Director of Highways
Mr R D Pearson
BEng (Hons) CEng MICE MCIHT DMS
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Date:
Chris Hannon
RDP/CH
November 2010
Dear Sir or Madam
Re: ROAD TRAFFIC AND HIGHWAYS (MISCELLANEOUS AMENDMENTS) BILL: PUBLIC
CONSULTATION
1.
I write to invite your comments, if I may, on the enclosed Bill. Its provisions have been developed
in part from proposals made in the Department's Road Safety Initiative of 2004, which received a broadly
favourable response from the public.
2.
Attached to the Bill is an Explanatory Memorandum describing the provisions, but it does not outline
the policy considerations that have led to them. It is therefore the purpose of this letter and the impact
assessment annexed to it to explain the Department's underlying reasons.
3.
The Bill is split into three principal Parts, namely 2, 3 and 4.
PART 2: AMENDMENT OF THE ROAD TRAFFIC ACT 1985 ("RTA")
4.
In seeking in this Part the creation of new driving offences, the imposition of increased penalties for
existing ones, and a wider range of alternative verdicts, the Department has three main objectives, all of
which are broadly in line with its Road Safety Initiative: first, to provide greater deterrents to unsafe
driving on roads; second, to cater for the punishment of offenders in accordance with the Department's and perhaps the general public's - increased perception of the gravity of the offences involved; and third,
to provide, as in Great Britain, a wider range of alternative verdicts so that, in any case, lesser offences
may be considered by the courts in the event that the principal offence is not proven.
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
www.gov.im/infrastructure
1 - New driving offences
General
5.
The Bill creates the following four new driving offences:
RTA
Offence
Mode of
prosecution
Penalties
Disqualification
Endorsement
Section
1A
Causing
grievous
bodily harm
by
dangerous
driving
On
information
5 years or a
fine or both
Obligatory
Obligatory
2B
Causing
death by
careless or
inconsiderate
driving
(a) Summarily
12 months or
£5000 or both
Obligatory
Obligatory
(b) On
information
5 years or a
fine or both
Causing
grievous
bodily harm
by careless
or inconsiderate
driving
(a) Summarily
6 months or
£5,000 or both
Obligatory
Obligatory
(b) On
information
2 years or a
fine or both
Causing
death by
driving
when
unlicensed,
disqualified
or
uninsured
(a) Summarily
12 months or
£5,000 or both
Obligatory
Obligatory
(b) On
information
5 years or a
fine or both
2C
3B
(Penalty refers to maximum custodial sentence)
6.
To be placed in context the new driving offences need to be set against those existing ones already
contained in the RTA. Excluding drink and drive offences and driving under age, the existing offences are
as follows:
Department of Infrastructure
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RTA
Offence
Mode of
prosecution
Penalties
Disqualification
Endorsement
Section
1
Causing
death by
dangerous
driving
On
information
10 years or a
fine or both
Obligatory
Obligatory
2
Dangerous
driving
(a) Summarily
6 months or
£5000 or both
Obligatory
Obligatory
(b) On
information
2 years or a
fine or both
Summarily
£2500
Discretionary
Obligatory
3
Careless or
inconsiderate driving
(Penalty refers to maximum custodial sentence)
7.
In line with the maximum custodial option in force in GB it is proposed to increase the term to 14
years for contravening RTA section 1. The reason for the increase is explained in para 37 below.
8.
Against this background it is considered that the proposed penalties for the new driving offences are
proportionate and complimentary to those prescribed for the existing offences.
9.
It is perhaps unnecessary to expatiate on the creation of new offences except to assert a perhaps
self-evident and simple fact, namely that a principal purpose is to deter by way of punishment actions or
omissions of a particularly injurious nature that in the public mind evoke disgust, extreme repugnance, or
horror. So, deterrence, both specific and general, is a predominant factor, but there is an equally
important purpose, namely retributive justice, which in its classical form embraces the idea that the amount
of punishment should be proportionate to the amount of harm caused by an offence. Despite criticism in
recent years the concept remains a central pillar of the criminal law, and it is perhaps right that it should be
so, for, if individuals begin to believe that society is unwilling or unable to impose penalties commensurate
with injurious behaviour, then seeds of anarchy and vigilante justice are sown.
10.
It is against this background that the cases cited in paras 12, 19 and 22 of this letter illustrate not
only the need for the new offences but also the need for retributive justice proportionate to the harm that
has been done.
11.
It is to be noted that the prescribed penalties for the new offences are maxima and that it will be
for the good sense of the courts to determine within those limits whatever penalties are appropriate in any
given case.
New offence of causing grievous bodily harm ("GBH") by dangerous driving
12.
It is not at present the practice to bring a charge of GBH (maximum penalty, without intent, 5 years'
custody) when there has been a road traffic accident involving serious injury and the defendant was driving
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
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dangerously. Instead, a charge is brought simply of dangerous driving (maximum penalty 2 years'
custody). It is considered that such a penalty remains appropriate when no one is injured, but the offence
does not address cases where someone is seriously injured, for example by being paralysed. Accordingly
the new offence of causing GBH by dangerous driving fills a gap in the law by prescribing a maximum
penalty commensurate with that for the general offence of GBH.
13.
The expression "GBH" is not defined statutorily but has long been interpreted in case law.
Generally, as interpreted by the courts, "GBH" has no other meaning than that which the words convey in
their ordinary and natural meaning. "Bodily harm" needs no explanation, and "grievous" means no more
and no less than "serious".
New offence of causing death by careless or inconsiderate driving
14.
The new offence fills another gap in the law by supplementing RTA section 3 (careless or
inconsiderate driving) in the same way that RTA section 1 (causing death by dangerous driving)
supplements RTA section 2 (dangerous driving).
15.
There is a close analogy between –

the way in which the lesser offence of careless or inconsiderate driving is elevated to the
aggravated offence of causing death while so driving, and

the way in which a minor assault can be elevated to a charge of manslaughter.
16.
The analogy is perhaps best illustrated by the following description of an actual case [Mitchell, 1983
2 All ER, 427] in which a common assault was elevated in this way.
17.
There was an altercation in a post office which resulted in A assaulting B. B fell against C and they
both fell to the ground. B incurred minor injuries but C suffered a broken femur and was taken to hospital.
A few days later, following an operation to replace her hip, C died as a result of a pulmonary embolism
attributable to the broken femur. A was convicted of assault on B and of manslaughter of C. He appealed
on the basis that it was necessary for the offence of manslaughter that the act should be "directed at" the
victim in the sense of having had some immediate impact on her. The Court of Appeal rejected this. As
long as there was sufficient causal link between A's unlawful act and C's death, then the charge of
manslaughter could be sustained.
18.
In the same way the Department is of opinion that the causal link between the unlawful act of
careless or inconsiderate driving and a person's death is sufficient to justify the proposed aggravated
offence, simply because, if the unlawful act had not been committed, the death would not have occurred.
There are also other considerations.
19.
Until a like offence was recently brought into force in GB, the only sanction there (as at present in
IOM) for causing death by careless or inconsiderate driving was to charge a person with the minor offence
of careless or inconsiderate driving, the maximum penalty for which, as at present in IOM, was £2500.
Such a penalty was seen by the GB authorities and the public at large as being in no way commensurate
with the gravity of causing death by an unlawful act. The point is perhaps best illustrated by a case which
received wide media publicity some 2½ years ago. A 17-year old driver who had just passed his test took
his car for a trip on Welsh country roads, accompanied by two young men and two young women. He lost
control of the car and veered off the road. All his passengers were killed but he survived. As the new GB
offence had not yet been brought into force, he could only be charged with the minor offence of careless or
inconsiderate driving (maximum penalty £2500), of which he was found guilty. In the public mind, and
Department of Infrastructure
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particularly among relatives of the deceased, the penalty was seen as being grossly out of kilter with the
material harm that he had done.
New offence of causing grievous bodily harm ("GBH") by careless or inconsiderate driving
20.
The new offence fills yet another gap in the law by supplementing RTA section 3 (careless or
inconsiderate driving) in the same way as RTA section 2C (causing GBH by dangerous driving) is proposed
to supplement RTA section 2 (dangerous driving).
21.
The following case is one of many which illustrates the Department's reasons for proposing the
offence.
22.
This case involved a woman who was travelling on the mountain road. A motorist heading north
lost control of his vehicle and collided with her car. She suffered multiple fractures and life-changing brain
injuries exacerbated by a stroke. In this case the only sanction available was to charge the offender with
the minor offence of careless or inconsiderate driving (maximum penalty £2500), of which the offender was
found guilty. The penalty imposed was far below the maximum and was not commensurate with the great
harm that had been done.
New offence of causing death by driving when unlicensed, disqualified or uninsured
23.
The Department's reasons for promoting this offence are the same as are set out in paras 9 and 18
above.
Contrary considerations so far taken into account in relation to the new offences
24.
Considerations of this kind have centred on the proposed offences of causing death or GBH by
careless or inconsiderate driving.
25.
As manœuvres amounting to careless or inconsiderate driving frequently take place without any
death or injury resulting, it is often argued that taking account of the victim's death or injury is to attribute
too much importance to chance or misfortune. This argument is not, however, supported by the
Department, which takes the view that –

the rules of the road are designed largely to avoid collisions, injuries, and deaths,

anyone who falls below the standards is culpable,

any driver who does so without causing an accident is fortunate, and

it is justifiable to punish those whose bad driving does cause death or injury because that is the
risk against which the rules of the road are meant to guard.
26.
Second, it has been argued that the Department should not promote the proposed offences in
advance of allowing sufficient time for an identical offence to bed down in GB. That offence, which
involves causing death by careless or inconsiderate driving, came into force in GB on 18 August 2008. As
more than two years have elapsed since then, the Department sought the views of the Ministry of Justice
there, which in turn asked the Crown Prosecution Service to comment. They advised that the offence had
been tested in the courts with cases resulting in a number of convictions. The Ministry confirmed that they
were not aware of any significant problems. This being so, the Department does not consider it premature
to promote the offences now.
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
www.gov.im/infrastructure
27.
Third, it has been advanced that promoting legislation that may coincide with the views of the
public at large is pandering to populism. On the contrary, the Department firmly believes that seeking the
views of the public at large is simply part and parcel of the democratic process, and, should their and
politicians’ views coincide, it would be disingenuous of politicians not to act.
Statistical matters appertaining to the new offences
28.
Although no comparable statistics are published in IOM, those published in GB indicate the
contributory factors in reported personal injury road accidents which the proposed offences seek to affect.
In GB approximately 1.5% of those accidents in 2007 involved fatalities, where the contributory factors
included "loss of control" (in 33% of accidents), "failed to look properly" (22%), and "careless, reckless or
in a hurry" (17%). Reported road accidents involving serious injury were 13% of the total number
involving injury, where the figures for the above contributory factors were 19, 30, and 17%.
29.
Recent serious personal injuries due to road accidents in IOM are:
Year
Fatalities
Serious injuries
2006
8
67
2007
9
79
2008
6
44
2009
7
62
30.
Also part of the equation is the average value of prevention per casualty. Taking into account
factors such as lost output, medical and ambulance costs, human costs, police cost, insurance,
administration, and damage to property, the total figure in GB for 2007 was estimated to be £1,648,390
per fatality and £185,220 per serious injury.1
31.
A rough order of the increased cost to the IOM Constabulary of dealing with the new offences has
been estimated by them to be in the region of £100,000 per annum.
2 - Punishment of existing offences
Level of fines - general
32.
According to the Bank of England's inflation calculator, the value of the pound sterling at the end of
2009 was 44.4% of its value in 1985 (when the RTA was passed). Over this period inflation averaged
3.6% per year.
33.
Consequently, if we are to use a rough rule of thumb, the existing levels of RTA fines mentioned in
the Bill need to be slightly more than doubled simply to restore them to their value in 1985; or, if we wish
to be precise, they need to be multiplied by a factor of 2.25. Thus, in real terms the financial impact of
those existing levels of fines has been more than halved in the intervening period.
2
The statistics in this and paragraph 28 are taken from "Road Casualties Great Britain 2007"
published by the GB Department for Transport.
Department of Infrastructure
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34.
Against this background the increases in fines proposed in the Bill are broadly in line with inflation.
Differences and alterations of other penalties are stated below.
Contravention of regulation 68 of the Road Vehicles (Maintenance and Use) Regulations 2002 (driving a
motor vehicle while holding a mobile telephone in a hand)
35.
In the light of the Department's increased perception of the gravity of this offence, particularly
where heavier vehicles are involved, the Bill proposes 
to increase the construction and use penalty from £1000 to £2500,

to provide for discretionary disqualification, obligatory endorsement,

and 4 penalty points, and

to provide that a court shall order the mobile telephone in question to be forfeited unless the
court for special reasons thinks fit not to order it to be so.
Contravention of RTA section 1 (causing death by dangerous driving) and RTA section 3A (causing death by
careless driving when under the influence of drink or drugs)
36.
The Bill proposes to increase the maximum custodial option in both cases from 10 to 14 years.
37.
These increases reflect partly the Department's and the general public's increased perception of the
gravity of the offences and partly widespread concern at the very lenient sentences imposed by the
judiciary, sentences which are often far below the maximum penalties. Raising the maximum penalties is
seen as a way of raising the general level of sentences.
Contravention of RTA section 20 (duties on occurrence of an accident caused by the presence of a motor
vehicle)
38.
The Department does not consider that the existing penalties adequately reflect the gravity of
failing to stop after an accident and either give particulars or report the accident to the police. Accordingly
the Bill proposes to increase the maximum penalties to 
9 months' imprisonment or a fine of £5000 or both (from 3
months' imprisonment or a fine of £2500 or both), and

5-10 penalty points (from 2-5).
Contravention of RTA section 49 (making false statements and withholding material information)
39.
The Department considers it appropriate to increase the deterrent effect of this offence by providing
for a custodial option not exceeding 3 months' imprisonment or a fine of £2500 or both. At present the
penalty is limited to a fine not exceeding that amount.
Endorsement of penalty points on contravening section 22(1) of the Road Traffic Regulation Act 1985
(speeding)
Department of Infrastructure
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40.
The Bill proposes to substitute 1-10 for 3 penalty points. The purposes are -
to enable a court to respond more flexibly in the light of the circumstances of a case, and

to provide a greater deterrent to excessive speeding, which is a problem.
Marginal exceeding of a speed limit would attract penalty point(s) at the low end of the scale, grossly
excessive speeding at the high end, and intermediate speeding in between.
Driving offences - prescribed alcohol limits
41.
There are two sets of prescribed limits operative in the IOM. The first set is the limit above which a
person commits an offence if he drives, attempts to drive, or is in charge of a mechanically propelled
vehicle on a road or other public place. The offence is set out in section 5A(1), and the prescribed limit in
section 7E(2), of the RTA. That limit, which is the same as in GB, is (a)
35 micrograms of alcohol in 100 millilitres of breath,
(b)
80 milligrams of alcohol in 100 millilitres of blood, or
(c)
107 milligrams of alcohol in 100 millilitres of urine.
4.
Clause 17 of the Bill keeps the above limit for experienced drivers but lowers the limit to 20, 46 and
61 respectively for provisional or newly qualified drivers in view of their inexperience in driving. This limit
equates approximately to that proposed generally in the Department's Road Safety Initiative, which stated
that it is the limit operative for all drivers in most EU states.
5.
The second set of prescribed alcohol limits in the IOM are those above which an offender is subject
to an increased minimum period of disqualification. They are set out in para 11(3A) of Schedule 3 to the
RTA and are as follows:
Proportion in 100 ml
of breath
Over 65 µg but not over 96 µg
2 years
Over 96 µg
3 years
Proportion in 100 ml
of blood
Over 150 mg but not over 220 mg
2 years
Over 220 mg
3 years
Proportion in 100 ml
of urine
Over 200 mg but not over 294 mg
2 years
Over 294 mg
3 years
Department of Infrastructure
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44.
Partly as a means to remove unsafe drivers from roads and partly as a further deterrent to unsafe
driving the Bill proposes to substitute the following prescribed alcohol limits beyond which an offender is
subject to an increased minimum period of disqualification:
Proportion in 100 ml Over 50 µg but not over 75 µg
of breath
Over 75 µg but not over 100 µg
2 years
3 years
Over 100 µg
Proportion in 100 ml Over 115 mg but not over 173 mg
of blood
Over 173 mg but not over 230 mg
5 years
2 years
3 years
Over 230 mg
Proportion in 100 ml Over 153 mg but not over 230 mg
of urine
Over 230 mg but not over 306 mg
5 years
2 years
3 years
Over 306 mg
5 years
Disqualification in other cases
45.
In the light of the Department's increased perception of the gravity of the offences, and partly for
the reasons outlined in para 44 above, the Bill proposes to increase the minimum period of disqualification
from 1 to 2 years in the case of a person convicted of 
an offence under RTA section 1 (causing death by dangerous driving), RTA section 1A (causing
GBH by dangerous driving), or RTA section 3B (causing death by driving when unlicensed,
disqualified or uninsured), or

an offence under RTA section 6(6) (failing to provide a specimen) or RTA section 7DA (failing to
allow laboratory test of specimen of blood), where such an offence involves obligatory
disqualification.
46.
Where a court orders that a disqualification shall remain until an offender has passed a driving test,
it is proposed that the test shall be an extended test as defined in the Bill.
47.
Inter alia, the RTA presently requires a court to order a driving test when it considers that the facts
of the case raise a "serious doubt" as to an offender's competence to drive. In the interests of road safety
the Bill proposes to substitute "reasonable doubt" for "serious doubt".
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
www.gov.im/infrastructure
48.
If a person accumulates 12 or more penalty points, a court must, unless special reasons obtain,
order him to be disqualified. Yet if a person is convicted of two or more offences committed on the same
occasion, at present only the highest number of points for one of those offences may be endorsed. The Bill
proposes to give the courts discretion to endorse in respect of all of the offences.
3 - Alternative verdicts
49.
As already precedented in the RTA and the Criminal Jurisdiction Act 1993, the Bill caters for a wider
range of alternative verdicts in cases where defendants are found not guilty of the principal offence. If in
those circumstances there is also a lesser charge or charges to answer, it is in the interests of justice that
they should be considered.
50.
The Bill provides safeguards for defendants answering lesser charges by 
affording them the opportunity of cross-examining witnesses whose evidence has already been
given,

otherwise answering the charges, and

requiring the court to adjourn hearings when it considers that defendants will be prejudiced in their
defence by reason of the new charge or charges.
4 - Other matters
Registered or licensed driving instructors
51.
At present only instructors giving paid instruction in the driving of passenger cars or light vans are
required to be registered or licensed by the Department's Registrar. In the interests of ensuring high and
uniform standards in the giving of such instruction to drivers of heavier vehicles the Bill enables regulations
to be made catering for registration or licensing in such cases.
Stop notices
52.
Paid instruction in the driving of passenger cars appears to have been given in recent years by an
unregistered and unlicensed instructor, but due to lack of resources the police have been unable to
investigate. Such a situation runs a coach and horses through the Act, bringing it into disrepute, for, selfevidently, if a person is seen to circumvent the Act without any sanction whatever, other instructors will see
no need to submit themselves to strict examination and registration or licensing with all the time, effort and
expense involved.
53.
The Bill therefore proposes an alternative means of enforcement by catering for the Registrar to
serve a stop notice in cases where 
it appears to the Registrar that a person is giving or has given paid instruction in the driving of a
motor vehicle in contravention of the Act, and

the Registrar considers it expedient to do so.
54.
This administrative procedure for the service of stop notices is modelled on, and precedented by,
the service of stop or other notices under the Town and Country Planning Act. It is thought to sit well
within the framework of the existing administrative arrangements which underpin Schedule 4 to the RTA,
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
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and a stop notice will - before it can take effect - be subject to the existing safeguards of written
representations to the Registrar and appeals to an independent adjudicator.
55.
Once a stop notice takes effect it will be an offence for the person in question to give instruction,
whether paid or unpaid, other than to his close relatives. Such a notice may not continue in force for
longer than two years.
56.
The police have confirmed that they will enforce stop notices, as the only question at issue will be
whether a person is giving instruction in contravention of a notice – a point easily verifiable.
Authorised insurers
57.
At present the RTA prescribes that a policy of motor insurance must be issued by a person who is 
authorised to carry on motor insurance business in the IOM or the UK, and

a member of the Motor Insurers' Bureau.
The Bill proposes to extend the first bulleted sub-para so that "anywhere in the British Islands or in the
territory of a member State of the EU" is substituted for "in IOM or the UK". The British Islands comprise
the IOM, the UK and the Channel Islands.
Seizure, retention and disposal of certain vehicles
58.
The Explanatory Memorandum attached to the Bill summarises the effect of clause 13, which deals
with the above matter.
59.
The policy underlying the provisions can be clearly and succinctly explained. It is based partly on
the impropriety of permitting persons to retain possession of their vehicles when, for example, they are to
be charged with driving while disqualified or with committing a serious driving offence connected with drink
or drugs (in case they should be tempted to reoffend before their cases are disposed of), partly on the risk
to the safety of the public if the vehicles are retained by the persons in question, and partly on the
desirability of providing a further deterrent to persons driving on roads when they are prohibited from
doing so.
60.
By virtue of regulations to be made under the provisions it is intended that vehicles will be kept in
storage until a court orders them to be released to the owner or otherwise disposed of. Where, for
example, the court convicts a person of an offence to which the seizure relates and orders the vehicle to be
sold, it is intended that the proceeds of sale will be given to the owner minus the police's expenses in
seizing, storing and selling the vehicle.
61.
The provisions are in part precedented by section 24 of the Criminal Justice, Police and Courts Act
2007, which is to be replaced.
PART 3: AMENDMENT OF THE ROAD TRAFFIC REGULATION ACT 1985
62.
This Part deals in self-explanatory ways with 
double parking etc and parking at dropped footways etc,

the use of portable light signals,
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
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
the prescribing of fixed penalties at differential rates with respect to the unlawful use of parking
spaces, for example those for use by holders of a disabled parking card, and

the use in certain circumstances of notices instead of orders for the purposes of regulating traffic.
63.
This Part also amends the provisions of the Act relating to road closures for filming. It will 
permit up to six vehicles to be parked on roads, despite any statutory provision to the contrary, if
they are being used in connection with recording a scene on film, and

extend from 24 to 48 hours, but not exceeding an aggregate of 48 hours in any period of 72 hours,
the period or periods in which a road may be closed to through traffic.
PART 4: AMENDMENT OF THE HIGHWAYS ACT 1986
64.
This Part deals in self-explanatory ways with 
the recovery of the Department's expenses due to extraordinary traffic,

the designation of improvement lines for the widening of highways, together with the acquisition of
land between those lines and the boundaries of highways,

the creation of walkways by agreement, being rights of way on foot in developments such as
shopping centres and blocks of flats, thereby better enabling access by the police to maintain public
order,

the deregulation of the temporary closure of highways for the purposes of entertainment, so that
closure may be effected by direction of the Department instead of a statutory order,

the cutting of trees or other vegetation overhanging highways in a dangerous or obstructive way
when such cutting has not been attended to by owners or occupiers, together with the recovery
from them of the Department's expenses in cases where the Department carries out the work itself,

the installation of lighting on highways designated by the Department to be lit for the purposes of
traffic management,

the improvement by the Department of means of access to any land from a highway in order to
ensure that it is properly and safely constructed, together with the recovery of the Department's
expenses from the owner or occupier,

agreements for providing means of access or other facilities at no cost to the Department, being
agreements mostly following on from planning permissions which, if they are to be implemented,
require the works involved to be carried out, and

the better reinstatement of highways or bridges by statutory undertakers in cases where such
bodies have opened up highways to gain access to their apparatus.
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
www.gov.im/infrastructure
PART 5: MISCELLANEOUS AMENDMENTS AND REPEALS
65.
This Part amends section 66(4) of the Petty Sessions and Summary Jurisdiction Act 1927 by
bringing the penalties for furious driving into line with those for the comparable offence of careless or
inconsiderate driving.
66.
The Part also makes a substantive amendment, which is self-explanatory, of the Road Transport
Act 2001 besides 
incorporating an up-to-date reference to the Armed Forces Act 2006, and

revising the definition of "the requisite skills".
TIMESCALE FOR SUBMISSION OF COMMENTS
67.
Should you wish to comment on the Bill, will you please do so in writing either by posting your
comments to the Highways Division at the address below or by e-mailing them to [email protected].
To be taken into consideration comments must be received by 14th January 2011.
Yours faithfully
R D PEARSON
Director of Highways
Department of Infrastructure
Sea Terminal Building, Douglas, Isle of Man, British Isles IM1 2RF
www.gov.im/infrastructure