The Traffic Commissioner’s Annual Report 2023-24: Challenges in the transport industry and the future
08 October 2024
The Traffic Commissioner’s Annual Report for the year ending 31 March 2024 (Annual Report) was published on 7 October 2024. In the Annual Report, amongst other things, the Traffic Commissioners provide updates on their strategic objectives to 2025 and evaluate the current state of the industry. The Traffic Commissioners have also attempted to identify common themes arising at hearings from which other operators might learn from in order to avoid regulatory action.
What are the main topics discussed?
This year the report links to real cases to allow the reader to gain a deeper understanding of the issues seen at public inquiry and it is really worth a read. It acknowledges that economic factors and changes in skills requirements continue to challenge operators.
The Annual Report examines topics such as: delivering a better regulatory service; changes to bus services; transport manager CPCs; and drivers and continuous control and use of “self-employed” drivers.
It also discusses maintenance shortage; drivers’ hours; and periods of grace.
The work undertaken around local bus services, such as bus open data, enhanced partnerships and bus franchising are also mentioned.
Statistics
The Annual Report provides a valuable insight into the licensing and regulatory activities undertaking by the Office of the Traffic Commissioner and is a useful reminder that action will be taken against non-compliant operators:
- 11,383 operator licence applications and variations processed.
- 11,332 local bus registrations processed.
- 1,283 public inquiries determined.
- 156 preliminary hearings held.
- 41 Senior Team Leader (STL) interviews held.
- 15,584 vocational driver cases closed.
The Annual Report also highlights some other interesting statistics:
- 81% (circa) of domestic freight was moved by road by UK registered vehicles (up from 77% last year).
- 7 billion local bus service passenger journeys took place (up from 3.1 billion last year).
- 1.62 million people employed in storage and transport.
Eye on the future
Digitalisation remains a key priority. In the next 12 months the process operators need to follow every five years to legally continue their licence will be digitalised. The intention is for this to provide faster processing times, a reduction in the burden and greater security.
Other areas that were discussed were autonomous and electric vehicles. The road haulage industry has been identified as having a critical role to play in reaching Net Zero across the UK by 2050.
Operators of light goods vehicles which currently rely upon a transport manager with Acquired Rights will soon need to appoint a suitability qualified transport manager when those Rights expire in law on 20 May 2025.
The Annual Report acknowledges it is becoming increasingly evident that, with new technology and differing ways of working, the role of the transport manager has changed. It states that is important for transport managers, particularly those who have been in the role for some time, to receive up-to-date training on managing the responsibilities they now have. The Annual Report stated “Transport managers now need to be able to understand the implications of the technical readout they receive from tachographs and preventative maintenance inspections, as well as the employment status of their drivers. Traffic Commissioners continue to highlight that there is a difference between obtaining a paper qualification and the ability to actually exercise effective and continuous management of a transport operation, which is the statutory requirement of a transport manager.” This approach is a continuation of the interest already shown by the Traffic Commissioners in the CPC exams for both drivers and transport managers. Following the consultation undertaken by DfT on Driver CPC changes this is still on their radar.
Regarding maintenance, the availability of timely and good maintenance is acknowledged as still being limited. The Annual Report flagged that operators should be aware of the changes to the DVSA Guide to Maintaining Roadworthiness from April 2025 in that a laden roller brake test or electronic braking performance monitoring system (EBPMS) will be the only accepted methods to assess brake performance.
The Annual Report highlights an increasing number of cases regarding drivers’ hours. They have included cases of driving without using tachograph cards, altering tachograph records and using the card of another driver to avoid resting. This is often seen as demonstrative of systemic issues with systems.
Periods of Grace and the misunderstandings that many operators have about what they are and how to use them is also cited as still being a problem – particularly the implications for operators who fail to take appropriate action following one being granted.
Dishonesty and operators “lending” their licence authorities to others was also picked up on this year.
Improving access to relevant compliance information
The Traffic Commissioners have published “Key Traffic Commissioner Resources” which provides users with links to key resources that Traffic Commissioners regularly refer to here.
Conclusion
As cited by the Senior Traffic Commissioner and Traffic Commissioner for the East of England, Richard Turfitt in his foreword to the Annual Report, it is the fiftieth anniversary of the introduction of the Health and Safety at Work etc Act 1974 which require businesses to create, review and update their systems, based on what is reasonably practicable to control their own risks. This year’s Annual Report is a poignant reminder of this and the importance of safe, fair, and reliable passenger and goods transport industries.
Backhouse Jones is an award-winning transport focussed law firm which specialises in the matters highlighted in this Annual Report. Please contact us here for a no-obligation conversation if you would like to discuss further.
You can view the Annual Report here.
This article was written by Jo Dawson-Gerrard.
