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Dummy run
IN those self-confident days when the Transport Bill was still at an early stage of its passage through Parliament the then Minister of Transport, Mrs. Barbara Castle, committed to paper an estimate of the possible costs and benefits which might arise from the road goods transport provisions. With de-licensing and quality licensing she may have thought she was on reasonably, safe ground in forecasting economies.
It was suggested that the release of 900,000 light goods vehicles must mean substantial administrative savings for the Government and probably also for operators. Quality licensing for the remaining 600,000 vehicles, said Mrs. Castle, should not of itself involve any increase in the costs of reputable operators. She agreed that the minority of less reputable operators might find themselves spending a good deal of money in bringing their vehicles up to the required standard.
The evidence
Evidence on the effect of de-licensing is beginning to come in. The Commons Select Committee in its recent report noted that it had reduced the receipts of the Ministry of Transport by about £130,000. The operators must have gained by not having to pay this amount but there is no suggestion in the Committee's report that so far the Ministry has been able to make corresponding economies in administration.
Perhaps it will have better luck with quality licensing. Some idea of what is involved has come with news of the pilot scheme which the Ministry is conducting to test the suitability of licence application forms. The scheme will cover Scotland, the West of England and South East England. In each of these areas between 300 and 500 operators are being asked to assist by completing the dummy form.
It is in any case a transitional document since it is appropriate only for holders of a current A, B or C licence. New applicants will have to give a good deal more information. They will be asked about their financial resources; about their plans for securing observance of the law on drivers' hours and overloading; and in due course about the proposed holder of the transport manager's licence. These additional points will also be included in the application form to be completed by established operators when their licence comes up for renewal.
Even the first draft form will take a considerable time to complete. It asks among other things for particulars of convictions and of licence revocations or suspensions over the past five years, and for precise details about the method used for vehicle inspection, the facilities available for the purpose and the system for recording inspections for defects and for work carried out.
It is a formidable document to which no summary can do justice. The specification of the vehicles will have to be precise and there must be some indication of the work they do. The Licensing Authority would otherwise hardly be able to judge whether the maintenance facilities are adequate. These facilities will also have to be split up between those which the operator provides for himself and those which he hires from a garage.
When the genuine forms have to be completed in earnest the operator will need one for every traffic area in which he has an operating centre. The clerical work will be multiplied several times. If the task is as onerous as it looks from the provisional form the operator who is invited to take part in the pilot scheme should not hesitate to say so. He has the opportunity to be as blunt as he likes in the knowledge that on this occasion at least it will not be held against him.
The Ministry has given an assurance that information from participating operators will be treated as confidential and that the dummy forms will be destroyed as soon as the results of the survey have been analysed. This ought to release a few inhibitions although at the same time it must contribute towards creating an atmosphere of unreality.
The whole truth
For example the assurance from the Ministry presumably means that no attempt or only a desultory attempt will be made to check the accuracy of a completed form. The operator will be on his honour to tell the truth and the whole truth. When the real application comes to be made the situation will be different. The operator can incur heavy penalties if the information he proffers is incorrect or incomplete.
In many cases the Licensing Authority will have the corroborative details in his possession. This will certainly happen where they are concerned with the revocation or suspension of earlier licences or generally speaking with convictions. It may even seem a little hard that the operator should be compelled to arraign himself for misdemeanours which he would prefer to forget and still perhaps not be safe from a sharp-eyed clerk who subsequently brings to light a penalty he has failed to include.
It is not clear what method Licensing Authorities have adopted for choosing operators to take part in the experiment. A random selection would have been preferable since it would eliminate the risk that too many of the forms would go to the more articulate operators who are well known to the Licensing Authority and who, it has to be admitted, are more likely than some of their fellow operators to take the trouble to fill in the form and return it. It is to be hoped also that a proper proportion of the forms will go to C-licence holders who in the past have had to endure much less of this type of clerical burden.
The likelihood
The likelihood is that in any event most operators will take the form they receive to their local association secretary or in a few cases to a transport consultant Small hauliers at least are notoriously backward in the art of filling forms. The Prices and Incomes Board was not the first to find this out. A document which may seem admirably explicit and even a thing of beauty to the bureaucrat who designs it may strike terror in the heart of the operator whose best friend is his waste paper basket. His first impulse if he is one of the chosen few hundred will be to call on the expert.
There is a possible danger here. Most transport association officials have had long experience of treating operators with paper allergy and have become adept at classifying random and even incoherent comments into the right pigeon-holes on a form. For them the new trial document will present few difficulties.
Their too active co-operation could defeat the Ministry's laudable purpose. If 1,000 dummy forms are distributed and 1,000 returned with all the required information correctly given the Ministry would be justified in concluding that it had wrought even better than it knew and that by some happy accident the perfect form had been devised.
The experts must restrain their enthusiasm. Naturally they will not discourage any operator from coming to them for advice. Their own opinions on the draft form would be valuable and ought not to he ignored by the Ministry. In the last resort the operator should ideally be left to his own devices once he has been given the advice and information available. Here is a unique occasion when he will not be penalized for lack of ability to translate his business activities into the linear form provided by several pages of numbered rectangles.
Like the plating and testing scheme which is complementary to it quality licensing runs a serious risk of sinking under its own weight. The purpose is sound if it is to eliminate those operators, said to be in a small minority, who should not be allowed to have control of vehicles and drivers.
Apparently there is no simple method of sorting the bad operators from the good. They must all undergo the same series of tests and scrutinies.
This may sound admirably scientific. But if the tests are too elaborate and the assistants too few there may be less satisfactory results than could be obtained from a more rough-and-ready process which is more accurately directed.