Consultation Papers

Below is a full list of recent consultations that the RMI have submitted responses to. Alternatively, you can click on the links below to search for consultation responses relevant to a specific policy area, or search by date using the navigation to the right of the screen.

EXAMINING THE SPEED LIMIT FOR HGVS OVER 7.5 TONNES ON SINGLE CARRIAGEWAY ROADS (DFT)

The Department for Transport released the above consultation to assess current speed limits for 7.5t HGVs on single road carriageways. Two policies of reform have been proposed. The NFDA is in full support of policy option one which states: Raise the national speed limit for HGVs over 7.5t from 40 to 50 mph on single carriageways roads. It is felt that through increasing the legislative speed limit, this will enable unfair competitive advantages with the market to be equalised and aid the reduction in vehicle collisions and mechanical maintenance costs.

Click here  to download the NFDA response

LOCAL AUTHORITY ENVIRONMENTAL REGULATION OF INDUSTRIAL PLANT: FEES AND CHARGES 2013/2014: DEFRA

The PRA has submitted a response to the Department for Environment, Food and Rural Affairs’s (DEFRA) consultation concerning the level of fees and charges to be imposed for: Local Air Pollution Prevention and Control (LAPPC) and Local Air – Integrated Pollution Prevention and Control (LA-IPPC). The consultation looks at the ‘level that will recover costs of local authorities of implementing the system’. The PRA has submitted that whilst the principle of cost recovery in the charging of fees is endorsed, Government monitoring of Local Authorities is a necessity and must be maintained. Furthermore, the PRA has expressed concerns that Local Authorities could easily manipulate minor infringements in order to gain additional revenue.

Click here to download the PRA response

REMOVAL OF MOTOR INSURANCE CERTIFICATES

The Department for Transport released the above consultation in November 2012. The NFDA has subsequently submitted a response. The consultation ‘seeks views on the principle of removing the need for insurers to issue a motor insurance certificate when an insurance policy is taken out’. The NFDA has endorsed the policy objective and agrees with the abolition of insurance certificates. The NFDA believes that by creating an online system this will simplify and quicken the verification process but has stated that alternative methods to an online system should be available when necessary.

Click here to download the NFDA response

CIVIL ENFORCEMENT REMEDIES - CONSULTATION ON EXTENDING THE RANGE OF REMEDIES AVAILABLE TO PUBLIC ENFORCERS OF CONSUMER LAW - BIS

The Civil Enforcement Remedies consultation is the third instalment from BIS in their reform package of consumer rights. This specific paper delineates whether ‘implementation of the Regulatory Enforcement and Sanctions Act 2008 or introducing new remedies under Part 8 of the Enterprise Act 2002 would be most appropriate’. The aim of the proposals is to enable improve redress for consumers and ensure business understanding of processes and compliance. The RMI has placed heavy emphasis on the need to ensure a higher burden of proof if the remedial process is to change from criminal level to civil. Therefore, the RMI has submitted that it does not support any reform package that moves the evidential burden of proof from the current standing of ‘beyond reasonable doubt’. Furthermore, the RMI has stated the need for enforcers to be Hampton-compliant, ensuring enforcers call for ‘proportionate and meaningful’ sanctions. Throughout the response, the RMI has submitted that elements of proportionality, flexibility and discretion must be available to businesses when they are negotiating the best method of redress with enforcers for consumers who have suffered a breach and finally that judicial intervention must be curtailed and quantified when unnecessary.

Click here  to download the RMI response

POWER TO SUSPEND CONSUMER CREDIT LICENCES - DRAFT OFT GUIDANCE FOR LICENCE HOLDERS - OFT

The Office of Fair Trading is being given the ability to suspend consumer credit licenses with immediate effect or from a date of their discretion, to prevent the potential or actual breaches of traders where it is felt a consumer is at risk. This is a result of the Financial Services Bill. The immediate consultation is looking for advice in the creation of guidance material for the suspension powers. The NFDA is pleased with the overall format of the guidance and its content, specifically the provided examples for suspension which should be used as a useful tool. The RMI has stated concerns over the ability of licence holders to appeal decisions and has raised this within the response; stating there is a need for wrongly accused businesses to have opportunity to appeal the decision to suspend a credit license.

Click here to download the NFDA response

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