards and assessment. He took on the task of investigating remote alternatives during the crisis using his experience to ensure that virtual training replicates, as far as possible, the benefits of more traditional, classroom-based training.

He started by engaging early with course providers to understand virtual training possibilities. He wanted to understand the pros and cons of such courses and then took part in some demonstration courses. After providing feedback to course providers he worked to develop a set of criteria as a starting point for online courses:

• making sure the participant and instructor are always visible to each other
• the participant taking part by means of a tablet, laptop or PC with camera and microphone
• the course replicating as closely as possible the same content as would be delivered in a classroom
• the course provider needing to be able to identify all participants
• the instructor needing to be able to interact with participants, display material and discuss it simultaneously
• the inclusion of some element of assessment during the training, to check participants have actively engaged in the course.

At the time of writing, the traffic commissioners are aware of at least 11 course providers who have used the above to develop their on-line offerings.

The above work was undertaken in response to the coronavirus pandemic but we will be looking at whether this is something that can be taken forward in the future. We want to see improvements in the accessibility of training, building on our work to encourage a professional approach to development. Traffic commissioners will have an eye on the future in considering opportunities for growth and development.

3.6 Supporting bus operations

The legislation already permitted bus operators to seek short notice dispensation from a traffic commissioner in case of emergencies. There can be little doubt of the scale of the current challenge. We sought to use the legislation to support operators in the short-term, with a view to services returning to normal when circumstances allow. The commissioners adopted a pragmatic approach, encouraging operators who needed to change their local bus service registrations at short notice to apply for a temporary variation of services and we waived the fees in order to facilitate this.

Traffic Commissioner for Scotland, Claire Gilmore, worked at pace with Transport Scotland and the Convention of Scottish Local Authorities (COSLA) which represent Scotland’s 32 local authorities to realise the opportunities. They agreed a significantly reduced period of notification to the local authorities. Due to the number of authorities in England, similar measures were introduced shortly afterwards. Victoria Davies, Traffic Commissioner for Wales, ensured that the Welsh Government was also kept fully involved.

The circumstances have identified the advantages of engagement with operators and local authorities, with the opportunity to develop a more formal mechanism in England. Operators have been able to vary their registrations quickly in response to the reductions in patronage and other demands, which arose due to coronavirus. Indications suggest a high level of compliance by operators and, through those operators taking up the opportunity to lawfully register a change in services, we have been able to maintain a clearer picture of what services are actually being operated during the crisis. The significant increase in applications tested the bus registration teams working remotely in Edinburgh and Leeds. Additional resource from elsewhere within the OTC were moved to support both teams requiring additional training.

3.7 Effective regulation

The ability to take proactive steps to support the national effort illustrates one of the great strengths of the system. We were more proactive in recognising the challenges posed by the coronavirus pandemic and we have endeavoured to keep the road transport industries informed of our actions and what support is available to them.

There are inevitably lessons to be learned about the support required by traffic commissioners. There is a question over how to better connect the work of traffic commissioners with civil contingency arrangements (as used to be the case). We will continue to work with DfT and other stakeholders to help operators.

All hearings listed to 29 May 2020 were postponed. This has inevitably led to a backlog of cases yet to be heard. Traffic commissioners have reviewed those cases and carried out a risk assessment to determine whether directions were required to address safety concerns. We have continued to apply the same priorities as set out in our published guidance. We have considered alternative disposals, wherever appropriate. This has included trialling the use of hearings via video conferencing software and confirmed our initial consideration of remote hearings and separation from our staff. We will continue to review as technology advances but there is very limited application to this tribunal due to the nature of our cases.

Developments such as access to DBAs are clearly positive and will allow us to make informed decisions. We will continue to give due consideration to the difficulties caused by the impact of the coronavirus pandemic for as long as it remains a challenge to UK operators. Our intention is not just to help operators weather the current crisis, but also to help them return to full operations once the pandemic has subsided.

4. Our strategic plans to 2021

The series of strategic measures we set to be completed by 2021 have been overtaken by the coronavirus pandemic. It will inevitably impact on our ability to meet targets and therefore on the regulated industries. Whilst significant progress has been made on several fronts since these targets were set it remains the case that any strategic plans rely upon the dependencies fully explained in legal Framework Document published back in 2011. DVSA supplies the staff of the OTC and that requires accountability and understanding across all the services we rely on.

4.1 Performance to 2020

Half-way towards the deadline we set, we have made progress. The next section of the annual report is dedicated to giving an update on each of our goals. As with everything in this report, the coronavirus pandemic looms large. It is not yet possible to say what can be delivered in the coming year.

The current crisis has only confirmed how important road transport is to the nation and the economic recovery. We will continue to be open and transparent about our progress and in our business recovery, but will continue to endeavour to improve the service to:

• deliver a modern, effective operator licence regime, that ensures operators are fit to hold a licence, whilst minimising the regulatory burden on the compliant; and
• promote a safe road transport industry, which supports compliance, fair competition and protects the environment.

Efficient Licensing services

We set a target to drive down the numbers of outstanding applications so that applications for new licences or for a major variation to an existing licence are accurately processed in an average of 35 working days by 31 March 2021.

This is something the traffic commissioners have taken particularly seriously over the last year. At the very least service users require swift and efficient processing of applications. We were aware of some cases where applications were going un-processed for months. We wanted to make it better for business and make the process fairer.

We have seen some progress. Commissioners initially insisted that all open applications more than six months old were referred to a commissioner on a monthly basis for review in an attempt to try and resolve them. This proved successful and was expanded to all applications open for more than four months. Going forward, it will be all applications open for more than three months.

This has helped to drive down processing times and increased accountability for the licensing functions.

A year ago, the statistics indicated that between April 2018 and March 2019 it took an average of:

• 40.79 days to process a goods vehicle licence application
• 70.66 days to process a PSV licence application

One year on the most recently published batch of statistics show that between April 2019 and March 2020 it took an average of:

• 36.45 days to process a goods vehicle licence application
• 50.1 days to process a PSV licence application

We have seen more than 4 days shaved from the average time for goods vehicles and more than 20 days off the average times for PSVs. The great majority of applications are concerned with goods operations – so the OTC is closer to the target that we set than the figures might otherwise suggest. Overall, it averages out at 37.5 days per application. We highlight that the processing times for restricted PSV applications is significantly longer than that for standard PSV operators: 70.8 days against 43.75. These figures support the initial findings from the small pilot we ran into existing restricted PSV licences. This is because of the additional checks required for restricted applications and the complicated nature of the legislation.

We had anticipated making good progress towards the target of 31 March 2021. The impact of the coronavirus epidemic will inevitably impact on the service provided by the OTC but there have been other challenges including a freeze on permanent recruitment resulting in vacancies going unfilled or being filled by temporary and largely inexperienced staff.

4.2 Leaving the European Union

In the current climate it is easy to forget the potential for change resulting from the above. We said we would help prepare to leave the European Union by:

• reviewing guidance available to industry to ensure that it reflects the legal position
• providing updated Statutory Documents
• engaging with the Secretary of State and the Upper Tribunal to support the development of legislation and case law during the period of transition
• supporting the development of Tribunal Rules that assist operators in the tribunal process
• providing relevant support to the competent authority in the issuing of road freight permits
• providing a single point of contact within the OTC for issues related to exiting the EU

As part of this, we assisted DfT with preparing for the impact on both passenger and goods industries. This included preparing to issue UK Licence for the Community for goods vehicles, and with issuing certified true copies of operator licences for passenger vehicles. The STC also drafted statutory directions and statutory guidance on potential changes. In the first instance this was a contingency step for the event that the UK left the EU without a deal. Traffic commissioners readied themselves to act as the appeals body following the removal of an operator’s community permits. A statutory document was prepared ready for publication if/or when it is needed.

Negotiations on the UK’s future relationship with the EU are ongoing. It is difficult to predict how the transition will develop and whether all of those efforts will be required.

4.3 Future-proofing the Office of the Traffic Commissioner

We frequently refer to the advantages of an audit, a fresh pair of eyes to look at your compliance. The report on Customer Service Excellence (CSE) accreditation of the licensing office in Leeds has prompted traffic commissioners to look at the OTC audit process more closely to ensure that there is in fact the level of continuous improvement required of a modern regulatory body. Emerging findings suggest a disjoint between the operating instructions issued to licensing staff and the requirements set out in the statutory directions.

We have now established an audit and risk sub-committee of the traffic commissioner board to advise us on the processes underpinning the management of risk, control and assurance, the planned activity and outcomes of internal (and any external) audit activity undertaken, and the adequacy of management response to issues identified by audit activity. We have already revamped the external complaints process. We will now look at the delivery of service by DVSA, the ability of OTC to learn lessons and make improvements, including in the handling of data by OTC.

Traffic Commissioners Claire Gilmore and Richard Turfitt lead in overseeing data governance. Operators trust us with their data. We take that responsibility seriously, but our efforts were frustrated by the lack of a Data Protection Officer. This was finally addressed in March 2020. In the intervening period the burden has fallen on those colleagues, our Information Access Manager, Vicki Harsant, and her small team who have dealt with 239 requests (without the benefit of the statutorily required DPO for almost all of 2019/20). Vicki has also led efforts to consolidate OTC’s paper records into a single, more secure and more cost-effective location. We have also worked to overhaul our privacy notice. The new privacy notice, coupled with the presence of a dedicated DPO for the OTC, provides security and assurance. It also underpins our communications with industry. This has proved so vital during the current crisis. We continue to push for a better understanding of the electronic level of protections within DVSA’s systems.

As the above examples make clear, almost all of the administrative and operational support for our licensing and tribunal work relies on what DVSA provides. We said we needed to review the capability of the Office of the Traffic Commissioner to support and deliver the statutory functions of traffic commissioners and to establish whether it is properly resourced, by reference to:

• the standard of evidence provided to it in targeting non-compliant operators.

Traffic commissioners recognise the key role of DVSA enforcement in the provision of admissible evidence and that this can only follow properly conducted investigations. It is for that reason that our two lead Commissioners, Kevin Rooney and Sarah Bell, have devoted so much time and effort to liaison with DVSA.

The TC team has a board range of skills and previous experience to draw on. In this case, as prosecutors and from involvement in criminal investigations and in practice before the criminal courts. Commissioners have shared examples of good practice and their observations of where there might be improvements, for example in understanding lines of inquiry.

It is hoped that DVSA’s work to include the two stages of the test under the Code for Crown Prosecutors may lead to greater emphasis on the vital enforcement role played by Examiners.

• the licensing function for the processing of applications and maintaining licence records

The streamlining of processes usually allows for the better use of our resources. Those benefits were hampered by DVSA’s decision to freeze recruitment. It is important not to treat the licensing and compliance teams differently as that risks silo-working and reduces opportunities for efficiency and accuracy. Neither of which aligns with the needs of the service user.

In order to work as efficiently as possible, we need OTC to have reliable and robust IT systems. Sporadic, but sometimes prolonged, failings of IT have resulted in an inability to process new and variation applications at various points during the year.

• the compliance function for the preparation of tribunal casework and ensuring that non-compliant applicants and operators are held to account

The OTC has faced numerous challenges during the year, not least from DVSA’s proposal to reduce our tribunal facilities. These proposals lacked any apparent detailed understanding and are contrary to the service standards required to deliver the traffic commissioners’ statutory functions. In this context DVSA’s purpose is to support traffic commissioners and this should include the provision of local justice to all parts of GB.

4.4 Improving transparency of income and expenditure

The fees collected in the name of commissioners go directly to DVSA, which then decides where to spend them and how much it will charge to provide its own services. If there is to be any reform of the operator licensing system, the income needs to be accounted for and used to improve the service for which it is charged. That is particularly important as we look to support the restart of the economy and the financial impact of the coronavirus pandemic.

DVSA undertook a discovery phase using external consultants to look at the efficiency of the OTC. We asked traffic commissioners Tim Blackmore and Sarah Bell to use their previous experience in project management and private business to try and establish the basis for this review.

In the absence of a detailed examination of the services needs and a deep understanding of the statutory framework it was perhaps inevitable that the review was unable to provide any concrete proposals and did not provide the type of transparency we were hoping to see.

Any review will need to consider whether DVSA continues to offer value for money based on a firm commitment to standards and accountability for the provision of services, such as accommodation and personnel. We believe that there are savings to be realised, for example traffic commissioners have previously expressed concern at the cost of estate. However, any savings need to be based on a proper understanding of what is required to deliver the statutory functions for which the fees are paid before there are any operational changes. Given the economic pressures operators will likely face as a result of coronavirus, the need for value for money becomes even more important.

4.5 Reducing the time to wait for a hearing

Listing a first Public Inquiry (PI) date within 12 weeks is good for operators and good for road safety. Shorter timeframes remove uncertainty of possible regulatory action, whilst still giving time to prepare. Equally, the public requires assurances that non-compliant operators will be dealt with swiftly but fairly.

To help reduce the time taken to allocate an operator’s first hearing date we set targets that would:

• ensure that all cases listed for a hearing before a traffic commissioner are allocated a first hearing date within 12 weeks, save where the interests of justice require it;
• develop a mechanism to facilitate the transfer of cases between offices to enable the 12-week target to be met whilst maintaining access to justice.

The most recent published statistics on PI listing shows that 98.2% of those hearings were listed within 12 weeks. Last year it was only 89.3%. The likelihood is that this will be never be 100% as the interests of justice inevitably require more time to prepare more complicated cases. We consider that 98.2% of cases is approaching the upper level of what is practicable.

Inevitably the listing of PIs will be hit by the impact of the coronavirus pandemic. We have had to take the necessary step of postponing all in person hearings. At the time of writing we have no firm date for a return but a small number of straightforward matters have proceeded using video conferencing software. (We provide a more detailed analysis below). There will be a backlog of cases to be heard once in person hearings resume.

4.6 Tribunal facilities that are fit for purpose

Last year we identified the need to make sure that our tribunal facilities are fit for the purposes of a modern regulatory tribunal so that they:

• are appropriately staffed and resourced
• comply with Article 6 of the European Convention on Human Rights and allow for fair proceedings and convey the independence of the traffic commissioners
• comply with the Equality Act 2010 and are therefore accessible for public transport users
• provide an appropriate level of security to all tribunal users
• can accommodate public hearings, whilst allowing adequate privacy for tribunal users and their representatives
• are compliant with all regulations relating to the storage and handling of personal data
• allow traffic commissioners to investigate the viability of technology and virtual hearings.

Facilities need to be fit for purpose and accessible by public transport. There is no evidence that the various proposals put forward, including moving traffic commissioners to whichever part of the DVSA estate is surplus, or separating traffic commissioners from their clerking and caseworker support, are actually viable.

Traffic commissioners considered the case for making use of video technology and engaged in a number of remote hearings. The review concluded that virtual/video hearings do not offer an alternative to the large majority of in-person hearings. In conducting this review, we have been able to draw on the experiences of HMCTS. Those efforts required significant support from those solicitors who were required to invest and put aside office space from which solicitor and client could appear by video before a judge. In our jurisdiction most parties are not legally represented. This raises the question of what video conferencing system the other parties in a virtual PI would use. In some cases, no suitable option may be available rendering virtual hearings impossible.

Similarly, another key difference is in the level of IT infrastructure available to the traffic commissioners. The HMCTS pilot identified the need for a secure, stable product as a foundation for hearings. We currently do not have such a product.

The main barrier to the widespread use of virtual hearings for public inquiries is the nature of the PIs themselves. They are heavily paper based with substantial evidence produced mostly on the day of the hearing. The level of paperwork and absence of tribunal rules will remain a block on any form of remote hearing where additional evidence may be produced as the expense of additional adjournments would outstrip any potential savings.

Even before the lock down, traffic commissioners had trialled video driver conduct hearings and found them to have limited application. It was useful to cover the unexpected absence of a presiding commissioner and the hearings were covered by video link from another tribunal centre.

Remote hearings have proved of some benefit during the coronavirus lockdown period, where public safety concerns and the need to ensure fairness for operators meant in-person hearings could not go ahead. A small number of straightforward cases were heard using Microsoft Teams that would otherwise not have been possible. These experiences have, however, reinforced our view that the potential for virtual hearings is limited in scope.

4.7 Targeting communication and education

We said we would seek an analysis of industry segmentation to enable traffic commissioners to effectively target communications and educational resources at specific service users. We were particularly concerned for those operators who do not enjoy ready access to relevant information or advice to assist them with compliance.

As part of this the TC communications team and lead traffic commissioner, Tim Blackmore, have worked with DVSA and produced a suite of 16 email bulletins for new operators. These bulletins provide advice, information and links to GOV.UK guidance so that new operators have all the reference material they need. They cover all the basic requirements for being a compliant operator, as well as some tips from the traffic commissioners based on what they see at PI on a regular basis. They encourage operators to apply a risk-based approach to all areas of compliance.

These topics include:

• registering for an OCRS score
• how to carry out a daily walkaround check and what to do with defect reports
• tachographs, tachograph records and drivers’ hours
• putting vehicle and driver management systems in place
• managing your licence online
• vehicle loading
• CPC
• getting an audit

Any new operator will start receiving these bulletins at regular intervals over the first 4 months of their licence. The aim will be to give them a point of reference for the various elements of compliance that form the undertakings on an operator’s licence. By actively drawing to their attention all the guidance they need we hope to improve knowledge and compliance among new operators.

This activity is achievable due to the improvements in the privacy policy, which allows traffic commissioners to make better use of the information we hold.

In addition to the more technical and legal assistance provided through regular updates of the STC’s Statutory Documents, we are now able to start communicating directly with all operators about matters of importance to their licence, their profession, and road safety. This starts with all new operators being sent the information they need to run safely and comply with the law.

Work had been ramping up to start this programme of emails in early April. The coronavirus pandemic meant, however, that full implementation will have to wait until after restrictions related to the pandemic are lifted.

In addition to this traffic commissioner, Nick Denton, has worked closely with DVSA to refresh and revitalise their new operator seminars. These seminars are run by DVSA and are offered to all new operators. They provide a run through of the key areas of compliance, so attendees can gain the right skills and have the knowledge to run safe and compliant operations.

Nick worked with DVSA to overhaul the content of the courses based on his own extensive experiences with the road transport industry, including his time as a traffic commissioner. The refreshed course content serves as a good example of improving the way the commissioners deliver the right skills and knowledge to the industry, and it serves as a good example of working with other organisations.

These are not the only example of commissioners working in partnership to strengthen guidance. The traffic commissioners have provided insight and expertise for several documents and pieces of guidance produced by others such as DfT. By way of example we refer to football related operations later in this report. Another example was working with DfT on formulating a risk-based approach for operators to combat the use of vehicles as a weapon.

4.8 Working with other regulators, enforcement agencies and stakeholders

We said we would revitalise the mechanisms for the communication of relevant information to traffic commissioners by enforcement agencies and other stakeholders. At its most basic form this involves the better sharing of knowledge and information. We start by highlighting our work with other, similar organisations both in the UK and abroad. First among these is the Transport Regulation Unit of Northern Ireland. In the last year we have assisted them in the provision of training. We have also facilitated the provision of new presiding officers to hear Northern Irish cases.

In 2019 we also hosted a delegation from Nationale en Internationale Wegvervoer Organisatie (NIWO), the Dutch regulator, led by their director. This has cemented relations between us and the Dutch competent authority. It has allowed for the sharing of information relevant to the regulation of safe operations in both countries and provides a valuable opportunity to discuss best practice.

We continue to engage with other regulators from the member states of the European Union. For example, provision of information to the French regulators and assisting the Swedish government with an inquiry into road enforcement.

We assisted representatives from Jersey at the start of their own operator licensing regime. We also offered similar support to the Isle of Man government.

We have engaged with the Law Commission on the use of automated vehicles for passenger services and public transport. Its second consultation paper refers to the PSV operator licensing system as a potential model for the regulation of Highly Automated Road Passenger Services (HARPS).

The wide level of experience and expertise amongst the commissioners is often called upon by other bodies.

For instance, the ongoing work as part of the Roads Policing Review. This is a 2-year review established by the DfT and Home Office to consider the future of roads policing and traffic enforcement. It was launched towards the end of 2019. The traffic commissioners see this as a once in a generation opportunity to improve road safety. The 2-year review will look at how roads policing currently works, its effectiveness, and where improvements could be made, or gaps bridged.

Richard Turfitt sits on the governance board, but the majority of our contribution has been made through Sarah Bell, who supports a number of the different work streams and brings her considerable experience and energy to the benefit of the review. The aim is to promote fair, timely and effective justice and to tackle the small but notable rogue element of the commercial vehicle industry, thereby protecting the rest of this vital industry and other road users.

Traffic Commissioners Sarah Bell and Kevin Rooney lead on enforcement liaison. They represent our interests at the Commercial Vehicle Road Safety Forum, chaired by DfT. They record their appreciation of Duncan Price’s chairing of the forum even whilst deployed to far-flung places as part of the preparations for 31st January 2020.

This level of engagement helps us to understand and influence pressing issues for industry and prioritise our focus. Notable achievements this year include:

• a commitment for enforcement bodies to promote national themes through Highways England facilitated projects on the strategic road network (SRN). This work is ongoing.
• a collaboration supported by Society of Motor Manufacturers and Traders (SMMT) for improved quality brake testing by technicians at Preventative Maintenance Inspections (PMIs).

There are many examples of joint working with stakeholders, for instance the work with the National Football Policing Unit. The head of the TC Corporate Office, John Furzeland, is engaged in regular liaison and we have contributed to workshops run by the police, outlining the role of the traffic commissioners and giving guidance on the conduct of transportation companies at football matches. This partnership has been successful in assisting the police to provide good evidence to the commissioners of poor compliance by operators offering transportation to football matches.

In a recent case about football fan transport, our colleague, Nick Jones, found that an operator had failed to comply with the voluntary code of conduct for transporting fans to sporting events by allowing fans to drink alcohol, which is prohibited by law; had ignored the approved timetabling and arrived later than arranged with the coach driver ignoring the planned route and depositing those fans near a large group of opposing supporters leading to avoidable exchanges. The consequences were not as serious as they might have been but did make policing even more difficult than it should have been. It was a textbook example of what not to do when transporting fans to sporting events. The importance of this work should not be underestimated and our commitment goes back to the aftermath of an alcohol fuelled event in 1976, where 70 fans were injured, two were stabbed, and 30 police officers injured. This is why we treat those risks so seriously.

Moving beyond the world of road transport regulators we want to mention a recent case concerning HMRC. We assisted HMRC in the successful prosecution of five criminals, who were involved in a black-market alcohol ring, through the supply of data in answer to lines of inquiry around licence applications, financial transactions and nominated directors and officers. We do not want to overstate our role as it was ultimately HMRC and the police who did most of the work but it confirms the benefits of public bodies working together through the lawful sharing of data.

The OTC information access team has fielded requests from dozens of other organisations over the last year or so, including:

• Police (most police forces within GB)
• The National Crime Agency (NCA)
• The Insolvency Service
• Various local authorities (councils)
• DfT – Bus Service Operators Grants (BSOG)
• The Environment Agency
• The Pensions Regulator
• The Home Office (Immigration Enforcement and Border Force)
• Transport Regulation Unit (Northern Ireland TRU)
• Scottish Environment Protection Agency (SEPA)
• National Trading Standards
• Gangmasters and Labour Abuse Authority (GLAA)
• Department of Works and Pensions
• The National Food Crime Unit (NFCU)
• The Health and Safety Executive
• NIWO – Dutch goods vehicle regulator
• GITD – Polish goods vehicle regulator

This demonstrates that, if nothing else, we are regularly communicating with other organisations, providing assistance and information where appropriate. It should be possible to conclude improved data sharing arrangements during the coming year, now we have finally been provided with a data protection officer. Future resourcing remains an issue to be resolved.

4.9 Reviewing and modernising bus performance monitoring

Last year we identified that bus performance monitoring appeared to be in need of reform. We highlighted the low number of bus performance cases referred to us, despite anecdotal evidence of poor punctuality.

We reached out to various stakeholders at the start of this work. We had early, useful discussions with the CPT, local authorities and DfT which provided a good foundation for further work strands. That early progress has been curtailed by the coronavirus outbreak. We will continue with this initiative as soon as we are able with a view to reporting back in next year’s annual report. We are grateful for the time the industry has taken to engage with us on this issue considering the other issues they are facing at this time, including the implementation of PSVAR.

One looming issue that will need consideration is how open data requirements in England will be reflected in our statutory documents. From 31 December 2020, bus operators in England will have an obligation to provide bus timetable data to the Bus Open Data Service. It will then become mandatory for them to provide vehicle location and basic fares and tickets data to the Bus Open Data Service from 7 January 2021 followed by an obligation to provide complex fares and ticket data to the Bus Open Data Service from 7 January 2022.

Further to this from 1 April 2021 operators will start having to report their own performance. This raises two questions – what happens if they fail to report, and what happens if they report poor performance? We will need to ensure that we work with the enforcement agency so that appropriate investigations are carried out.

5. Summary from England, Scotland, and Wales

Regular readers of our annual reports will know that we adopted a different format for the document last year, by collating the collective observations of the traffic commissioners into defined narrative sections. Adopting this format, the following sections again combine the themes and observations of the traffic commissioners.

5.1 Traffic commissioners for England

The traffic commissioners for England are Sarah Bell, Tim Blackmore, Nick Denton, Gerallt Evans, Kevin Rooney, Richard Turfitt.

Tackling the non-compliant

We continue to urge operators to take a risk-based approach to the management of their transport. There is sometimes an expectation that there should be guidance or a direction on every topic. That approach ignores the innovation and sophistication of the transport industries. No set of rules can envisage the circumstances of each individual business in this country. The operator licence requirements offer a framework for compliance. It is for the individual operator and transport manager to work out how to best manage the risks which are particular to their own operations. That is why we place so much store on training and audits to better equip them to comply and have gone to great efforts to share experiences and best practice. We share a few examples below.

Last year commissioners reported on the concern within the haulage industry about the employment status of drivers and how “self-employment” might be used to avoid paying national insurance and pension contributions to obtain a competitive advantage. The outbreak of coronavirus has added a further perspective where self-employed drivers or those using corporate entities were left outside the furlough scheme. The Chancellor’s announcement on 26 March 2020 provided support for genuinely self-employed individuals who had completed their 2019 tax return.

In a decision handed down at the beginning of March 2020 the Upper Tribunal (2019/054 Bridgestep Ltd & Another) has provided guidance on the approach to be taken. The legitimacy or otherwise of a driver’s self-employment status maybe fact specific, depending on clauses in the contract and the degree of control over the vehicles provided and over the work undertaken. However, the Upper Tribunal referred to the Road Haulage Association (RHA) factsheet based on HMRC guidance: “Unless they are an owner-driver, it is very rare for a lorry driver to be legally “self-employed”.

The case provides ample warning against conscious decisions to enter into any questionable arrangements and it described the motives as anti-competitive and concerned with reducing the cost of employing the drivers, thereby gaining a competitive advantage over other compliant operators. The consequence was that the company and transport manager felt unable to give any instruction to drivers. The Upper Tribunal correctly referred to most new operators making the right decision to employ their drivers, paying national insurance, pension contributions, holiday and sickness entitlements. The advantages of proper employment arrangements are obvious to responsible operators and should now be clearer to drivers. The legislation (IR35) is designed to tax disguised employment at a rate similar to employment. The reform of IR35 by reference to off-payroll working may have been postponed until 2021 but drivers and operators need to review their employment status as a matter of urgency and to ensure that they have the level of control required to deliver the operator licence requirements.

Brake testing

Last year we reported on improvements to brake test results at annual tests of heavy commercial vehicles. We are pleased to report that support for continuing improvements is strong.

The Freight Transport Association (FTA, Logistics UK from July 2020) made brake performance testing central to its annual round of Transport Manager seminars. This was supported by a detailed publication aimed at making roller brake test reports understandable to all. DfT’s Commercial Vehicle Road Safety Forum has now commissioned DVSA to lead a further collaborative piece of work looking at the quality of brake performance testing both at annual test and during regular maintenance inspections. The review is broad-ranging and includes a look at the way in which the performance of tri-axle semi-trailer braking systems is undertaken at annual test and the potential of new technology. We are mindful of the difficulties now facing the haulage sector and the review will be taken forward in a way which does not seek to add to that burden.

National ANPR System (NAS)

DVSA is now using the National ANPR (Automatic Number Plate Recognition) System. Resource to follow-up our regulatory decisions to revoke, curtail or suspend licences has traditionally been scarce. NAS revolutionises the ability of DVSA to enforce our regulatory decisions. It has also introduced new processes to ensure that there is an appropriate follow-up on all revoked licences to ensure compliance. NAS also appears to have the capability to increase the effectiveness of drivers’ hours enforcement. Traffic commissioners welcome its introduction and deployment.

Bridge Strikes

Operators should be in a position, to assess the risks attached to their undertakings and to take appropriate control measures. Traffic commissioners have spent the last year speaking at engagements and educational events using the example of bridge strikes to illustrate the approach they expect to see.

These are now a matter of national focus, particularly due to an ongoing campaign by Network Rail (NR). NR provides free detailed guidance online for drivers and managers alike.

Following an appeal the approach is now established law. It is incumbent upon any operator and transport manager to ensure that the operator’s vehicles are operated without risk to road safety. That includes the risk of bridge strikes which bring with them potentially serious consequences. Operators should assess the risks and ensure that routes are planned in advance to reduce that risk as far as is reasonably practicable. Where that planning involves drivers they must be provided with adequate information including about the vehicles which they are driving. This goes beyond simply placing responsibility on drivers.

Traffic commissioners address these incidents in the same way as any other serious incident, on a case by case basis. As commissioners have repeatedly made clear, regulatory action hangs over those operators who fail to take appropriate action. We understand that there can be issues with signage itself and road surface repairs impacting accuracy. However, the commercial vehicle industry has overcome far more complex matters and we are pleased that the trade associations are engaged with Network Rail on this.

Operators should now ensure that drivers check the height of the vehicle and/or trailer, that the in-cab height indicator is an accurate indication of the ride height, that the driver is properly trained to plan the route and has the equipment to do so. There is ample guidance about avoiding bridge strikes available to assist operators, transport managers and drivers.

Express Delivery and the Final Mile

Traffic commissioners have seen the sector of express courier logistics grow in both size and professionalism in the last ten years. Interest in the sector is growing, final mile food to home, medical deliveries and work at home kit delivery during the pandemic brings ever more attention to what is becoming a key sector of logistics. This has been recognised by the Institute of Couriers (IoC) in launching a new degree apprenticeship for express managers. As part of her liaison role Sarah Bell continues to support innovation by the IoC. In response to the current crisis it has launched its ‘Code of Values - Doing the right thing during the COVID-19 pandemic’ and a campaign ‘‘Mark your door – keep the drivers safe’.

Accessibility of justice

The six English areas (in fact all traffic areas) can be geographically very large. DVSA’s original internal review showed limited appreciation of the indirect costs to operators and drivers who are not located close to our tribunal facilities. We use the Western Traffic Area as an example. It runs from Penzance to Slough taking in Oxford and the Isle of Wight along the way. The tribunal facility is in Bristol which is four hours travel each way for some. To reduce the burden on operators and drivers the Western Traffic Area have been trialling regular, high-volume sitting days in Cornwall using low cost, good quality local authority facilities. In the South East, collaborative working with HMCTS is allowing us access to facilities in West Croydon far closer to all the London operators than Eastbourne. This type of initiative means that, whilst that there may be a slight increase in our direct costs, the cost and accessibility to justice for operators and drivers is greatly reduced. It also helps to ensure the attendance of parties and witnesses so that cases can proceed on the date given. None of our functions can be delivered without the support and flexibility of the staff. We are also lucky to enjoy the assistance of a pool of deputy traffic commissioners.

5.2 Traffic Commissioner for Scotland

The Traffic Commissioner for Scotland is Claire Gilmore

Last year, I predicted that 2019/20 would bring challenges, and opportunities, for our industry. At the close of my first full year in office, I expected to be reporting on our success in meeting familiar challenges and highlighting the many improvements we have made in delivering our core business this year.

However, as I write, the country is in lockdown in response to the coronavirus pandemic. The challenge of operating vital transport services in such a context was not one which was widely anticipated, and the impact of the crisis on our industry cannot be underestimated. Such adversity has, nevertheless, brought with it, opportunities. We have focused on our priorities, developed new and innovative ways of delivering services, and found strength in working together in the most challenging of circumstances.

Prior to the coronavirus outbreak, this year saw the usual mix of preliminary hearings, public inquiries, and driver conduct hearings in my reserved jurisdiction. In order to increase access to justice for the industry in Scotland, and to offer more opportunity for public attendance at hearings, I undertook to sit away from my Edinburgh base more often. Inquiries and hearings are now held weekly in Glasgow, and more frequently than before in Inverness and Aberdeen. As a result, we have seen increased public participation and raised the profile of our work throughout Scotland.

This year has also seen a steady volume of devolved Scottish work in relation to local bus service registrations, the use of traffic regulation conditions and taxi fare scale appeals. However, I have now been given additional responsibilities in respect of Bus Service Improvement Partnerships and franchising under the Transport (Scotland) Act 2019. My office is currently working to support partners in Transport Scotland to develop the regulations which will underpin the new Act.

I am the only traffic commissioner in the Scottish jurisdiction, in contrast to the six Commissioners appointed across England. At present, my office receives no contribution in support of my devolved responsibilities. As the demands in relation to devolved work continue to increase, so will the need for resource to support those. I have raised this issue with Scottish Government and will continue to engage in dialogue with them in relation to what additional support may be required.

Traffic commissioners have focused this year on the need for meaningful brake testing and on the perils of bridge strikes. Over the course of the year I attended a range of events, including those organised by the Confederation of Passenger Transport, the Freight Trade Association and the Road Haulage Association. These events have proved invaluable as a means of communicating with the industry on these important topics. My thanks go to all of those organisations for their warm welcome and, in particular, to the operators and others who took time to engage with me. A particular highlight was attending the Transport News Scottish Rewards breakfast presentation which gave me an opportunity to join with others in celebrating the very best in the Scottish haulage industry.

In common with all other courts and tribunals, the coronavirus outbreak has had a significant impact on our work. Inquiries and hearings have had to be postponed as a result of the lockdown. In response, we have embraced technology and we are holding remote hearings where it is appropriate to do so. We are also actively case managing work to ensure road safety is prioritised.

The need for stakeholders to work together has never been greater and traffic commissioners across GB have collaborated in developing guidance to support operators as they deal with the crisis. Last year, I reflected on the strong partnership working that exists in the Scottish industry and we have reaped the benefits of that in recent weeks in developing new flexible arrangements for local bus service registrations.

In anticipation of the lockdown my office worked, at pace, with partners from Transport Scotland, the Convention of Scottish Local Authorities and the Association of Transport Co-ordinating Officers (ATCO) to develop a new process to allow operators to vary registered services at short notice in response to rapidly declining patronage. That work has been vital in ensuring that we keep an accurate record of which services are operating. Operators across the country have made good use of the new process and as a result we have high levels of compliance in Scotland. Working together, as an industry, we have created a firm foundation on which to build as we recover and follow the route map out of lockdown.

I have already joined with my commissioner colleagues in extending gratitude to those in our industry who have kept lifeline services running. Drivers who appear before me at conduct hearings already know the value I place on professionalism in the industry. They know that I expect them to set the bar for other drivers and to maintain exemplary standards in relation to road safety. But now, more than ever, we have seen their professionalism and dedication come to the fore as they continue to deliver vital supplies, and transport those who keep us safe to work. What has already been achieved by our industry, in the most challenging of circumstances, is testament to dedication of the people in it. As Traffic Commissioner for Scotland, I formally extend my thanks to you all. We must now look forward to recovery. Our industry will continue to embrace innovation and draw on the resilience that this crisis has demanded of us. Road safety and fair competition remain my priorities and I look forward to working with all industry stakeholders to achieve those ends in the coming year.

My sincere thanks go to the OTC Scotland team who have worked hard to ensure that vital support to our industry has been maintained. The hastily created Local Service Registration team, comprising of Audrey Dick, Brian Torry, Steven Jones and Charlee Mayes, worked tirelessly to process the many thousands of local bus service variation applications submitted in response to the coronavirus pandemic, but they could not have done that without the support of the wider team. They have kept the reins, and without them we would not have the firm foundations that we do.

My thanks also go to partners in COSLA, ATCO and Transport Scotland for their co-operation with my office in tackling the issues which have arisen for the industry. Finally, as ever, my thanks go to Hugh Olson, Deputy Traffic Commissioner for Scotland, for his support in ensuring that our business is effectively discharged.

5.3 Traffic Commissioner for Wales

The Traffic Commissioner for Wales is Victoria Davies.

I am privileged to have been appointed as Traffic Commissioner for Wales and took up post in February 2020, following the retirement of Nick Jones. This annual report largely covers the period of Nick Jones’ tenure and I would like to thank him for laying such strong foundations for my work as the new Traffic Commissioner for Wales. I look forward to continuing his legacy, working to improve compliance, road safety and fair competition in the heavy goods vehicle and public service vehicle industries throughout Wales.

In the first few weeks following my appointment, I was delighted to attend the opening ceremony of the new Traffic Commissioner office in Caernarfon. The office has been funded by the Welsh Government and was officially opened by Ken Skates, Welsh Government Minister for the Economy, Transport and North Wales, on 27th February 2020. The establishment of an office in Wales with bilingual administrative support staff and facility to hold Public Inquiry and driver conduct hearings is long awaited and will greatly enhance our ability to provide a first-class service to people throughout Wales. Two staff members took up post in October 2019 and a third has recently been recruited and will start in the Autumn.

The staff in Caernarfon are being trained, developed, and mentored by an experienced OTC Senior Team Leader, Deborah Crosby, who has also been a huge support to me in these early weeks of my appointment. I would also like to thank Anthony Seculer, Deputy Traffic Commissioner for Wales, for his support sitting in Public Inquiries and driver conduct cases in both Cardiff and Caernarfon. Finally, I would like to thank my traffic commissioner colleagues who have been so generous with the support and guidance they have given me, as well as the licensing and compliance staff in Leeds, Caernarfon and Birmingham offices.

Since taking up post, I have had the opportunity to meet some key transport stakeholders and heard directly from them about their experiences of industry regulation in Wales, and their thoughts and ideas about changes needed. Those meetings have given me an excellent insight into the industries I regulate and some of the difficult issues that they face. Sadly, at the time of writing, those industries are facing an unprecedented challenge as they deal with the impact of the coronavirus crisis on their businesses. I have worked closely with Welsh Government officials responding to the pandemic to put in place a range of measures to support the bus industry in Wales. As regards registration requirements, I have agreed short notice temporary changes to these, given that operators have needed to respond very quickly to the challenges presented by coronavirus. It will be equally important for me to continue working closely and responsively with the Welsh Government and the bus industry in Wales as we plan how to emerge from the emergency measures into a period of recovery.

As we look to the year ahead, I hope to continue building a strong relationship with the Welsh Government and am also looking forward to engaging with Local Authorities, transport bodies and trade associations (the CPT, FTA and RHA) to promote safe, fair and reliable passenger and goods transport in Wales.

6. Further Acknowledgements

During the course of the current pandemic we have sought to recognise the efforts of key workers within the road haulage and passenger transport industries who have contributed to the national effort in fighting the coronavirus outbreak. The role of commercial vehicle operators and drivers is not celebrated enough.

We have already acknowledged the work of key DVSA personnel who have offered their expertise and support. In particular, we must mention the efforts of Caroline Hicks, Del Evans, Neil Barlow and Dave Woods which have brought noted benefits to our operators. We recognise the value of the partnership work with HSE and in particular, Alan Craddock who is leaving his post as Head of the Transport and Public Services Unit for a well-deserved promotion. The report refers to the efforts of IoC under the leadership of Carl Lomas (Chair) and Tracey Worth (CEO).

We make particular mention of the support we have received from key stakeholders: the CILT, CPT, FTA, and RHA. We benefit enormously from the honest relationship and feedback we enjoy and, in particular from their respective Chief Executives: Kevin Richardson, Graham Vidler, David Wells and Richard Burnett.

The support of our sponsorship team, led by Duncan Price, is invaluable. We are grateful for the close working relationship we enjoy with that team. The loss of Elizabeth Shovelton is a gain for the rail policy team. During the current emergency the readiness of those officials and those in Buses and Taxis Division has been key to developing successful delivery policies.

We wish to record the efforts of Steve Jordan who, prior to the pandemic, insisted on the issue of laptops to OTC staff. Without this foresight we would not have been able to support operators during the lock down. The staff have continued to work remotely and to address challenges such as a sudden change in bus registrations or the need for temporary exemptions for vital goods operations. Many citizens have had to adapt to the challenges of balancing family responsibilities with working at home but OTC work can be very complicated. We pay tribute to the OTC staff who have worked so hard to maintain the service during the most testing times.

Our achievements to date have relied heavily on the dedication of John Furzeland, as head of our Corporate Office. His knowledge and experience informed so much of what we have achieved and was key to the additional guidance which has supported operators through the current crisis.

In current circumstances it is easy to forget that we saw the retirement of two experienced colleagues, Nick Jones and Simon Evans. They kindly stayed on in order to secure the recruitment of their successors, Victoria Davies and Gerallt Evans. It is a testament to them that they have succeeded in the most unusual of induction periods. Through the support of traffic commissioner colleagues they have made a positive start to their TC careers. What makes this a genuinely great place to work is the diversity of thought. The constitution of the Team has been refreshed and we are ready to meet the undoubted challenges of recovery and renewal.

7. Statistics

Our statistics for the year are contained in this downloadable statistics ODS file.

Please note that some of the statistics set out in the tables are compiled manually by OTC staff. This can result in the potential for minor inaccuracies occurring within the statistics. To minimise the potential for inaccuracies the figures have been subject to a validation exercise undertaken by OTC managers who have provided the traffic commissioners with their assurance that the figures are accurate to the best of their knowledge.

8. Contact Details

Further details about the commissioners and their other publications can be found on the Traffic Commissioners for Great Britain GOV.UK page.

Subject	Person	Contact information
Licensing Statistics (tables 1-5 and 8-14)	Simon Griffiths	Office of the Traffic Commissioner, Hillcrest House, 386 Harehills Lane Leeds, LS9 6NF, Email: simon.griffiths@otc.gov.uk
Bus Permit Statistics (table 15)	Lee Betts	Office of the Traffic Commissioner Hillcrest House 386 Harehills Lane Leeds LS9 6NF, Email: lee.betts@otc.gov.uk
Regulatory Statistics (tables 6-7 and 16-21)	Deborah Crosby	Office of the Traffic Commissioner, Hillcrest House, 386 Harehills Lane, Leeds, LS9 6NF, Email: deborah.crosby@otc.gov.uk
Media enquiries	-	Email: pressoffice@otc.gov.uk, Visit our media enquiries page