Section 19 and 22 operators play an important role in the provision of transport for councils and are often the only means by which people can maintain an independent life, reducing the demands on other public services.
1. DfT need to ensure that new definitions of non-commercial and not-for-profit are clear and understood by CT operators, councils and others that rely on their services and permit issuers so that the status of an organisation or contract is not challenged, leading to service disruption for councils and communities. Transport schemes do not have the resources to seek legal advice on these regulations – funding should not be diverted from meeting transport needs, therefore the guidance must be clear. A review of organisations that can issue permits may also be appropriate.
2. It would be helpful to clarify how an organisation which has a main occupation other than that of road passenger transport is defined. It would seem that under new proposals a stand-alone community transport provider offering identical services as one where community transport is a small part of their operations will operate under different legislation. This could create significant inconsistencies and we do not think that it would be helpful to communities if licensing is impacted by the type of organisation providing the service.
3. In response to questions regarding possible exemptions for short distance undertakings it is difficult to define minor impact and short distances. Community transport is a minority transport provider except in areas where no other transport exists. Community Transport schemes can operate regionally to access such facilities as healthcare which are now being centralised to provide specialist care. Short distances are therefore difficult to define, particularly in rural areas.