Written evidence submitted by Bedale Community Minibus (CTT0114)

              I am the Secretary and a Trustee of the Bedale Community Minibus and make this submission on behalf of all of the Trustees.

              In this submission we wish to express our concern that any changes being considered to the Section 19 Permit scheme take full account of all segments  of the Community Transport system not just one element . The case that has brought this matter to the fore appears to involve a large CTO operating with full time paid staff in an urban environment in a position to directly challenge a commercial operator.

              It must be emphasized that we are at the opposite end of the spectrum and our fear is that changes, possible justified, affecting the large CTOs will have unintended and detrimental consequences to ourselves and many other small rural CTOs.

1.              ABOUT OUR CHARITY

a.              We have provided a service to our local community in North Yorkshire for over 25 years, initially as part of the Voluntary Service Association, and more recently (October 2014) when we became an independent charity.  We have two 13 seat minibuses. One, from the beginning of Volunteer Minibus project, has been supported and replaced on a number of occasions by self-financing and some local district council support , the second was recently purchased ( 2016) with a grant from the DfT.

b.              Our charities governing document states that we are to provide affordable transport to those with disabilities, the elderly, local community groups and those in danger of becoming socially isolated in the local area. Our main activities in relation to those purposes, all for the public benefit, are to provide transport to: 

- Weekly markets.

- Patients to the local GP surgery (a first in the country).

- Children with learning difficulties to farm schools and weekend activities

- To local community groups on outings.

- Training all drivers to the MIDAS Standard  

c.              The charity relies entirely on volunteers for running the office, driving the buses, maintaining the buses, fundraising and training. Without them there is no community minibus. Our pool of 23 volunteer drivers provide over 2668 hours annually of driving time. 

d.              Our income is derived from vehicle hire, fund raising and donations, as such our day to day operations are self-funding. We do receive a fuel rebate form DfT. The charges we raise for the use of our buses are commensurate with the monies required to keep the buses operating. We do not make a profit, if there is a surplus it is transferred into reserves, which are of course monitored by the Charity Commission.  Our only recourse to external funding is by applying to North Yorkshire County Council for grant aid to part fund the purchase of new busses. Normally once every 4 to 5 years. 

2.              THE EFFECTIVENESS OF THE DFT, DVSA AND TRAFFIC COMMISSIONERS’ GUIDANCE TO, AND REGULATION OF, COMMUNITY TRANSPORT.

a.              We were unaware of any of the matters to do with the letter of 31 July, until we received newsletters from Mobility Matters in mid late October 2017.

b.              If we require guidance on the operational side of the minibus we contact the Community Transport Association or the MIDAS Training Organisation. They have been very useful and have the requisite back ground experience, to where necessary, interpret government documentation, to a level the volunteer organisation can fully understand.

c.              Our suspicion is that government do not fully understand the needs of the small operator, our voice is not sufficiently strong.  

3.              RELATIONS with COMMERCIAL OPERATORS and SUPPORT FORM LOCAL AUTHORITIES

a.              We have two major commercial operators and a number of taxi companies in our local area. To our knowledge there has been no complaints made by these operators at the services we provide. We suspect that they are not interested in them as they would be commercially unviable. On some occasion’s we have referred potential hirers to the commercial operators if we are unable to provide a minibus or the hirer does not pass the ‘public benefit’ test.

b.              North Yorkshire, with a very large rural road network, has had bus services provided by commercial operators. Many of those services have stopped in the recent past as not viable, some have been maintained, solely linking the main populations centre on a limited service. There is one service run by a CTO, the commercial operator withdrew from it, is heavily supported by North Yorkshire County Council (NYCC) with buses and subsidies. We have been asked to run a local service under Section 19 by NYCC with a minibus loaned to us by NYCC but after a trial period the service was stopped through lack of demand. We were not disappointed at that outcome as our volunteer drivers were unwilling to continue.

c.              Transporting patients to our local GP Surgery is a recent innovation aimed particularly at those with no access to personal transport, or public transport (in most cases because there is none) and cannot afford taxi fares. We receive some limited support via a donation from a church group  to maintain this service. This however is no a guaranteed income stream.

d.              We receive no support from NYCC or other public bodies to maintain our day to day operations.       

4.              THE SAFETY, SECURITY AND SERVICE QUALITY IMPLICATIONS OF LICENSING COMMUNITY TRANSPORT SERVICES VIA SUCH PERMITS

a.              Our servicing schedule is based on the laid down guidelines and this includes tail lifts. The minibuses are fitted with the lap/diagonal seatbelts and WTORS for different types of wheelchair

It is of note that our buses undergo rigorous MOT equivalent inspections every 3 months and the tail lifts every 6 months. Whilst not denying this ensures the buses are always in good working condition it means that one bus has now been inspected every 2000 miles, a bus in commercial use which operates under the same regime is inspected every 4500 miles. Our new bus, funded by DfT in 2016 with less with 5000 miles on the milometer has been inspected 5 times already. The cost of each inspection is not insignificant and is a drain on scarce funds   

c.              All our drivers and escorts are MIDAS trained to Accessible level (Disability and the carriage of Wheelchairs in Minibuses etc). They are all DBS certified.

d.              We place great emphasis on service quality. Dependant on the passenger, we are fully prepared to offer a door to door service and will provide escorts on some tasks where we know additional support is required. This ethos comes not from any dictat but how our drivers wish to serve the community  

5.              THE POTENTIAL EFFECTS OF A MOVE AWAY FROM PERMITS TOWARDS PSV OPERATOR AND PCV DRIVER CERTIFICATES AND LICENCES  

a.              A move to this level of certification and licensing would see the Bedale Community Minibus ceasing operations. We could not afford the cost of training drivers to PSV and providing medicals. It is very unlikely that our volunteer drivers would wish to go through that level of training and continuing certification.

b.              It would certainly not encourage others to join and it is suspected that those that did would see it merely as a route to acquiring a D Licence and not give any allegiance to the minibus. This allegiance to the minibus by our volunteer drivers is critical to sustaining our operations.   

c              A service based on smaller vehicles ( 8 seats ) would not, in the majority of cases, be workable, because of the numbers we carry. There are no other organisations in the local area to combine with.

CONCLUSIONS

The services we provide do not challenge commercial operators in our local area.

We are very careful to work with the conditions laid down by the Section 19 permit.  

We are a small CT operating in a limited local geographic area, to a very specific service user base that is not provided for by other commercial operators. Make harsher/more restrictive the conditions under which we presently operate and we would have to cease operating thus depriving many needy folk of an essential service.

RECOMMENDATIONS

Great care is needed, if legislation is changed, to ensure that the basis under which we operate is not adversely affected thus threatening our ability to continue operating and providing an essential service to the local community.

November 2017