The document summarizes a consultation discussion hosted by the Community Transport Association (CTA) regarding the UK Department for Transport's consultation on licensing arrangements for community transport. The discussion re-capped what is known about the issue so far, shared key points from CTA's response to the consultation, and the impact of their #WithoutCT campaign. Attendees were encouraged to share their concerns and views, and discuss how CTA could support their organizations.

1. Discussion: Department for
Transport Consultation
@CTAUK1|#CTARoadshow

2. Purpose of the session
• Re-cap of what we know so far
• Share key points from our consultation response
• Share the impact of the #WithoutCT campaign
• Hear your concerns and views
• Understand how CTA could support your organisation

3. Background to the issue
• In 2015 the European Commission told the UK Government to address how its
directives on operator licensing were interpreted into UK law.
• On the 31 July 2017 DfT wrote to permit issuing bodies informing them of DVSA
action in relation to a live case
• They have reached a view that the nature of their minibus operations is such that
they cannot use derogations from 1071/2009 because:
they did not have “a main occupation other than that of road passenger
transport operator”
The type of work they are doing did not justify a conclusion that this was
“exclusively for non-commercial purposes”

4. Transport Select Committee Inquiry
• On the 10 of October 2017 the Transport Select
Committee launched an inquiry into licensing
arrangements for community transport
• Two oral evidence sessions took place in November,
CTA’s Chief Executive Bill Freeman gave evidence
• On the 14 of December 2017 the committee
published their report on community transport

5. The Consultation
• The DfT launched their consultation on the use of
section 19 and section 22 permits on the 8th of
February 2018
• It was open for 12 weeks and closed on the 4th of
May 2018
• An impact assessment was released by the
Department at the same time

6. Supporting Members to Respond
• Produced guidance and toolkits.
• Worked with numerous MP’s to raise
the issue in Westminster.
• Worked with other national
membership bodies to extend the
reach of our arguments .

7. #WithoutCT
• #WithoutCT was used on social media to
highlight the value of community transport
and consequences of a world with out
community transport.
• Tweets using #WithoutCT were seen over half
a million times and helped to encourage to
encourage a wider range of organisations,
such as Age UK, to respond.

8. The content of the consultation
• The consultation document proposed a ‘General
principle’ that:
operating a vehicle to provide passenger
transport for payment should be treated as
using that vehicle for commercial purposes,
whether or not the operator has not-for-profit
status’

9. The non-commercial tests
• The consultation outlined non-commercial tests which could be used as
exemptions from the general principle:
 The service is free of charge
 Any charge for the service is substantially less than cost
 Any charge for the service equals (or exceeds) cost
 Occasional services
 Incidental services

10. Short distance exemption
• The consultation also sort to explore a further exemption for services
‘engaged exclusively in national transport operations having only a
minor impact on the transport market because of…the short
distances involved’
• The DfT suggested that a radius of 15 to 20 miles from the base of an
organisation could be considered

11. CTA’s Response
• Three big issues were identified from initial
conversations with members:
1. Things are still unclear
2. Outsourcing enforcement to commercial
operators is unworkable
3. This is unfair

12. Our Eight Fundamental Points
• CTA’s response to the consultation was formed by
8 fundamental points which were reinforced
throughout the document in answer to the 6
consultation questions asked by DfT

13. Our Eight Fundamental Points
1) The legal foundation of these reforms are questionable
2) The guidance is not clear in its purpose
3) Trying to regulate by individual services in unworkable
4) Allowing commercial operators to decide how to enforce the Regulation
is the wrong approach

14. Our Eight Fundamental Points
5) There are too many costs and consequences that go
beyond settling the nature of the complaints about
community transport
6) This will not create fair competition or end the challenges
and disruption to community transport

15. Our Eight Fundamental Points
7) Local authorities and other public bodies that commission
services are best placed to determine the nature of the
local market and enable fair access to it
8) The UK Government needs to assert its leadership over
the tone and terms of its approach to community
transport

16. The Department’s Interim Summary
• On 20th July the DfT released a summary of the responses they had received.
• Almost 500 responses were received mostly from community transport
operators.
• The DfT stated that they plan to “undertake further work in order to
determine the final approach to be taken to the guidance and draft
regulations” with a view to announcing the Government’s response to the
consultation “in the autumn.”
• The Department also reiterated that, whilst the consultation process is still
ongoing, it would be premature for any local authorities to end or withhold
contracts from permit holders.

17. Group Discussion
• We want to hear your thoughts and concerns.
• Is there something CTA could do to support your organisation?