Decision for Just Haulage Limited (OD2076359)
Written decision of the Deputy Traffic Commissioner in the West Midlands for Just Haulage Limited, Craig Hipkins, transport manager and driver Paul Jones
IN THE WEST MIDLANDS TRAFFIC AREA
JUST HAULAGE LIMITED - OD2076359
AND CRAIG HIPKINS, FORMER TRANSPORT MANAGER
DECISION OF DEPUTY TRAFFIC COMMISSIONER G. PENGELLY
DECISION
The operator license is REVOKED pursuant to section 27(1)(a) (loss of operator’s good repute), section 27(1)(a) (operator no longer of appropriate financial standing), section 27(1)(b) (TM no longer of good repute) and pursuant to section 26(1)(c)(iii) (prohibition notices), section 26(1)(f) (failed to honour undertakings), and section 26(1)(h) (change of circumstances);
Mr. Hipkins has LOST HIS GOOD REPUTE, with immediate effect, as a TM under Schedule Three;
Mr. Hipkins is DISQUALIFIED FOR A PERIOD OF TWELVE MONTHS (effective from 19.02.26 until 19.02.27) from being a Transport Manager on any operator’s license in Great Britain: paragraph 16(2) of Schedule Three;
All orders for revocation will take effect from 19.02.26 at 23:59;
The request for a PoG is REFUSED;
The former director, Ms. Lamb, will be written to in order to establish if she wishes to make written representations or request a hearing for there to be consideration as to disqualification under section 28.
Background
This was a conjoined public inquiry (“PI”) and driver conduct hearing (“DCH”) concerning Just Haulage Limited (“the operator”) and their driver, Paul Jones
The operator holds a standard international license issued in this Traffic Area on 19.11.24.
The operator was authorised to operate a fleet of four tractors and four trailers.
Mr. Craig Hipkins was transport manager (“TM”) in the period from 24.01.25 to 30.11.25; after Mr. Hipkins resigned in November 2025, there was an application – dated 04.12.25 – for Mr. Steve Daley to be added to the license as the new TM.
A period of grace (“PoG”) was requested by Mr. Daley but not granted: that application, among many other issues, has fallen to be considered at this PI.
There was an application, dated 08.01.26, for Mr. Jesse Penfold to be added to the license in the capacity of a director. I will return to the significance of this below.
The Call to Public Inquiry
The call-up letter was dated 24.11.25.
The call-up letter required the attendance of a director; at that time, the sole director of the operator was Ms. Julie Lamb.
There is an extant application for her to be removed from the license as director and Mr. Penfold to be added; I will say further about that below.
After receiving the proposed attendance list for this PI, the administrative staff of this Traffic Area enquired whether Ms. Lamb would attend the forthcoming PI.
An email was sent on 03.01.26 in these terms,
“Please find attached the information for the above operator [for] The Public Inquiry on 13 January 2026 at 11:00 hours.
Who should attend
It is important that you attend the public inquiry. Please note that the previous director Julie Lamb may be still required to attend…”.
Ms. Lamb did not attend at the PI. I will return to this email below.
The call-up letter refers to various issues and allegations that were to form the basis of the PI; namely:
- Whether the operator breached various license conditions (section 26(1)(b) of the Goods Vehicles (Licensing of Operators) Act 1995 (“the Act”)), including failing to notify matters affecting good repute and professional competence;
- The fact that the operator had acquired prohibition notices issued by the Driver Vehicle Standards Agency (“DVSA”) (section 26(1)(c)(iii) of the Act);
- The fact a fixed penalty notice was issued (section 26(1)(ca) of the Act);
- Whether statements made on application to the Traffic Commissioner (“TC”) were false or have not been fulfilled, specifically the requirement to notify the TC within 28 days of convictions, of a change in maintenance provider, or of a change in financial status (section 26(1)(e) of the Act);
- Whether the operator had failed to honour undertakings it made on application; specifically, the requirement to keep vehicles in a fit and serviceable condition, retain driver defect report (“DDR”) records, safety inspection records, and routine maintenance records and make them available on request (section 26(1)(f) of the Act);
- Whether there had been a material change in circumstances in respect of the license arising from the prohibition issued by the DVSA (section 26(1)(h) of the Act).
Alongside the operator, Mr. Hipkins was required to attend this PI to consider his good repute as a TM; that is under Schedule Three of the Act.
Mr. Jones was required to attend here to consider his fitness to hold a vocational driving license at a DCH as he was the driver when the prohibition (see below) was issued on 30.04.25.
The Public Inquiry
The PI took place at the Office of the Traffic Commissioner in Birmingham on 13.01.26.
Mr. Daley and Mr. Penfold were in attendance in person; the TM was present remotely.
Before the PI, there was an email drawn to my attention, dated 12.01.26, which indicated that Mr. Hipkins could not attend in person because he was unwell with Covid. In that email, Mr. Hipkins asked if he could attend remotely; there was no accompanying evidence addressing his asserted illness.
At my request, the administrative staff in this Traffic Area indicated – before the PI - that this PI would not be adjourned on account of this issue; it was explained in that email that Mr. Hipkins could appear remotely.
Practical arrangements were put in place to allow Mr. Hipkins to appear remotely.
During the PI itself, I could not actually see Mr. Hipkins’ face. I was told, in terms, that the best that could be done with the video connection (because Mr. Hipkins was using his mobile phone rather than a computer) was for a black screen to appear on the television in the hearing room; Mr. Hipkins could otherwise be heard clearly by everyone in the PI room.
Twice during the PI, whilst I was asking Mr. Hipkins questions, his video connection froze or was broken; there were short adjournments on each occasion for efforts to be made to phone him to allow the PI to resume.
There was no occasion where the quality of the connection, once it was established, was poor. On the occasions the connection failed, a re-cap was given of where we had got to and my questions to him were repeated.
Right at the end of my questions, the video connection stopped working. For those final questions, Mr. Hipkins was connected to me by loudspeaker via Mr. Daley’s mobile phone. I am grateful to Mr. Daley for facilitating that.
At all times, I was satisfied that the practical arrangements used to overcome Mr. Hipkins’ physical non-attendance at the PI were satisfactory and allowed a fair hearing to take place. The circumstances were not ideal but Mr. Hipkins’ evidence was given and considered fully.
At the start of the PI, I started with the DCH concerning Mr. Jones. I pause to say, here – straightaway - that I adjourned that DCH after asking him only a few questions because it became clear to me that he did not accept the evidence of Vehicle Examiner Matthews (“VE Matthews”) that the issue in respect of the wheel nuts that resulted in the prohibition on 30.04.25 (paragraph 41(d), below) was a “long-standing defect”.
I decided to adjourn Mr. Jones’ DCH so that VE Matthews could attend and give evidence at an adjourned DCH. Mr. Jones had not had VE Matthews’ evidence before this PI began and I considered that it was important he have sight of that evidence and an opportunity to challenge the evidence of VE Matthews if he so desired.
At the next DCH, I will direct that Mr. Jones be supplied with pages 62, 102, 128, and 147 of the hearing bundle for this PI.
The Evidence
Neither Mr. Hipkins, Mr. Penfold, nor Mr. Daley took material issue with the contents of either of VE Matthews’ written reports.
The reports from VE Matthews were dated, respectively, July 2025 (“the MIVR”) and January 2026 (“the addendum”).
In each of those reports, VE Matthews explains the significant shortcomings he identified in respect of this operator’s maintenance regime following his visit in July 2025 and, in the addendum, following his review of the materials sent to him in advance of this PI.
Mr Matthews’ visit, in July 2025, was triggered because of an ‘S-marked’ DVSA prohibition imposed in the Durham area on 30.04.25 concerning the condition of trailer ‘2885 and the tractor with registration ending ‘UCE.
I have considered all the written evidence in the hearing bundle prepared in advance of this PI.
I have also considered the oral evidence given by Mr. Hipkins, Mr. Penfold, and Mr. Daley. I have not placed any reliance on the factually disputed matters between Mr. Jones and VE Matthews.
Findings of fact
I remind myself that the burden of proof is on the DVSA in respect of any of the allegations it makes – no-one in this PI room had to prove anything. The standard of proof is the civil standard: where I am satisfied that something is more likely than not to have happened, then my duty is to find that matter ‘proved’; where I am not satisfied that something is more likely than not to have happened in an allegation, my duty is to find the matter ‘not proved’.
Considering all the written evidence I have read and the oral evidence that I have heard, I find the following facts are proved to the required standard:
- The tractor unit with registration ending ‘UCE was not in a fit and serviceable condition on 30.04.25. That vehicle had had its engine management light illuminated since 28.03.25. That light may indicate issues with the engine that are ‘safety critical’; it is impossible for someone looking at the light itself to work out whether it is one issue that is causing the light to go off or several. The tractor with the registration ending ‘UCE should have been ‘off-road’ until whatever was causing the light to go off, however seemingly trivial, was rectified; those steps were necessary to make sure that the engine management light was otherwise effective in ensuring road safety. Allowing that vehicle to operate for some time with the light ‘on’ imperilled road safety;
- The PMI record sheets were incomplete and limited at the time of VE Matthews’ visit in July 2025;
- There was a single PMI sheet in respect of the trailer with the number ending ‘2885 in the period November 2024 to July 2025. I do not accept Mr. Hipkins’ evidence at the PI that there were, or might have been, other PMIs for that trailer; there is no evidence to support that assertion and he did not say as much in his response to the MIVR dated 29.07.25. Nor, for that matter, did the operator say that in their response to the MIVR either. The trailer should have been inspected at six-weekly intervals but there is no evidence of that trailer’s being examined in 2025 at all until the prohibition on 30.04.25. A trailer being in use for a substantial amount of time without a PMI is a situation that imperilled road safety;
- The prohibition of 30.04.25 was imposed for road safety critical matters both in respect of the condition of a tyre on the trailer and a wheel. All ten wheel-nuts were loose on one of the trailer’s wheels. I have seen the video at page 147. Given, on Mr. Jones’ evidence, he had started at around 05:30 that day, had the DVSA stop not happened at around 09:49, I find the trailer would likely have been in use for some time in that condition on that day. Whatever the outcome of the adjourned DCH on the matters in dispute, there cannot have been an effective inspection of the trailer at the start of that day given how loose those wheel-nuts were that morning and the number of them that were loose. The prohibition was ‘immediate’ and ‘significant’ (i.e. ‘S’) marked. Pedestrians and road users were put at serious risk by the condition of that wheel on the trailer: there was a far from fanciful risk of a tyre becoming insecure – all of the nuts had become loose. The scale of injury that would be caused to a person if a heavy tyre came off a heavy goods vehicle trailer - whilst the latter was moving, and hit them - does not bear thinking about. In short, that trailer was used in a very dangerous condition on 30.04.25;
- The driver defect reports (“DDRs”) were inadequate in July 2025: there were issues that should have been ‘picked up’ by the driver that were not picked up until the PMI; as VE Matthews explains, these were defects that were spottable by the driver. That situation indicates that this operator’s drivers were not conducting proper ‘walkaround’ checks in accordance with the DVSA’s Guide to Maintaining Roadworthiness; that, too, is a situation that imperilled road safety;
- There was a very poor initial and final MOT pass rate as at July 2025 – 50%; further, the issues picked up at the MOT such as oil leaks and items blocking the driver’s view of the road should have been clear to the TM before submitting that vehicle for an MOT. Such a low pass rate imperilled road safety because:
The vehicle was in service, before the MOT, in a condition that was not roadworthy; and
If that was the condition of 50% of the vehicles at MOT on the one day of the year, known about in advance, when the vehicle needed to meet the minimum standard of roadworthiness, what – I ask - does that say about the condition of the vehicles on the other days of the year?
- The operator did not produce to VE Matthews in late 2025, as required by the directions in advance of this PI, the complete DDR records (including evidence of rectification). The operator was aware of what was needed to be supplied following VE Matthews’ critique of the records previously supplied to him in July 2025. If the proposed printouts did not display what VE Matthews required, then an investigation should have been made as to whether there was any other way the software could produce the material VE Matthews needed. Alternatively, the operator should not have continued to use software that they must have known would be regarded as inadequate;
- The operator did not produce to VE Mathews in late 2025, as required by the directions circulated in advance of this PI, the complete PMI sheets. It would have been obvious to the operator why those complete records were needed – it was needed to see if this operator had ‘turned a corner’ and had implemented a proper maintenance system since July 2025. By failing to forward complete records to VE Matthews, there is very little evidence at this PI to gauge the extent of the efforts undertaken by this operator to change and make progress towards being a compliant operator;
- The operator has not demonstrated financial standing as at today’s PI in the manner contemplated by the Senior TC’s Statutory Document Number Two. I do not propose to grant a PoG to the operator for the reasons I give below (paragraph 55 onwards).
- The operator’s attitude was co-operative with VE Matthews and the DVSA; whilst the operator did not produce all the records required to the DVSA, I am otherwise satisfied that they tried to assist the DVSA within the confines of the flawed maintenance regime they operated in 2025 – there was no attempt to deliberately obstruct the DVSA;
- Between July 2025 and late 2025, there were some positive changes such as changes in the maintenance provider, the introduction of helpful policies, steps such as a ‘show and tell’ discussion between the TM and the driver about wheel security, and some improvements in respect of record-keeping, particularly around the PMIs – the latter, where there were records, were better at the end of 2025 than in July 2025;
- Further, I find that Mr. Penfold did genuinely intend to bring about positive change to this operator to make it a compliant operation.
Moving through each of the findings I made in the preceding paragraph, I now explain – in respect of each sub-paragraph - the weight I have placed upon each matter:
- I place some weight on this factor because it shows a lack of supervision of the driver by the TM and, by failing to intervene, a lack of effective oversight and control of the operation by the TM;
- I place some weight on this factor because it demonstrates a lack of rigour in respect of record-keeping by the operator; as I explained in the PI, record-keeping is important to ensure that an operator and TM can properly understand what is happening ‘on the ground’ in their operation; the existence of a system reduces the likelihood of important, safety-critical matters being missed;
- I place some weight on this factor. The TM failed to ensure that a proper maintenance system was in place that ensured PMIs were being conducted at the stated intervals for the operator’s trailers. The failure to conduct PMIs for some time for trailer ‘2885 reflects very poorly on the operator and the TM;
- I place some weight on this factor. It offers insight into the quality of the ‘walkaround checks’ conducted by this operator’s drivers and, consequently, the level of supervision they received from the TM;
- This recurring issue should have given the TM the opportunity to check that the drivers were conducting proper ‘walkaround’ checks in accordance with the DVSA’s Guide to Maintaining Roadworthiness. Walkaround checks are the touchstone of any maintenance regime. I give this factor some weight;
- I place some weight on this factor as it gives me insight into the general effectiveness of the maintenance regime and the level of supervision from the TM;
- I place significant weight on this factor as the failure to produce this material upon request, which is required by the license itself (see paragraph 44(b), below), has prevented VE Matthews from properly examining that material in advance of this PI;
- The same reasoning as the preceding sub-paragraph;
- This is a mandatory ground for me to revoke the license;
- I can only give limited weight to this factor because the operator knew, or ought to have known, that – however co-operative they intended to be – that the records VE Matthews required were full, complete records. They were ‘on notice’ about what would be regarded as inadequate by VE Matthews because of his MIVR;
- I can only give these matters limited weight because, whilst each of these strands of the evidence demonstrate improvement between July 2025 and the end of 2025, the critical improvements that needed to be seen by the time of this PI was the establishment of an effective, comprehensive maintenance system that was consistently implemented by the operator ‘on the ground’;
- I can only give this matter limited weight because of how recently Mr. Penfold has become involved and the lack of any tangible evidence, at the time of this PI, for me to assess this operator’s ability to become compliant.
I pause to say, further, that I have also given this operator credit for appearing at this PI in the form of the attendance of both Mr. Daley and Mr. Penfold. I have given Mr. Hipkins the same credit, save in respect of that one point where I did not accept his evidence (paragraph 41(c), above). Mr. Daley, Mr. Hipkins, and Mr. Penfold answered all my questions fully and clearly and assisted me in deciding what I should do at this PI. I recognise that appearing at a PI is a stressful experience; I made appropriate allowance for that when I assessed each witness’ evidence.
Findings regarding breaches of the legislation
As a result of the above findings of fact, I find that the operator has fallen foul of the following provisions in the statutory scheme:
- The operator had acquired prohibition notices issued by the DVSA (section 26(1)(c)(iii) of the Act);
- The operator has failed to honour undertakings it made on application; specifically, the requirement to keep vehicles in a fit and serviceable condition, retain DDR records, safety inspection records, and routine maintenance records, and make them available on request (section 26(1)(f) of the Act);
- There has been a material change in circumstances in respect of the license arising from the prohibition issued by the DVSA, the failure to keep proper maintenance records, and the failure of this operator to be of appropriate financial standing (section 26(1)(h) of the Act);
- The operator fails to meet the requirements in respect of financial standing as at the date of the PI: section 27(1)(a) of the Act.
Balancing Exercise
I repeat all my findings in this case, including the evidential weight I have attached to each one, to assess the operator as it appeared before me at the date of the PI.
Having carefully balanced the evidential weight I have given for all the positive findings in this case against the evidential weight I have given for all the negative findings (paragraphs 41-42, above) I have determined that balance tips firmly in favour of the negative findings.
I now go on to consider Annexe Four of Statutory Document Ten issued by the Senior TC.
Relevant considerations
I am satisfied that the following ‘negative’ factors apply to this case:
- There were reckless acts by the operator that led to an undue risk to road safety. This finding is primarily based on the lack of PMIs for the ‘2885 trailer and the continued use of a vehicle with the engine management light on; I repeat that I have not relied on disputed matters of fact that may be resolved at the adjourned DCH;
- There was ineffective management control and insufficient systems in place to prevent license failings;
- There were road safety critical defects on a vehicle or trailer in service;
- There was a low average first time MOT pass rate.
None of the ‘positive’ factors listed in Annexe Four applied to this case.
I recognise that Mr. Penfold’s recent involvement in this operator means that its management has completely changed very shortly before, or on the day of, this PI. Indeed, I was told the shares were transferred on the day of the PI.
I have not been informed of anything concerning Mr. Penfold’s repute and, indeed, in his evidence to me in the PI, he appeared genuine and earnest in his commitment to ‘turn this operator around’ into being a compliant operation.
What Mr. Penfold’s evidence to me amounted to was an account of how a different operator, not this operator, would – in future - behave with this operator’s license.
Mr. Penfold does not yet have a history of showing what he can do for this operator; that is not a criticism of him, it is simply that – having only become involved with this operator so shortly before/at the PI – he has not had the opportunity to show me the positive effects of his influence.
My duty, on behalf of compliant operators and the public, is to determine the future of this operator, today, based on its historic and present performance.
I accept that I could allow this operator to continue with a PoG granted by me today to give it time to find a new TM and put money into the company bank account to satisfy financial standing.
Mr. Penfold referred, in his evidence, to the imminent appointment of a new Road Haulage Association (“RHA”)-approved TM if the operator were allowed to continue.
I remind myself of the Upper Tribunal’s decision in T/2014/008 Duncan McKee; when considering the grant of a PoG, the Upper Tribunal said (among other things), “[TCs] will need some tangible evidence, beyond mere hope and aspiration, that granting a period of grace will be worthwhile, and that there are reasonable prospects for a good outcome” (emphasis added).
Because of the lateness of Mr. Penfold’s arrival in this operator, there is no tangible evidence before me – today – to allow me to make the finding that a PoG would be worthwhile and carry reasonable prospects of a good outcome.
It is often said that ‘actions speak louder than words’. I accept that Mr. Penfold’s intentions are genuine; however, set against the background of such poor compliance by this operator over such a sustained period of time, the lack of any tangible evidence before me today - to persuade me that any practical steps taken by the operator were now ensuring compliance - leads me to doubt whether any PoG would be worthwhile and carry any reasonable prospects of a good outcome.
I recognise that there has been a significant outlay of capital by Mr. Penfold in preparing for his future role in this operator. My duty is to assess the operator as it stands at this PI, today, based on the evidence before me.
Applying Annexe Four to this case, I determine that this operator’s conduct puts it firmly in the ‘Severe’ category in the Senior TC’s guidance. I make that finding because the cumulative effect of the ineffective maintenance regime was that it seriously compromised road safety for some time. My findings in respect of how road safety was put at risk are rehearsed above at paragraphs 41(a), (c)-(f).
The public and other operators must know that when an operator runs a fleet of vehicles in this way, showing – as this operator did – disregard for basic requirements of any truly effective safety regime, that TCs are prepared to take serious regulatory action.
The TM in this case was completely ineffective; examples of that are at paragraphs 41(a)-(f) above. The TM was ineffective at the time of the MIVR; in the period that elapsed between July 2025 and 30.11.25, when he resigned, Mr. Hipkins remained ineffective. I cannot trust him to exercise continuous and effective management of a transport operation.
After repeating all my findings, I have no confidence at all in this operator because many of the matters identified by VE Matthews in July 2025 were still evident at the end of 2025.
After repeating all my findings of fact, I have decided that I cannot trust this operator to run a compliant operation; in consequence, it is proportionate that I answer the question posed in the Upper Tribunal case of T/2009/225 Priority Freight – ‘is this an operator I can trust to be complaint in the future?’ - in the negative.
Having, again, repeated all my findings of fact I have then asked myself the question in the Upper Tribunal case of T/2002/217 Bryan Haulage (No. 2) – ‘should this operator be put out of business?’. For the reasons I have given above, I conclude that the proportionate answer to that question is an answer in the affirmative. As a result of that finding, the operator has lost its good repute.
For the reasons given above (paragraph 63), I find that Mr. Hipkins was an ineffective TM during his tenure at the operator. I note how many of my findings in respect of this operator, on the TM’s ‘watch’, put road safety at real risk. The risks this operator’s transport operation posed to road users and others were due to the TM’s ineffectiveness in implementing a comprehensive maintenance regime and his ineffectiveness at supervising the work of the operator’s drivers. What Mr. Hipkins has done since resigning as TM does not go far enough to enable me to step back from deciding that, as at the date of the PI, it was proportionate to determine that Mr. Hipkins had lost his good repute as a TM.
Because I have made that finding, by law, I am required to disqualify Mr. Hipkins and set a rehabilitation measure for him.
Mr. Hipkins himself knew what that rehabilitation measure should be because he said so himself in his evidence – he needs to learn from an experienced TM.
I disqualify Mr. Hipkins for a period of twelve months - the shortest period I can legally impose - and require that, in order to apply to the TC for the restoration of his good repute as a TM, Mr Hipkins needs to spend at least 40 hours with an experienced TM. Those hours should be completed in the final three months of his disqualification. To fulfil the rehabilitation measure, the TM he has shadowed should produce a letter, on headed paper, setting out full details of Mr. Hipkins’ attendance with them and what Mr. Hipkins shadowed/did when he was with them on each occasion. Without the latter detail, the rehabilitation measure will not be regarded as having been fulfilled.
I wish to give consideration as whether to disqualify the former director, Ms. Lamb, from the industry for a period of time. I have concluded that, before I make any decision whether she should be disqualified, that I should give her the opportunity to send me any written representations or, if she so desires, request a further hearing to consider her position. I am not satisfied, from the email I referred to (paragraph 17, above), that she has had sufficient opportunity to be heard on this point if she wishes to be heard.
Decisions
As a result of the above, my decisions are:
- The operator license is REVOKED pursuant to section 27(1)(a) (loss of operator’s good repute), section 27(1)(a) (operator no longer of appropriate financial standing), section 27(1)(b) (TM no longer of good repute);
- The TM has LOST HIS GOOD REPUTE, with immediate effect, under Schedule Three;
- The TM is DISQUALIFIED FOR A PERIOD OF TWELVE MONTHS (effective from 19.02.26 until 19.02.27) from being a Transport Manager on any operator’s license in Great Britain: paragraph 16(2) of Schedule Three;
- Having repeated all my findings, and despite the credit I have given, I still determine that it is proportionate to revoke the operator’s licence under the following sections of the Act: section 26(1)(c)(iii) (prohibition notices), section 26(1)(f) (failed to honour undertakings), and section 26(1)(h) (change of circumstances);
- All orders for revocation will take effect from 19.02.26 at 23:59;
- I make no order under section 28 against the operator itself;
- The request for a PoG is REFUSED;
However, I direct that this Traffic Area shall write to the former director, Ms. Lamb, providing her with a copy of this decision, and inviting her to confirm:
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Whether she wishes to make written representations on the question of whether she should be disqualified from the industry for a period of time pursuant to section 28 on the understanding that, if she elects to do that, this matter will be decided without a hearing ;
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Whether she would like to attend a further hearing for that matter to be decided there;
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If she wishes to make written representations and not attend a hearing, then her representations should be sent to this Traffic Area by no later than 12.02.26;
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If she wishes to request a hearing then that request is made by 12.02.26;
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In the absence of any response to this Traffic Area’s letter or any written representations from her, a decision will be made without a hearing by me after 12.02.26.
G. Pengelly
Deputy Traffic Commissioner
22.01.26