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29 October 2013 - communications with BIS PDF Print E-mail


In October 2013 was informed that "there have been staff changes in the Consumer and Competition directorate at BIS and Paul Bland has recently taken over responsibility for pedlars and street trading policy [2007 Dennison then 2009 Branton & Onikosi et al]... he seeks detailed account of difficulties experienced by pedlars and is keen to engage with the pedlar community before finalising policy details".

The following communications in black are from and in blue from Paul Bland at BIS:


Subject:     BIS URN consultation
From:         Pedlars Admin < This e-mail address is being protected from spambots. You need JavaScript enabled to view it >;
Date:         29 October 2013 14:13:44 GMT
To:             Bland Paul (CCP) < This e-mail address is being protected from spambots. You need JavaScript enabled to view it >;


BIS URN consultation confuses principles and attempts to bulldoze civil liberty

I emailed you yesterday requesting your telephone number... no reply.
Am I to deduct that you too have fallen subject to the BIS policy to ignore stakeholders.
It is unacceptable that you are too busy, or out, or in a meeting, or have more important work or any other empty excuse.

The following is a summary of both the most recent and historical issues that pedlars have raised as questions needing to be addressed immediately as a priority to any meeting that you are now wanting to  propose. is requested to respond to growing concern about reform to pedlars self-regulated profession.
As you have been appointed as BIS point of contact for progressing the consultation and its policy formulation - pedlars ask exactly what procedural steps lie ahead.
Pedlars ask if you are tasked with addressing the many outstanding complaints and how you intend taking them towards resolution.
All of this may be outlined in your employment brief on this URN consultation from the minister...

1 Copy of that document please.

2 For you to address pedlars' concern that your predecessors erred in transposing the European Services Directive into UK law, in particular Sect 45 PSRA.

3 For you to address a) Onikosi's refusal to read pedlars' draft proposals and not informing colleagues & the minister prior to the URN publication and then b) refusing to open discussion about pedlars "Third Option" proposals to reform the Pedlars Act as national resolution to all street trading and pedlary legislation.

4 You are aware of substantive communication on pedlars' Third Option and the BIS refusal to engage with the issue all of which is publicly accessible on-line at

5 You will address pedlars' contention that the notion to repeal the Pedlars Act is an attempt to cover-up past negligence by BIS operatives.


You have said that policy formulation will not be finalised until after a meeting with stakeholder pedlars - initially Autumn and lately November.
You are aware that the pre-Christmas period is very busy for pedlars and many have given authority to to act on their behalf at such a meeting.
That meeting cannot occur until we have your agreement that counsel and the minister will be in attendance to have full and frank discussion about the merits of pedlars Third Option proposals to amend the Civil/Social Contract of the Pedlars Act. Your department has provided no legal reasons why it has precluded the Third Option within the consultation in parallel to consideration of "do nothing" or "repeal".


Your predecessors indicated a lack of competence or willful neglect in understanding the principle that differentiate street trading regulation and pedlary's self-regulation.
You will know that pedlars contend that the two disciplines are legislatively incompatible and frankly should never have become the remit of BIS but rather that of the Home Office.
Pedlars contend that the BIS remit lies only in consulting on street trading regulation because unlike pedlary licensed trading is a cause of public liability.
Pedestrian consumers are self-regulating under conditions of the general law the Pedlars Certificate provides a simple additional right that an adult pedestrian may also trade in public.
Your department's URN policy is dangerous to this civil liberty of 50+ million adults.   

All trust in your BIS consultation is lost if this BBC News article dated 25 October is how "democratic" reality is to be enforced.

Your departmental continuing silence is not an option.

admin - note minor edits to original transmission for clarity


On 21 Oct 2013, at 11:50, Bland Paul (CCP) wrote:

Thank you Robert
I am not aware of any further HC Library articles.  Good luck with the rebuttal - it is important that decision makers are given the full picture before making policy and legislation.

From: Pedlars Admin [mailto: This e-mail address is being protected from spambots. You need JavaScript enabled to view it ]
Sent: 21 October 2013 11:41
To: Bland Paul (CCP)
Subject: Re: John [Pedlar] Application for Pedlars Certificate

I am pleased to note that you have returned to work.
It has taken us some time to extract archived communications.
For yours and for the public benefit we have published on-line many of the recent accounts (circa 2013) that pedlars have communicated.
Please click this Q&A link to some 23 articles one of which I sent you last week (as below).
Some are quite candid but unedited and we have noted where names have been redacted.
We are currently preparing a Briefing in response to being informed about the House of Commons Library SN/HA/5693-5 Home Affairs Section 'Regulation of street traders and pedlars' and aim to publish this week under the HMG Consultation link.
Please inform me if there is a more up to date or any other HC Library articles that inform government about pedlary & street trading. The article is so misleading that it requires a considered rebuttal to be made public.
I look forward to maintaining an open and transparent developmental dialogue with you that can replace your predecessors policy to ignore my communications.

On 21 Oct 2013, at 11:08, Bland Paul (CCP) wrote:

Thank you Robert.  I will read them with interest.

From: Pedlars Admin [mailto: This e-mail address is being protected from spambots. You need JavaScript enabled to view it ]
Sent: 16 October 2013 15:07
To: Bland Paul (CCP)
Subject: Fwd: John [Pedlar] Application for Pedlars Certificate

Dear Sir

I understand from Mr McGerr that you have been newly appointed the single point of contact at BIS for URN12/605 & 606.
In your correspondence with Mr McGerr you have invited "detailed accounts of difficulties experienced by fellow pedlars" and with this in mind Mr McGerr has requested that I forward various detailed accounts that indicate current difficulties.
I shall endeavour over the next few days to work backwards through our files to fwd sample accounts of difficulties.
Yours sincerely

Robert Campbell-Lloyd
This e-mail address is being protected from spambots. You need JavaScript enabled to view it



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