The Traffic Commissioners (TCs) produce an annual report for the Secretary of State giving their observations from the last year and their strategic plans for the following year. In this article Richard Smith outlines the main points of the report for 2020–2021 and examines some of the detailed statistics included about licensing and disciplinary functions.
The Senior Traffic Commissioner’s Foreword
The Senior TC rightly identifies 2020–21 as a difficult year for the transport industry and for the Traffic Area (TA) Offices. Nevertheless, both have responded and adapted to the circumstances and, as the figures emphasise, the TCs and their staff have provided an example for other government agencies in the provision of service to their sector.
The average time taken to process a goods vehicle operator’s licence has increased from 36 days in March 2020, before the pandemic really had any effect, to 47 days at the time of the report — an inevitable increase, but only a modest one in the circumstances and well within the statutory nine-week requirement.
The contingency guidance published by the Senior TC early in the pandemic and before the first lockdown, has been kept regularly updated and the wider service provided to the industry has been instrumental in keeping supply chains moving. The relaxations and concessions made (see Concessions for Transport Operators During Covid-19) have been proportionate while maintaining public safety and illustrate the flexibility and effectiveness of the regulatory system.
Traffic Commissioners’ Reports
The Commissioners express concern over the emergence of a trend concerning poor maintenance of trailers, perhaps due to an increase in the number of traction-only operators driven by the increase in e-commerce. While routine maintenance and safety inspections of trailers on short-term hire is normally the responsibility of the trailer owner, O-licence holders are reminded that the obligations on them also extend to the trailer.
The availability of drivers is an acknowledged problem, but the Commissioners emphasise that the shortage should not lead operators to retain the services of unsatisfactory drivers who, even after retraining and disciplinary processes, fail to improve.
The Shape of the Industry
The report snapshot shows, as previously, that the majority of domestic freight (79%) was moved by road. This amounted to 153 billion tonne kilometres (bn t/km) — an increase of one billion tonne km. UK registered vehicles were involved in 4.9 bn t/km of international freight movement, understandably down on the previous report’s 5.6 bn t/km. “Transport and storage” employed 1.46 million people, a marked decrease from the previous report’s 1.56 million.
In a general overview, such as these figures provide, it is impossible to attribute any particular reason for the changes in the figures and, although Brexit and Covid-19 have likely had some effect, it is difficult to assess the scale of that impact, particularly bearing in mind the different reporting periods for different sets of statistics and that neither factor has necessarily been in effect for a full 12 months.
While some of the headline statistics show a small decline, with the number of licences rising by 545 to 69,528, it is not possible to say whether this is because of new operators entering the market or existing ones establishing new operating centres in other Traffic Areas. The rise appears to break a 10-year trend of decline, however, 2015-16 saw a similar reversal but only for one year. We must therefore wait and see whether the increase will be maintained.
On this occasion the entire increase was in international licences, which rose by 1% (to 13% of the total) having seen no significant rise in the 2015-16 aberration. Numbers of national and restricted licences continued to fall, although the trend appears to have levelled-off. The split between the different types of licence within the overall total remains much the same with most (51% — down 1%) being restricted licences, and national licences accounting for the remaining 36% (the same percentage as last year, though slightly down in absolute numbers).
The South Eastern and Metropolitan (SE&M) and Scottish Traffic Areas (TAs) saw a continued fall in the number of licences in total, which is accounted for by restricted and national licences. All TAs shared in the increased numbers of international licences, although to a much lesser extent in SE&M, Scotland and Wales. The Traffic Area with the highest total number of licences in every category is the Eastern TA, which also saw by far the greatest increase in international licences, closely followed by West Midlands TA, which also has the smallest number of international licences of all the English TAs and only Scotland and Wales have fewer.
The total number of vehicles in use in 2020–21 rose to 369,287 after a reduction in 2019-20, although numbers of vehicles on restricted licences fell again. The greatest number of vehicles by far (192,831) are held on national licences with the numbers held on restricted and international licences showing a converging trend towards a mean of about 88,000 on each.
Despite the growth in international licences and the number of vehicles held on them, the number of vehicles in international service fell by 1% (to 41%) having risen steadily since a 10-year low point in 2016-17; evidence that in addition to the increase in vehicles held on national licences, international operators are also expanding their operations within the UK.
The report no longer includes a detailed breakdown of operators by fleet size and it is only possible to calculate an average across the industry. However, such averages can be misleading or meaningless on their own and it is worth recognition that this average is made up of a large number of small fleets and a small number of large ones. Taken over time, however, these averages do perhaps show a trend and in this case the average fleet size for all types of licence remained steady, having plateaued at 5.3 since 2018 after a general rising trend from the beginning of the decade.
Within this overall picture, the average number on international licences (9.4) fell slightly while those on national licences (7.7) rose. Perhaps this indicates that the increase in international licence holders comes from very small operators. It is also possible that new or expanding operators are choosing to take out international licences for national work. There is, after all, no difference in the requirements between national and international licences and it would give flexibility for the future. The average number on restricted licences remains the same at 2.6.
Regionally it seems that while average fleets on restricted licences are about the same across the country (very slightly higher in SE&M) the averages for international licences are generally larger in the north of England than in the south while the reverse is true for fleets on national licences.
There are no data on the number of licences refused (if any) solely on environmental grounds but the numbers of licences granted with environmental restrictions (both new licences and publishable variations) have been recorded since 2015-16.
There is no clear trend that emerges from the limited data but in general the greatest number of licences granted with restrictions are, unsurprisingly perhaps, in the South Eastern and Metropolitan TA, with the Western TA close behind despite both these areas having the lowest total number of licences in England.
Again, the figures vary dramatically year on year, but two trends are apparent. The first is that TCs regularly make much greater use of revocation, curtailment and a warning than they do of suspension of the licence and disqualification of the licence holder or transport manager. The second is that during the period since 2010-11 the numbers in the first group have fallen by 54%, 35% and 41%, respectively, while disqualifications were up by 77% in the case of the licence holder and 37% in the case of the Transport Manager. Licence suspensions also fell by 41% over the same period.
The report shows a sector that continues to be of vital, and growing, importance to the nation, especially during the pandemic, and it is one that continues to lead the way in regulatory and operational agility in difficult circumstances.
Please also refer to — The Annual Traffic Commissioners’ Report 2020–21.