The compliance landscape for coach and bus has long been intricate, and there can be no argument that barriers to both entering the industry and operating large vehicles should be high.
But there is also potentially a position to be made that gradual but consistent rollout of new and changed requirements has made the position borderline unmanageable for some. Good news for transport consultants and other advisors perhaps, but not always so for parties whose interest and skillset are in operating compliant, high-quality services.
A report from the recent UK Coach Operators Association conference shows that transport legal specialist James Backhouse covered many areas in his address.
A rise in the compliance field of senior team leader meetings and preliminary hearings held by Office of the Traffic Commissioner staff, while no doubt allowing more misdemeanours to be targeted while focusing Traffic Commissioner (TC) time where it is most needed, was among Mr Backhouse’ points.
The prospect of ‘propose to revoke’ letters arriving, seemingly out of the blue, will strike fear into any recipient, and a need to address them by requesting a Public Inquiry (PI) is hardly a tempting course of resolution.
Likelihood of the current position easing is limited, Mr Backhouse warns. Instead, he cautions that the level of scrutiny will grow increasingly stringent, with PIs set to become more rigorous and complex.
It remains to be seen where the additional resource might come from to deliver that. Few are those familiar with TCs’ conference presentations who will be unaware of existing limitations on their function, with several TCs having made their frustrations there very clear.
When combined with the addition of new items to the regulatory spectrum, the picture is extraordinarily complex. One operator notes how testing it is not just to ensure compliance, but to be aware of every facet of those requirements in the first place.
Few would want the current conformity requirements that underpin the sector to be reduced. There is no reason to suggest that they should be. A look at some other parts of the overall transport world illustrates what happens when barriers to entry and general levels of regulation are low.
But there must be a more cohesive way while maintaining high standards. A new Senior TC is on the way in 2025. Will they seek to change things?
It is difficult to see how they could without backing from ministers, and even then, the task would be gargantuan. Progress with the PSVAR review and BSOG overhaul in England illustrates that high-level reform progresses slowly, or not at all in the case of BSOG.
Instead, legal webinars, consultants and advisors will be an ever-more prominent part of running a compliant PSV operation. That is as good as certain.
