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1 January 2014 - Official Conduct at BIS 2 PDF Print E-mail


On 15 November 2013 wrote to Martin Donnelly, Permanent Secretary for BIS and by the end of December Mr Donnelly had not replied and pedlars wrote again:
1st January 2014

Mr Donnelly


The potential to fail informing Parliament about a matter of Principle.


This concerns my letter to you of 15 November 2013 about Official Conduct at BIS.

By November 29 I wrote to Adrian Bailey MP, Chair of the BIS Committee in Parliament about the lack of appropriate prevailing conditions for proper Oversight at BIS.


This is an issue raised by pedlars requiring to be addressed by you on behalf of all people subject to the constitution of the United Kingdom and for it to be made clear to Parliament.

It is a matter that is in the General Interest and as such I am obliged to inform the public.


The central concern of those letters was a House of Commons Standard Note SN/HA/5693  that pedlars consider misleads the Commons depending on such briefings to assist them and their constituents.

Pedlars decided as stakeholders in consultation with the BIS CCP directorate to inquire about the relevance of the Note and were invited to write a robust rebuttal by Paul Bland, CCP team leader - this was published 5 November 2013.

A pedlar constituent of Alun Cairns MP requested an update from the author of SN/HA/5693 and he received a Note ref: 2013/12/55-HAS dated 18 December 2013 entitled “Pedlars” - now relevant to what follows and how it impacts on your position and your department.


It is apparent that Adrian Bailey either failed to refer the rebuttal to Lorraine Conway author of both Notes or that he did but that her research is not competent to provide the Commons with understanding the Principle governing pedlars.

It is apparent that Lorraine’s research is garnered from instruction by CCP BIS as the update is no more than regurgitation of selected extracts from the blatantly flawed policy proposals of the BIS CCP “Street Trading and Pedlar Law” consultancy URN12/605-606.


The effect of these proposals is to meddle with the social, cultural and economic life of a significant majority of people, to obliterate the social franchise of the Pedlars Act and makes pedlary a new offence under local street trading regulation.

Your department, your CCP team, intend that people and pedlars will no longer have the safety of the Crown’s prerogative and pedlars will no longer have statutory protection from any aggression or disproportionate and repressive enforcement.

In that respect it is apposite and salutary for you and your department to review the causes of the Tunisian street trader Bouazzi’s fate relevant to how you scope future policy.

Your department’s influence on the December Note sent to Alun  Cairns fails to assist Alun or any other MP to understand the Principle that continues to be ignored by BIS and it is his constituent’s concern that councils will abuse enforcement powers to prohibit his social right to engage in a lawful activity of pedlary. 



read full 5 page letter - download .pdf copy



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