In response to the DfT’s proposed changes to S19 and S22 permit regulation [routeone/News/11 April], the financial costs to the government will be astronomical let alone what impact it will have to the less mobile members of a community.
I agree with some of the Bus and Coach Association’s points that there are many community transport organisations (CTOs) that abuse the S19 and S22 permit system.
In my eyes, a CTO is simply a single non-tied organisation from that community and it should be them and them alone that should be permitted to use the S19 and S22 permits.
Then there is the loophole that if the CTO is operating under the umbrella of something other than transport it would be able to get around the legislation.
Instead of fighting among ourselves as to who can and cannot operate under the permits, the government should be challenging the EU to determine their correct definition as I believe even they are uncertain.
There is no point crippling more than 80% of CTOs for a legislation that will most definitely have to change once the UK leaves the EU. Once the CTOs have gone, who is going to meet the needs of the end users and who is going to pay (more) for it?
It doesn't take rocket science for the legislation to be changed to allow CTOs to operate under S19 and S22 permits contrary to the EU ruling as we do for speed limits, HGV road usage at weekends, and all other road regulations that don't currently match those of the rest of Europe.
John McGowan
