letters
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re welcome letters for publication on transport topics. Address them to )mmercial Motor, Dorset House, Stamford Street, London SE1
HA objection
r Granville Russell's letter (CM February 5 I71) states that he resigned from the Road iulage Association principally because the isociation "appears to be unwilling" to iject to applications for operators' licences
,d because it did nothing to "combat" entry :o the industry of "new light van operators",
I should like to point out that the R HA has aged objections to applications in circum3nces only when there is evidepee to supwt the pa rticular grounds of objection which e prescribed in Section 64(21 of the Transport ,tt 1968. Neither inexperience of the industry, as Mr Granville Russell described it, he crowding out of established operators" a ground for objection under the Act.
So far as light vans are concerned the RHA epared, but was unable to interest Members Parliament in, amendments to the Transport II that were designed, in appropriate cases, bring these vehicles under the control of )erators' licensing.
Not only are Mr Granville Russell's cornaints misconceived but his resignation (if it
m properly be called "resignation") is mis-ned since the only notice of it given to the HA is in his letter to Commercial Motor. E. W. RUSSELL, Secretary, RHA, London.
latter of management
urging road hauliers to review their costs Id to inform customers without delay of creased rates, Mr William McMillan, chairan of the Road Haulage Association, in a cent speech said hauliers were not obtaining wthing like as great a return on their capital .3 trade and industry in general. I am sure no le would argue with that statement.
But what precisely is a road haulier to do ith this piece of advice and what will be the fect if he takes it? After all if the market aders, namely BRS Ltd, who in 1970 raised 'elf rates by nearly 20 per cent are still ly able to manage a 3 per cent return on )pital (MB report), then what hope is there for le average haulier, who inevitably has to illow rather than lead, of achieving anything (e a reasonable return?
I think this obsession with costs and rates concealing the real problem of poorer iturns in the industry. In fact I doubt if any ut a few have systematically identified the basic problem and found a method of solving it: and spending a lot of money on such things as CAPS exercises land thereby implying that identification of costs is the major problem) is like a doctor trying to cure a patient before he has defined the nature of the patient's ailment.
If we examine the few haulage companies that are making adequate profits, the only factor common to all of them is that of good management. Of course they are cost conscious, and rate conscious, and personnel conscious and customer orientated, but they do not rely on any one of these by themselves to produce the desired result.
Merely chasing cost increases by rate increases will not achieve anything without a clearly defined and quantified year-end (and long-term) objective, and in fact the purpose of business management is just that: to achieve the company's objective. Once this principle has been accepted and acted upon, all the other activities that together make the business function successfully begin to fall into place. To quote Peter Drucker: "Profit in a well-managed business is not what one happens to make. It is what one sets out to make because one has to make it."
The R HA does a good job in publicizing its members' problems and the financial plight of the industry but I would like to see a lot more emphasis placed on the business management aspects of the industry. The fact that the R HA is sponsoring business courses for senior managers later this year is an encouraging start.
MAURICE ROUNDING, Freight Information Services, Formby, Liverpool.
Trade plate amendment
We would disagree with a statement in the article "Trade plate amendment will hit operators", CM August 28 1970. In the first paragraph -An amendment, under the 1970 Finance Act, to the definition of recovery vehicles means that operators will not be able to use trade-licensed vehicles to tow disabled commercials unless the towing vehicle is equipped with lifting gear or equipment designed for drawing a disabled vehicle when raised" (my italics). It is in particular with the italicized words that it appears to us that too narrow a view or misinterpretation is made.
It seems that this misinterpretation is per petuated by Mr L. Oldridge in CM January 29 1971 "Know the Law-, in which he says: "In plain English this Would seem to mean that a vehicle used under trade plates for towing broken-down vehicles back to the workshop must either be fitted with a crane or be carrying or towing an ambulance or 'tow boy'. In other words it must be equipped with some specialist equipment for raising the wheels of broken-down vehicles off the ground. It is not permissible to draw a disabled vehicle with a towbar, chain or tow rope behind an ordinary vehicle not equipped with the special lifting gear. The unlicensed vehicle standing in the yard can no longer be used under a trade licence for the odd towing jOb.
There appears to be a tendency for both the FTA and Mr Oldridge to be influenced by the intention of the first definition in the Finance Act 1969 in that the vehicle should be specially fitted or constructed for recovery purposes, when interpreting the later definition in the Finance Act 1970.
We would read the definition more broadly and go as far as to say the definition can be separated into alternatives as follows: (1) A vehicle on which is mounted; (2) or is drawing; (3) or which is carrying as part of its equipment apparatus designed for raising a disabled vehicle wholly or partly from the ground; (4) or for drawing a disabled vehicle when so raised, The word apparatus is defined in the dictionary as "things provided as a means to an end, collection of implements or utensils for affecting an experiment or given work". Taking the third alternative "which is carrying as part of its equipment apparatus designed for raising a disabled vehicle wholly or partly from the ground" it appears to us that a jack suitable to raise the disabled vehicle would fit this part of the definition of a recovery vehicle's equipment apparatus. Therefore, any vehicle, even a car carrying a suitable jack for the recovery to be undertaken, would fit this part of the definition. It would follow that a rigid towbar or chain could be used; there is no requirement to tow the disabled vehicle in a raised position.
We are not arguing with the intention of the definition of a recovery vehicle but with the wording.
The Ministry maintained in the article in CM August 28 1970 that vehicles for recovery purposes should as a general rule qualify by their design or construction. However, as they will quickly point out when pressed, they are unable to interpret their own Acts; this is a matter for the courts. D. G. SENIOR and H. BENROSE, Sheffield 5. [Interpretation is certainly a matter for the courts, but until this point is tested in the courts we believe our view (supported by Mr Oldridge) to be the correct one. This is still very firmly the view also of the Freight Transport Association. Ed.I
A Pitt design
Apropos the article on rubber suspension (CM February 5) it would appear that the credit for designing the suspension fitted to the 35-ton ultra-low-loading and the lighter low-loading trailers of Pitt Trailers has been given to Aeon Products (London) Ltd. Although every help was given to Pitt Trailers by Aeon Products the complete design was evolved and completed by the Pitt Trailers design engineers.
G. N. ANDERSON and WILLIAM PRESS, Ex-Pitt Trailers