Department for Transport Consultation On

Department for Transport consultation on:

Strengthening local delivery – Modernising the traffic commissioner system

Response from Brake, the road safety charity, October 2007

Introduction

Brake, the national road safety charity, is dedicated to stopping deaths and injuries on roads and caring for people bereaved and affected by road crashes. Brake’s division the Fleet Safety Forum works to promote best practice among fleet managers and people who drive for work, focusing on risk management, driver safety and vehicle safety. Alongside many other road safety issues, Brake campaigns for better enforcement of commercial vehicle safety and tougher penalties for companies flouting safety regulations.

General comments

Brake’s primary concern is with road safety. Its comments are therefore restricted to the impact any modernisation of the traffic commissionersystem might have on commercial vehicle safety issues.

Answers to questions

Do the proposals strike the right balance between local accountability and national consistency?

While Brake appreciates the need for and benefits of a nationally consistent traffic commissioner framework, it is concerned that the creation of a panel of traffic commissioners could lead to a reduction in the regional knowledge heldby existing regional-based traffic commissioners. Brake therefore recommends that should a Board of Traffic Commissioners be created, casework should be largely allocated to individual traffic commissioners on a regional basis, to allow each commissioner to build up expertise about their region.

What are your views on the resources implications of the proposed changes?

The consultation paper seems to focus heavily onbus punctuality and Brake is concerned that increased emphasis on this function may take resources away from other, more important functions of traffic commissioners.As outlined in the consultation paper, the prime function of traffic commissioners is the licensing of operators of heavy goods vehicles and public service vehicles. Their primary concern, inextricably linked with this function, ought to be safety and Brake would like reassurance that resources will not be diverted away from this function in order to make improvements inother areas such as punctuality of buses, which are not matters of life or death.

Should the terms of appointment for future traffic commissioners be fixed?/ Would limiting the terms of appointment compromise the impartiality of the traffic commissioners?

The independence of traffic commissioners is absolutely essential. Brake is concerned that introducing time-limited contracts, which may not be renewed, may encourage a more target-based approach to the role of the traffic commissioner. While targets can be helpful, in this case they would be undesirable if they focussed on quantitative achievementsat the expense of quality decision-making.While the consultation paper states that ‘the independence of traffic commissioners is of paramount importance’, there is no detail on how the Department will preserve this independence if traffic commissioners’ terms of appointment are changed.

Do you agree that separate traffic areas be retained for Scotland and Wales?

Brake agrees with this proposal. Regional knowledge can be a useful tool for traffic commissioners, and therefore there are substantial benefits to having separate traffic commissioners for Scotland and Wales.

For information, contact Rachel Burr, campaigns officer, on 01484 530085.